EXHIBIT FOR SUB-ITEM 77O

For Period Ending     10/31/03
File Number    811-7902


Issuer

From Whom Acquired

Identity of Syndicate Members

Terms of Transaction
Florida Housing Finance Corporation
UBS PaineWebber Inc.
UBS PaineWebber Inc.
Bear, Stearns & Co. Inc.
Citigroup
Williarm R. Hough & Co.
Amount of Purchase:	$300,000
Purchase Price:	        $100
Commission or Spread:	$0
Date of Offering:	06/05/03
Date of Purchase:	06/05/03
Total Amount Offered:	$105,000,000.00


Each transaction met with the following conditions:

1.	The securities are part of an issue registered under the Securities
Act of 1933, or are 'municipal securities' as defined under the Securities
Exchange Act of 1934.

2.	The purchase price paid did not exceed the offering price at the
close of the first full business day after the first day of the offering
(or fourth day before termination, if a rights offering).

3.	The underwriting was a firm commitment.

4.	The commission, spread or profit was reasonable and fair in relation
to that being received by others for underwriting similar securities during
a comparable period of time.

5.	In respect of any securities other than municipal securities, the
issuer of such securities has been in continuous operation for not less than
three years (including the operations of predecessors), or in respect of any
municipal securities, the issuer of such securities has received an
investment grade rating from a nationally recognized statistical rating
organization or, if the issuer or entity supplying the revenues from which
the issue is to be paid has been in continuous operations for less than
three years (including any predecessors), it has received one of the
three highest ratings from at least one such rating service.

6.	The amount of the securities purchased by the Fund(s) did not exceed
the greater of (i) 10% of the principal amount of the offering, or
(ii) $1,000,000 in principal amount, but in no event was greater than 25% of
the principal amount of the offering.

7.	William R. Hough & Co., or any of its affiliates, as underwriter
was not a direct or indirect participant in, or benefited directly or
indirectly from, the purchase.

8.	The purchase was not part of a group sale, or otherwise allocated to
the account of an officer, director, of an advisory board, investment
adviser, or employee of the Fund or an affiliate thereof.