(b) Check services listed below which are supplied or paid for by the investment adviser in connection with the management contract for each registered investment company. If such services are supplied or paid for by any person, other than the investment company or the investment adviser, so note and identify such person. Where the services provided or paid for differ between series of a multiseries company the information is to be furnished separately for each series.

h. Salaries and compensation of directors of the investment companies. -i. Salaries and compensation of officers of the investment companies. ------j. Reports to stockholders.

.k. Determination of offering and redemption prices.

Other (specify):

_m.

(c) If any person, other than the investment adviser, principal underwriter, or personnel of the investment company furnishes administrative, statistical, bookkeeping, or similar services to the registered investment company, itemize the services performed and the amount charged therefor in the past fiscal year. 8. (a) State whether the investment adviser acts as such pursuant to contract or other arrangement for clients other than registered investment companies. If so, for each type of client (e.g., insurance companies, pension funds, individuals, etc.) state separately the schedule of fees and method of calculation for such services and indicate whether investment advisory service includes administration and recordkeeping of clients' securities. Also state the number of such clients, and the aggregate net asset value of portfolios managed for all such clients.

(b) List the three most imporatnt activities of the investment adviser in order of their importance measured by relative gross income from the various activities.

Instructions:

(1) The investment advisory function with respect to investment companies and with respect to other investment advisory clients, should be considered as separate activities.

(2) The gross income from the activities listed need not be shown. (3) If any significant activities are designed for the realization of capital gains, this factor should be considered in listing the three most important activities.

(c) State the net worth of the investment adviser as of the end of its most recent fiscal year as reflected by the books.

9. If during the past 5 years the investment adviser has sold its securities pursuant to a public offering, state the number and class of securities sold, the unit offering price (s) and the date(s) of the offer(s).

10. If within the past 5 years any person who owned more than 25 percent of the voting securities of, or who was an officer or director of, the investment adviser has sold an aggregate of 10 percent or more of securities of any class of the investment adviser (other than a bank) owned by him, state the number and class of securities sold, the price (s) per unit, and the date(s) of sale. If the investment adviser is a partnership, state whether any part who owned more than a 25 percent partnership interest has sold within the past 5 years an interest in the partnership aggregating 10 percent or more and indicate the date(s) of sale.

11. (a) Is there a policy or practice with respect to the use, by officers, directors, members of an advisory board or committee, partners or employees of the investment company, the investment adviser or the principal underwriter, of investment research information developed by or on behalf of the investment adviser in connection with its investment advisory services to the investment company? If so, set forth the policy or practice, and state to whom it applies. (b) If the investment adviser acts as such to more than one investment com

pany, is there a policy or practice with respect to the execution of purchase and sale orders in implementation of investment advice which has been given to more than one such investment company? If so, set forth the policy or practice.

(c) Is there a policy or practice with respect to the deposit by the investment company or custodian for the investment compary of part or all of the investment company's funds or equivalent in banks other than the custodian bank or banks. If so, describe such policy or practice.

SECTION II-TRANSACTIONS IN THE INVESTMENT COMPANY'S PORTFOLIO

1. With respect to the process of selection and recommendation for purchases and sales of portfolio securities, furnish the following information:

(a) To whom are recommendations made by the investment adviser and indicate whether such are made in writing or orally.

(b) Is the execution of the recommendations made only following action by the board of directors of the investment company.

(c) If the recommendations of purchases and sales are carried out prior to action of the board of directors with respect thereto, by whom is the decision made.

(d) If the decision is made by an executive committee or other group acting on behalf of the fund, identify the members of such group and state their relationships to the investment adviser and/or the principal underwriter.

(e) State how frequently the board of directors of the fund meets and generally the matters considered at such meetings.

(f) Is approval of the investment company's directors who are not affiliated os associated with the investment adviser, the principal underwriter, or any broker specifically required with respect to purchases and sales of portfolio securities.

