<DOCUMENT>
<TYPE>EX-99.77Q1 OTHR EXHB
<SEQUENCE>8
<FILENAME>q771a3.txt
<TEXT>
FITCH CRITERIA
FITCH CRITERIA

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Closed-End Funds / U.S.A.
RATING CLOSED-END FUND DEBT AND PREFERRED STOCK
MASTER <1>

<PAGE>







Criteria


This  report  updates and replaces the master criteria report titled "Closed-End
Fund Debt and Preferred Stock Rating Criteria," dated Aug. 17, 2009. This report
primarily covers  collateralized  short-  and  long-term  obligations  issued by
country-regionplaceU.S.  closed-end  funds  (CEFs)  regulated  by the Investment
Company Act of 1940 (1940 Act).
STRESSED  ASSET  VALUES  EMPHASIS:  The  ability  of  a  CEF to redeem debt  and
preferred  stock  is  fundamentally  linked to the market value  of  the  fund's
assets, especially in times of market  stress.  Stress testing a CEF portfolio's
market value under a liquidation scenario to repay  rated  liabilities is a core
element of Fitch's rating methodology for CEFs.
STRUCTURAL   PROTECTIONS   SUPPORT   RATINGS:  CEFs  must  adhere  to   leverage
restrictions and structural features prescribed by the 1940 Act, which provide a
baseline  set  of protections. Fitch's criteria  considers  the  stressed  price
volatility of specific  asset  types,  all  forms  of  on- and off-balance sheet
leverage,  the  level  of  diversification,  and  other risk factors  not  fully
addressed by the 1940 Act.
DISCOUNT FACTORS DRIVE COVERAGE: Stressed  discount  factors  (DFs)
are  applied  to specific portfolio assets based on the assets' historical worst
volatility. In  turn,  the  discounted  value  of  the  portfolio  provides  the
overcollateralization  (OC)  available  to  rated  liabilities.  DFs are largely
unchanged  in this criteria update. Notable exceptions include clarification  of
certain DFs, inclusion of previously released structured finance DFs, and a more
conservative framework for single-state municipal CEFs.
CONSERVATIVE  SINGLE-STATE MUNICIPAL FRAMEWORK: Asset DFs have been increased by
an additional 1.25x  multiple  for  high concentrations in states rated `BBB' or
lower.  This  change  is intended to compensate  for  the  risks  of  holding  a
portfolio of assets from  a  state  undergoing  extreme  financial stress. Asset
price volatility and correlations may be more pronounced in such instances.
IMPORTANCE OF PORTFOLIO DIVERSIFICATION: The criteria places  heavy  emphasis on
the fund's portfolio diversification to limit overall portfolio risk.  Portfolio
guidelines  that  allow  for  issuer,  industry,  municipal sector, and/or state
concentrations  higher than Fitch's diversification  framework  will  result  in
higher DFs and potentially lower ratings.
CAPTURING ECONOMIC  LEVERAGE:  The  Fitch  OC tests seek to capture all forms of
leverage  -  traditional and economic - utilized  by  CEFs.  Forms  of  economic
leverage include derivatives, tender options bonds (TOBs), and other off-balance
sheet liabilities, many of which are not captured by the 1940 Act.
RECOGNITION OF  SUBORDINATION  RISKS: The Fitch Net OC test captures the effects
of  subordination that may pose a  risk  to  rated  debt  and  preferred  stock.
Subordination  arises  from the presence of senior debt and other obligations in
the fund's capital structure, which may have a first priority on fund assets.
DYNAMIC  DELEVERAGING  A  KEY   FEATURE:  CEFs  typically  implement  structural
deleveraging mechanisms to protect  investors  in  CEF debt and preferred stock.
The  deleveraging  triggers  are based on minimum OC ratios  recalculated  on  a
regular basis, with an allowable cure period before mandatory deleveraging takes
place. Fitch's criteria closely  consider  the frequency and robustness of these
deleveraging mechanisms.

RATINGS ASSIGNED TO SECURITIES ISSUED BY CEFS

Fitch assigns long- and short-term credit ratings  to  debt  and preferred stock
issued by leveraged CEFs, consistent with Fitch's published ratings definitions.
Ratings do not address liquidity in secondary markets.

LONG-TERM RATINGS

The long-term credit ratings address the likelihood of full and  timely  payment
of  interest  or  dividends on each payment date and principal upon optional  or
mandatory redemption or at maturity and are based on the following:
{circle}STRUCTURAL MECHANISMS: OC triggers, mandatory redemption parameters, and
    other structural protections for rated debt obligations.
{circle}CAPITAL STRUCTURE: The fund's capital structure and sufficiency of asset
    coverage, according to seniority of the liabilities.
{circle}INVESTMENT  PORTFOLIO:  Evaluation of the fund's portfolio assets with a
    focus on the potential market value loss under stress scenarios.
{circle}INVESTMENT  MANAGER  REVIEW:   Qualitative   assessment  of  the  fund's
    investment manager.
{circle}LEGAL CONSIDERATIONS: Integrity of the legal structure.

SHORT-TERM RATINGS

Fitch  may also assign short-term credit ratings to notes  and  preferred  stock
with maturities viewed as short-term based on market convention (typically up to
13 months)  and notes and preferred stock that offer a demand feature that gives
investors the  right  to tender the securities back to the fund or the liquidity
provider on pre-specified  periods or dates. In the latter case, Fitch assigns a
long-term rating to the leverage to address the sufficiency of asset coverage to
note and preferred investors  and a short-term rating to address the strength of
the put feature based on:
{circle}LIQUIDITY PROVIDER'S OBLIGATION:  Review  of the terms and conditions of
    the liquidity provider's obligation to purchase  all debt or preferred stock
    tendered for sale that have not been sold on the tender date or upon certain
    events  defined  in the transaction documents, such  as  expiration  of  the
    liquidity agreement or downgrade of the liquidity provider below a specified
    threshold.
{circle}LIQUIDITY  PROVIDER'S  CREDIT  STRENGTH:  The  credit  strength  of  the
    liquidity provider  or  the  guarantor  supporting  the liquidity provider's
    obligation.
{circle}LEGAL CONSIDERATIONS: The integrity of the legal structure.

RATINGS ASSIGNED TO OTHER CEF LEVERAGE TYPES

Fitch also assigns ratings to other types of financing instruments  for CEFs and
CEF-like fund structures. Examples include credit facilities, margin  loans, and
reverse repurchase agreements extended to CEFs and bespoke exchange-traded  note
transactions.

CEF DEBT AND PREFERRED STOCK RATED BELOW INVESTMENT GRADE

The  majority  of  Fitch-rated  CEFs  seek to achieve and maintain `AAA' or `AA'
ratings on their debt and preferred stock  obligations. The baseline protections
of the 1940 Act help support such rating levels. As such, Fitch does not publish
DFs below the `BBB' rating level. In a scenario  where  a  CEF's obligations are
rated  below `BBB,' Fitch would evaluate the portfolio, the structure,  and  the
manager  on  a  case-by-case  basis,  taking into account potential future asset
market value losses.

STRUCTURAL MECHANISMS SUPPORT RATINGS

Fitch's criteria for CEF debt and preferred  stock  assess  the  stressed  asset
coverage or OC as the primary means for repaying rated debt and preferred stock.
The analytical focus is on the asset pool and the structural mechanisms in place
to redeem rated obligations even during a stressful market environment where  no
refinancing  options  are  available. Asset liquidations and forced deleveraging
are presumed to be the only  means  of debt repayment upon an early or mandatory
redemption,  as well as repayment at maturity.  CEF  debt  and  preferred  stock
investors therefore are exposed to risks stemming from:
{circle}MARKET  RISK:  The  general  risk  of  declines  in  the market value of
    portfolio assets, particularly in periods of market stress  such as what was
    experienced in 2008.
{circle}LIQUIDITY  RISK: The risk that a security cannot be sold quickly  enough
    in the market to  prevent  a  further  loss  or  only can be liquidated at a
    haircut  to  its  intrinsic  value. This risk is present  in  the  event  of
    mandatory deleveraging or redemption  following  a  breach  of certain asset
    coverage ratios.
{circle}LEVERAGE  RISK:  The  risk  that  leverage  carried  by  the  fund  will
    exacerbate market losses allocated to investors and, depending on the  exact
    nature  of  each  form of debt, may also subordinate investors of rated debt
    and preferred stock.
{circle}MORAL HAZARD RISK:  The  risk  that  an  investment manager may manage a
    fund's portfolio and leverage to the benefit of  common  stockholders and to
    the detriment of debt and preferred stock investors.

OC IN TIMES OF STRESS

OC is measured by evaluating the market value of collateral available  to retire
rated liabilities adjusted by DFs to address the possibility that market  values
could  decline  further  prior  to  sale.  The presence of market value-based OC
triggers serves as the primary source of credit  enhancement  and protection for
rated   obligations.   Consequently,   CEFs   with  rated  instruments  maintain
overcollateralization guidelines within their governing documents.

Fitch will assign ratings by analyzing how funds  seek to maintain sufficient OC
compared  with Fitch OC tests. By maintaining a minimum  standard  for  OC,  the
asset coverage  tests  are  designed  to  protect  CEF  debt and preferred stock
investors against default on principal and any accrued interest or dividends.

MANDATORY DELEVERAGING OR REDEMPTION

Fitch's  CEF  rating  criteria  are  based on deleveraging/mandatory  redemption
provisions over a pre-specified and limited timeframe. Fitch views favorably any
additional provisions CEFs incorporate to increase asset coverage upon breaching
the tests, such as ceasing distributions  to common stockholders until the OC is
restored.

Fitch reviews mandatory deleveraging and other collateral maintenance provisions
within transaction documents to assess whether  CEFs  maintain sufficient OC for
debt and preferred stock for a given rating level. The  period  for deleveraging
usually takes the form of a cure period followed by a set period  for performing
mandatory redemptions.

For instance, the fund is first afforded a cure period within which  it may take
voluntary action to bring the tests back into compliance upon a breach of either
the  1940  Act or Fitch OC tests. During this period, funds may sell assets  and
use proceeds  to deleverage the portfolio or seek a capital injection through an
equity offering.  Fund  managers  may also elect to rebalance the portfolio into
more liquid, less risky assets to cure  a  breach  of  the tests. If the manager
fails  to  cure  a  breach  of  a  test within the prescribed cure  period,  the
governing documents require redemption  of  debt  and  preferred  stock within a
predefined  period in sufficient amounts to restore compliance with  the  failed
test(s).

EXPOSURE PERIOD TO MARKET RISK

The exposure  period is the period of time from the last valuation date when the
OC tests passed  to  the  last  allowable  date  when any OC test breach must be
cured. The exposure period is a central factor in Fitch's rating analysis, as it
limits the maximum number of days that a CEF debt or preferred stock investor is
exposed  to  portfolio market value declines before  deleveraging  and/or  early
redemption takes  place.  The  average  exposure period is around 40-60 business
days for Fitch-rated CEFs.

