<DOCUMENT>
<TYPE>EX-99.77D POLICIES
<SEQUENCE>4
<FILENAME>d77.txt
<TEXT>

Effective   January   1,   2008,   the   Trustees   of  the  Trust   approved  a
level-distribution  plan of the Trust (the  "Plan")  pursuant to which the Trust
would make  distributions at an annual fixed  distribution rate of up to 8.5% of
the  Trust's  average  monthly  net  asset  value.  The  Trustees  of the  Trust
determined that the adoption and  implementation of the Plan are consistent with
the Trust's  Investment  Objective and Policies contained in Amendment No. 11 to
the Registration  Statement of the Trust (File No. 811-5400),  as filed with the
Securities  and Exchange  Commission via EDGAR on February 28, 2006, on Form N-2
under the Investment  Company Act of 1940. Such document is incorporated  herein
by reference.
</TEXT>
</DOCUMENT>