2. Indicate briefly the organizational structure relevant to and the steps involved in the formulation of the recommendation by the investment adviser for the purchases and sales of portfolio securities. If pursuant to any understanding, formal or otherwise, any person not a full-time employee regularly furnished to the investment adviser or the investment company during the past fiscal year advice or information (other than solely through uniform publications distributed generally) concerning purchases and sales of securities for the portfolio of the investment company, name such person, describe the circumstances involved, and report the remuneration (including commissions paid in connection with transactions in portfolio securities of the investment company) paid for such advice.

3. (a) Do dealers who sell shares of the investment company, or brokerdealers who furnish benefits in the form of payment of expenses or otherwise (but not including investment advice or information covered under item 2) to the investment company or to its investment adviser or to dealers who sell shares of the investment company, participate in commissions paid in connection with purchases and sales of portfolio securities for the investment company, either directly in payment for executing purchase and sale orders or indirectly by participating in the commissions paid to the brokers who execute purchase and sale orders?

(b) If the answer to (a) is "Yes," describe briefly the policy followed with respect to the degree of participation of such dealers or brokers and the basis or bases upon which such participation is allocated, including the nature of the benefits made available to the investment adviser or investment company. In connection with this description set forth the names and positions held, in the investment company, investment adviser, underwriter or otherwise, of the person or persons who advise with respect to such participation, and the names and positions held of the person or persons who direct such participation.

State whether or not there has been any material change in this policy during the 3 most recent fiscal years. If there has been such a change, describe the previous policy in the same manner, and state when the change in policy was made.

(c) Set forth, in order for the last fiscal year, the 20 dealers selling the largest dollar amount of shares of the investment company. Show the total dollar amount of shares sold by each. Also set forth the brokerage commissions received by each by virtue of direct or indirect participation in the purchase and sale of portfolio securities for the investment company. Show separately gross commissions received for executing portfolio transactions; amounts received from other brokers or dealers at the request of the investment company,

its principal underwriter or its investment adviser; amounts paid to other brokers or dealers or other persons at the direction or request of the investment company, its principal underwriter or its investment adviser. (For purposes of this item and item (d) below, consider as brokerage the amount of the profit or commission on those principal transactions (i.e., new issues and secondary distributions) where the profit or commission is fixed by agreement under the rules of a national securities exchange, or where the discount or concession is fixed by prospectus.)

(d) Set forth, in order for the last fiscal year, the 20 brokers who received the greatest amount of brokerage commissions by virtue of direct or indirect participation in the purchase or sale of portfolio securities of the investment company. For each, give the brokerage commissions received, set forth as called for by item (c) above.

(e) Set forth for the alst fiscal year the total cost of portfolio securities (including Government securities) purchased by the investment company from, and the total proceeds of portfolio securities sold by the investment company to, each dealer or broker named in answer to (c) and (d) acting as principal, and each other dealer or broker among the 20 dealers or brokers who engaged as principals in the largest amount of such purchase and sale transactions. (Do not consider, for purposes of this question, principal transactions in which the profit or commission to the dealer is fixed by the rules of a national securities exchange, or in which the discount or concession is fixed by prospectus.)

(f) If, pursuant to any arrangement or understanding or practice, whether occasional or regular, orders for the purchase or sale of securities on behalf of one investment company are placed with a broker or dealer in return for advice, information or other services provided to another investment company, explain the nature of any such arrangement or practice and indicate the number and amount of such transactions within the past fiscal year. Identify the broker or dealer in each such case.

State whether or not there has been any material change in this arrangement or practice during the 3 most recent fiscal years. If there has been such a change, describes the previous arrangement or practice in the same manner, and state when the change was made.

Instruction: If records with respect to broker-dealer participation are kept on a combined basis for investment companies which have the same investment adviser or principal underwriter, the information called for in (c), (d), (e) and (f) of this item may in the alternative be given with respect to transactions in the portfolio securities of all investment companies for which the investment adviser or the principal underwriter acted in such capacity.