The exposure period, which is specified in  the  fund  governing  documents,  is
calculated as the sum of the following periods:
{circle}VALUATION  PERIOD: The frequency with which the fund calculates coverage
    ratios to ensure it is passing the tests (typically weekly).
{circle}CURE PERIOD:  The  number of days the fund has to cure any breach before
    entering into a mandatory redemption period (typically 10 business days).
{circle}MANDATORY REDEMPTION  PERIOD: The covenanted time allotted for redeeming
    shares or notes, during which time funds cannot issue additional leverage or
    pay common stock dividends  (typically  30  days).  This  period  is  set to
    account  for  mandated  shareholder notification periods, auction dates, and
    other structural considerations.

In  determining the asset DFs  presented  in  the  table  on  pages  7-8,  Fitch
calculated  stressed  DFs using exposure periods of between 40-60 business days.
Governing documents that  specify  an  exposure  period greater than 60 business
days may result in more conservative DFs being applied  at a given rating level.
Conversely,  an  exposure  period  under  40 business days may  result  in  less
conservative DFs at a given ratings level.  Fitch will evaluate shorter exposure
periods on a case-by-case basis, as shorter liquidation periods can also lead to
higher losses due to periods of market illiquidity and forced selling.

INVESTOR ACTIONS TO ENFORCE OR WAIVE DELEVERAGING

Some closed-end fund debt and preferred stock transaction documents permit their
investors to enforce or waive the fund's deleveraging and collateral maintenance
procedures when asset coverage tests are breached.  Typically,  a minimum number
of  votes  by  certain  investor  classes  are needed for the actions to  become
effective. A waiver of the deleveraging mechanisms may extend the length of time
investors are exposed to volatility in the market  value of the fund's portfolio
and, thus, could put negative pressure on the ratings.

CEF OC TESTS

1940 ACT -  BASELINE PROTECTION TO RATED DEBT AND PREFERRED STOCKHOLDERS

The 1940 Act does not mandate fund deleveraging upon  breach  of  asset coverage
but  does  restrict  payments/declaration  of  common  dividends and limits  the
issuance of new leverage until sufficient 1940 Act asset  coverage  is restored.
However,     fund     operating     documents    usually    include    mandatory
deleveraging/redemptions as a mechanism  for  curing  a  breach of the 1940 Act.
Therefore, 1940 Act asset coverage ratios, as typically incorporated  into  fund
governing  documents,  effectively  limit  the  amount  of  leverage  a fund can
maintain.  The  1940  Act  requires  a  minimum  OC  of  200% for total debt and
preferred  stock  leverage  and  a  minimum  asset  OC of 300% for  senior  debt
leverage.  These  OC tests are based on current, rather  than  stressed,  market
values.




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   Fitch monitors funds' compliance with such 1940 Act asset coverage ratios, as
    they are an important structural protection for investors of rated notes and
  preferred stock. The 200% asset coverage ratio for debt and preferred stock is
  typically calculated in one of two ways, both of which yield the same result:
<2>
 The 300% asset coverage ratio for senior debt is typically calculated in one of
                             two ways, both of which also yield the same result:

ASSIGNING RATINGS BASED ONLY ON INVESTMENT COMPANY ACT OF 1940 ASSET COVERAGE
RATIOS
<3>
Fitch may rely on the  leverage  limits  embedded  in  the  1940 Act when rating
certain CEFs holding less volatile assets. To determine whether  Fitch  can rely
solely  on  1940  Act asset coverage ratios for assigning an `AAA' rating, Fitch
seeks to determine that the fund:
{circle}Is limited to only purchasing lower risk assets.
{circle}Has appropriate levels of issuer and industry diversification consistent
    with Fitch's criteria.
{circle}Restricts forms of leverage to those captured under the 1940 Act.
{circle}Maintains appropriately  conservative  mandatory deleveraging provisions
    that ensure deleveraging and/or redemption of rated obligations within a 60-
    business-day (or less) period.

The table on page 8 shows which asset types have  Fitch  DFs that are lower than
those implied by the 1940 Act's asset coverage tests. These  asset  types may be
analyzed  on  the basis of the 1940 Act's asset coverage tests, subject  to  the
caveats   above.    Fitch's   diversification   guidelines   are   outlined   in
Diversification Framework, pages10-14.

FITCH OC TESTS: GOING BEYOND THE 1940 ACT

The asset coverage/leverage  restrictions  of  the 1940 Act are not sufficiently
conservative at higher ratings levels for many of  the asset types held by CEFs.
Moreover, the 1940 Act tests often do not capture certain forms of leverage.

Fitch's CEF rating criteria measures the OC of debt  and preferred stock via the
Fitch Total OC and Fitch Net OC tests (together, the Fitch  OC tests). The Fitch
OC  tests  address  the  potential  for  additional forms of leverage  and  more
volatile asset classes. Fitch OC tests seek to measure whether the risk-adjusted
market  value  of  fund  assets  is  sufficient   to   meet  all  principal  and
interest/dividends  payments  of  debt  and  preferred stock  upon  optional  or
mandatory redemption. In the absence of other  qualitative considerations, Fitch
OC  and  Fitch  Net  OC  ratios in excess of 100% are  generally  deemed  to  be
consistent with the rating assigned to the debt and preferred stock.

FITCH TOTAL OC TEST: SUFFICIENCY OF ASSET COVERAGE

Fitch evaluates a fund's asset coverage on the basis of the Fitch Total OC
test for each rated class  of  leverage  in  the  fund's  capital structure. The
calculation of the Fitch Total OC test includes, in the numerator, all portfolio
assets  discounted  using  Fitch  DFs  along  with any applicable  haircuts  for
insufficient diversification. The denominator includes all portfolio liabilities
that  are pari passu or are senior to that class  of  rated  debt  or  preferred
stock.
<4>
FITCH NET OC TEST: SUBORDINATION RISK PROTECTION

Fitch also  evaluates  a  CEF's  asset coverage on the basis of the Fitch Net OC
test, which is relevant if a fund  has liabilities that are senior to the Fitch-
rated debt and preferred stock or if  it  has  liabilities  that  are secured by
specific assets. The Fitch Net OC test assesses whether the fund has  sufficient
assets  to  provide  asset coverage for the rated debt or preferred stock  after
first repaying liabilities  that  are legally or structurally more senior in the
capital structure. The Fitch Net OC test is calculated as follows:
<5>
The Fitch Net OC test may be either  more  or  less  conservative than the Fitch
Total OC test and may be particularly relevant for CEFs that utilize senior bank
lines, depending on the collateralization requirements.  For instance, the Fitch
Net OC test could be more conservative when senior bank liabilities  are secured
by specific assets. This may result in the remaining portfolio assets being more
highly concentrated by issuer and/or industry or concentrated in terms  of  more
volatile  asset  types.  Fitch  discounts  the  portfolio's  assets applying the
diversification  framework after subtracting any assets that are  encumbered  as
collateral for senior  obligations.  Fitch  will  calculate available net assets
after subtracting the total amount of senior liabilities  if  senior liabilities
have  a  general  claim  on  fund  assets. If specific assets are encumbered  or
segregated, Fitch will seek to exclude these assets from the OC tests.





FITCH DFS REFLECT ASSETS' MARKET VALUE RISK

Fitch's DFs are used to calculate  the Fitch OC tests. These DFs reflect each
asset class's unique price volatility based  on historically observed worst-case
price declines. For higher ratings levels, Fitch  applied  an  additional stress
factor  multiple and a liquidity haircut to the worst-observed loss.  (For  more
information  on  Fitch's  determination  of  asset-specific DFs, see Appendix 2:
Market Value Approach to DF Development on page  20.)  The DFs in many cases are
higher (i.e. afford CEFs lower levels of leverage) than  allowed  under the 1940
Act, in some cases substantially so (see Fitch DFs tables below and  on page 8).
Fitch will evaluate the sufficiency of the fund's asset coverage in the  context
of the Fitch OC and Fitch Net OC tests for CEFs that invest in higher risk asset
classes in addition to the fund's compliance with the 1940 Act.

<6>Fitch's  DFs  assume a market value exposure period between 40-60 days. Fitch
may determine and  publicly  disclose  DFs  for other collateral types, exposure
periods, and rating stresses on a case-by-case basis. Where DFs are based on the
credit rating of the portfolio asset, Fitch looks  to the Fitch rating first, if
available, otherwise to the lowest available rating  assigned  by  other  global
rating  agencies.  Where only a short-term security rating is available, Fitch's
rating correspondence  table,  available  in  the  Ratings  Definitions  page of
Fitch's  Web  site at www.fitchratings.com, is used to map the security's short-
term rating to a long-term rating.
<7>



                                 Rating Closed-End Fund Debt and Preferred Stock
                                                                               9

                                                                August 16, 2011
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                                                   Leverage Outside the 1940 Act

Fitch  OC tests  also  capture  leverage  that  falls  outside  the  1940  Act's
definitions  of leverage. Nontraditional leverage that is excluded from the 1940
Act asset coverage  tests  include  reverse repurchase agreements, tender option
bonds (TOBs), securities lending arrangements,  to  be  announced (TBA) security
rolls,  forwards,  futures,  total  return  swaps,  credit  default  swaps,  and
purchased and written put and call options, among others.

The 1940 Act generally allows funds to exclude such leverage  from  their  asset
coverage  tests  if  the  leverage  is fully collateralized by segregated liquid
assets or if completely offsetting leverage positions exist, e.g. long and short
credit default swaps referencing the  same  name.  For  more information on this
topic, see Fitch Research on "Closed-End Funds: Evolving  Use  of  Leverage  and
Derivatives,"   dated   Sept.  27,  2010,  available  on  Fitch's  Web  site  at
www.fitchratings.com.

The full effects of leverage  as measured by the 1940 Act may be understated for
funds utilizing such nontraditional  forms  of  leverage. Fitch seeks to include
all forms of leverage, whether on- or off-balance  sheet  for  purposes  of  the
Fitch  OC  tests.  (For  more information on how to calculate the Fitch Total OC
test  and  Fitch  Net  OC  test  based  on  various  types  of  traditional  and
nontraditional leverage, see Appendix 1: Fund Liabilities, page 17.)

DEFERRED TAX LIABILITIES

Most CEFs elect to be treated as regulated investment companies (RICs) under the
Internal Revenue Code of 1986, as amended, allowing them not to pay entity-level
income tax, subject to certain  requirements.  However,  some  CEFs choose to be
treated  as corporations to take advantage of preferred tax treatment  given  to
certain assets,  such  as  MLPs.  As a result, these CEFs may carry deferred tax
liabilities (or assets) on their balance sheets due to appreciation of portfolio
securities and tax deferral on income.

Fitch treats a limited portion (10%)  of  a  fund's  deferred tax liability as a
fund liability for the purposes of calculating the Fitch OC tests. Fitch expects
that, under most market stress scenarios, declines in prices of portfolio assets
will  eliminate the deferred tax liabilities. However,  including  deferred  tax
liabilities in the Fitch OC tests accounts for the remote risk that a portion of
the liability may be realized upon sale of securities in a stressed scenario.

