<DOCUMENT>
<TYPE>EX-99.(R)(3)
<SEQUENCE>23
<FILENAME>dex99r3.txt
<DESCRIPTION>CODE OF ETHICS FOR PACIFIC INVESTMENT MGMT COMPANY
<TEXT>
<PAGE>

                                                                     Exhibit r.3

                              PIMCO CODE OF ETHICS

                        Effective as of December 31, 2001

                                  INTRODUCTION

                               General Principles

     This Code of Ethics is based on the principle that you, as a director,
officer or other Advisory Employee of Pacific Investment Management Company
("PIMCO"), owe a fiduciary duty to, among others, the shareholders of the Funds
and other clients (together with the Funds, the "Advisory Clients") for which
PIMCO serves as an advisor or subadvisor. Accordingly, you must avoid
activities, interests and relationships that might interfere or appear to
interfere with making decisions in the best interests of our Advisory Clients.

     At all times, you must observe the following general rules:

     1.    You must place the interests of our Advisory Clients first. In other
           words, as a fiduciary you must scrupulously avoid serving your own
           personal interests ahead of the interests of our Advisory Clients.
           You must adhere to this general fiduciary principle as well as comply
           with the Code's specific provisions. Technical compliance with the
           Code's procedures will not automatically insulate from scrutiny any
           trades that indicate an abuse of your fiduciary duties or that create
           an appearance of such abuse.

           Your fiduciary obligation applies not only to your personal trading
           activities but also to actions taken on behalf of Advisory Clients.
           In particular, you may not cause an Advisory Client to take action,
           or not to take action, for your personal benefit rather than the
           benefit of the Advisory Client. For example, you would violate this
           Code if you caused an Advisory Client to purchase a Security or
           Futures Contract you owned for the purpose of increasing the value of
           that Security or Futures Contract. If you are a portfolio manager or
           an employee who provides information or advice to a portfolio manager
           or helps execute a portfolio manager's decisions, you would also
           violate this Code if you made a personal investment in a Security or
           Futures Contract that might be an appropriate investment for an
           Advisory Client without first considering the Security or Futures
           Contract as an investment for the Advisory Client.

     2.    You must conduct all of your personal Investment Transactions in full
           compliance with this Code and the PIMCO Advisors L.P. Insider Trading
           Policy and Procedures (the "Insider Trading Policy"), and in such a
           manner as to avoid any actual or potential conflict of interest or
           any abuse of your position of trust and responsibility. PIMCO
           encourages you and your family to develop personal investment
           programs. However, those investment programs must remain within
           boundaries reasonably necessary to ensure that appropriate safeguards
           exist to protect the interests of our Advisory Clients and to avoid
           even

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                  the appearance of unfairness or impropriety. Accordingly, you
                  must comply with the policies and procedures set forth in this
                  Code under the heading PERSONAL INVESTMENT TRANSACTIONS. In
                  addition, you must comply with the policies and procedures set
                  forth in the Insider Trading Policy, which is attached to this
                  Code as Appendix II. Doubtful situations should be resolved in
                  favor of our Advisory Clients and against your personal
                  trading.

         3.       You must not take inappropriate advantage of your position.
                  The receipt of investment opportunities, perquisites, gifts or
                  gratuities from persons seeking business with PIMCO directly
                  or on behalf of an Advisory Client could call into question
                  the independence of your business judgment. Accordingly, you
                  must comply with the policies and procedures set forth in this
                  Code under the heading GIFTS AND SERVICE AS A DIRECTOR.
                  Doubtful situations should be resolved against your personal
                  interest.

                         The General Scope Of The Code's
                 Applications To Personal Investment Activities

         The Code reflects the fact that PIMCO specializes in the management of
fixed income portfolios. The vast majority of assets PIMCO purchases and sells
on behalf of its Advisory Clients consist of corporate debt Securities, U.S. and
foreign government obligations, asset-backed Securities, money market
instruments, foreign currencies, and futures contracts and options with respect
to those instruments. For its StocksPLUS Funds, PIMCO also purchases futures and
options on the S & P 500 index and, on rare occasions, may purchase or sell
baskets of the stocks represented in the S & P 500. For its Convertible Fund and
other Advisory Clients, PIMCO purchases convertible securities that may be
converted or exchanged into underlying shares of common stock. Other PIMCO Funds
may also invest in convertible securities. The Convertible Fund and other
Advisory Clients may also invest a portion of their assets in common stocks.

         Rule 17j-1 under the Investment Company Act of 1940 requires reporting
of all personal transactions in Securities (other than certain Exempt
Securities) by certain persons, whether or not they are Securities that might be
purchased or sold by PIMCO on behalf of its Advisory Clients. The Code
implements that reporting requirement.

         However, since the purpose of the Code is to avoid conflicts of
interest arising from personal trading activities in Securities and other
instruments that are held or might be acquired on behalf of our Advisory
Clients, this Code only places restrictions on personal trading activities in
such investments. As a result, this Code does not place restrictions (beyond
reporting) on personal trading in most individual equity Securities. Although
equities are Securities, they are not purchased or sold by PIMCO on behalf of
the vast majority of PIMCO's Advisory Clients and PIMCO has established special
procedures to avoid conflicts of interest that might otherwise arise from
personal trading in such equity securities. On the other hand, this Code does
require reporting and restrict trading in certain Futures Contracts which,
although they are not Securities, are instruments in which PIMCO frequently
trades for many of its Advisory Clients.

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        This Code applies to PIMCO's officers and directors as well as to all of
its Advisory Employees. The Code recognizes that portfolio managers and the
investment personnel who provide them with advice and who execute their
decisions occupy more sensitive positions than other Advisory Employees and that
it is appropriate to subject their personal investment activities to greater
restrictions.

                          The Organization Of The Code

        The remainder of this Code is divided into three sections. The first
section concerns Personal Investment Transactions. The second section describes
the restrictions on Gifts And Service As A Director. The third section
summarizes the methods for ensuring Compliance under the Code. In addition, the
following Appendices are also a part of this Code:

I.      Definitions of Capitalized Terms
II.     The PIMCO Advisors L.P. Insider Trading Policy and Procedures
III.    Form for Acknowledgment of Receipt of this Code
IV.     Form for Annual Certification of Compliance with this Code
V.      Form for Initial Report of Accounts
VI.     Form for Quarterly Report of Investment Transactions
VII.    Form for Annual Holdings Report
VIII.   Preclearance Request Form
IX.     Preclearance Request Form - PIMCO Closed End Funds
X.      List of PIMCO Compliance Officers

                                    Questions

        Questions regarding this Code should be addressed to a Compliance
Officer listed on Appendix X. Those Compliance Officers compose the PIMCO
Compliance Committee.

                        PERSONAL INVESTMENT TRANSACTIONS

                                   In General

        Subject to the limited exceptions described below, you are required to
report all Investment Transactions in Securities and Futures Contracts made by
you, a member of your Immediate Family or a trust in which you have an interest,
or on behalf of any account in which you have an interest or which you direct.
In addition, you must preclear certain Investment Transactions in Securities and
Futures Contracts that PIMCO holds or may acquire on behalf of an Advisory
Client, including certain Investment Transactions in Related Securities.

        The details of these reporting and preclearance requirements are
described below. This Code uses a number of capitalized terms, e.g. Advisory
Employee, Beneficial Ownership, Designated Equity Security, Exempt Security,
Fixed Income Security, Fund, Futures Contract, Immediate Family, Initial Public
Offering, Investment Transaction, Personal Account, Portfolio

                                       3

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Employee, Private Placement, Qualified Foreign Government, Related Account,
Related Security, and Security. The definitions of these capitalized terms are
set forth in Appendix I. To understand your responsibilities under the Code, it
is important that you review and understand the definitions in Appendix I.

                              Reporting Obligations

        Notification Of Reporting Obligations

        As an Advisory Employee, you are required to report accounts and
Investment Transactions in accordance with the requirements of this Code.

        Use Of Broker-Dealers And Futures Commission Merchants

        Unless you are an independent director, you must use a registered
broker-dealer or registered futures commission merchant to engage in any
purchase or sale of a publicly-traded Security or Publicly-Traded Futures
Contract. This requirement also applies to any purchase or sale of a
publicly-traded Security or of a Publicly-Traded Futures Contract in which you
have, or by reason of the Investment Transaction will acquire, a Beneficial
Ownership interest. Thus, as a general matter, any Investment Transaction in
publicly-traded Securities or Publicly-Traded Futures Contracts by members of
your Immediate Family will need to be made through a registered broker-dealer or
futures commission merchant.

        Initial Report

        Within 10 days after commencing employment or within 10 days of any
event that causes you to become subject to this Code (e.g. promotion to a
position that makes you an Advisory Employee), you shall supply to a Compliance
Officer copies of the most recent statements for each and every Personal Account
and Related Account that holds or is likely to hold a Security or a Futures
Contract in which you have a Beneficial Ownership interest, as well as copies of
confirmations for any and all Investment Transactions subsequent to the
effective date of those statements. These documents shall be supplied to the
Compliance Officer by attaching them to the form appended hereto as Appendix V.

        On that same form you shall supply the name of any broker, dealer, bank
or futures commission merchant and the number for any Personal Account and
Related Account that holds or is likely to hold a Security or a Futures Contract
in which you have a Beneficial Ownership interest for which you cannot supply
the most recent account statement. You shall also certify, where indicated on
the form, that the contents of the form and the documents attached thereto
disclose all such Personal Accounts and Related Accounts.

        In addition, you shall also supply, where indicated on the form, the
following information for each Security or Futures Contract in which you have a
Beneficial Ownership interest, to the extent that this information is not
available from the statements attached to the form:

        1.    A description of the Security or Futures Contract, including its
              name or title;

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        2.    The quantity (e.g. in terms of numbers of shares, units or
              contracts) and principal amount (in dollars) of the Security or
              Futures Contract; and

        3.    The name of any broker, dealer, bank or futures commission
              merchant with which you maintained an account in which the
              Security or Futures Contract was held.

        New Accounts

        Immediately upon the opening of a new Personal Account or a Related
Account that holds or is likely to hold a Security or a Futures Contract, you
shall supply a Compliance Officer with the name of the broker, dealer, bank or
futures commission merchant for that account, the identifying number for that
Personal Account or Related Account, and the date the account was established.

