<DOCUMENT>
<TYPE>EX-99.77Q2 ITEM 405
<SEQUENCE>3
<FILENAME>compliance2002.txt
<DESCRIPTION>COMPLIANCE STATEMENT
<TEXT>



Section 16(a) Beneficial Ownership Reporting Compliance

Directors and officers of the Fund and certain of its affiliates and
beneficial owners of more than 10% of the Fund's common stock are
required to file initial reports of ownership and reports of changes in
ownership of the Fund's common stock pursuant to Section 16(a) of the
Securities Exchange Act of 1934, as amended.  The Fund has reviewed
such reports received by it and written representations of such persons
who are known by the Fund, and based solely upon such review, the Fund
believes that during the year ended December 31, 2002 all filing
requirements were met, though Messrs. O'Hara, Janke, and Rockwell each
inadvertently filed late Form 4's. Mr. O'Hara was late in filing one report
for three different transactions; Mr. Rockwell was late in filing two reports
for seven different transactions; and Mr. Janke was late in filing three
reports for three different transactions.




</TEXT>
</DOCUMENT>