REFINANCING RISKS

CEFs can  be  exposed  to refinancing risk when senior debt matures or is called
early or when debt and term  preferred stock reach maturity, forcing the fund to
liquidate portfolio assets to  provide  for  repayment. To provide for liquidity
upon maturity, the transactional documents for debt and term preferred stock may
require a fund to segregate assets in an amount  at least equal to the amount of
maturing  securities  and  to  convert  the segregated  assets  to  more  liquid
securities  as  maturity approaches. Fitch  views  favorably  the  use  of  such
liquidity accounts and also provisions for longer termination notice periods for
senior financing securities, as they may serve to minimize forced asset sales in
a stressed environment  and  offer additional time to find alternative financing
sources.

DIVERSIFICATION FRAMEWORK

Fitch's CEF ratings guidelines  include  a  minimum diversification framework by
issuer, municipal sector, or corporate industry,  and  by state. Fitch developed
its  DFs  for  various  asset classes based on an analysis of  historical  price
declines and volatility of  various  indices.  As  a  result, the DFs implicitly
assume  that  the  CEF  portfolio  being  evaluated  is  sufficiently   diverse,
consistent with Fitch's diversification framework.

1940 ACT DIVERSIFICATION GUIDELINES

The 1940 Act provides a baseline diversification framework. CEFs regulated under
the 1940 Act may elect to register as a diversified or a nondiversified company,
both with respect to single issuer and industry/sector concentration. The issuer
concentration  guidelines of the 1940 Act permit diversified funds to invest  up
to 5% in a single issuer for up to 75% of their portfolio and allow up to 25% in
a  single  issuer   (also   known   as  the  PlaceNameplaceSafe  PlaceTypeHarbor
provision). The corporate industry and municipal sector concentration guidelines
permit funds to register as diversified  and  subject  their portfolios to a 25%
concentration limitation per industry or municipal sector.  Alternatively,  CEFs
may elect to operate as nondiversified CEFs and concentrate their holdings in  a
particular  industry/sector.  The nondiversified status is utilized primarily by
sector funds, such as real estate- and energy-sector CEFs.

FITCH'S DIVERSIFICATION FRAMEWORK

Fitch views the 1940 Act diversification  framework  as insufficient for ratings
obligations  of  CEFs.  Fitch's CEF rating criteria includes  a  diversification
framework that goes beyond  the 1940 Act, addressing concentration risk relative
to issuers, corporate industries,  municipal  sectors,  and  concentrated  CEFs,
including single-state municipal CEFs.

ISSUER DIVERSIFICATION

Fitch's  criteria captures issuer concentration risk for purposes of calculating
the Fitch  OC  tests.  Fitch  excludes  the  market  value  of any single-issuer
holdings  in  excess of the concentration framework when calculating  the  Fitch
Total  and  Net  OC  tests.  Issuer  concentration  for  corporate  obligors  is
calculated as the  sum  of  debt  and equity securities issued by an entity on a
consolidated basis, rolled up to the holding company level, if applicable.
<8>

The issuer diversification framework  for  municipal  CEFs  is similar, with the
exception of state-level GO bonds and other issues backed by  state-level taxing
authority.  For `AAA' rated CEF obligations, state-level GO obligations  have  a
maximum issuer  guideline  of  20%.  This  is intended to promote an appropriate
amount of portfolio diversification without creating an incentive for portfolios
to diversify away from what is traditionally the most creditworthy and liquid of
municipal issuances from within a given state.

Concentration  for  municipal obligors is aggregated  on  the  basis  of  the
revenue source supporting  repayment.  For example, all general obligation bonds
of a particular city are aggregated to calculate issuer concentration.

CORPORATE INDUSTRY AND MUNICIPAL SECTOR DIVERSIFICATION

Fitch also applies a 25% concentration threshold  to  corporate  industries  and
municipal sectors. Any exposure in excess of 25% is discounted at a higher DF to
account  for  increased  concentration  risks.  Specifically,  the DF applied to
municipal assets in excess of the 25% industry/municipal sector  diversification
guidelines are increased by an additional 1.1x or 1.25x, depending  on the state
GO ratings. The DF multiple for corporate industry concentrations above  25%  is
1.5x.
<9><10><11>
The  particular  multiples  Fitch  applies  to  DFs  on  the  basis of portfolio
concentration were derived by comparing the performance of broad  market indices
to indices concentrated in particular corporate industries and municipal sectors
and states.

<12>Certain  indices  utilized  by Fitch to derive DFs, such as and the  Merrill
Lynch Preferred Stock indices for preferred stock securities and the Alerian MLP
Index for equity securities issued  by MLPs, are inherently sector concentrated.
As such, the worst-case losses and resultant DFs already include a concentration
element. Therefore, Fitch does not apply  an additional DF multiple with respect
to preferred stock securities or securities issued by MLPs, RITs, or MTS.

SINGLE-STATE MUNICIPAL CEFS POSE ADDED RISKS

Fitch's  CEF criteria consider the inherent  concentration  risks  presented  by
single-state  CEFs, which typically invest 75%-100% of assets in a single state.
For single-state  concentrations  above 25%, Fitch applies a DF multiple of 1.1x
for securities of issuers located in  a  single  state  rated at least `BBB' and
1.25x  for  issuers located in a state rated below `BBB'. This  is  intended  to
capture the increased  likelihood  of  price  volatility and correlation between
portfolio  assets  from  a  single  state  under credit  stress,  which  may  be
exacerbated by headline risk and/or forced selling.
<13>
ASSET MARKET DEPTH AN IMPORTANT CONSIDERATION

The depth and diversity of a given asset class  is an important consideration in
Fitch's  analysis of CEFs' portfolios and the liquidity  of  underlying  assets.
Assets in a market with a homogenous or overly concentrated investor base may be
less liquid,  particularly  in  periods  of  stress  where  such  investors  may
experience  simultaneous  selling  pressures.  For example, an asset market with
significant open-end fund and CEF composition could  be  exposed  to  a downward
spiral  of  pricing  pressure  as  CEFs  simultaneously hit liquidation triggers
and/or open-end funds experience redemption pressure due to NAV declines.







OTHER RATING CONSIDERATIONS

EARLY DEBT AND PREFERRED STOCK REDEMPTIONS

Historically, CEFs have made prepayments or  early  redemptions  of  outstanding
securities at par or full liquidation preference. More recently, some  CEFs have
elected  to  make tender offers to repurchase outstanding ARPS at a price  below
their full liquidation  preference  as  a  means to offer ARPS investors partial
liquidity.

Fitch typically does not view such tender offers  at  a  price  less than par or
full liquidation amount as a distressed debt exchange leading to  a  restrictive
default, provided that the redemption is fully discretionary to investors and is
not  coercive. On the other hand, Fitch may consider a tender offer coercive  if
the securities  were  not redeemed in cash and/or if the fund announced that the
interest or dividend rate  is  lowered for securities that are not tendered. For
more  information  on this topic,  see  Fitch  Research  on  "Closed-End  Funds:
Redemptions Provide  Some  Liquidity  to  Illiquid  ARPS Market," dated Aug. 31,
2010, available on Fitch's Web site at www.fitchratings.com.

PREPAYMENT PREMIUMS AND MAKE-WHOLE AMOUNTS

Transaction documents of certain CEF liabilities at times incorporate a variable
make-whole amount that is required to be paid to investors  as  a  result  of  a
breach  of  asset  coverage  tests.  The  increased  payment  may put additional
pressure  on the CEF's ability to restore appropriate levels of  asset  coverage
and/or redeem  obligations.  Therefore,  Fitch  includes  any  make-whole amount
dictated  by transaction documents for purposes of calculating the  Fitch  asset
coverage tests.  Fitch  may also elect to apply an additional stress factor in a
higher and/or more volatile interest rate environment.

Similar to make-whole amounts,  fixed  prepayment  premium  obligations are also
added to total principal and accrued expenses when grossing up  the fund's total
liabilities for purposes of calculating the Fitch OC tests. Given  the fixed and
pre-specified  nature  of  the  potential  liability  to the fund, no additional
stress beyond the prepayment premium amount is applied.

Some CEF liabilities have a make-whole provision that is  enacted  solely in the
event  of a voluntary and optional prepayment of the notes at the discretion  of
the fund  and  is  not  applicable  in the event of an early redemption due to a
breach of the fund's asset coverage/deleveraging tests. In such instances, Fitch
makes no adjustments in calculating Fitch OC tests.

EVALUATING COUNTERPARTY RISK

Fitch  evaluates  counterparty  risk  arising   from   funds'   over-the-counter
derivative   positions   when   assigning   ratings   to  CEF  liabilities.  The
effectiveness of hedges and the value of speculative positions are linked to the
performance of the derivative counterparty.

To evaluate counterparty risk, Fitch reviews the structure  of  the  transaction
and credit risk of the counterparty in comparison to Fitch's criteria,  as noted
in "Counterparty Criteria for Structured Finance Transactions," dated March  14,
2011,  available  on  Fitch's Web site at www.fitchratings.com. Fitch looks to a
minimum Fitch long-term  issuer default rating (IDR) of `A' and a minimum short-
term IDR of `F1' of the swap  counterparty  to support notes and preferred stock
ratings in the `AA' category or higher. If sufficient  collateral is posted, the
criterion is extended to counterparties rated a minimum of `BBB+' and `F2'.

For  purposes of calculating the Fitch Total and Net OC Tests,  Fitch  does  not
include  any collateral posted by funds' counterparties in nonhedging derivative
transactions  as  part  of the tests' numerator because such amounts are already
reflecting in Fitch's treatment  of  derivatives described in Appendix 1. On the
other hand, Fitch includes any assets  posted  by  the fund to a counterparty as
part of the Fitch Total OC Test numerator, subject to appropriate DFs.

For  other  counterparty transactions such as securities  lending  arrangements,
counterparty  concentration remains a risk regardless of the market value of the
transaction. In  securities  lending arrangements, securities lent are typically
handled by the same counterparty  that  retains  the  cash  collateral received,
exposing  the  fund  to risk of loss on both the securities lent  and  the  cash
collateral. Fitch will  assess  such  risk  on  a case-by-case basis, evaluating
whether cash collateral is held by a bankruptcy-remote  entity  apart  from  the
counterparty, and calculating the Fitch Net OC test by subtracting the higher of
discounted  cash  collateral received or the discounted securities lent from the
numerator.

IMPLEMENTATION OF STRUCTURAL MECHANISMS

Historically, CEF governing documents incorporated most, if not every, aspect of
the rating criteria  that prevailed when the fund was originally rated. However,
the absence of detailed  descriptions  of Fitch's CEF rating criteria, including
asset-specific  DFs,  will  not on its own  have  adverse  rating  implications,
provided that the fund maintains  sufficient deleveraging mechanisms and adheres
to  guidelines  that  are conservative  compared  with  Fitch's  current  rating
criteria. From the perspective  of  the  investor  and  the  fund manager, Fitch
believes  this  offers  greater  transparency and easier implementation  of  any
future criteria changes.