        Timely Reporting Of Investment Transactions

        You must cause each broker, dealer, bank or futures commission merchant
that maintains a Personal Account or a Related Account that holds a Security or
a Futures Contract in which you have a Beneficial Ownership interest to provide
to a Compliance Officer, on a timely basis, duplicate copies of trade
confirmations of all Investment Transactions in that account and of periodic
statements for that account ("duplicate broker reports").

        In addition, you must report to a Compliance Officer, on a timely
basis, any Investment Transaction in a Security or a Futures Contract in which
you have or acquired a Beneficial Ownership interest that was established
without the use of a broker, dealer, bank or futures commission merchant.

        Quarterly Certifications And Reporting

        At the end of the first, second and third calendar quarters, a
Compliance Officer will provide you with a list of all accounts that you have
previously identified to PIMCO as a Personal Account or a Related Account that
holds or is likely to hold a Security or Futures Contract. Within 10 days after
the end of that calendar quarter, you shall make any necessary additions,
corrections or deletions to that list and return it to a Compliance Officer with
a certification that: (a) the list, as modified (if necessary), represents a
complete list of the Personal Accounts and Related Accounts that hold Securities
or Futures Contracts in which you have or had a Beneficial Ownership interest
and for which PIMCO should have received or will receive timely duplicate broker
reports for the calendar quarter just ended, and (b) the broker, dealer, bank or
futures commission merchant for each account on the list has been instructed to
send a Compliance Officer timely duplicate broker reports for that account.

        You shall provide, on a copy of the form attached hereto as Appendix
VI, the following information for each Investment Transaction during the
calendar quarter just ended, to the extent that the duplicate broker reports for
that calendar quarter did not supply this information to PIMCO:

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        1.    The date of the Investment Transaction, the title, the interest
              rate and maturity date (if applicable), the number of shares or
              contracts, and the principal amount of each Security or Futures
              Contract involved;

        2.    The nature of the Investment Transaction (i.e. purchase, sale or
              any other type of acquisition or disposition);

        3.    The price of the Security or Futures Contract at which the
              transaction was effected; and

        4.    The name of the broker, dealer, bank, or futures commission
              merchant with or through which the transaction was effected.

You shall provide similar information for the fourth calendar quarter on a copy
of the form attached hereto as Appendix VII, which form shall also be used for
the Annual Holdings Report described below.

        Annual Holdings Reports

        At the end of each calendar year, a Compliance Officer will provide to
you promptly a list of all accounts that you have previously identified to PIMCO
as a Personal Account or a Related Account that held or was likely to hold a
Security or Futures Contract during that calendar year. Within 10 days after the
end of that calendar year, you shall make any necessary additions, corrections
or deletions to that list and return it to a Compliance Officer with a
certification that: (a) the list, as modified (if necessary), represents a
complete list of the Personal Accounts and Related Accounts that held Securities
or Futures Contracts in which you had a Beneficial Ownership interest as of the
end of that calendar year and for which PIMCO should have received or will
receive an account statement of holdings as of the end of that calendar year,
and (b) the broker, dealer, bank or futures commission merchant for each account
on the list has been instructed to send a Compliance Officer such an account
statement.

        You shall provide, on a copy of the form attached hereto as Appendix
VII, the following information for each Security or Futures Contract in which
you had a Beneficial Ownership interest, as of the end of the previous calendar
year, to the extent that the previously referenced account statements have not
supplied or will not supply this information to PIMCO:

        1.    The title, quantity (e.g. in terms of numbers of shares, units or
              contracts) and principal amount of each Security or Futures
              Contract in which you had any Beneficial Ownership interest; and

        2.    The name of any broker, dealer, bank or futures commission
              merchant with which you maintain an account in which any such
              Securities or Futures Contracts have been held or are held for
              your benefit.

In addition, you shall also provide, on that same form, Investment Transaction
information for the fourth quarter of the calendar year just ended. This
information shall be of the type and in the form required for the quarterly
reports described above.

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         Related Accounts

         The reporting and certification obligations described above also apply
to any Related Account (as defined in Appendix I) and to any Investment
Transaction in a Related Account.

         It is important for you to recognize that the definitions of "Related
Account" and "Beneficial Ownership" in Appendix I may require you to provide, or
to arrange for the broker, dealer, bank or futures commission merchant to
furnish, copies of reports for any account used by or for a member of your
Immediate Family or a trust in which you or a member of your Immediate Family
has any vested interest, as well as for any other accounts in which you may have
the opportunity, directly or indirectly, to profit or share in the profit
derived from any Investment Transaction in that account.

         Exemptions From Reporting

         You need not report Investment Transactions in any account over which
neither you nor an Immediate Family Member has or had any direct or indirect
influence or control.

         You also need not report Investment Transactions in Exempt Securities
(as defined in Appendix I) nor need you furnish, or require a broker, dealer,
bank or futures commission merchant to furnish, copies of confirmations or
periodic statements for accounts that hold only Exempt Securities. This includes
accounts that only hold U.S. Government Securities, money market interests, or
shares in open-end mutual funds. This exemption from reporting shall end
immediately, however, at such time as there is an Investment Transaction in that
account in a Futures Contract or in a Security that is not an Exempt Security.

                       Prohibited Investment Transactions

         Initial Public Offerings of Equity Securities

         If you are a Portfolio Employee (as defined in Appendix I), you may not
acquire Beneficial Ownership of any equity Security in an Initial Public
Offering.

         Private Placements and Initial Public Offering of Debt Securities

         If you are a Portfolio Employee, you may not acquire a Beneficial
Ownership interest in any Security through a Private Placement (or subsequently
sell it), or acquire a Beneficial Ownership interest in any debt Security in an
Initial Public Offering unless you have received the prior written approval of
the Chief Executive Officer of PIMCO or of a Compliance Officer listed on
Appendix X. Approval will not be given unless a determination is made that the
investment opportunity should not be reserved for one or more Advisory Clients,
and that the opportunity to invest has not been offered to you by virtue of your
position with PIMCO.

         If, after receiving the necessary approval, you have acquired a
Beneficial Ownership interest in Securities through a Private Placement, you
must disclose that investment when you play a part in any consideration of any
investment by an Advisory Client in the issuer of the

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         Securities, and any decision to make such an investment must be
independently reviewed by a portfolio manager who does not have a Beneficial
Ownership interest in any Securities of the issuer.

         Allianz AG

         You may not engage in any Investment Transaction in securities of
Allianz AG, except during the trading windows applicable to such transactions.

                                  Preclearance

         All Investment Transactions in Securities and Futures Contracts in a
Personal Account or Related Account, or in which you otherwise have or will
acquire a Beneficial Ownership interest, must be precleared by a Compliance
Officer unless an Investment Transaction, Security or Futures Contract falls
into one of the following categories that are identified as "exempt from
preclearance."

         Preclearance Procedure

         Preclearance shall be requested by completing and submitting a copy of
the applicable preclearance request form attached hereto as Appendix VIII or IX
to a Compliance Officer. No Investment Transaction subject to preclearance may
be effected prior to receipt of written authorization of the transaction by a
Compliance Officer. The authorization and the date of authorization will be
reflected on the preclearance request form. Unless otherwise specified, that
authorization shall be effective, unless revoked, until the earlier of: (a) the
close of business on the day the authorization is given, or (b) until you
discover that the information on the preclearance request form is no longer
accurate.

         The Compliance Officer from whom authorization is sought may undertake
such investigation as he or she considers necessary to determine that the
Investment Transaction for which preclearance has been sought complies with the
terms of this Code and is consistent with the general principles described at
the beginning of the Code.

         Before deciding whether to authorize an Investment Transaction in a
particular Security or Futures Contract, the Compliance Officer shall determine
and consider, based upon the information reported or known to that Compliance
Officer, whether within the most recent 15 days: (a) the Security, the Futures
Contract or any Related Security is or has been held by an Advisory Client, or
(b) is being or has been considered for purchase by an Advisory Client. The
Compliance Officer shall also determine whether there is a pending buy or sell
order in the same Security or Futures Contract, or in a Related Security, on
behalf of an Advisory Client. If such an order exists, authorization of the
personal Investment Transaction shall not be given until the Advisory Client's
order is executed or withdrawn. This prohibition may be waived by a Compliance
Officer if he or she is convinced that: (a) your personal Investment Transaction
is necessary, (b) your personal Investment Transaction will not adversely affect
the pending order of the Advisory Client, and (c) provision can be made for the
Advisory Client trade to take precedence (in terms of price) over your personal
Investment Transaction.

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         Exemptions From Preclearance

         Preclearance shall not be required for the following Investment
Transactions, Securities and Futures Contracts. They are exempt only from the
Code's preclearance requirement, and, unless otherwise indicated, remain subject
to the Code's other requirements, including its reporting requirements.

                Investment Transactions Exempt From Preclearance

         Preclearance shall not be required for any of the following Investment
Transactions:

         1.    Any transaction in a Security or Futures Contract in an account
               that is managed or held by a broker, dealer, bank, futures
               commission merchant, investment adviser, commodity trading
               advisor or trustee and over which you do not exercise investment
               discretion, have notice of transactions prior to execution, or
               otherwise have any direct or indirect influence or control. There
               is a presumption that you can influence or control accounts held
               by members of your Immediate Family sharing the same household.
               This presumption may be rebutted only by convincing evidence.

         2.    Purchases of Securities under dividend reinvestment plans.

         3.    Purchases of Securities by exercise of rights issued to the
               holders of a class of Securities pro rata, to the extent they are
               issued with respect to Securities in which you have a Beneficial
               Ownership interest.

         4.    Acquisitions or dispositions of Securities as the result of a
               stock dividend, stock split, reverse stock split, merger,
               consolidation, spin-off or other similar corporate distribution
               or reorganization applicable to all holders of a class of
               Securities in which you have a Beneficial Ownership interest.

               Securities Exempt From Preclearance
               Regardless Of Transaction Size

         Preclearance shall not be required for an Investment Transaction in the
following Securities or Related Securities, regardless of the size of that
transaction:

         1.    All "Exempt Securities" defined in Appendix I, i.e. U.S.
               Government Securities, shares in open-end mutual funds, and high
               quality short-term debt instruments.

         2.    All closed-end mutual funds (other than any fund for which PIMCO
               serves as the investment advisor or sub-advisor), and rights
               distributed to shareholders in closed-end mutual funds.

