<DOCUMENT>
<TYPE>EX-99.77Q2 ITEM 405
<SEQUENCE>3
<FILENAME>adxpeo_dec2017_77q2_sect16.txt
<TEXT>
Section 16(a) Beneficial Ownership Reporting Compliance

Each director and officer of the Fund who is subject to Section
16 of the Securities Exchange Act of 1934, as amended, and
persons who own more than ten percent of a registered class of
the Fund's securities are required to report to the Securities
and Exchange Commission (the "Commission") by a specified date
his or her beneficial ownership of or transactions in the Fund's
securities. Based upon a review of filings with the Commission,
such forms received by the Fund, and written representations that
no other reports are required, the Fund believes that each
director, officer, and greater than ten percent beneficial owners
filed all requisite reports with the Commission on a timely basis
during 2017, except for Ms. Prue, former Executive Vice President
and Director of Shareholder Communications, who retired in June
2017. Upon her retirement, certain shares granted to her under
the Fund's 2005 Equity Incentive Compensation Plan vested. When
those shares vested, she elected to forfeit shares to cover tax
liabilities and the Form 4 to report the surrender of these
shares was filed late.
</TEXT>
</DOCUMENT>