STRESS TESTING AS PART OF THE ANALYSIS

Fitch may conduct stress tests on  CEF  portfolios  in  cases  where  the fund's
structure  and/or  portfolio guidelines differ from Fitch's criteria at a  given
ratings level. Stress  tests  contemplate  worst  case  scenarios  to ensure the
assigned  rating  can  withstand  adverse  changes  in  the fund's profile.  For
example, the tests may model migration in the fund's portfolio  composition  and
leverage to the limits of the fund's operating and investment guidelines.

For municipal CEFs, additional stress tests may include the instantaneous credit
migration  of  financial  guarantors  providing financial guarantee insurance to
portfolio securities or the instantaneous  decreases  in  the  prices of unrated
and/or below investment-grade portfolio assets, among others.

INFORMATION USED TO DETERMINE A RATING

In issuing and maintaining its ratings, Fitch relies on factual  information  it
receives  from issuers and underwriters and from other sources the rating agency
believes to  be  credible.  Fitch  conducts  a  reasonable  investigation of the
factual  information  relied on by it in accordance with its rating  methodology
and  obtains  reasonable  verification  of  that  information  from  independent
sources, to the  extent  such sources are available for a given security or in a
given jurisdiction. Issuers  may  choose  not  to share certain information with
external parties, including rating agencies, at  any  time.  While Fitch expects
that each issuer that has agreed to participate in the rating  process,  or  its
agents,  will  supply  promptly all information relevant for evaluating both the
ratings of the issuer and  all relevant securities, Fitch neither has, nor would
it seek, the right to compel  the disclosure of information by any issuer or any
agents of the issuer.

INVESTMENT MANAGER REVIEW

Fitch assigns ratings at the request  of  investors or fund management and after
reviewing all pertinent material and conducting an on-site manager review. Fitch
performs a manager evaluation on a pass/fail basis. A failed review would likely
preclude Fitch from assigning ratings in the  case  of a review for a new rating
or lead to negative rating pressure in the case of an  existing  rating. Fitch's
initial  and  ongoing  reviews  of  CEFs  encompass an analysis of the following
areas:
{circle}INVESTMENT POLICIES AND PROCEDURES:  Sector  overview, sector allocation
    and diversification, portfolio strategy construction and target composition,
    use of derivatives, and asset liquidity.
{circle}OPERATIONS: Asset pricing and portfolio valuation,  fair  value  pricing
    procedures,  trading  and  settlement  trade, reconciliation, and technology
    support.
{circle}LEGAL AND COMPLIANCE: Regulatory compliance,  including  compliance with
    the  fund's  governing  documents  on  the 1940 Act and Fitch OC tests,  SEC
    examinations, board of directors structure  and  independence,  and external
    and internal audits.
{circle}ORGANIZATION: Organizational and management structure, assets  by amount
    and  type  under  management,  key  personnel  experience and track records,
    product marketing, and distribution.

The  on-site  review includes meetings with the portfolio  management  team  and
related personnel.  During the on-site review, the company has an opportunity to
present information on  its  history,  ownership  structure, business plans, and
investment strategies, as well as demonstrate its credit selection and portfolio
monitoring  capabilities.  Fitch  also  evaluates  the  appropriateness  of  the
alignment of interests between the fund manager and the rated note and preferred
stock  investors.  The  organization  is  asked  to provide information  on  its
operating processes, related technologies, controls, and staffing resources.

INVESTMENT MANAGER REPLACEMENT

Due to the importance of the investment manager to  a  CEF's  operations,  Fitch
reviews  the  legal framework for replacement of the investment manager in cases
of a bankruptcy  or  insolvency  of  the  manager,  or otherwise in an event the
manager cannot perform its duties. The 1940 Act sets  forth parameters to govern
the  manager's  advisory  relationship  with  a CEF, providing  for  the  timely
replacement of an investment manager. Fitch anticipates that the fund's board of
directors, acting in its fiduciary duty, would  reassign  the manager's advisory
responsibilities on determining that the manager is unable to perform them.

SURVEILLANCE

Fitch monitors fund compliance with Fitch OC and 1940 Act tests as follows:
{circle}Weekly, funds internally calculate the Fitch OC and  1940  Act tests. If
    the  resultant  ratios are less than 5% above the minimum passing  threshold
    (e.g. 105% for a  Fitch  OC tests and 210% for a 1940 Act test for preferred
    stock), Fitch expects CEF  managers  to  notify  the  fund analyst so a more
    frequent dialogue can be held as necessary.
{circle}At  least  monthly,  funds  calculate  and  provide Fitch  with  updated
    portfolio holdings and Fitch OC and 1940 Act test results.
{circle}Fitch typically performs a review of each rated  fund and its investment
    manager annually . The review includes assessing the fund's adherence to its
    stated investment objectives and constraints, net asset  value  performance,
    and  recent  asset  coverage  ratios;  an  evaluation  of  the alignment  of
    interests  between  the fund manager and the rated note and preferred  stock
    investors; and a discussion  with  the  fund  manager  to  determine  future
    investment strategies, plans, and other forms of research.
{circle}In  periods of heightened credit and/or liquidity stress, Fitch reserves
    the right to initiate more frequent/detailed surveillance procedures.

The regular reporting  of asset coverage tests and updated portfolio holdings to
Fitch  by  the  fund  manager   and/or   administrator  is  central  to  Fitch's
surveillance process and critical to maintaining  the outstanding ratings on CEF
debt and preferred stock. Failure to receive this information in a timely manner
may result in negative rating actions and/or the withdrawal of assigned ratings.

To facilitate standardized reporting of fund information  and  to  assist in the
adoption of the new criteria and weekly testing, Fitch has developed a reporting
template.  The  Microsoft  Excel-based  template  includes a coverage page  that
summarizes the fund's assets, liabilities, and relevant  asset  coverage  ratios
and a portfolio holdings page, with built-in formulas for determining asset  DFs
and  diversification  guidelines.  Parties interested in receiving a copy of the
reporting template may contact any of the analysts listed on page 1.

In  addition  to  the information and analysis  provided  by  the  funds,  Fitch
performs its own internal  analysis  to  support ratings surveillance. First, to
assist in developing a current credit opinion  for  each fund and to measure up-
to-date  performance  for  all rated CEF debt and preferred  stock,  Fitch  will
internally calculate a 1940  Act  ratio  on  a  regular basis to gauge portfolio
volatility between monthly surveillance reports.  The internal monitoring serves
as a trigger point for further dialogue with managers  and  helps  Fitch  verify
performance  figures  noted  in the monthly/weekly surveillance reports received
from funds. Fitch also periodically  monitors  ongoing  asset price movements to
ensure DFs remain appropriate.




<PAGE>

                                               <14>  APPENDIX 1: CEF LIABILITIES

<15>


<PAGE>








                             Appendix 2: Market Value Approach to DF Development

Fitch  has  developed  DFs  through  historical  worst-loss stress  testing,  an
approach that is consistent with its criteria as detailed in the criteria report
"Rating Market Value Structures," dated Aug. 16, 2011,  available on Fitch's Web
site at www.fitchratings.com. To reflect the dynamic and  diverse  nature of CEF
portfolios, Fitch has developed specific DFs for common asset types.

Discounted portfolio assets are used as the numerator for the Fitch OC tests and
are calculated by dividing current portfolio market value by the appropriate  DF
for  each  asset  type.  DFs  are not intended to provide a static view of asset
performance, rather they express  current  views  of potential market value loss
through current economic conditions and the credit  cycle.  Fitch will perform a
periodic review of DFs using the methodology described in this  criteria report.
Fitch's  determination  of  asset  DFs was primarily based on worst-loss  events
experienced by each asset class. Therefore,  even  if  future analysis indicates
more  positive  and/or stable asset performance than implied  in  the  currently
presented DFs, Fitch may leave the DFs unchanged.

Fitch  established   DFs   through   determination   of  the  appropriate  asset
categorization, quantitative analysis, and modeling of  historical  asset  price
movements, as well as other qualitative considerations.

CATEGORIZATION OF ASSET CLASSES

Fitch  reviewed  major  asset  classes  within  the  CEF investable universe and
assigned asset groups differentiated by type and exhibited  magnitude  of market
value risk (for a list of Fitch-identified asset classes, see the table on pages
7-8).  This  approach segregated assets by sector, subordination in the issuer's
capital  structure,   domicile,   credit   rating,  and  duration.  Market-based
characteristics,  such  as  price or spread measures,  were  not  utilized  when
segregating assets into distinct  categories for the purposes of assigning asset
DFs. The grouping of asset types is  intended  to  strike an appropriate balance
between  differences  in market value performance of asset  subclasses  and  the
diminishing benefit of overly specific classification (due to the correlation of
similar assets and the  challenges  a  more  expanded  approach  would  bring to
implementation  by  funds).  Assigning  portfolio  assets  to  broader groups is
intended  to allow funds to allocate DFs and perform the Fitch OC  tests  in  an
efficient and transparent manner.

QUANTITATIVE ANALYSIS AND MODELING

For each asset  class,  Fitch constructed a base case stress based on historical
index performance and considered  the  volatility  and  liquidity  of  the given
index.  The  base  case stress was then converted into an expected loss at  each
rating level by multiplying  the base case stress by a representative factor for
higher rating stress scenarios.

VOLATILITY

Fitch's analysis of a given asset  category  was  based  on  observation  of the
worst-case  price decline experienced by the index, given a rolling 45-business-
day exposure  period.  The  analysis  used  historical  price data drawn from an
asset's representative index. Qualified indices typically  had at least 10 years
of available data. The starting dates for the index data varied but in all cases
included the financial crisis of 2008 and ended in June 2011.  At  times,  Fitch
used  multiple  indices  for  its analysis, looking at both price volatility and
index constituents. Representative indices for each asset class were selected on
the  basis  of  the  best fit between  the  index  constituents.  Factors  Fitch
considered in determining  robustness  included frequency of data points, length
of pricing history, inclusion of multiple  stress  periods  and business cycles,
and  appropriateness of data series for the asset category under  consideration.
Examples  of  indices  used include the S&P 500 Index, as a proxy for historical
price volatility of U.S.  large  cap common stock; the Alerian MLP
Index, for MLPs; the LSTA Leveraged Loan Index,  for first lien leveraged loans;
and   the  Lehman  Intermediate  Corporate  Index,  for  U.S.
investment-grade corporate debt that matures in less than 10 years.

As an added  measure  of  conservatism,  in  certain  instances, Fitch increased
historically observed worst losses if the asset class had  experienced its worst
45-business-day  loss  within  the  preceding six months. This was  intended  to
address the uncertainty of potential  further price declines in the near future.
The size of the increase was based on the  timing of the observed worst loss and
the degree of historical volatility experienced by the index.