         3.    All options on any index of equity Securities.

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         4.    All Fixed Income Securities issued by agencies or
               instrumentalities of, or unconditionally guaranteed by, the
               Government of the United States.

         5.    All options on foreign currencies or baskets of foreign
               currencies (whether or not traded on an exchange or board of
               trade).

         6.    Except for Designated Equity Securities (as defined in Appendix I
               and discussed below), all equity Securities or options, warrants
               or other rights to equity Securities.

               Securities Exempt from Preclearance
               Depending On Transaction Size

         Preclearance shall not be required for an Investment Transaction in the
following Securities or Related Securities if they do not exceed the specified
transaction size thresholds (which thresholds may be increased or decreased by
PIMCO upon written notification to employees in the future depending on the
depth and liquidity of Fixed Income Securities or Tax-Exempt Municipal Bonds
market):

         1.    Purchases or sales of up to $1,000,000 (in market value or face
               amount whichever is greater) per calendar month per issuer of
               Fixed Income Securities issued by a Qualified Foreign Government.

         2.    Purchases or sales of the following dollar values (measured in
               market value or face amount, whichever is greater) of corporate
               debt Securities, mortgage-backed and other asset-backed
               Securities, Tax-Exempt Municipal Bonds, taxable state, local and
               municipal Fixed Income Securities, structured notes and loan
               participations, and foreign government debt Securities issued by
               non-qualified foreign governments (hereinafter collectively
               referred to as "Relevant Debt Securities"):

               a.    Purchases or sales of up to $100,000 per calendar month per
                     issuer if the original issue size of any Relevant Debt
                     Security being purchased or sold was less than $50 million;

               b.    Purchases or sales of up to $500,000 per calendar month per
                     issuer if the original issue size of any Relevant Debt
                     Security being purchased or sold was at least $50 million
                     but less than $100 million; or

               c.    Purchases or sales of up to $1,000,000 per calendar month
                     per issuer if the original issue size of any Relevant Debt
                     Security being purchased or sold was at least $100 million.

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         Preclearance of Designated Equity Securities

         If a Compliance Officer receives notification from a Portfolio Employee
that an equity Security or an option, warrant or other right to an equity
Security is being considered for purchase or sale by PIMCO on behalf of one of
its Advisory Clients, the Compliance Officer will send you an e-mail message or
similar transmission notifying you that this equity Security or option, warrant
or other right to an equity Security is now a "Designated Equity Security." A
current list of Designated Equity Securities (if any) will also be available on
the PIMCO intranet site. You must preclear any Investment Transaction in a
Designated Equity Security or a Related Security during the period when that
designation is in effect.

               Futures Contracts Exempt From Preclearance
               Regardless Of Transaction Size

         Preclearance shall not be required for an Investment Transaction in the
following Futures Contracts, regardless of the size of that transaction (as
indicated in Appendix I, for these purposes a "Futures Contract" includes a
futures option):

         1.    Currency Futures Contracts.

         2.    U.S. Treasury Futures Contracts.

         3.    Eurodollar Futures Contracts.

         4.    Futures Contracts an any index of equity Securities.

         5.    Futures Contracts on physical commodities or indices thereof
               (e.g. contracts for future delivery of grain, livestock, fiber
               or metals whether for physical delivery or cash).

         6.    Privately-Traded Contracts.

               Futures Contracts Exempt From Preclearance
               Depending On Transaction Size

         Preclearance shall not be required for an Investment Transaction in the
following Futures Contracts if the total number of contracts purchased or sold
during a calendar month does not exceed the specified limitations:

         1.    Purchases or sales of up to 50 Publicly-Traded Futures Contracts
               to acquire Fixed Income Securities issued by a particular
               Qualified Foreign Government.

         2.    Purchases or sales of up to 10 of each other individual
               Publicly-Traded Futures Contract if the open market interest for
               such Futures Contract as reported in The Wall Street Journal on
               the date of your Investment Transaction (for the previous trading
               day) is at least 1,000 contracts. Examples of Futures Contracts
               for which this exemption would be available include a Futures
               Contract

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               on a foreign government debt Security issued by a non-qualified
               foreign government as well as a 30-day federal funds Futures
               Contract.

For purposes of these limitations, a Futures Contract is defined by its
expiration month. For example, you need not obtain preclearance to purchase 50
December Futures Contracts on German Government Bonds and 50 March Futures
Contracts on German Government Bonds. Similarly, you may roll over 10 September
Fed Funds Futures Contracts by selling those 10 contracts and purchasing 10
October Fed Funds Futures Contracts since the contracts being sold and those
being purchased have different expiration months. On the other hand, you could
not purchase 10 January Fed Funds Future Contracts if the open interest for
those contracts was less than 1,000 contracts, even if the total open interest
for all Fed Funds Futures Contracts was greater than 1,000 contracts.

               Additional Exemptions From Preclearance

         The Compliance Committee may exempt other classes of Investment
Transactions, Securities or Futures Contracts from the Code's preclearance
requirement upon a determination that they do not involve a realistic
possibility of violating the general principles described at the beginning of
the Code.

               Preclearance Required

         Given the exemptions described above, preclearance shall be required
for Investment Transactions in:

         1.    Designated Equity Securities.

         2.    Relevant Debt Securities (as defined under the section
               "Securities Exempt from Preclearance Depending on Transaction
               Size, paragraph 2") in excess of the per calendar month per
               issuer thresholds specified for purchases or sales of those
               Securities.

         3.    More than $1,000,000 per calendar month in debt Securities of a
               Qualified Foreign Government.

         4.    Related Securities that are exchangeable for or convertible into
               one of the Securities requiring preclearance under (1), (2), or
               (3) above.

         5.    More than 50 Publicly-Traded Futures Contracts per calendar
               month to acquire Fixed Income Securities issued by a particular
               Qualified Foreign Government.

         6.    More than 10 of any other individual Publicly-Traded Futures
               Contract or any Publicly-Traded Futures Contract for which the
               open market interest as reported in The Wall Street Journal on
               the date of your Investment Transaction (for the previous trading
               day) is less than 1,000 contracts, unless the Futures Contract is
               exempt from preclearance regardless of transaction size.

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         7.     Any other Security or Publicly-Traded Futures Contract that is
                not within the "exempt" categories listed above.

         8.     Any closed end fund for which PIMCO serves as the investment
                advisor or sub-advisor (i.e. PIMCO Commercial Mortgage
                Securities Trust, Inc., PIMCO Municipal Income Fund, PIMCO
                California Municipal Income Fund, PIMCO New York Municipal
                Income Fund, PIMCO Corporate Income Fund or any other closed
                end fund which PIMCO may advise from time to time).

                           Short-Term Trading Profits

         You may not profit from the purchase and sale, or the sale and
purchase, within 60 calendar days, of Fixed Income Securities, Tax-Exempt
Municipal Bonds or Related Securities. You may not profit from the purchase and
sale, or sale and purchase, within 6 months, of any closed end fund for which
PIMCO serves as investment advisor or sub-advisor. Portfolio Employees may not
profit from the purchase and sale, or the sale and purchase, within 60 calendar
days, of Designated Equity Securities. Any such short-term trade must be
unwound, or if that is not practical, the profits must be contributed to a
charitable organization.

         This ban does not apply to Investment Transactions in U.S. Government
Securities, most equity Securities, mutual fund shares, index options or Futures
Contracts. This ban also does not apply to a purchase or sale in connection with
one of the four categories of Investment Transactions Exempt From Preclearance
described on pages 9-10, above.

         You are considered to profit from a short-term trade if Securities in
which you have a Beneficial Ownership interest are sold for more than their
purchase price, even though the Securities purchased and the Securities sold are
held of record or beneficially by different persons or entities.

                                Blackout Periods

         You may not purchase or sell a Security, a Related Security or a
Futures Contract at a time when you intend or know of another's intention to
purchase or sell that Security or Futures Contract on behalf of any Advisory
Client.

         As noted previously in the description of the Preclearance Process, a
Compliance Officer may not preclear an Investment Transaction in a Security or a
Futures Contract at a time when there is a pending buy or sell order in the same
Security or Futures Contract, or a Related Security, until that order is
executed or withdrawn.

         These prohibitions do not apply to Investment Transactions in any
Futures Contracts that are exempt from preclearance regardless of transaction
size.

                                       13

<PAGE>

                         GIFTS AND SERVICE AS A DIRECTOR

                                      Gifts

         You may not accept any investment opportunity, gift, gratuity or other
thing of more than nominal value from any person or entity that does business,
or desires to do business, with PIMCO directly or on behalf of an Advisory
Client (a "Giver"). You may, however, accept gifts from a single Giver so long
as their aggregate annual value does not exceed $500, and you may attend
business meals, sporting events and other entertainment events at the expense of
a Giver (without regard to their aggregate annual value), so long as the expense
is reasonable and both you and the Giver are present.

         If you are a registered representative of PIMCO Funds Distributors LLC
(PFD), the aggregate annual gift value from a single Giver shall not exceed
$100.00. As a PFD representative, you are required to maintain a record of each
gift, gratuity, investment opportunity or similar item, and make such record
available to the Compliance Department upon request.

                              Service As A Director

         If you are an Advisory Employee, you may not serve on the board of
directors or other governing board of a publicly traded entity, other than of a
Fund for which PIMCO is an advisor or subadvisor, unless you have received the
prior written approval of the Chief Executive Officer and the Chief Legal
Officer of PIMCO. Approval will not be given unless a determination is made that
your service on the board would be consistent with the interests of our Advisory
Clients. If you are permitted to serve on the board of a publicly traded entity,
you will be isolated from those Advisory Employees who make investment decisions
with respect to the Securities of that entity, through a "Chinese Wall" or other
procedures.

                                       14

<PAGE>

                                   COMPLIANCE

                                 Certifications

       Upon Receipt Of This Code

       Upon commencement of your employment or the effective date of this Code,
whichever occurs later, you shall be required to acknowledge receipt of your
copy of this Code by completing and returning a copy of the form attached hereto
as Appendix III. By that acknowledgment, you will also agree:

       1.     To read the Code, to make a reasonable effort to understand its
              provisions, and to ask questions about those provisions you find
              confusing or difficult to understand.

       2.     To comply with the Code, including its general principles, its
              reporting requirements, its preclearance requirements, and its
              provisions regarding gifts and service as a director.

