<DOCUMENT>
<TYPE>EX-99.77D POLICIES
<SEQUENCE>2
<FILENAME>rfi77d.txt
<DESCRIPTION>POLICIES
<TEXT>
ITEM 77D: On June 9-10, 2009, the Board of Directors of the Registrant
approved that the Registrant may, but is not required to, use, without
limit, various strategic transactions described below to seek to
generate return, facilitate portfolio management and mitigate risks.
Although the Investment Manager may seek to use these kinds of transactions
to further the Registrant's investment objectives, no assurance can be
given that they will achieve this result.  The Registrant may enter into
exchange-listed and over-the-counter put and call options on securities
(including securities of investment companies and baskets of securities),
indexes, and other financial instruments; purchase and sell financial
futures contracts and options thereon; enter into various interest rate
transactions, such as swaps, caps, floors or collars or credit
transactions; equity index, total return and credit default swaps;
forward contracts; and structured investments.  In addition, the
Registrant may enter into various currency transactions, such as
forward currency contracts, currency futures contracts, currency
swaps or options on currency or currency futures. The Registrant
also may purchase and sell derivative instruments that combine features
of these instruments. The Registrant may invest in other types of
derivatives, structured and similar instruments which are not currently
available but which may be developed in the future.

</TEXT>
</DOCUMENT>