LIQUIDITY

Fitch views market liquidity in periods of stress to be particularly relevant to
ensure deleveraging mechanisms work as intended.  Therefore,  Fitch  constructed
separate  liquidity stresses based on observations of stressed liquidations  and
discussions   with   various   internal  sector  analysts  and  external  market
participants. The amount of liquidity  adjustments  varied  by  asset  type; for
example, publicly traded equities received no additional liquidity haircut given
the deep, established market for such securities.

Overall,  Fitch  made  an  assessment  of an asset's liquidity profile based  on
factors such as:
{circle}Market size.
{circle}Market volumes (current and historical).
{circle}Bid/offer spreads, both in regular and stressed markets.
{circle}Observed liquidation prices during periods of stress.
{circle}Breadth and diversity of investors.
{circle}Size of issuance.
{circle}Transparency of the issuer.
{circle}Assessment of normal and large block trading sizes.
{circle}Depth of market making and stability in times of stress.

EXPECTED LOSS

A base case stress was calculated for each  asset  class as the sum of the worst
loss plus any illiquidity adjustment. Each base case  stress  was  classified by
Fitch  as  being  consistent  with a particular rating stress, as determined  by
reviewing the main worst-loss drivers,  the scale of decline during the specific
economic period, and the magnitude of worst  loss  compared  to other historical
losses. Once a rating level was determined for each base case  stress,  the base
case  stress  was  increased  using  corresponding multipliers to reflect higher
expected losses under higher rating stress  scenarios.  The multiplier was based
on historical asset performance by rating category. For example,  to  increase a
`BBB' rating stress to an `AAA' level, a multiple of two was used. Therefore, if
an asset class's observed worst case loss for a 45-business-day period  was  11%
and  this  loss  was deemed consistent with a `BBB' rating stress, then an `AAA'
level worst loss was  estimated  at  22%  over  the  45-day  period, assuming no
additionally liquidity add on. For `A' rating level base cases,  the  add-on for
an  `AAA'  is 1.5x. Most base case worst case losses were judged to be `BBB'  or
`A' rating stresses for purposes of this criteria.

QUALITATIVE ASSESSMENT

Calculating  base  case historical stresses per asset category was only one of a
number of factors Fitch considered when determining DFs. Fitch also analyzed the
fundamental characteristics of assets, which included an analysis of the asset's
structure  (e.g. convertible  securities)  and  information  transparency  (e.g.
liquidity).  The  asset's  place  in  the  issuer's  capital  structure was also
analyzed, with assets falling lower in the capital structure typically receiving
higher  DFs.  For example, equities received more conservative DFs  compared  to
bonds. However,  this  was not always the case; for instance, third-lien secured
leveraged loans received  lower  DFs  than unsecured high-yield bonds, primarily
due to the relatively poor liquidity associated  with  such  loans. Furthermore,
given  the  importance  of  robust  historical  data  in determining  worst-loss
estimates, asset classes that did not include significant periods of stress were
afforded little to no credit for the purpose of Fitch's analysis.







<16>


<PAGE>










Endnotes

                                                                           <1>











RELATED CRITERIA
Counterparty Criteria for Structured Finance Transactions, March 14, 2011

Rating Market Value Structures, Aug. 16, 2011
Global Bond Fund Rating Criteria, Aug. 16, 2011
placePuerto Rico Closed-End Fund Debt and Preferred Stock, Aug. 16, 2011


RELATED RESEARCH
Tax-Exempt  CEFs  Change Leverage (ARPS Balances Reduced; New Securities Provide
Flexibility), June 17, 2011

Taxable Closed-End  Funds  Reduce ARPS Leverage, Shift to Alternate Forms, May
25, 2011

CLOs and CEFs: A Comparison  of  Leveraged Loan Investment Vehicles, April 26,
2011

Tax-Exempt Closed-End Funds Weather  Price  Declines  (Asset  Coverage Remains
Strong), Feb. 2, 2011

Closed-End Funds: Evolving Use of Leverage and Derivatives, Sept. 27, 2010

Closed-End Funds: Redemptions Provide Some Liquidity to Illiquid ARPS Market
, Aug. 31, 2010


ANALYSTS
Ian Rasmussen
+1 212 908-0232
ian.rasmussen@fitchratings.com



Yuriy Layvand, CFA
+1 212 908-9191
yuriy.layvand@fitchratings.com



Greg Fayvilevich
+1 212 908-9151
gregory.fayvilevich@fitchratings.com

Nathan Flanders
+1 212 908-0827
nathan.flanders@fitchratings.com

Roger W. Merritt
+1 212 908-0636
roger.merritt@fitchratings.com





<2>

<TABLE>
<CAPTION>
=                     [Total Assets at MV - Current Liabilities[a]]/
<S> <C>
            [All 1940 Act Leverage[b] + Accrued Expenses and Fees on Leverage]
                                            or
=   [Common Equity + All 1940 Act Leverage[ ] + Accrued Expenses and Fees on Leverage]/
              [All 1940 Act Leverage + Associated Accrued Expenses and Fees]
[
</TABLE>

]
<TABLE>
<CAPTION>
aCurrent liabilities do not include any liabilities associated with fund leverage, as recognized by the 1940 Act in Section 18.
[b]1940 Act leverage only includes leverage that funds interpret to be recognized as leverage under Section 18 of the 1940 Act (e.g.
preferred stock, notes, and bank facility). Other types of leverage, such as reverse repurchase agreements, mortgage dollar rolls,
and noncash settled derivatives, are excluded from this test and, instead, follow asset segregation rules. For more information see
Fitch Research on "Closed-End Funds: Evolving Use of Leverage and Derivatives
," dated Sept. 27, 2010, available on Fitch's Web site at www.fitchratings.com.
<S>



<3>


<CAPTION>
=                     [Total Assets at MV - Current Liabilities[a]]/
<S> <C>
        [All Senior 1940 Act Leverage[a] + Accrued Expenses and Fees on Leverage]
                                            or
=   [Common Equity + All 1940 Act Leverage[ ] + Accrued Expenses and Fees on Leverage]/
          [All Senior 1940 Act Leverage + Accrued Expenses and Fees on Leverage]
[
</TABLE>

]
<TABLE>
<CAPTION>
aSenior 1940 Act leverage only includes leverage that funds interpret to be recognized as senior securities other than preferred
stock under Section 18 of the 1940 Act. (e.g. notes and bank facility). Similar to the 200% test, other types of leverage such as
reverse repurchase agreements, mortgage dollar rolls, and noncash settled derivatives are excluded from the 300% test and instead
follow asset segregation rules. For more information, see Fitch Research on "Closed-End Funds: Evolving Use of Leverage and
Derivatives," dated Sept. 27, 2010, available on Fitch's Web site at www.fitchratings.com.
<S>



<4>

<CAPTION>
Fitch Total OC =                        Total Net Discounted Assets at MV[a]/
<S>              <C>
                 Fitch Rated Liability + Other Liabilities Pari Passu and Senior to Rated Liability
[
</TABLE>

]
<TABLE>
<CAPTION>
aTotal net discounted assets at market value (MV) equal total portfolio assets at MV and accrued income, including assets held as
collateral for other fund liabilities, less nonleverage liabilities that are not part of a rolling leverage strategy (such as to-be-
announced (TBA) securities, futures, and forwards, among others), then discounted at the Fitch DFs in the table on pages 7-8 and
adjusted as per the Fitch diversification criteria discussed on pages xx-xx.
<S>



<5>



------------------------------------------------------------------------------
|Fitch Net OC =|             Available Net Discounted Assets[a]/              |
------------------------------------------------------------------------------
|              |Fitch Rated Liability + Other Liabilities That Are Pari Passu|
------------------------------------------------------------------------------
|[             |                                                             |
------------------------------------------------------------------------------

]

<CAPTION>
aAvailable net discounted assets equals total portfolio assets at MV and accrued income minus all assets that are either held as
collateral for other fund liabilities and/or subject to a first claim of a senior liability in the capital structure minus
nonleverage liabilities that are not part of a rolling leverage strategy (such as TBA security rolls, futures, and forwards, among
others), then discounted at the Fitch DFs in the table on pages 7-8 and adjusted per Fitch's criteria discussed in Diversification
Framework on pages10-14.
<S>




<6>
------------------------
|FITCH DISCOUNT FACTORS|
------------------------

<CAPTION>
 DISCOUNT FACTORS APPROPRIATE FOR DIFFERENT RATING LEVELS OF CEF DEBT AND PREFERRED STOCK
<S> <C>
</TABLE>
<TABLE>
<CAPTION>
ASSETS                                                                                                            AAA   AA    A  BBB
<S>                                                                                                              <C>  <C>  <C>  <C>
CASH AND SHORT-TERM INVESTMENTS
Cash and Receivables Due in 10 Business Days or Less                                                             1.00 1.00 1.00 1.00
Securities Rated in `A' to `AAA' Rating Categories; < 1 Year                                                     1.10 1.08 1.05 1.00

U.S. GOVERNMENT SECURITIES
Treasuries, Supranationals, Direct U.S. Agency Debt, and U.S. Agency-Backed                                      1.10 1.08 1.05 1.00
MBS; 1-10 Years[a]
Treasuries, Supranationals, Direct U.S. Agency Debt and U.S. Agency MBS; >10                                     1.25 1.20 1.15 1.10
Years

SOVEREIGNS
Debt of Developed Countries; 1-10 Years[ b c]                                                                    1.15 1.10 1.08 1.05
Debt of Developed Countries; >10 Years                                                                           1.30 1.25 1.20 1.15
Debt of Emerging Countriesd                                                                                      3.10 2.40 1.75 1.50

MUNICIPALS
Obligations in `AAA' or `AA' Rating Categories; 1-10 Years[e]                                                    1.20 1.15 1.10 1.08
Obligations in `A' Rating Category; 1-10 Years                                                                   1.30 1.20 1.15 1.10
Obligations in `AAA' Or `AA' Rating Categories; >10 Years                                                        1.45 1.35 1.25 1.20
Obligations in `BBB' Rating Category; 0-10 Years                                                                 1.45 1.35 1.25 1.20
Obligations in `A' Rating Category; >10 Years                                                                    1.50 1.40 1.30 1.20
Obligations in `BBB' Rating Category; >10 Years                                                                  1.70 1.50 1.40 1.25
Obligations Below Investment Grade or Unrated                                                                    2.50 2.00 1.70 1.45

CORPORATES
Bonds, Developed Countries, in `AAA' or `AA' Rating Categories; 1-10 Years[f]                                    1.30 1.20 1.15 1.10
Bonds, Developed Countries, in `A' Rating Category; 1-10 Years                                                   1.40 1.30 1.25 1.20
Bonds, Developed Countries, in `BBB' Rating Category; 0-10 Years                                                 1.40 1.30 1.25 1.20
Bonds, Developed Countries, in `AAA' or `AA' Rating Categories; >10 Years                                        1.40 1.30 1.25 1.20
Bonds, Developed Countries, in `A' or `BBB' Rating Categories; >10 Years                                         1.65 1.50 1.35 1.25
Bonds, Developed Countries, in `BB' Rating Category                                                              1.80 1.60 1.40 1.30
Bonds, Developed Countries, in `B' Rating Category                                                               2.15 1.80 1.55 1.40
Bonds, Developed Countries, Rated `CCC' or Lower or Unrated                                                      3.70 2.55 1.95 1.60
Bonds, Emerging Countries                                                                                        4.60 2.90 2.10 1.65