       3.     To advise the members of your Immediate Family about the existence
              of the Code, its applicability to their personal trading activity,
              and your responsibility to assure that their personal trading
              activity complies with the Code.

       4.     To cooperate fully with any investigation or inquiry by or on
              behalf of a Compliance Officer to determine your compliance with
              the provisions of the Code.

In addition, your acknowledgment will recognize that any failure to comply with
the Code and to honor the commitments made by your acknowledgment may result in
disciplinary action, including dismissal.

       Annual Certificate Of Compliance

       You are required to certify on an annual basis, on a copy of the form
attached hereto as Appendix IV, that you have complied with each provision of
your initial acknowledgment (see above). In particular, your annual
certification will require that you certify that you have read and that you
understand the Code, that you recognize you are subject to its provisions, that
you complied with the requirements of the Code during the year just ended and
that you have disclosed, reported, or caused to be reported all Investment
Transactions required to be disclosed or reported pursuant to the requirements
of the Code.

                              Post-Trade Monitoring

       The Compliance Officers will review the duplicate broker reports and
other information supplied to them concerning your personal Investment
Transactions so that they can detect and prevent potential violations of the
Code. The Compliance Officers will perform such investigation and make such
inquiries as they consider necessary to perform this function. You agree to
cooperate with any such investigation and to respond to any such inquiry. You
should

                                       15

<PAGE>

expect that, as a matter of course, the Compliance Officers will make inquiries
regarding any personal Investment Transaction in a Security or Futures Contract
that occurs on the same day as a transaction in the same Security or Futures
Contract on behalf of an Advisory Client.

                                Remedial Actions

       If you violate this Code, you are subject to remedial actions, which may
include, but are not limited to, disgorgement of profits, imposition of a fine,
censure, demotion, suspension or dismissal. As part of any sanction, you may be
required to reverse an Investment Transaction and to forfeit any profit or to
absorb any loss from the transaction.

       The Compliance Committee shall have the ultimate authority to determine
whether you have violated the Code and, if so, the remedial actions it considers
appropriate. In making its determination, the Compliance Committee shall
consider, among other factors, the gravity of your violation, the frequency of
your violations, whether any violation caused harm or the potential of harm to
any Advisory Client, your efforts to cooperate with their investigation, and
your efforts to correct any conduct that led to a violation.

                        Reports To Directors And Trustees

       Reports Of Significant Remedial Actions

       The General Counsel of PIMCO Advisors L.P. and the directors or trustees
of any affected Fund that is an Advisory Client will be informed on a timely
basis of each significant remedial action taken in response to a violation of
this Code. For this purpose, a significant remedial action will include any
action that has a significant financial effect on the violator.

       Reports of Material Changes To The Code

       PIMCO will promptly advise the directors or trustees of any Fund that is
an Advisory Client if PIMCO makes any material change to this Code.

       Annual Reports

       PIMCO's management will furnish a written report annually to the General
Counsel of PIMCO Advisors L.P. and to the directors or trustees of each Fund
that is an Advisory Client. Each report, at a minimum, will:

       1.     Describe any significant issues arising under the Code, or under
              procedures implemented by PIMCO to prevent violations of the Code,
              since management's last report, including, but not limited to,
              information about material violations of the Code or those
              procedures and sanctions imposed in response to material
              violations; and

       2.     Certify that PIMCO has adopted procedures reasonably necessary to
              prevent Advisory Employees from violating the Code.

                                       16

<PAGE>

                                  Recordkeeping

       Beginning on the effective date of this Code, PIMCO will maintain, at its
principal place of business, the following records, which shall be available to
the Securities and Exchange Commission or any representative of the Commission
at any time and from time to time for reasonable periodic, special or other
examination:

       1.     PIMCO's Chief Compliance Officer shall maintain, in any easily
              accessible place:

              (a)    a copy of PIMCO's current Code and of each predecessor of
                     that Code that was in effect at any time within the
                     previous five (5) years;

              (b)    a record of any violation of the Code, and of any action
                     taken as a result of the violation, for at least five (5)
                     years after the end of the fiscal year in which the
                     violation occurred;

              (c)    a copy of each report made by an Advisory Employee pursuant
                     to this Code, including any duplicate broker report
                     submitted on behalf of that Advisory Employee, for at least
                     two (2) years after the end of the fiscal year in which
                     that report was made or that information was provided;

              (d)    a record of all persons, currently or within the past five
                     (5) years, who are or were required to make reports
                     pursuant to this Code or who are or were responsible for
                     reviewing such reports; and

              (e)    a copy of each report to the General Counsel of PIMCO
                     Advisors L.P. or to the directors or trustees of each Fund
                     that is an Advisory Client for at least two (2) years after
                     the end of the fiscal year in which that report was made.

       2.     PIMCO shall also maintain the following additional records:

              (a)    a copy of each report made by an Advisory Employee pursuant
                     to this Code, including any duplicate broker report
                     submitted on behalf of that Advisory Employee, for at least
                     five (5) years after the end of the fiscal year in which
                     that report was made or that information was provided;

              (b)    a copy of each report to the General Counsel of PIMCO
                     Advisors L.P. or to the directors or trustees of each Fund
                     that is an Advisory Client for at least five (5) years
                     after the end of the fiscal year in which that report was
                     made; and

              (c)    a record of any decision, and the reasons supporting the
                     decision, to approve the acquisition by a Portfolio
                     Employee of a Beneficial Ownership interest in any Security
                     in an Initial Public Offering or in a Private Placement for
                     at least five (5) years after the end of the fiscal year in
                     which such approval was granted.

                                       17

<PAGE>

                                   APPENDIX I

                        Definitions Of Capitalized Terms

       The following definitions apply to the capitalized terms used in the
Code:

Advisory Employee

       The term "Advisory Employee" means: (1) a director, officer, general
partner or employee of PIMCO who, in connection with his or her regular
functions or duties, makes, participates in, or obtains information regarding
the purchase or sale of a Security or Futures Contract by PIMCO on behalf of an
Advisory Client, or whose functions relate to the making of any recommendations
with respect to such purchases or sales, or (2) or a natural person in a control
relationship to PIMCO, or an employee of any company in a control relationship
to PIMCO, who: (a) makes, participates in, or obtains information regarding the
purchase or sale of a Security by a Fund that is an Advisory Client, or whose
functions relate to the making of any recommendations with respect to such
purchases or sales, or (b) obtains information concerning recommendations to a
Fund with regard to the purchase or sale of a Security by the Fund.

Beneficial Ownership

       As a general matter, you are considered to have a "Beneficial Ownership"
interest in a Security or a Futures Contract if you have the opportunity,
directly or indirectly, to profit or share in any profit derived from an
Investment Transaction in that Security or Futures Contract. You are presumed to
have a Beneficial Ownership interest in any Security or Futures Contract held,
individually or jointly, by you or a member of your Immediate Family (as defined
below). In addition, unless specifically excepted by a Compliance Officer based
on a showing that your interest in a Security or Futures Contract is
sufficiently attenuated to avoid the possibility of conflict, you will be
considered to have a Beneficial Ownership interest in a Security or Futures
Contract held by: (1) a joint account to which you are a party, (2) a
partnership in which you are a general partner, (3) a limited liability company
in which you are a manager-member, or (4) a trust in which you or a member of
your Immediate Family has a vested interest.

       As a technical matter, the term "Beneficial Ownership" for purposes of
this Code shall be interpreted in the same manner as it would be under SEC Rule
16a-1(a)(2) (17 C.F.R. (S)240.16a-1(a)(2)) in determining whether a person has a
beneficial ownership interest in a Security for purposes of Section 16 of the
Securities Exchange Act of 1934 and the rules and regulations thereunder.

Designated Equity Security

       The term "Designated Equity Security" shall mean any equity Security,
option, warrant or other right to an equity Security designated as such by a
Compliance Officer, after receiving notification from a Portfolio Employee that
said Security is being considered for purchase or sale by PIMCO on behalf of one
of its Advisory Clients.

                                      I-1

<PAGE>

Exempt Security

       The term "Exempt Security" shall mean any Security not included within
the definition of Covered Security in SEC Rule 17j-l(a)(4) (17 C.F.R. (S)
17j-1(a)(4)), including:

       1.     Direct obligations of the Government of the United States;

       2.     Shares issued by open-end Funds; and

       3.     Bankers' acceptances, bank certificates of deposit, commercial
              paper and high quality short-term debt instruments, including
              repurchase agreements. For these purposes, a "high quality
              short-term debt instrument" means any instrument having a maturity
              at issuance of less than 366 days and that is rated in one of the
              two highest rating categories by a Nationally Recognized
              Statistical Rating Organization.

Fixed Income Security

       For purposes of this Code, the term "Fixed Income Security" shall mean a
fixed income Security issued by an agency or instrumentality of, or
unconditionally guaranteed by, the Government of the United States, a corporate
debt Security, a mortgage-backed or other asset-backed Security, a taxable fixed
income Security issued by a state or local government or a political subdivision
thereof, a structured note or loan participation, a foreign government debt
Security, or a debt Security of an international agency or a supranational
agency. For purposes of this Code, the term "Fixed Income Security" shall not be
interpreted to include a U.S. Government Security or any other Exempt Security
(as defined above) nor shall it be interpreted to include a Tax-Exempt Municipal
Bond (as defined below).

Fund

       The term "Fund" means an investment company registered under the
Investment Company Act.

Futures Contract

       The term "Futures Contract" includes (a) a futures contract and an option
on a futures contract traded on a United States or foreign board of trade, such
as the Chicago Board of Trade, the Chicago Mercantile Exchange, the London
International Financial Futures Exchange or the New York Mercantile Exchange (a
"Publicly-Traded Futures Contract"), as well as (b) a forward contract, a swap,
a cap, a collar, a floor and an over-the-counter option (other than an option on
a foreign currency, an option on a basket of currencies, an option on a Security
or an option on an index of Securities) (a "Privately-Traded Contract"). Consult
with a Compliance Officer prior to entering into a transaction in case of any
doubt. For purposes of this definition, a Publicly-Traded Futures Contract is
defined by its expiration month, i.e. a Publicly-Traded Futures Contract on a
U.S. Treasury Bond that expires in June is treated as a separate Publicly-Traded
Futures Contract, when compared to a Publicly-Traded Futures Contract on a U.S.
Treasury Bond that expires in July.

