<DOCUMENT>
<TYPE>EX-99.77Q2
<SEQUENCE>3
<FILENAME>v175722_ex77q2.txt
<TEXT>

             Section 16(a) Beneficial Ownership Reporting Compliance

Based solely upon a review of Forms 3 and 4 and amendments thereto furnished to
the Registrant pursuant to Rule 16a-3(e) under the Securities Exchange Act of
1934 during its most recent fiscal year and Forms 5 and amendments thereto
furnished to the Registrant with respect to its most recent fiscal year, and any
written representation referred to referred to in paragraph (b)(2)(i) of Item
405 of Regulation S-K, following is each person who, at any time during the
fiscal year, was subject to section 16 of the Exchange Act with respect to the
Registrant because of the requirements of section 30 of the Investment Company
Act ("reporting person") that failed to file on a timely basis, as disclosed in
the above Forms, reports required by section 16(a) of the Exchange Act during
the most recent fiscal year or prior fiscal years.

                                 Number of Late      Number of Transactions Not
Reporting Person                    Reports          Reported on a Timely Basis
-------------------------------------------------------------------------------
Babson Capital Management, LLC          1                       0
</TEXT>
</DOCUMENT>
