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<TYPE>EX-99.77D POLICIES
<SEQUENCE>2
<FILENAME>peo77d_policy.txt
<TEXT>
Item 77D(g)

The Board of Directors has approved a material change in the
investment policies of the registrant on Investments in Options
with respect to engaging in short sales of securities.
Previously, the registrant's investment policy on Investments in
Options provided that the registrant's practice is not to make
short sales except in limited volume when done solely in
conjunction with the sale of a put or the purchase of a call
option as a hedge against its exposure under the option. The
Board has approved the removal of the limitations on engaging in
short sales to permit making short sales as part of an investment
strategy in which the registrant opportunistically sells short a
security and takes a corresponding long position in another
security in a "paired trade".



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</DOCUMENT>