                                      I-2

<PAGE>

Immediate Family

       The term "Immediate Family" means any of the following persons who reside
in your household or depend on you for basic living support: your spouse, any
child, stepchild, grandchild, parent, stepparent, grandparent, sibling,
mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or
sister-in-law, including any adoptive relationships.

Initial Public Offering

       The term "Initial Public Offering" means an offering of securities
registered under the Securities Act of 1933 (15 U.S.C. (S) 77a), the issuer of
which, immediately before the registration, was not subject to the reporting
requirements of Sections 13 or 15(d) of the Securities Exchange Act of 1934 (15
U.S.C. (S) 78m or (S) 78o(d)).

Investment Transaction

       For purposes of this Code, the term "Investment Transaction" means any
transaction in a Security or Futures Contract in which you have, or by reason of
the transaction will acquire, a Beneficial Ownership interest, and includes,
among other things, the writing of an option to purchase or sell a Security.

Personal Account

       The term "Personal Account" means the following accounts that hold or are
likely to hold a Security (as defined below) or a Futures Contract (as defined
above) in which you have a Beneficial Ownership interest: any account in your
individual name; any joint or tenant-in-common account in which you have an
interest or are a participant; any account for which you act as trustee,
executor, or custodian; any account over which you have investment discretion or
otherwise can exercise control (other than non-related clients' accounts over
which you have investment discretion), including the accounts of entities
controlled directly or indirectly by you; and any other account in which you
have a Beneficial Ownership interest (other than such accounts over which you
have no investment discretion and cannot otherwise exercise control).

Portfolio Employee

       The term "Portfolio Employee" means: (1) a portfolio manager or any
employee of PIMCO (or of any company in a control relationship with PIMCO) who,
in connection with his or her regular functions or duties, makes or participates
in making recommendations regarding the purchase or sale of securities by a
Fund, or (2) any natural person who controls PIMCO and who obtains information
concerning recommendations made to a Fund that is an Advisory Client regarding
the purchase or sale of Securities by the Fund. For these purposes, "control"
has the same meaning as in Section 2(a)(9) of the Investment Company Act (15
U.S.C. (S) 80a-2(a)(9)).

                                      I-3

<PAGE>

Private Placement

     The term "Private Placement" means an offering that is exempt from
registration under the Securities Act of 1933 pursuant to Section 4(2) or
Section 4(6) (15 U.S.C. (S) 77d(2) or (S) 77d(6)) or pursuant to SEC Rules 504,
505 or 506 (17 C.F.R. (S)(S) 230.504, 230.505, or 230.506) under the Securities
Act of 1933.

Qualified Foreign Government

     The term "Qualified Foreign Government" means a national government of a
developed foreign country with outstanding Fixed Income Securities in excess of
fifty billion dollars. A list of Qualified Foreign Governments will be prepared
as of the last business day of each calendar quarter, will be available from the
Chief Compliance Officer, and will be effective for the following calendar
quarter.

Related Account

     The term "Related Account" means any account, other than a Personal
Account, that holds a Security or Futures Contract in which you have a
Beneficial Ownership interest.

Related Security

     The term "Related Security" shall mean any option to purchase or sell, and
any Security convertible into or exchangeable for, a Security that is or has
been held by PIMCO on behalf of one of its Advisory Clients or any Security that
is being or has been considered for purchase by PIMCO on behalf of one of its
Advisory Clients.

Security

     As a general matter, the term "Security" shall mean any stock, note, bond,
debenture or other evidence of indebtedness (including any loan participation or
assignment), limited partnership interest or investment contract other than an
Exempt Security (as defined above). The term "Security" includes an option on a
Security, on an index of Securities, on a currency or on a basket of currencies,
including such an option traded on the Chicago Board of Options Exchange or on
the New York, American, Pacific or Philadelphia Stock Exchanges, as well as such
an option traded in the over-the-counter market. The term "Security" shall not
include a Futures Contract or a physical commodity (such as foreign exchange or
a precious metal).

     As a technical matter, the term "Security" shall have the meaning set forth
in Section 2(a)(36) of the Investment Company Act of 1940 (15 U.S.C. (S)
80a-2(a)(36)), which defines a Security to mean:

     Any note, stock, treasury stock, bond debenture, evidence of indebtedness,
certificate of interest or participation in any profit-sharing agreement,
collateral-trust certificate, preorganization certificate of subscription,
transferable share, investment contract, voting-trust certificate, certificate
of deposit for a security, fractional undivided interest in oil, gas, or other
mineral rights, any put, call, straddle, option, or privilege on any security
(including a certificate


                                       I-4

<PAGE>

of deposit) or on any group or index of securities (including any interest
therein or based on the value thereof), or any put, call, straddle, option, or
privilege entered into on a national securities exchange relating to foreign
currency, or, in general, any interest or instrument commonly known as a
"security", or any certificate of interest or instrument commonly known as a
"security", or any certificate of interest or participation in, temporary or
interim certificate for, receipt for, guarantee of, warrant or right to
subscribe to or purchase, any of the foregoing, except that the term "Security"
shall not include any Security that is an Exempt Security (as defined above), a
Futures Contract or a physical commodity (such as foreign exchange or precious
metal).

Tax-Exempt Municipal Bond

     The term "Tax-Exempt Municipal Bond" shall mean any Fixed Income Security
exempt from federal income tax that is issued by a state or local government or
a political subdivision thereof.


                                       I-5

<PAGE>

                                   Appendix II

                                 PIMCO ADVISORS

                      Insider Trading Policy and Procedures

                             Effective July 1, 2001

Section I. Policy Statement on Insider Trading

A.   Policy Statement on Insider Trading

PIMCO Advisors L.P. ("PIMCO Advisors"), its affiliates, PIMCO Partners, G.P.,
Cadence Capital Management, NFJ Investment Group, Oppenheimer Capital, and PIMCO
Equity Advisors (collectively the "Company" or "PIMCO Advisors") forbid any of
their officers, directors or employees from trading, either personally or on
behalf of others (such as, mutual funds and private accounts managed by PIMCO
Advisors), on the basis of material non-public information or communicating
material non-public information to others in violation of the law. This conduct
is frequently referred to as "insider trading". This is a group wide policy.

The term "insider trading" is not defined in the federal securities laws, but
generally is used to refer to the situation when a person trades while aware of
material non-public information or to communications of material non-public
information to others in breach of a duty of trust or confidence.

While the law concerning insider trading is not static, it is generally
understood that the law prohibits:

(1)       trading by an insider, while aware of material, non-public
          information; or

(2)       trading by a non-insider, while aware of material, non-public
          information, where the information was disclosed to the non-insider in
          violation of an insider's duty to keep it confidential; or

(3)       communicating material, non-public information to others in breach of
          a duty of trust or confidence.

This policy applies to every such officer, director and employee and extends to
activities within and outside their duties at the Company. Every officer,
director and employee must read and retain this policy statement. Any questions
regarding this policy statement and the related procedures set forth herein
should be referred to a Compliance Officer of PIMCO Advisors.

                                      II-1

<PAGE>

The remainder of this memorandum discusses in detail the elements of insider
trading, the penalties for such unlawful conduct and the procedures adopted by
the Company to implement its policy against insider trading.

1.   To Whom Does This Policy Apply?

This Policy applies to all employees, officers and directors (direct or
indirect) of the Company ("Covered Persons"), as well as to any transactions in
any securities participated in by family members, trusts or corporations
controlled by such persons. In particular, this Policy applies to securities
transactions by:

     the Covered Person's spouse;
     the Covered Person's minor children;
     any other relatives living in the Covered Person's household;
     a trust in which the Covered Person has a beneficial interest, unless such
     person has no direct or indirect control over the trust;
     a trust as to which the Covered Person is a trustee;
     a revocable trust as to which the Covered Person is a settlor;
     a corporation of which the Covered Person is an officer, director or 10% or
     greater stockholder; or
     a partnership of which the Covered Person is a partner (including most
     investment clubs) unless the Covered Person has no direct or indirect
     control over the partnership.

2.   What is Material Information?

Trading on inside information is not a basis for liability unless the
information is material. "Material information" generally is defined as
information for which there is a substantial likelihood that a reasonable
investor would consider it important in making his or her investment decisions,
or information that is reasonably certain to have a substantial effect on the
price of a company's securities.

Although there is no precise, generally accepted definition of materiality,
information is likely to be "material" if it relates to significant changes
affecting such matters as:

     dividend or earnings expectations;
     write-downs or write-offs of assets;
     additions to reserves for bad debts or contingent liabilities;
     expansion or curtailment of company or major division operations;
     proposals or agreements involving a joint venture, merger, acquisition,
       divestiture, or leveraged buy-out;
     new products or services;
     exploratory, discovery or research developments;
     criminal indictments, civil litigation or government investigations;
     disputes with major suppliers or customers or significant changes in

                                      II-2

<PAGE>

        the relationships with such parties;
       labor disputes including strikes or lockouts;
       substantial changes in accounting methods;
       major litigation developments;
       major personnel changes;
       debt service or liquidity problems;
       bankruptcy or insolvency;
       extraordinary management developments;
       public offerings or private sales of debt or equity securities;
       calls, redemptions or purchases of a company's own stock;
       issuer tender offers; or
       recapitalizations.

Information provided by a company could be material because of its expected
effect on a particular class of the company's securities, all of the company's
securities, the securities of another company, or the securities of several
companies. Moreover, the resulting prohibition against the misuses of "material"
information reaches all types of securities (whether stock or other equity
interests, corporate debt, government or municipal obligations, or commercial
paper) as well as any option related to that security (such as a put, call or
index security).

Material information does not have to relate to a company's business. For
example, in Carpenter v. U.S., 108 U.S. 316 (1987), the Supreme Court considered
as material certain information about the contents of a forthcoming newspaper
column that was expected to affect the market price of a security. In that case,
a reporter for The Wall Street Journal was found criminally liable for
disclosing to others the dates that reports on various companies would appear in
the Journal and whether those reports would be favorable or not.

3.     What is Non-public Information?

In order for issues concerning insider trading to arise, information must not
only be "material", it must be "non-public". "Non-public" information is
information which has not been made available to investors generally.
Information received in circumstances indicating that it is not yet in general
circulation or where the recipient knows or should know that the information
could only have been provided by an "insider" is also deemed "non-public"
information.