CONVERTIBLES
Busted Convertible Debt, Developed Countries, in `AAA' or `AA' Rating Categories or Unrated; 1 -10 Years[f]      1.30 1.20 1.15 1.10
Busted Convertible Debt, Developed Countries, in `A' or `BBB' Rating Categories; 1 -10 Years                     1.40 1.30 1.25 1.20
Busted Convertible Debt, Developed Countries, in `AAA' or `AA' Rating Categories or Unrated; >10 Years           1.40 1.30 1.25 1.20
Busted Convertible Debt, Developed Countries, in `A' or `BBB' Rating Categories; >10 Years                       1.65 1.50 1.35 1.25
Typical Convertible Debt, Typical Convertible Preferred Stock and Busted Convertible Preferred Stock, Developed  1.80 1.60 1.40 1.30
Countries, Investment Grade, or Unrated[h]
Busted Convertible Debt and Busted Convertible Preferred Stock, Developed Countries, in `BB' Rating Category     1.80 1.60 1.40 1.30
Busted Convertible Debt and Busted Convertible Preferred Stock, Developed Countries, in `B' Rating Category      2.15 1.80 1.55 1.40
Equity Sensitive Convertible Debt and Equity Sensitive Convertible Preferred Stock, Investment Grade, or         2.15 1.80 1.55 1.40
Unrated[i]
Typical Convertible Debt and Typical Convertible Preferred Stock, Below Investment Grade                         2.55 2.05 1.65 1.45
Synthetic Convertible Securities[j]                                                                                 -    -    -    -
[
</TABLE>

]
<TABLE>
<CAPTION>
aAsset category for agency-backed MBS excludes interest- and principal-only issues. [b]Sovereign debt excludes-
U.S. [c]Developed countries are advanced economies, as defined by the IMF. [d]Emerging countries are defined as all
countries not included in the aforementioned definition of developed countries. [e]`AAA' rated municipals include refunded and pre-
refunded municipal bonds, backed by U.S. government collateral. [f]Bonds category includes the collateralized
bond asset class. [g]Busted convertible securities are defined as convertible securities having a conversion premium in excess of
70%. Conversion premium is calculated as (MV  of the convertible security MV of total stock into which the security may be converted
to)/MV of the convertible security). [h]Typical convertible securities are defined as convertible securities that have a conversion
premium between 20% and 70%. [i]Equity sensitive convertible securities are defined as convertible securities that have a conversion
premium less than 20%. [j]Fitch will evaluate synthetic convertible securities on a case-by-case basis to determine the appropriate
DF and diversification treatment. In making this determination, Fitch will review the credit rating of the issuer and put provider,
the provisions on put protection and stock delta, and whether the underlying stock is trading at an equity sensitive, typical, or
busted conversion premium.
<S>





<7>
------------------------------------
|FITCH DISCOUNT FACTORS (CONTINUED)|
------------------------------------

<CAPTION>
 DISCOUNT FACTORS APPROPRIATE FOR DIFFERENT RATING LEVELS OF CEF DEBT AND PREFERRED STOCK
<S> <C>
</TABLE>
<TABLE>
<CAPTION>
ASSETS                                                                                                            AAA   AA    A  BBB
<S>                                                                                                              <C>  <C>  <C>  <C>
CONVERTIBLES (CONTINUED)
Busted Convertible Debt and Busted Convertible Preferred Stock, Rated 'CCC' or Lower or Unrated Distressed       3.70 2.55 1.95 1.60
Convertible Debt and Unrated Distressed Convertible Preferred Stock, Developed Countries[i]
Equity Sensitive Convertible Debt and Equity Sensitive Convertible Preferred Stock, Below Investment Grade       4.00 2.70 2.05 1.60
Convertible Debt and Convertible Preferred Stock, Emerging Countries                                             5.00 3.50 2.10 1.75

LEVERAGED LOANS
Performing U.S., Canadian, and European Union (EU) First Lien Loans Not Covenant Light[j k]                      1.55 1.40 1.30 1.25
Performing U.S., Canadian, and EU Second Lien and Covenant Light First                                           2.50 2.00 1.60 1.40
Performing U.S., Canadian, and EU Third Lien and Covenant Light Second                                           5.00 3.50 2.10 1.65

EQUITY
MLPs, RITs, and MTS, $1.5+ Billion Float-Adjusted Market Capitalization[l]                                       2.20 1.75 1.50 1.35
U.S. and Developed Countries, Large Capitalization[m]                                                            2.60 2.10 1.70 1.50
U.S. and Developed Countries, Medium Capitalization, and Small Capitalization, and MLPs, RITs                    4.00 2.70 2.05 1.60
and MTS, with Less Than $1.5 Billion Float-Adjusted Market Capitalization[n o]
Emerging and Developing Markets                                                                                  5.50 3.75 2.20 1.75

PREFERRED STOCK
Preferred Stock                                                                                                  2.50 2.00 1.60 1.40

FOREIGN CURRENCY
Unhedged Foreign Currency Exposure, Investment-Grade Countries (In Addition to Standard Asset DFs)               1.50 1.40 1.30 1.25

STRUCTURED SECURITIES
ABS Student Loans 'AAA' FFELP Non-ARS; < 10 Years[p]                                                             1.35 1.25 1.20 1.15
CMBS Issued 2005 or Earlier: Super-Senior Tranches Rated; 'AAA'[q]                                               1.45 1.35 1.25 1.20
ABS Student Loans 'AAA' FFELP Non-ARS; > 10 Years[p]                                                             1.45 1.35 1.25 1.20
CMBS Issued After 2005: Super-Senior Tranches Rated 'AAA'[q]                                                     1.70 1.50 1.35 1.30
Non-Agency RMBS, other ABS, other CMBS, and CLOs rated 'AAA'[r]                                                  1.80 1.60 1.40 1.30
Non-Agency RMBS, other ABS, other CMBS, and CLOs rated 'AA' or 'A'[r]                                            2.50 2.00 1.60 1.45

OTHER
All Other Assets                                                                                                   NC   NC   NC   NC
[
</TABLE>

]
<TABLE>
<CAPTION>
iDistressed convertibles have a bid price below 60% of par, as defined on page 303 of the March 2008 edition of "A Guide to the
Lehman Brothers Global Family of Indices." [j]Performing loans are defined as loans that remain current on principal and interest
payment obligations. [k]Covenant light loans are defined as loans without maintenance-style financial covenants, such as maximum
leverage and minimum interest and cash flow coverage tests, which are required to be tested (and passed) each quarter or half year.
Fitch's DFs on leveraged loans are primarily derived from the performance of the U.S. leveraged loan market and
reflects the jurisdictional support of creditor's rights in the U.S. To date, this analysis has also been
applicable to leveraged loans originating from Canada and the EU, which together with U.S.
leveraged loans constitute the majority of investments made by Fitch-rated loan closed-end funds. However, should a marked change in
jurisdictional mix and creditor's rights take place in any of these geographical locations, Fitch will re-evaluate its DFs to
reflect such data. [l]Defined as excluding closely held stock and cross holdings, among others, consistent with the calculation
methodology of the Alerian MLP Index. Also includes publicly traded c-corps with more than 80% of assets in MLPs, RITs, and MTS.
Notwithstanding this, MLPs, RITs, and MTS that are restricted from trading with 180 days or less until the first available
registration date are afforded same DFs as MLPs, RITs and MTS with less than $1.5 billion market capitalization, subject to a 10%
overall limit on exposure. [m]Large capitalization is defined as company stock that has market capitalization equal to or more than
$5 billion. [n]Medium capitalization is defined as company stock that has market capitalization of less than $5billion and equal to
or more than $1 billion. [o]Small capitalization is defined as company stock that has market capitalization of less than $1 billion.
[p]FFELP non-ARS student loans refer to the private sector student loan programs organized through one of the-
U.S. federal agencies' family education loan program. These loans have either full or almost-full support of the-
U.S. government, depending on vintage. Non-ARS refers to those investments that do not trade as an auction-rate security.
[q]Super-senior tranche refers to a tranche that has at least one other 'AAA' rated tranche junior to it and no other tranches
senior to it in the capital structure. Furthermore, such tranche should not be on Rating Watch Negative or Rating Outlook Negative.
[r]Other ABS includes 'AAA' rated obligations securitized by credit card and automobile loan receivables and student loans that are
not already captured by other security-type categories in the above table. Notes: For all asset classes, asset maturity is
calculated on the basis of the security's final maturity, except for securities that contain a put provision at the security
holder's option. In such instances and for the purpose of determining the appropriate asset DF, the next available put date may be
assumed to be the asset maturity date. For investments that synthetically reference diversified indices or portfolios, Fitch
calculates the average credit quality needed to select the appropriate DF by: looking to the Fitch rating of each underlying
security, if available, otherwise at the lowest available rating of other global rating agencies; assigning a probability of default
value to each underlying security based on Fitch's Corporate CDO Criteria; and calculating the probability-of-default weighted-
average credit rating of that index/portfolio in consistency with Fitch's report "Global Bond Fund Rating Criteria," DATED AUG. 16,
2011. MLPs - Master limited partnerships. RITs - Royalty or income trusts. MTS - Marine transportation securities. NC - No credit
given unless evidence of stable market value risk can be demonstrated.
<S>





<8>
----------------------------------------------------
|FITCH CORPORATE ISSUER DIVERSIFICATION GUIDELINES||
                                                  --
-------------------------------------------------------------------------------
|OBLIGOR                   | MAXIMUM AMOUNT ELIGIBLE FOR FITCH OC TESTS (%)[A]|
-------------------------------------------------------------------------------
|Largest Obligor           |                                             10[b]|
|Next Five Largest Obligors|                                                 5|
-------------------------------------------------------------------------------
|All Other Obligors        |                                                 3|
-------------------------------------------------------------------------------
|[                         |                                                  |
-------------------------------------------------------------------------------

]

<CAPTION>
aOn a case-by-case basis, Fitch may raise its issuer concentration thresholds for funds where Fitch rates the issued debt or
preferred stock below investment grade, since such rating already reflects, to an extent, the increased risk associated with the
idiosyncratic risk in the fund's portfolio. [b]On a case-by-case basis, Fitch may raise its issuer concentration thresholds for
exposure to broadly diversified investment portfolios or holding companies. Notes: It is not uncommon for some fund managers to
invest in other diversified funds, indices, or investment vehicles. In such cases, Fitch's single obligor guidelines may not apply.
For restricted MLPs, RITs, and MTS securities, up to 10% aggregate exposure may be counted toward the Fitch OC tests. Any excess
exposure is not eligible for credit. In cases where an obligor is in excess of these guidelines and the fund's exposure is to
multiple securities, Fitch excludes the market values of securities with the highest DF first.
<S>





