<DOCUMENT>
<TYPE>EX-99.77Q2 ITEM 405
<SEQUENCE>3
<FILENAME>item77q2.txt
<DESCRIPTION>SECTION 16A
<TEXT>

Item 77Q2
SECTION 16(A) BENEFICIAL OWNERSHIP REPORTING COMPLIANCE.

Based solely upon a review of copies of reports of ownership, and
transactions in, the Funds securities as required under Section 16(a)
of the Securities Exchange Act of 1934 and Section 30(f) of the
Investment Company Act of 1940, the Fund believes the Initial Statement
of Beneficial Ownership on Form 3 may not have been filed on a timely
basis for Mr. William Cox, an employee of State Street Bank and Trust
Company, the Funds Administrator, and Assistant Treasurer of the Fund.
Mr. Cox did not own or dispose of shares of the Fund during the
reporting period.

</TEXT>
</DOCUMENT>