At such time as material, non-public information has been effectively
distributed to the investing public, it is no longer subject to insider trading
restrictions. However, for "non-public" information to become public
information, it must be disseminated through recognized channels of distribution
designed to reach the securities marketplace.

To show that "material" information is public, you should be able to point to
some fact verifying that the information has become generally available, for
example, disclosure in a national business and financial wire service (Dow Jones
or Reuters), a national news service (AP or UPI), a national newspaper (The Wall
Street Journal, The New York Times or Financial Times), or a publicly
disseminated disclosure document (a proxy statement or prospectus). The
circulation of


                                      II-3

<PAGE>

rumors or "talk on the street", even if accurate, widespread and reported in the
media, does not constitute the requisite public disclosure. The information must
not only be publicly disclosed, there must also be adequate time for the market
as a whole to digest the information. Although timing may vary depending upon
the circumstances, a good rule of thumb is that information is considered
non-public until the third business day after public disclosure.

Material non-public information is not made public by selective dissemination.
Material information improperly disclosed only to institutional investors or to
a fund analyst or a favored group of analysts retains its status as "non-public"
information which must not be disclosed or otherwise misused. Similarly, partial
disclosure does not constitute public dissemination. So long as any material
component of the "inside" information possessed by the Company has yet to be
publicly disclosed, the information is deemed "non-public" and may not be
misused.

Information Provided in Confidence. It is possible that one or more directors,
officers, or employees of PIMCO Advisors may become temporary "insiders" because
of a duty of trust or confidence. A duty of trust or confidence can arise: (1)
whenever a person agrees to maintain information in confidence; (2) when two
people have a history, pattern, or practice of sharing confidences such that the
recipient of the information knows or reasonably should know that the person
communicating the material non-public information expects that the recipient
will maintain its confidentiality; or (3) whenever a person receives or obtains
material non-public information from certain close family members such as
spouses, parents, children and siblings. For example, personnel at PIMCO
Advisors may become insiders when an external source, such as a company whose
securities are held by one or more of the accounts managed by PIMCO Advisors,
discloses material, non-public information to PIMCO Advisors' portfolio managers
or analysts with the expectation that the information will remain confidential.

As an "insider", PIMCO Advisors has a duty not to breach the trust of the party
that has communicated the "material, non-public" information by misusing that
information. This duty may arise because PIMCO Advisors has entered or has been
invited to enter into a commercial relationship with the company, client or
prospective client and has been given access to confidential information solely
for the corporate purposes of that company, client or prospective client. This
duty remains whether or not PIMCO Advisors ultimately participates in the
transaction.

Information Disclosed in Breach of a Duty. Analysts and portfolio managers at
PIMCO Advisors must be especially wary of "material, non-public" information
disclosed in breach of corporate insider's duty of trust or confidence that he
or she owes the corporation and shareholders. Even where there is no expectation
of confidentiality, a person may become an "insider" upon receiving material,
non-public information in circumstances where a person knows, or should know,
that a corporate insider is disclosing information in breach of a duty of trust
and confidence that he or she owes the corporation and its shareholders. Whether
the disclosure is an improper "tip" that renders the recipient a "tippee"
depends on whether the corporate insider expects to benefit personally, either
directly or indirectly, from the disclosure. In the context of an improper
disclosure by a corporate insider, the requisite "personal benefit" may not be
limited to a present or future monetary gain. Rather, a prohibited personal
benefit

                                      II-4

<PAGE>

could include a reputational benefit, an expectation of a "quid pro quo" from
the recipient or the recipient's employer by a gift of the "inside" information.

A person may, depending on the circumstances, also become an "insider" or
"tippee" when he or she obtains apparently material, non-public information by
happenstance, including information derived from social situations, business
gatherings, overheard conversations, misplaced documents, and "tips" from
insiders or other third parties.

4.     Identifying Material Information

Before trading for yourself or others, including investment companies or private
accounts managed by the Company, in the securities of a company about which you
may have potential material, non-public information, ask yourself the following
questions:

i.     Is this information that an investor could consider important in making
       his or her investment decisions? Is this information that could
       substantially affect the market price of the securities if generally
       disclosed?

ii.    To whom has this information been provided? Has the information been
       effectively communicated to the marketplace by being published in The
       Financial Times, Reuters, The Wall Street Journal or other publications
       of general circulation?

Given the potentially severe regulatory, civil and criminal sanctions to which
you the Company and its personnel could be subject, any director, officer and
employee uncertain as to whether the information he or she possesses is
"material non-public" information should immediately take the following steps:

i.     Report the matter immediately to a Compliance Officer or the General
       Counsel of PIMCO Advisors;

ii.    Do not purchase or sell the securities on behalf of yourself or others,
       including investment companies or private accounts managed by PIMCO
       Advisors; and

iii.   Do not communicate the information inside or outside the Company, other
       than to a Compliance Officer or the General Counsel of PIMCO Advisors.

After the Compliance Officer or General Counsel has reviewed the issue, you will
be instructed to continue the prohibitions against trading and communication or
will be allowed to trade and communicate the information.

5.     Penalties for Insider Trading

Penalties for trading on or communicating material non-public information are
severe, both for individuals involved in such unlawful conduct and their
employers. A person can be subject to

                                      II-5

<PAGE>

some or all of the penalties below even if he or she does not personally benefit
from the violation. Penalties include:

       civil injunctions
       treble damages
       disgorgement of profits
       jail sentences
       fines for the person who committed the violation of up to three times
         the profit gained or loss avoided, whether or not the person actually
         benefited, and
       fines for the employer or other controlling person of up to the greater
         of $1,000,000 or three times the amount of the profit gained or loss
         avoided.

In addition, any violation of this policy statement can be expected to result in
serious sanctions by the Company, including dismissal of the persons involved.

Section II. Procedures to Implement the Policy Against Insider Trading

A.     Procedures to Implement the Policy Against Insider Trading

The following procedures have been established to aid the officers, directors
and employees of PIMCO Advisors in avoiding insider trading, and to aid PIMCO
Advisors in preventing, detecting and imposing sanctions against insider
trading. Every officer, director and employee of PIMCO Advisors must follow
these procedures or risk serious sanctions, including dismissal, substantial
personal liability and criminal penalties.

Trading Restrictions and Reporting Requirements

1.     No employee, officer or director of the Company who is aware of material
       non-public information relating to the Company or any of its affiliates
       or subsidiaries, including Allianz AG, may buy or sell any securities of
       the Company, including Allianz AG, or engage in any other action to take
       advantage of, or pass on to others, such material non-public information.

2.     No employee, officer or director of the Company who is aware of material
       non-public information which relates to any other company or entity in
       circumstances in which such person is deemed to be an insider or is
       otherwise subject to restrictions under the federal securities laws may
       buy or sell securities of that company or otherwise take advantage of, or
       pass on to others, such material non-public information.

3.     No employee, officer or director of PIMCO Advisors shall engage in a
       securities transaction with respect to the securities of Allianz AG,
       except in accordance with the specific procedures published from time to
       time by PIMCO Advisors.

                                      II-6

<PAGE>

4.     No employee shall engage in a securities transaction with respect to any
       securities of any other company, except in accordance with the specific
       procedures set forth in PIMCO Advisors' Code of Ethics.

5.     Employees shall submit reports concerning each securities transaction in
       accordance with the terms of the Code of Ethics and verify their personal
       ownership of securities in accordance with the procedures set forth in
       the Code of Ethics.

6.     Because even inadvertent disclosure of material non-public information to
       others can lead to significant legal difficulties, officers, directors
       and employees of PIMCO Advisors should not discuss any potentially
       material non-public information concerning PIMCO Advisors or other
       companies, including other officers, employees and directors, except as
       specifically required in the performance of their duties

B.     Chinese Wall Procedures

The Insider Trading and Securities Fraud Enforcement Act in the US requires the
establishment and strict enforcement of procedures reasonably designed to
prevent the misuse of "inside" information/1/. Accordingly, you should not
discuss material non-public information about PIMCO Advisors or other companies
with anyone, including other employees, except as required in the performance of
your regular duties. In addition, care should be taken so that such information
is secure. For example, files containing material non-public information should
be sealed; access to computer files containing material non-public information
should be restricted.

C.     Resolving Issues Concerning Insider Trading

The federal securities laws, including the US laws governing insider trading,
are complex. If you have any doubts or questions as to the materiality or
non-public nature of information in your possession or as to any of the
applicability or interpretation of any of the foregoing procedures or as to the
propriety of any action, you should contact your Compliance Officer. Until
advised to the contrary by a Compliance Officer, you should presume that the
information is material and non-public and you should not trade in the
securities or disclose this information to anyone.




--------------
/1/ The antifraud provisions of United States securities laws reach insider
trading or tipping activity worldwide which defrauds domestic securities
markets. In addition, the Insider Trading and Securities Fraud Enforcement Act
specifically authorizes the SEC to conduct investigations at the request of
foreign governments, without regard to whether the conduct violates United
States law.

                                      II-7

<PAGE>

                                  Appendix III

                            ACKNOWLEDGMENT OF RECEIPT

                                     of the
                                 Code of Ethics
                                     and the
                    Insider Trading Policy and Procedures of

                      PACIFIC INVESTMENT MANAGEMENT COMPANY

       I hereby certify that I have received the attached Code of Ethics and
Insider Trading Policy and Procedures. I hereby agree to read the Code, to make
a reasonable effort to understand its provisions and to ask questions about
those provisions I find confusing or difficult to understand. I also agree to
comply with the Code, including its general principles, its reporting
requirements, its preclearance requirements, and its provisions regarding gifts
and service as a director. I also agree to advise members of my Immediate Family
about the existence of the Code of Ethics, its applicability to their personal
trading activity, and my responsibility to assure that their personal trading
activity complies with the Code of Ethics. Finally, I agree to cooperate fully
with any investigation or inquiry by or on behalf of a Compliance Officer to
determine my compliance with the provisions of the Code. I recognize that any
failure to comply in all aspects with the Code and to honor the commitments made
by this acknowledgment may result in disciplinary action, including dismissal.



