<DOCUMENT>
<TYPE>EX-99.77P EXMPT INFO
<SEQUENCE>4
<FILENAME>p3102a1.txt
<TEXT>
                                                         SUB-ITEM 102P3(a)(1)

                                                      MFS Municipal Income Trust

                                                       CODE OF ETHICS DISCLOSURE

The  Registrant  has  adopted a Code of Ethics  pursuant  to Section  406 of the
Sarbanes-Oxley Act and as defined in the instructions to Form N-SAR that applies
to the  Registrant's  principal  executive  officer and principal  financial and
accounting officer.

</TEXT>
</DOCUMENT>
