Sub-item 77Q3

(a)(i)  The  Chief   Executive  and  Financial   Officers   concluded  that  the
Registrant's  Disclosure  Controls and  Procedures  are  effective  based on the
evaluation of the Disclosure Controls and Procedures as of a date within 90 days
of the filing date of this report.

(a)(ii) There were no significant  changes in Registrant's  internal controls or
in other factors that could  significantly  affect these controls  subsequent to
the date of their  evaluation,  including any corrective  actions with regard to
significant deficiencies and material weaknesses.