Date:_____________________________             _________________________________
                                               Signature




                                               _________________________________
                                               Print Name

<PAGE>

                                   Appendix IV

                       ANNUAL CERTIFICATION OF COMPLIANCE

                                    with the
                                Code of Ethics of

                      PACIFIC INVESTMENT MANAGEMENT COMPANY



       I hereby certify that I have complied with the requirements of the Code
of Ethics and Insider Trading Policy and Procedures that have applied to me
during the year ended December 31, 200_. In addition, I hereby certify that I
have read the Code and understand its provisions. I also certify that I
recognize that I am subject to the provisions of the Code and that I have
disclosed, reported, or caused to be reported all transactions required to be
disclosed or reported pursuant to the requirements of the Code. I recognize that
any failure to comply in all aspects with the Code and that any false statement
in this certification may result in disciplinary action, including dismissal.



Date:______________________________            _________________________________
                                               Signature



                                               _________________________________
                                               Print Name

<PAGE>

                                   Appendix V

                           INITIAL REPORT OF ACCOUNTS

                                 Pursuant to the
                                Code of Ethics of

                      PACIFIC INVESTMENT MANAGEMENT COMPANY

     In accordance with the Code of Ethics, I have attached to this form copies
of the most recent statements for each and every Personal Account and Related
Account that holds or is likely to hold a Security or Futures Contract in which
I have a Beneficial Ownership interest, as well as copies of confirmations for
any and all Investment Transactions subsequent to the effective dates of those
statements./1/

     In addition, I hereby supply the following information for each and every
Personal Account and Related Account in which I have a Beneficial Ownership
interest for which I cannot supply the most recent account statement:

(1)  Name of employee:                              ____________________________

(2)  If different than #1, name of the person
     in whose name the account is held:             ____________________________

(3)  Relationship of (2) to (1):                    ____________________________

(4)  Firm(s) at which Account is maintained:        ____________________________

                                                    ____________________________

                                                    ____________________________

                                                    ____________________________

(5)  Account Number(s):                             ____________________________

                                                    ____________________________

                                                    ____________________________

                                                    ____________________________

(6)  Phone number(s) of Broker or Representative:   ____________________________

                                                    ____________________________

                                                    ____________________________

                                                    ____________________________

_____________________________
/1/  The Code of Ethics uses various capitalized terms that are defined in
Appendix I to the Code. The capitalized terms used in this Report have the same
definitions.

<PAGE>
(7)  Account holdings:

     Name of Security      Quantity        Principal Amount   Custodian
1.   ___________________   ______________  _______________    __________________

2.   ___________________   ______________  _______________    __________________

3.   ___________________   ______________  _______________    __________________

4.   ___________________   ______________  _______________    __________________

5.   ___________________   ______________  _______________    __________________

(Attach additional sheets if necessary)

     I also supply the following information for each and every Security or
Futures Contract in which I have a Beneficial Ownership interest, to the extent
this information is not available elsewhere on this form or from the statements
and confirmations attached to this form. This includes Securities or Futures
Contracts held at home, in safe deposit boxes, or by an issuer.

<TABLE>
<CAPTION>
         Person Who           Description
     Owns the Security      of the Security
    Or Futures Contract   Or Futures Contract       Quantity         Principal Amount       Custodian
    -------------------   -------------------       --------         ----------------       ---------
<S>                       <C>                  <C>                  <C>                 <C>
1.  ___________________    _________________   _________________    _________________   _________________

2.  ___________________    _________________   _________________    _________________   _________________

3.  ___________________    _________________   _________________    _________________   _________________

4.  ___________________    _________________   _________________    _________________   _________________

5   ___________________    _________________   _________________    _________________   _________________
</TABLE>


(Attach additional sheets if necessary.)

     I hereby certify that this form and the attachments (if any) identify all
of the Personal Accounts, Related Accounts, Securities and Futures Contracts in
which I have a Beneficial Ownership interest as of this date.


                                                ________________________________
                                                Signature


                                                ________________________________
                                                Print Name


Date:_________________

Attachments

<PAGE>

                                   Appendix VI

                    PACIFIC INVESTMENT MANAGEMENT COMPANY LLC

                          PIMCO FUNDS DISTRIBUTORS LLC

                   QUARTERLY REPORT OF INVESTMENT TRANSACTIONS

                     FOR THE QUARTER ENDED DECEMBER 31, 2001

================================================================================

Please mark one of the following:

     [_] No reportable Investment Transactions have occurred.

     [_] Except as indicated below, all reportable Investment Transactions were
made through Personal Accounts and Related Accounts identified on the attached
list, which, except as indicated, represents a complete list of the Personal
Accounts and Related Accounts that hold Securities or Futures Contracts in which
I have or had a Beneficial Ownership interest and for which PIMCO should have
received or will receive timely duplicate broker reports for the calendar
quarter just ended./1/ I hereby certify that the broker, dealer, bank or futures
commission merchant for each such account has been instructed to send a
Compliance Officer timely duplicate broker reports for that account.

The following information for Investment Transactions during the calendar
quarter just ended does not appear on the duplicate broker reports referenced
above.

<TABLE>
<CAPTION>
Transaction  Title, Interest Rate and Maturity    Number of Shares or Contracts  Nature of Transaction  Transaction  Broker, Dealer,
   Date     Date of Security or Futures Contract      And Principal Amount        (i.e., Buy or Sell)      Price       Bank or FCM
<S>         <C>                                   <C>                            <C>                    <C>          <C>
____________________________________________________________________________________________________________________________________

____________________________________________________________________________________________________________________________________

____________________________________________________________________________________________________________________________________

____________________________________________________________________________________________________________________________________
</TABLE>

SPECIAL NOTE TO PIMCO FUNDS DISTRIBUTORS LLC REGISTERED REPS AND ACCESS PERSONS:
You will not have to fill out an extra form for each quarter for PIMCO Funds
Distributors LLC.

                                      SIGNED:     ______________________________

                                      PRINT NAME: ______________________________

                                      DATE:       ______________________________

_______________________
     1   The Code of Ethics uses various capitalized terms that are defined in
Appendix I to the Code. The capitalized terms used in this Report have the same
definitions.

<PAGE>

1.    Please see the Code of Ethics for a full description of the Investment
      Transactions that must be reported.

2.    Transaction Date. In the case of a market transaction, state the trade
      date (not the settlement date).

3.    Title of Security or Futures Contract. State the name of the issuer and
      the class of the Security (e.g., common stock, preferred stock or
      designated issue of debt securities). For Fixed Income Securities, please
      provide the Security's interest rate and maturity date. For a Futures
      Contract, state the title of any Security subject to the Futures Contract
      and the expiration date of the Futures Contract.

4.    Number of Shares or Contracts and Principal Amount. State the number of
      shares of Securities, the face amount of Fixed Income Securities or the
      units of other securities. For options, state the amount of securities
      subject to the option. Provide the principal amount of each Security or
      Futures Contract. If your ownership interest was through a spouse,
      relative or other natural person or through a partnership, trust, other
      entity, state the entire quantity of Securities or Futures Contracts
      involved in the transaction. You may indicate, if you wish, the extent of
      your interest in the transaction.

5.    Nature of Transaction. Identify the nature of the transaction (e.g.,
      purchase, sale or other type of acquisition or disposition).

6.    Transaction Price. State the purchase or sale price per share or other
      unit, exclusive of brokerage commissions or other costs of execution. In
      the case of an option, state the price at which it is currently
      exercisable. No price need be reported for transactions not involving
      cash.

7.    Broker, Dealer, Bank or FCM Effecting Transaction. State the name of the
      broker, dealer, bank or FCM with or through which the transaction was
      effected.

8.    Signature. Sign and date the report in the spaces provided.

9.    Filing of Report. A report should be filed NOT LATER THAN 10 CALENDAR DAYS
      after the end of each calendar quarter with:

            PIMCO
            ATTN: Compliance Officer
            840 Newport Center Drive
            Suite 300
            Newport Beach, CA 92660

10.   Duplicate Broker Reports. Please remember that duplicates of all trade
      confirmations, purchase and sale reports, and periodic statements must be
      sent to the firm by your broker. You should use the address above.

<PAGE>


                                  Appendix VII

                    PACIFIC INVESTMENT MANAGEMENT COMPANY LLC

                          PIMCO FUNDS DISTRIBUTORS LLC

                           ANNUAL HOLDINGS REPORT AND
                FOURTH QUARTER REPORT OF INVESTMENT TRANSACTIONS

================================================================================


                FOR THE YEAR AND QUARTER ENDED DECEMBER 31, 2001

================================================================================

         I hereby certify that, except as indicated below, all Securities or
Futures Contracts in which I had a Beneficial Ownership interest at the end of
the 2001 calendar year were held in Personal Accounts or Related Accounts
identified on the attached list, for which PIMCO should have received or will
receive an account statement of holdings as of the end of that calendar year./1/
I hereby certify that the broker, dealer, bank or futures commission merchant
for each such account has been instructed to send a Compliance Officer timely
duplicate broker reports, including a statement of holdings in that account as
of the end of the calendar year.

The following information describes other Securities or Futures Contracts in
which I had a Beneficial Ownership interest as of the end of the 2001 calendar
year:

<TABLE>
<CAPTION>
     Title, Interest Rate and Maturity                Number of Shares or Contracts               Broker, Dealer,
    Date of Security or Futures Contract                   And Principal Amount                     Bank or FCM
<S>                                                   <C>                                         <C>
____________________________________________________________________________________________________________________________________

____________________________________________________________________________________________________________________________________

____________________________________________________________________________________________________________________________________

____________________________________________________________________________________________________________________________________

____________________________________________________________________________________________________________________________________

____________________________________________________________________________________________________________________________________

____________________________________________________________________________________________________________________________________
</TABLE>

-----------------------
1 The Code of Ethics uses various capitalized terms that are defined in
Appendix I to the Code. The capitalized terms used in this Report have the same
definitions.

<PAGE>

     Except as indicated below, all reportable Investment Transactions during
the quarter ended December 31, 2001, were made through Personal Accounts and
Related Accounts identified on the attached list, which, except as indicated,
represents a complete list of the Personal Accounts and Related Accounts that
hold Securities or Futures Contracts in which I have or had a Beneficial
Ownership interest and for which PIMCO should have received or will receive
timely duplicate broker reports for the calendar quarter just ended.

The following information for Investment Transactions during the calendar
quarter just ended does not appear on the duplicate broker reports referenced
above.

