<DOCUMENT>
<TYPE>EX-99.77Q2 ITEM 405
<SEQUENCE>3
<FILENAME>77Q2.txt
<DESCRIPTION>EXHIBIT 77Q2
<TEXT>
EXHIBIT 99.77Q2

SUB-ITEM 77Q2.

Section 16(a) Beneficial Ownership Reporting Compliance

Based solely on a review of the copies of Section 16(a) forms furnished
to the registrant, or written representations that no Forms 5 were
required, the registrant believes that during the fiscal year ended
October 31, 2011 all Section 16(a) filing requirements applicable to
its officers, directors and greater than 10% beneficial owners were
complied with, except that one Form 4 (reporting two transactions) was
filed late by Bank of America Corporation.



</TEXT>
</DOCUMENT>
