<DOCUMENT>
<TYPE>EX-99.77Q2 ITEM 405
<SEQUENCE>4
<FILENAME>compliance.txt
<DESCRIPTION>COMPLIANCE-SECTION 16 (A) DISCLOSURE
<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, 2003 all filing
requirements were met, though Mrs. Schmeltz inadvertently filed
one late report for one transaction.


</TEXT>
</DOCUMENT>