<TABLE>
<CAPTION>
Transaction   Title, Interest Rate and Maturity   Number of Shares or Contracts  Nature of Transaction  Transaction  Broker, Dealer,
   Date     Date of Security or Futures Contract      And Principal Amount        (i.e., Buy or Sell)      Price       Bank or FCM
<S>         <C>                                   <C>                             <C>                    <C>          <C>
___________________________________________________________________________________________________________________________________

___________________________________________________________________________________________________________________________________

___________________________________________________________________________________________________________________________________

___________________________________________________________________________________________________________________________________
</TABLE>

SPECIAL NOTE TO PIMCO FUNDS DISTRIBUTORS LLC REGISTERED REPS AND ACCESS PERSONS:
You will not have to fill out an extra form for each year for PIMCO Funds
Distributors LLC.

                                                SIGNED:_________________________


                                                PRINT NAME:_____________________


                                                DATE:___________________________

<PAGE>

1.     Please see the Code of Ethics for a full description of the Investment
       Transactions that must be reported.

2.     Transaction Date. In the case of a market transaction, state the trade
       date (not the settlement date).

3.     Title of Security or Futures Contract. State the name of the issuer and
       the class of the Security (e.g., common stock, preferred stock or
       designated issue of debt securities). For Fixed Income Securities, please
       provide the Security's interest rate and maturity date. For a Futures
       Contract, state the title of any Security subject to the Futures Contract
       and the expiration date of the Futures Contract.

4.     Number of Shares or Contracts and Principal Amount. State the number of
       shares of Securities, the face amount of Fixed Income Securities or the
       units of other securities. For options, state the amount of securities
       subject to the option. Provide the principal amount of each Security or
       Futures Contract. If your ownership interest was through a spouse,
       relative or other natural person or through a partnership, trust, other
       entity, state the entire quantity of Securities or Futures Contracts
       involved in the transaction. You may indicate, if you wish, the extent
       of your interest in the transaction.

5.     Nature of Transaction. Identify the nature of the transaction (e.g.,
       purchase, sale or other type of acquisition or disposition).

6.     Transaction Price. State the purchase or sale price per share or other
       unit, exclusive of brokerage commissions or other costs of execution. In
       the case of an option, state the price at which it is currently
       exercisable. No price need be reported for transactions not involving
       cash.

7.     Broker, Dealer, Bank or FCM Effecting Transaction. State the name of the
       broker, dealer, bank or FCM with or through which the transaction was
       effected.

8.     Signature. Sign and date the report in the spaces provided.

9.     Filing of Report. A report should be filed NOT LATER THAN 10 CALENDAR
       DAYS after the end of each calendar quarter with:

                  PIMCO
                  ATTN: Compliance Officer
                  840 Newport Center Drive
                  Suite 300
                  Newport Beach, CA 92660

10.    Duplicate Broker Reports. Please remember that duplicates of all trade
       confirmations, purchase and sale reports, and periodic statements must be
       sent to the firm by your broker. You should use the address above.

<PAGE>

                                  Appendix VIII

                            PRECLEARANCE REQUEST FORM

       This form must be submitted to a Compliance Officer before executing
any Investment Transaction for which preclearance is required under the PIMCO
Code of Ethics. Before completing this form, you should review the PIMCO Code,
including the terms defined in that Code. The capitalized terms used in this
form are governed by those definitions. In addition, the Code provides
information regarding your preclearance obligations under the Code, and
information regarding the Transactions, Securities and Futures Contracts that
are exempt from the Code's preclearance requirement./1/

       No Investment Transaction subject to preclearance may be effected prior
to receipt of written authorization of that Investment Transaction by a
Compliance Officer. Unless otherwise specified, that authorization shall be
effective, unless revoked, until the earlier of (a) the close of business on the
date authorization is given, or (b) until you discover that information on this
preclearance request form is no longer accurate.

<TABLE>
<S>                                                                       <C>
(1)  Your Name:                                                           _____________________________________

(2)  If the Investment Transaction will be in someone else's name or
     in the name of a trust, the name of that person or trust:            _____________________________________

     The relationship of that person or trust to you:                     _____________________________________

(3)  Name of the firm (e.g., broker, dealer, bank, futures
     commission merchant) through which the Investment Transaction will
     be executed:                                                         ____________________________________

     The relevant account number at that firm:                            ____________________________________

(4)  Issuer of the Security or identity of the Futures Contract for
     which preclearance is requested:                                     ____________________________________

     The relevant CUSIP number or call symbol:                            ____________________________________

(5)  The maximum number of shares, units or contracts for which
     preclearance is requested, or the market value or face amount of
     the Fixed Income Securities for which preclearance is requested:     ____________________________________

(6)  The type of Investment Transaction for which preclearance is
     requested (check all that apply):                                    ____ Purchase       ___ Sale     ____ Market Order
                                                                          ____ Limit Order (Price Of Limit Order:_______)

                         Please answer the following questions TO THE BEST OF YOUR KNOWLEDGE AND BELIEF:

(a)  Do you possess material nonpublic information regarding the Security or
     Futures Contract identified above or regarding the issuer of that Security?                        ____ Yes   ____ No

(b)  Is the Security or Futures Contract identified above held by any PIMCO
     Advisory Client or is it a Related Security (as defined in the PIMCO Code)?                        ____ Yes   ____ No

(c)  Is there a pending buy or sell order on behalf of a PIMCO Advisory Client
</TABLE>

_________________________________
/1/      Preclearance is required for any Investment Transaction in Securities,
Related Securities or Futures Contracts in a Personal Account or a Related
Account in which you have or will acquire a Beneficial Ownership interest.

<PAGE>

<TABLE>
<S>                                                                                                <C>             <C>
     for the Security or Futures Contract identified above or for a Security for
     which the Security identified above is a Related Security?                                    ____ Yes        ____ No

(d)  Do you intend or do you know of another's intention to purchase or sell the
     Security or Futures Contract identified above, or a Security for which the
     Security identified above is a Related Security, on behalf of a PIMCO
     Advisory Client?                                                                              ____ Yes        ____ No

(e)  Has the Security or Futures Contract identified above or a Related
     Security been considered for purchase by a PIMCO Advisory Client within the
     most recent 15 days?  (Note: rejection of any opportunity to purchase the
     Security or Futures Contract for an Advisory Client would require an
     affirmative response to this question.)                                                       ____ Yes        ____ No

(f)  If you are a Portfolio Employee, is the Security being acquired in an
     Initial Public Offering?/2/                                                                   ____ Yes        ____ No

(g)  If you are a Portfolio Employee, are you acquiring or did you acquire
     Beneficial Ownership of the Security in a Private Placement?/3/                               ____ Yes        ____ No

(h)  If you are seeking preclearance of a purchase or sale of Securities, have
     you purchased or sold the same or similar Securities, or have you acquired
     or disposed of a Beneficial Ownership interest in the same or similar
     Securities, within the past 60 calendar days?/4/                                              ____ Yes        ____ No
</TABLE>

By executing this form, you hereby certify that you have reviewed the PIMCO Code
of Ethics and believe that the Investment Transaction for which you are
requesting preclearance complies with the General Principles and the specific
requirements of the PIMCO Code.

                                              __________________________________
                                                      Employee Signature


                                              __________________________________
                                                      Print or Type name


                                              __________________________________
                                                        Date Submitted

__________________________
/2/ Under the PIMCO Code, Portfolio Employees generally are not permitted to
acquire Securities in an Initial Public Offering.
/3/ The PIMCO Code applies special rules to the acquisition of Securities
through a Private Placement and to the disposition of Securities acquired
through a Private Placement.
/4/ Under the PIMCO Code, you may not profit from short-term trades in Fixed
Income Securities. A Portfolio Employee may not profit from short-term trades in
Designated Equities Securities and a Municipal Bond Portfolio Employee may not
profit from short-term trades in Tax-Exempt Municipal Bonds. This rule does not
apply to transactions in U.S. Government Securities, mutual fund shares, index
options or Futures Contracts.

<PAGE>

You are authorized to execute the Investment Transaction described above. Unless
indicated otherwise below, this authorization remains effective, unless revoked,
until: (a) the close of business today, or (b) until you discover that the
information on this request form is no longer accurate.

                        _________________________________________________
                                     Compliance Officer

                        _________________________________________________
                                     Date of Authorization

<PAGE>

                                   Appendix IX

                            PRECLEARANCE REQUEST FORM

                                       for

                            PIMCO'S CLOSED END FUNDS

<TABLE>
<S>                                                                       <C>
(1) Name of employee requesting authorization:                            ________________________

(2) If different from #1, name of account where the trade
    will occur:                                                           ________________________

(3) Relationship of (2) to (1):                                           ________________________

(4) Name of Firm at which the account is held:                            ________________________

(5) Name of the PIMCO Closed End Fund:                                    ________________________

(6) Maximum number of shares to be purchased or sold:                     ________________________

(7) Check those that are applicable:

    ____Purchase   ____ Sale   ____ Market Order  ____ Limit Order (Price of Limit Order: _______)

Prior to trading, you must consult with your Compliance Officer for authority to
trade.

(8) Do you possess material nonpublic information regarding
     the PIMCO Closed End Fund/5/                                              ____ Yes    ____ No

(9) Have you or any Related Account covered by the authorization
    provisions of the Code purchased or sold shares of the
    PIMCO Closed End Fund within the past 6 months?                            ____ Yes    ____ No
</TABLE>


__________________
/5/ Please note that employees are not permitted to acquire or sell securities
when they possess material nonpublic information regarding the security or the
issuers of the security.

<PAGE>

I have read the Code of Ethics for PIMCO dated December 31, 2001, within the
prior 12 months and believe that the proposed trade fully complies with the
requirements of the Code.


                               ______________________________
                               Employee Signature


                               ______________________________
                               Print Name


                               ______________________________
                               Date Submitted


Authorized By: _______________________

Authorization Date: ___________________

THIS TRADE MUST BE EXECUTED BY THE CLOSE OF BUSINESS ON THE AUTHORIZATION DATE.

<PAGE>

                                   Appendix X

                               COMPLIANCE OFFICERS

                    PACIFIC INVESTMENT MANAGEMENT COMPANY LLC




           PIMCO's Compliance Officers, as of December 31, 2001, are:


                                Denise C. Seliga
                           (Chief Compliance Officer)

                               Bradley W. Paulson

                               Mohan V. Phansalkar

                                 Richard M. Weil

</TEXT>
</DOCUMENT>