<9>
---------------------------------------------------
|FITCH MUNICIPAL ISSUER DIVERSIFICATION GUIDELINES|
---------------------------------------------------
*-------------------------------------------
||MAXIMUM % ELIGIBLE FOR FITCH OC  TESTS[A]|
*-------------------------------------------

<CAPTION>
                                                                                                   AAA  AA   A  BBB
<S>                                                                                               <C>  <C> <C> <C>
State-Level General Obligations and Other Municipal Issues Backed by State-Level Taxing Authority   20  40  60   80
Largest Obligor[b]                                                                                  10  10  10   10
Next Five Largest Obligors                                                                           5   5   5    5
All Other Obligors                                                                                   3   3   3    3
[
</TABLE>

]
<TABLE>
<CAPTION>
aOn a case-by-case basis, Fitch may raise its issuer concentration thresholds for funds where it rates the issued debt or preferred
stock below investment grade, since such rating already reflects, to an extent, the increased risk associated with the idiosyncratic
risk in the fund's portfolio. Reflects maximum concentrations at a given rating stress for debt or preferred obligations issued by
CEFs. [b]Excluding state-level general obligation and other municipal issues backed by state-level taxing authority, on a case-by-
case basis, Fitch may raise its issuer concentration thresholds for exposure to broadly diversified investment portfolios or holding
companies. Notes: In cases where an obligor is in excess of these guidelines and the fund's exposure is to multiple securities,
Fitch excludes the market values of securities with the highest DF first.
<S>





<10>

CORPORATE INDUSTRIES FOR PURPOSES OF DETERMINING FUNDS' SINGLE-INDUSTRY EXPOSURE[A]

--------------------------------------------------------------------------------
|INDUSTRIES SUBJECT TO 25% THRESHOLD PER FUND  |                               |
--------------------------------------------------------------------------------
|Aerospace and Defense                         |General Retail                 |
--------------------------------------------------------------------------------
|Automobiles, Building and Materials, Chemicals|Healthcare                     |
--------------------------------------------------------------------------------
|Banking, Finance, and Insurance               |Industrial/Manufacturing       |
--------------------------------------------------------------------------------
|Broadcasting, Media, and Cable                |Lodging and Restaurants        |
--------------------------------------------------------------------------------
|Business Services                             |Metals and Mining              |
--------------------------------------------------------------------------------
|Computer and Electronics, Telecommunications  |Packaging and Containers       |
--------------------------------------------------------------------------------
|Consumer Products                             |Paper and placeForest Products |
--------------------------------------------------------------------------------
|Energy (Oil and Gas)                          |Pharmaceuticals                |
--------------------------------------------------------------------------------
|Environmental Services                        |Real Estate                    |
--------------------------------------------------------------------------------
|Farming and Agricultural Services             |Sovereigns                     |
--------------------------------------------------------------------------------
|Food and Drug Retail                          |Textiles and Furniture         |
--------------------------------------------------------------------------------
|Food, Beverage, and Tobacco                   |Transportation and Distribution|
--------------------------------------------------------------------------------
|Gaming, Leisure, and Entertainment            |Utilities (Power)              |
--------------------------------------------------------------------------------
|[                                             |                               |
--------------------------------------------------------------------------------

]
-----------------------------------------
|aBased on Fitch corporate CDO criteria.|
-----------------------------------------





<11>
------------------------------------------------------------------------------
|MUNICIPAL SECTORS FOR PURPOSES OF DETERMINING FUNDS' SINGLE-SECTOR EXPOSURE||
------------------------------------------------------------------------------

<CAPTION>
SECTORS SUBJECT TO 25% THRESHOLD[A]
<S>                                               <C>
Pre-Refunded/Escrowed                             Municipal Essential Service
Revenue[c]
General Obligation and Lease/Appropriation Backed Transportation Revenue
Special Tax Backed                                Corporate Backed[d]
Healthcare Revenue[b]                             Housing Revenue
Higher Education Revenue
[
</TABLE>

]
<TABLE>
<CAPTION>
aInvestments in bonds that have been pre-refunded or escrowed to maturity and in bonds that are backed by state-level general
obligation are exempt from the 25% threshold. [b]Includes hospitals, nursing, and senior care facility bonds, among others.
[c]Includes power, water, and sewer bonds, among others. [d]Includes tobacco bonds, investor-owned utilities, and industrial
development bonds, among others.
<S>




<12>

SUMMARY OF INDUSTRY DIVERSIFICATION GUIDELINES FOR TAXABLE CEFS

Treatment for Exposure in Excess of 25% to a Single Corporate Industry
Additional 1.5x Multiple to Applicable Asset DF
Note: In instances where a fund has concentration in excess of  25%,
Fitch's diversification framework applies the DF multiple on a
pro rata basis across all instruments within such a group.




<13>
---------------------------------------------------------------------------
|SUMMARY OF SECTOR/STATE DIVERSIFICATION GUIDELINES FOR TAX-EXEMPT CEFS[A]|
---------------------------------------------------------------------------

<CAPTION>

<S>           <C>                                                    <C>
State General Treatment for Exposures in Excess of 25% to a Single   Treatment for Exposures in Excess of 25% to a
Obligation    Municipal Sector[b]                                    placePlaceNameSingle PlaceTypeState
Rating
BBB or Higher Additional 1.1x Multiple to Applicable Asset DF        Additional 1.1x Multiple to Applicable Asset DF
BBB- or Lower Additional 1.1x Multiple to Applicable Asset DF        Additional 1.25x Multiple to Applicable Asset DF
[
</TABLE>

]
<TABLE>
<CAPTION>
aThis table summarizes sector/state diversification guidelines that are applicable to municipal CEFs. Other general guidelines, such
as the issuer diversification framework, continue to apply. [b]Excludes state-level general obligation bonds and issues backed by
state-level taxing authority. Note: In instances where a fund has concentration in excess of 25%, Fitch's diversification framework
applies the DF multiple on a pro rata basis across all instruments within such a group.
<S>












<14>
--------------------------------------------------------------
|TREATMENT OF FUND LIABILITIES FOR FITCH OC TEST CALCULATIONS|
--------------------------------------------------------------
*--------------------------------------------------
||FITCH OC TESTS FOR RATED DEBT OR PREFERRED STOCK|
*--------------------------------------------------
*---------------------------------------
||FITCH TOTAL OC TEST|FITCH NET OC TEST|
*---------------------------------------

<CAPTION>
COLUMN 1                  COLUMN 2                                                          COLUMN 3      COLUMN 4      COLUMN 5
<S>                       <C>                                                               <C>           <C>           <C>
TREATMENT OF NONRATED     NUMERATOR                                                         DENOMINATOR   NUMERATOR     DENOMINATOR
LIABILITIES IN FUND'S
CAPITAL STRUCTURE
Current Liabilities       - Current liabilities that will settle within 10 days (does not   No            + Amount in   No
                          include rolled securities, forwards, futures, and other leverage  adjustments   column 2      adjustments
                          instruments)
Notes or Preferred Stock  +Discounted MV of reinvested assets                               No            + Amount in   No
(Subordinate to Rated                                                                       adjustments   column 2      adjustments
Liability)
                                                                                                          - Any
                                                                                                          earmarked
                                                                                                          asset
                                                                                                          collateral MV
                                                                                                          for the
                                                                                                          liabilities
Notes or Preferred Stock  + Discounted MV of reinvested assets                              + Outstanding + Amount in   +
(Pari Passu to Rated                                                                        liability     column 2      Outstanding
Liability)                                                                                                              liability
                                                                                            +accrued      - Any         + accrued
                                                                                            interest and  earmarked     interest and
                                                                                            fees          asset         fees
                                                                                                          collateral MV
                                                                                                          for the
                                                                                                          liabilities
Notes or Preferred Stock  + Discounted MV of reinvested assets                              + Outstanding + Amount in   No
(Senior to Rated                                                                            liability     column 2      adjustments
Liability)
                                                                                            +accrued      - Any
                                                                                            interest and  earmarked
                                                                                            fees          asset
                                                                                                          collateral MV
                                                                                                          for the
                                                                                                          liabilities;
                                                                                                          if no
                                                                                                          earmarked
                                                                                                          collateral,
                                                                                                          then - column
                                                                                                          3
Bank Credit Facilities    + Discounted MV of reinvested assets                              + Outstanding + Amount in   No
                                                                                            liability     column 2      adjustments
                                                                                            + accrued     - Any
                                                                                            interest and  earmarked
                                                                                            fees          asset
                                                                                                          collateral MV
                                                                                                          for the
                                                                                                          liabilities;
                                                                                                          if no
                                                                                                          earmarked
                                                                                                          collateral,
                                                                                                          then - column
                                                                                                          3
ABCP Conduit Financing    + Discounted MV of reinvested assets                              + Outstanding + Amount in   No
Facilities                                                                                  liability     column 2      adjustments
                                                                                            +accrued      - Any
                                                                                            interest and  earmarked
                                                                                            fees          asset
                                                                                                          collateral MV
                                                                                                          for the
                                                                                                          liabilities;
                                                                                                          if no
                                                                                                          earmarked
                                                                                                          collateral,
                                                                                                          then - column
                                                                                                          3
Reverse Repurchase        + Discounted MV of reinvested assets                              + Outstanding + Amount in   No
Agreements                                                                                  liability     column 2      adjustments
                                                                                            + accrued     - Any
                                                                                            interest and  earmarked
                                                                                            fees          asset
                                                                                                          collateral MV
                                                                                                          for the
                                                                                                          liabilities;
Floating Rate             + Discounted MV of reinvested assets                              + Note        + Amount in   No
Certificates of Tender                                                                      liability;    column 2      adjustments
Option Bonds (TOB) -                                                                        +accrued
corresponding to any                                                                        interest and
inverse floaters                                                                            fees
(residuals) held by the
fund
                          + Discounted MV of bond in TOB subject to an additional 10%                     - Bond
                          haircut                                                                         collateral MV
                                                                                                          held in TOB
                                                                                                          trust
Securities Lending        + Discounted MV of securities lent                                + Liability   + Amount in   No
                                                                                            due upon      column 2      adjustments
                                                                                            return of
                                                                                            securities
                          + Discounted MV of collateral held for securities lent                          - Amount in
                                                                                                          column 3
Security Rolls (e.g.      + Discounted MF of referenced assets                              + Liability   + Amount in   No
Mortgage Dollar Rolls)                                                                      due on        column 2      adjustments
                                                                                            settlement
                                                                                            date
                                                                                                          - Amount in
                                                                                                          column 3
Futures and Forwards,     + Discounted MV of referenced assets                              + Liability   + Amount in   No
Long (includes                                                                              due on        column 2      adjustments
eurodollar, euribor and                                                                     settlement
UK 90                                                                                       date
day futures, "Money
Market Futures")
                          + Discounted MV of collateral held                                              - Amount in
                                                                                                          column 3
Futures and Forwards,     + Amount receivable on settlement date                            + Referenced  + Amount in   No
Short (includes money                                                                       asset MV      column 2      adjustments
market futures)[a]                                                                          multiplied by
                                                                                            1 + [1 -
                                                                                            (1/DF)]
                          + Discounted MV of collateral held                                              - Amount in
                                                                                                          column 3
Securities Sold Short[a]  + Discounted MV of reinvested assets                              + MV of       + Amount in   No
                                                                                            Securities    column 2      adjustments
                                                                                            Sold Short
                                                                                            multiplied by
                                                                                            1 + [1 -
                                                                                            (1/DF)]
                          + Discounted MV of collateral held                                              - Amount in
                                                                                                          column 3
Interest Rate Swaps       + Discounted value of (swap notional {plus-minus} MV of fixed-    + Swap        + Amount in   No
(Long, Receive Fixed and  rate leg)                                                         notional      column 2      adjustments
Pay Floating)
                                                                                                          - Amount in
                                                                                                          column 3
Interest Rate Swaps       + Swap notional                                                   + Swap        + Amount in   No
(Short, Receive Floating                                                                    Notional      column 2      adjustments
and Pay Fixed)                                                                              {plus-minus}
                                                                                            1 + [1 -
                                                                                            (1 /DF)]      - Amount in
                                                                                                          column 3
Total Return Swaps (Long) + Discounted referenced assets MV                                 + (Referenced + Amount in   No
                                                                                            asset MV -    column 2      adjustments
                                                                                            equity stake
                                                                                            or collateral
                                                                                            put up)
                                                                                                          - Amount in
                                                                                                          column 3
Credit Default Swaps      + Discounted (CDS notional {plus-minus} MV)                       + CDS         + Amount in   No
(Long Credit, Protection                                                                    notional      column 2      adjustments
Seller)
                          + Discounted MV of assets' reinvested proceeds or assets                        - Amount in
                          segregated as a result of entering into the position (such as                   column 3
                          received upfront fee and any collateral held)
</TABLE>
**
||
**




