<DOCUMENT>
<TYPE>EX-99
<SEQUENCE>7
<FILENAME>s476061.txt
<DESCRIPTION>EX 99 LETTER OF REPRESENTATIONS
<TEXT>
                         The Depository Trust Company
          A subsidiary of The Depository Trust & Clearing Corporation


                   BLANKET ISSUER LETTER OF REPRESENTATIONS
                          [To be Completed by Issuer]

                         The Gabelli Equity Trust Inc.
                       ----------------------------------
                               [Name of Issuer]


                                                            September     , 2003
                                                            --------------------
                                                                   [Date]

The Depository Trust Company
General Counsel's Office; 49th Floor
55 Water Street
New York, NY 10041-0099

Ladies and Gentlemen:

         This letter sets forth our understanding with respect to all issues
(the "Securities") that Issuer shall request be made eligible for deposit by
The Depository Trust Company ("DTC").

         To induce DTC to accept the Securities as eligible for deposit at
DTC, and to act in accordance with DTCs Rules with respect to the Securities,
Issuer represents to DTC that Issuer will comply with the requirements stated
in DTCs Operational Arrangements, as they may be amended from time to time.

<TABLE>
<CAPTION>

Note:                                                           Very truly yours,
----

<S>                                                             <C>
Schedule A contains statements that DTC believes accurately
describe DTC, the method of effecting book-entry transfers      The Gabelli Equity Trust Inc.
of securities distributed through DTC, and certain related      -------------------------------------------------------------
matters.                                                                                 (Issuer)

                                                                By:
                                                                   ----------------------------------------------------------
                                                                              (Authorized Officer's Signature)
Received and Accepted:
THE DEPOSITORY TRUST COMPANY                                    Bruce N . Alpert
                                                                -------------------------------------------------------------
                                                                                        (Print Name)
By:
   -------------------------------------------------
                                                                One Corporate Center
                                                                -------------------------------------------------------------
                                                                                      (Street Address)

                                                                Rye, New York 10580-1422
                                                                -------------------------------------------------------------
                                                                (City) (State) (Country) (Zip Code)

                                                                (914) 921-5100
                                                                -------------------------------------------------------------
                                                                                        (Phone Number)

                                                                Balpert@gabelli.com
                                                                -------------------------------------------------------------
                                                                                      (E-mail Address)
</TABLE>


<PAGE>



                                                                      SCHEDULE A

                                   (To Blanket Issuer Letter of Representations)

                        SAMPLE OFFERING DOCUMENT LANGUAGE
                       DESCRIBING BOOK-ENTRY-ONLY ISSUANCE
                      ------------------------------------
 (Prepared by DTC-bracketed material may be applicable only to certain issues)

         1. The Depository Trust Company ("DTC"), New York, NY, will act as
securities depository for the securities (the "Securities"). The Securities
will be issued as fully-registered securities registered in the name of Cede &
Co. (DTC's partnership nominee) or such other name as may be requested by an
authorized representative of DTC. One fully-registered Security certificate
will be issued for [each issue of] the Securities, [each] in the aggregate
principal amount of such issue, and will be deposited with DTC. [If, however,
the aggregate principal amount of [any] issue exceeds $500 million, one
certificate will be issued with respect to each $500 million of principal
amount, and an additional certificate will be issued with respect to any
remaining principal amount of such issue.]

         2. DTC, the world's largest depository, is a limited-purpose trust
company organized under the New York Banking Law, a "banking organization"
within the meaning of the New York Banking Law, a member of the Federal
Reserve System, a "clearing corporation" within the meaning of the New York
Uniform Commercial Code, and a "clearing agency" registered pursuant to the
provisions of Section 17A of the Securities Exchange Act of 1934. DTC holds
and provides asset servicing for over 2 million issues of U.S. and non-U.S.
equity issues, corporate and municipal debt issues, and money market
instruments from over 85 countries that DTC's participants ("Direct
Participants") deposit with DTC. DTC also facilitates the post-trade
settlement among Direct Participants of sales and other securities
transactions in deposited securities, through electronic computerized
book-entry transfers and pledges between Direct Participants' accounts. This
eliminates the need for physical movement of securities certificates. Direct
Participants include both U.S. and non-U.S. securities brokers and dealers,
banks, trust companies, clearing corporations, and certain other
organizations. DTC is a wholly-owned subsidiary of The Depository Trust &
Clearing Corporation ("DTCC"). DTCC, in turn, is owned by a number of Direct
Participants of DTC and Members of the National Securities Clearing
Corporation, Government Securities Clearing Corporation, MBS Clearing
Corporation, and Emerging Markets Clearing Corporation, (NSCC, GSCC, MBSCC,
and EMCC, also subsidiaries of DTCC), as well as by the New York Stock
Exchange, Inc., the American Stock Exchange LLC, and the National Association
of Securities Dealers, Inc. Access to the DTC system is also available to
others such as both U.S. and non- U.S. securities brokers and dealers, banks,
trust companies, and clearing corporations that clear through or maintain a
custodial relationship with a Direct Participant, either directly or
indirectly ("Indirect Participants"). DTC has Standard & Poor's highest
rating: AAA. The DTC Rules applicable to its Participants are on file with the
Securities and Exchange Commission. More information about DTC can be found at
www.dtcc.com.

