<DOCUMENT>
<TYPE>EX-99.77D POLICIES
<SEQUENCE>4
<FILENAME>pcminvpolicy.txt
<DESCRIPTION>INV. POLICY
<TEXT>
Changes in Investment Policy:

Effective June 1, 2012, the Fund eliminated its non-fundamental policy to
invest at least 50% of its total assets in commercial mortgage-backed
securities ("CMBS") ("50% Policy"), such that the Fund no longer has a minimum
investment policy with respect to CMBS.

The elimination of the 50% Policy provides the Fund with additional flexibility
to invest a greater portion of its portfolio in asset classes other than CMBS,
including, but not limited to, agency-guaranteed mortgage-backed securities,
private label (commonly known as "non-agency") mortgage-backed securities,
investment-grade corporate debt securities and high yield corporate debt
securities. The Fund's management team believes that greater investment
flexibility may further serve to diversify the portfolio across a variety of
potentially higher yielding securities. Such increased investment flexibility
is particularly attractive to the management team in light of ongoing
volatility across financial markets. While the Fund's management team
currently expects the Fund to continue to have exposure to CMBS, the
management team now has greater flexibility to pursue, subject to market
conditions and other factors, other income generating opportunities in fixed
income investments.

Changes in Fundamental Investment Policy:

Amendment and Restatement of Fundamental Policy on Industry Concentration. At
a special meeting of stockholders held on August 20, 2012, stockholders of the
Fund approved an amendment and restatement of the Fund's current fundamental
investment policy regarding industry concentration. The Fund;s amended and
restated policy (the "New Policy") is as follows: "The Fund, under normal
circumstances, will invest at least 25% of its total assets (i.e., concentrate)
in privately-issued mortgage-related securities not issued or guaranteed as to
principal or interest by the U.S. Government or its agencies or
instrumentalities. The Fund may not purchase any security if as a
result 25% or more of the Fund's total assets (taken at current value at the
time of investment) (i.e., concentrate) would be invested in a single industry
(for purposes of this restriction, investment companies are not considered to
be part of any industry)."

For purposes of applying the second sentence of the New Policy (the "industry
concentration policy"), the Sub-Adviser will, on behalf of the Fund, make
reasonable determinations as to the appropriate industry classification to
assign to each security or instrument in which the Fund invests. Investments in
securities of a single foreign government represent investments in a separate
industry, although currency positions are not considered to be an investment in
a foreign government for these purposes. Mortgage-related or other asset-backed
securities that are issued or guaranteed as to principal or interest by the
U.S. Government or its agencies or instrumentalities are not subject to the
industry concentration policy, by virtue of the exclusion from that test
available to all U.S. Government securities.

For purposes of applying the first sentence of the New Policy, privately-issued
mortgage-related securities means any mortgage-related security (other than
those issued or guaranteed as to principal or interest by the U.S. Government
or its agencies or instrumentalities), such as securities representing
interests in, collateralized or backed by, or whose values are determined in
whole or in part by reference to any number of mortgages or pools of mortgages
or the payment experience of such mortgages or pools of mortgages, including
Real Estate Mortgage Investment Conduits ("REMICs"), which could include
resecuritizations of REMICs ("Re-REMICs"), mortgage passthrough securities,
inverse floaters, collateralized mortgage obligations, collateralized loan
obligations, multiclass pass-through securities, private mortgage pass-through
securities, and stripped mortgage securities (generally interest-only and
principal-only securities). Exposures to mortgage-related securities through
derivatives or other financial instruments will be considered investments in
mortgage-related securities. Privately-issued mortgage related securities also
may include, without limitation, interests in pools of residential mortgages or
commercial mortgages, and may relate to domestic or non-U.S. mortgages.
</TEXT>
</DOCUMENT>