<15>
--------------------------------------------------------------------------
|TREATMENT OF FUND LIABILITIES FOR FITCH OC TEST CALCULATIONS (CONTINUED)|
--------------------------------------------------------------------------
*--------------------------------------------------
||FITCH OC TESTS FOR RATED DEBT OR PREFERRED STOCK|
*--------------------------------------------------
*---------------------------------------
||FITCH TOTAL OC TEST|FITCH NET OC TEST|
*---------------------------------------
<TABLE>
<CAPTION>
COLUMN 1                                        COLUMN 2                                           COLUMN 3    COLUMN 4  COLUMN 5
<S>                                             <C>                                                <C>         <C>       <C>
TREATMENT OF NONRATED LIABILITIES IN FUND'S     NUMERATOR                                          DENOMINATOR NUMERATOR DENOMINATOR
CAPITAL STRUCTURE
Credit Default Swaps (Short Credit, Protection  + Lower of 0 or (CDS MV - present value of future  No          + Amount  No
Buyer)                                          payments)                                          adjustments in column adjustments
                                                                                                               2
Deferred Swaps                                  Same as active swaps                               Same as     Same as   Same as
                                                                                                   active      active    active
                                                                                                   swaps       swaps     swaps
Put Options (Purchased)                         + Max 0, (Strike price - Reference Asset MV x [1 + No          + Amount  No
                                                (1 - (1/DF))]                                      adjustments in column adjustments
                                                                                                               2
Call Options (Purchased)                        + Max 0, (Reference Asset MV/ DF) - Strike Price   No          + Amount  No
                                                                                                   adjustments in column adjustments
                                                                                                               2
Put Options (Written)                           + Min 0, (Reference Asset MV/ DF) - Strike Price   No          + Amount  No
                                                                                                   adjustments in column adjustments
                                                                                                               2
Call Options (Written)                          + Min 0, (Strike price - Reference Asset MV x [1 + No          + Amount  No
                                                (1 - (1/DF))]                                      adjustments in column adjustments
                                                                                                               2
Any On- and Off-Balance Sheet Liabilities Not   Case-by-case basis                                 Case-by-    Case-by-  Case-by-
Addressed Above                                                                                    case basis  case      case basis
                                                                                                               basis
[
</TABLE>

]

<CAPTION>
aFitch considers naked short selling as a form of leverage.
Naked short selling is economically similar to a short
future or forward
contract, except the asset value recovered on the date of
unwind/call is unknown in advance because it is driven by
the value of the
reinvested assets on that date. Whereas in a short
future or forward contract, the value received
on date of contract expiration is
known in advance. As a general matter, Fitch
will evaluate the use of naked short selling
on a case-by-case basis, paying particular
attention to issuer and industry concentration
added by the positions in the context of the
overall portfolio. Note: derivative
positions that are used to hedge portfolio
assets should first be netted before
determining any net long or short derivative
exposure. Treatment for any net derivative
exposure (an amount not used to hedge or
offset other derivatives or portfolio assets) is
described in the table above. Appropriate
DFs from the Fitch DFs table on pages 7-8
apply where noted. Derivatives referencing money
market indices, such as the three-month
LIBOR rate, three-month Euribor rate, and
the UK 90-day rate would
utilize a DF of 1.01.






<16>ALL FITCH CREDIT RATINGS ARE SUBJECT TO CERTAIN LIMITATIONS AND DISCLAIMERS.
PLEASE   READ   THESE  LIMITATIONS  AND  DISCLAIMERS  BY  FOLLOWING  THIS  LINK:
HTTP://FITCHRATINGS.COM/UNDERSTANDINGCREDITRATINGS
. IN ADDITION, RATING  DEFINITIONS  AND  THE  TERMS  OF  USE OF SUCH RATINGS ARE
AVAILABLE  ON  THE  AGENCY'S PUBLIC WEB SITE AT WWW.FITCHRATINGS.COM.  PUBLISHED
RATINGS, CRITERIA, AND  METHODOLOGIES ARE AVAILABLE FROM THIS SITE AT ALL TIMES.
FITCH'S  CODE OF CONDUCT,  CONFIDENTIALITY,  CONFLICTS  OF  INTEREST,  AFFILIATE
FIREWALL,  COMPLIANCE,  AND  OTHER  RELEVANT  POLICIES  AND  PROCEDURES ARE ALSO
AVAILABLE FROM THE CODE OF CONDUCT SECTION OF THIS SITE.
Copyright  {copyright}  2011  by  Fitch,  Inc.,  Fitch  Ratings  Ltd.   and  its
subsidiaries. One State Street Plaza, NY, NY 10004.Telephone:
1-800-753-4824,   (212)   908-0500.   Fax:   (212)   480-4435.  Reproduction  or
retransmission  in  whole  or in part is prohibited except  by  permission.  All
rights reserved. In issuing and maintaining its ratings, Fitch relies on factual
information it receives from  issuers  and  underwriters  and from other sources
Fitch believes to be credible. Fitch conducts a reasonable  investigation of the
factual   information  relied  upon  by  it  in  accordance  with  its   ratings
methodology,  and  obtains  reasonable  verification  of  that  information from
independent  sources,  to  the  extent  such sources are available for  a  given
security or in a given jurisdiction. The manner of Fitch's factual investigation
and the scope of the third-party verification  it obtains will vary depending on
the nature of the rated security and its issuer,  the requirements and practices
in the jurisdiction in which the rated security is  offered  and sold and/or the
issuer  is located, the availability and nature of relevant public  information,
access to  the  management  of  the issuer and its advisers, the availability of
pre-existing  third-party  verifications  such  as  audit  reports,  agreed-upon
procedures letters, appraisals,  actuarial  reports,  engineering reports, legal
opinions  and  other  reports  provided  by third parties, the  availability  of
independent and competent third-party verification  sources  with respect to the
particular  security  or  in  the particular jurisdiction of the issuer,  and  a
variety  of other factors. Users  of  Fitch's  ratings  should  understand  that
neither an  enhanced  factual investigation nor any third-party verification can
ensure that all of the  information  Fitch relies on in connection with a rating
will be accurate and complete. Ultimately,  the  issuer  and  its  advisers  are
responsible for the accuracy of the information they provide to Fitch and to the
market  in  offering  documents  and other reports. In issuing its ratings Fitch
must rely on the work of experts, including independent auditors with respect to
financial statements and attorneys  with  respect  to  legal  and  tax  matters.
Further,  ratings  are  inherently  forward-looking  and  embody assumptions and
predictions  about  future  events that by their nature cannot  be  verified  as
facts. As a result, despite any  verification  of  current facts, ratings can be
affected by future events or conditions that were not  anticipated at the time a
rating was issued or affirmed.
The information in this report is provided "as is" without any representation or
warranty of any kind. A Fitch rating is an opinion as to the creditworthiness of
a security. This opinion is based on established criteria and methodologies that
Fitch  is  continuously  evaluating  and updating. Therefore,  ratings  are  the
collective work product of Fitch and no  individual, or group of individuals, is
solely responsible for a rating. The rating  does  not  address the risk of loss
due to risks other than credit risk, unless such risk is specifically mentioned.
Fitch  is not engaged in the offer or sale of any security.  All  Fitch  reports
have shared  authorship.  Individuals identified in a Fitch report were involved
in,  but  are not solely responsible  for,  the  opinions  stated  therein.  The
individuals  are  named  for  contact  purposes only. A report providing a Fitch
rating is neither a prospectus nor a substitute  for  the information assembled,
verified and presented to investors by the issuer and its  agents  in connection
with the sale of the securities. Ratings may be changed or withdrawn  at anytime
for  any  reason  in  the  sole  discretion  of  Fitch.  Fitch  does not provide
investment advice of any sort. Ratings are not a recommendation to buy, sell, or
hold any security. Ratings do not comment on the adequacy of market  price,  the
suitability  of any security for a particular investor, or the tax-exempt nature
or taxability  of  payments made in respect to any security. Fitch receives fees
from issuers, insurers,  guarantors, other obligors, and underwriters for rating
securities.  Such fees generally  vary  from  US$1,000  to  US$750,000  (or  the
applicable currency equivalent) per issue. In certain cases, Fitch will rate all
or a number of issues issued by a particular issuer, or insured or guaranteed by
a particular insurer  or  guarantor,  for  a  single  annual  fee. Such fees are
expected  to  vary  from  US$10,000 to US$1,500,000 (or the applicable  currency
equivalent). The assignment,  publication, or dissemination of a rating by Fitch
shall not constitute a consent  by  Fitch  to  use  its  name  as  an  expert in
connection  with any registration statement filed under the United
States securities  laws,  the  Financial  Services  and  Markets  Act of 2000 of
Great  Britain,  or  the  securities  laws  of any particular
jurisdiction.  Due  to  the  relative  efficiency  of electronic publishing  and
distribution, Fitch research may be available to electronic  subscribers  up  to
three days earlier than to print subscribers.
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