         3. Purchases of Securities under the DTC system must be made by or
through Direct Participants, which will receive a credit for the Securities on
DTC's records. The ownership interest of each actual purchaser of each
Security ("Beneficial Owner") is in turn to be recorded on the Direct and
Indirect Participants' records. Beneficial Owners will not receive written
confirmation from DTC of their purchase. Beneficial Owners are, however,
expected to receive written confirmations providing details of the
transaction, as well as periodic statements of their holdings, from the Direct
or Indirect Participant through which the Beneficial Owner entered into the
transaction. Transfers of ownership interests in the Securities are to be
accomplished by entries made on the books of Direct and Indirect Participants
acting on behalf of Beneficial Owners. Beneficial Owners will not receive
certificates representing their ownership interests in Securities, except in
the event that use of the book-entry system for the Securities is
discontinued.

         4. To facilitate subsequent transfers, all Securities deposited by
Direct Participants with DTC are registered in the name of DTC's partnership
nominee, Cede & Co., or such other name as may be requested by an authorized
representative of DTC. The deposit of Securities with DTC and their
registration in the name of Cede & Co. or such other DTC nominee do not effect
any change in beneficial ownership. DTC has no knowledge of the actual
Beneficial Owners of the Securities; DTC's records reflect only the identity
of the Direct Participants to whose accounts such Securities are credited,
which may or may not be the Beneficial Owners. The Direct and Indirect
Participants will remain responsible for keeping account of their holdings on
behalf of their customers.

         5. Conveyance of notices and other communications by DTC to Direct
Participants, by Direct Participants to Indirect Participants, and by Direct
Participants and Indirect Participants to Beneficial Owners will be governed
by arrangements among them, subject to any statutory or regulatory
requirements as may be in effect from time to time. [Beneficial Owners of
Securities may wish to take certain steps to augment the transmission to them
of notices of significant events with respect to the Securities, such as
redemptions, tenders, defaults, and proposed amendments to the Security
documents. For example, Beneficial Owners of Securities may wish to ascertain
that the nominee holding the Securities for their benefit has agreed to obtain
and transmit notices to Beneficial Owners. In the alternative, Beneficial
Owners may wish to provide their names and addresses to the registrar and
request that copies of notices be provided directly to them.]

         [6. Redemption notices shall be sent to DTC. If less than all of the
Securities within an issue are being redeemed, DTCs practice is to determine
by lot the amount of the interest of each Direct Participant in such issue to
be redeemed.]

         7. Neither DTC nor Cede & Co. (nor any other DTC nominee) will
consent or vote with respect to Securities unless authorized by a Direct
Participant in accordance with DTC's Procedures. Under its usual procedures,
DTC mails an Omnibus Proxy to Issuer as soon as possible after the record
date. The Omnibus Proxy assigns Cede & Co.'s consenting or voting rights to
those Direct Participants to whose accounts Securities are credited on the
record date (identified in a listing attached to the Omnibus Proxy).

         8. Redemption proceeds, distributions, and dividend payments on the
Securities will be made to Cede & Co., or such other nominee as may be
requested by an authorized representative of DTC. DTCs practice is to credit
Direct Participants' accounts upon DTCs receipt of funds and corresponding
detail information from Issuer or Agent, on payable date in accordance with
their respective holdings shown on DTC's records. Payments by Participants to
Beneficial Owners will be governed by standing instructions and customary
practices, as is the case with securities held for the accounts of customers
in bearer form or registered in "street name," and will be the responsibility
of such Participant and not of DTC [nor its nominee], Agent, or Issuer,
subject to any statutory or regulatory requirements as may be in effect from
time to time. Payment of redemption proceeds, distributions, and dividend
payments to Cede & Co. (or such other nominee as may be requested by an
authorized representative of DTC) is the responsibility of Issuer or Agent,
disbursement of such payments to Direct Participants will be the
responsibility of DTC, and disbursement of such payments to the Beneficial
Owners will be the responsibility of Direct and Indirect Participants.

         [9. A Beneficial Owner shall give notice to elect to have its
Securities purchased or tendered, through its Participant, to
[Tender/Remarketing] Agent, and shall effect delivery of such Securities by
causing the Direct Participant to transfer the Participant's interest in the
Securities, on DTC's records, to [Tender/Remarketing] Agent. The requirement
for physical delivery of Securities in connection with an optional tender or a
mandatory purchase will be deemed satisfied when the ownership
rights in the Securities are transferred by Direct Participants on DTC's
records and followed by a book- entry credit of tendered Securities to
[Tender/Remarketing] Agent's DTC account.]

         10. DTC may discontinue providing its services as depository with
respect to the Securities at any time by giving reasonable notice to Issuer or
Agent. Under such circumstances, in the event that a successor depository is
not obtained, Security certificates are required to be printed and delivered.

         11. Issuer may decide to discontinue use of the system of book-entry
transfers through DTC (or a successor securities depository). In that event,
Security certificates will be printed and delivered.

         12. The information in this section concerning DTC and DTC's
book-entry system has been obtained from sources that Issuer believes to be
reliable, but Issuer takes no responsibility for the accuracy thereof.

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</DOCUMENT>