4. Name each broker or dealer participating, directly or indirectly in brokerage commissions paid in connection with transactions in portfolio securities of the investment company, any officer, director, partner, or registered representative of which is, to the knowledge of any of the persons named in response to item 3(b) or of any officer, director, partner or owner of 5 percent or more of outstanding voting securities of the investment adviser, a member of the immediate family of any person named in response to item 3(b) or of any officer, director, partner or owner of 5 percent or more of outstanding voting securities of the investment company, the investment adviser, or the principal underwriter. With respect to each such family relationship, give the names, relationships to each other, and the respective positions held by the persons concerned. Also show the brokerage commissions (set forth as required by item 3(c)) received by each such broker or dealer during the most recent fiscal year.

As used herein "immediate family" shall include any of the following: spouse, son, daughter, father, mother, brother, sister, son-in-law, daughter-in-law, brother-in-law, sister-in-law, father-in-law, mother-in-law, uncle, aunt, nephew, and niece. For the purpose of determining whether any of these relations exists a legally adopted child of a person shall be considered a child of such person.

SECTION III DIRECTORS AND OFFICERS OF INVESTMENT ADVISER

1.. With respect to each director, officer, member of an advisory board or committee of, and any person (other than employees or persons providing statistical service) who pursuant to contract or other arrangement regularly furnishes investment advice or information to, the investment adviser and with respect to each partner having one of the three largest partnership interests or each owner of 5 percent or more of the outstanding voting securities of the investment adviser, as the case may be:

(a) State the name and relationship to the investment adviser of each such person and the principal occupation or employment in which he is engaged. Give the name and principal business of any corporation or other organization in which such employment is carried on.

(b) State when he was first elected or appointed to each such position with the investment adviser. As to each named partner and each such owner of 5 “percent or more state the date as of which he qualified as such.

(c) Indicate the interest he may have in the principal underwriter or any broker for the investment company. In the case of publicly owned companies only an interest of 5 percent or more need be shown. In the case of a partnership only indicate whether or not he has one of the three largest partnership -interests.

(d) If there is an advisory board or committee indicate its functions and the frequency of its meetings.

2. Describe each transaction within the last fiscal year between the investment company, its principal underwriter or any broker named in response to item 3 of section II, and (a) any director of the investment adviser, (b) any officer of the investment adviser or (c) to the knowledge of any officer or director of the investment adviser, any other corporation or organization of which any such officer or director was an affiliated person, other than by virtue of being a director thereof.

Instruction:

(a) Include the name of each person whose interest in any transaction is described and the nature of the relationship by reason of which such interest is described.

(b) As to any transaction involving the purchase or sale of assets state the cost of the assets to the purchaser and the cost thereof to the seller if he seller was such officer, director, or other corporation or organization, and such assets were acquired by the seller within 2 years prior to the transaction. If the interest of any person arises from the position of such person as a partner in a partnership, only the amount involved in the transaction with the partnership need be stated.

(c) No information need to be given with respect to normal brokerage. commercial and investment banking, legal, accounting, public utility and telephone services or with respect to services solely as an officer, director or employee.

(d) No information need be given with respect to transactions not involving remuneration for services where the aggregate amount did not exceed $1.000 nor with respect to transactions involving remuneration for services where the remuneration did not exceed $1,000.

1 Include custodian, transfer and dividend disbursing fees for investment companies. Do not include brokerage. Specify items included.

2 Net, after deduction for dealers' or wholesalers' commissions.

3 Include all other remuneration and profit-sharing plan contributions. Also include partners' withdrawals or any portion thereof, if such amounts are considered compensation or payments in lieu of salaries. 4 Special charges or credits-list and describe

If subject to corporation income tax.

NOTE.-Include in cols. (a) through (c) the expense items as allocated to sources of income in the company's accounts showing separately direct charges and allocations by formula or otherwise. If possible use direct charges; otherwise use allocation made for internal purposes. If neither of these is available allocate charges for the purpose of this report indicating the basis of allocation by footnote.

SECTION V-DIRECTORS AND OFFICERS OF PRINCIPAL UNDERWRITER

1. With respect to each director and officer of the principal underwriter, and with respect to each partner having one of the three largest partnership interests or each owner of 5 percent or more of the outstanding voting securities of the principal underwriter, as the case may be:

(a) State the name and relationship to the principal underwriter of each such person and the principal occupation or employment in which he is engaged. Give the name and principal business of any corporation or other organization in which such employment is carried on.