April 16, 2010
Ms. Christina DiAngelo
U.S. Securities and Exchange Commission
450 5th Street, NW
Washington, D.C. 20549
Re: Nuveen Closed-End and Open-End Funds - Sarbanes Oxley Review
Dear Christina:
This letter addresses your comments provided in a telephone discussion on September 29, 2009. Each comment is shown below followed by our response. Unless otherwise noted, the responses relate to all funds listed on Appendix A attached hereto.
| 1) | Comment: (a) 479 Letters – Nuveen was recently sent 479 letters regarding de-registering funds no longer in existence. Please de-register funds identified within letter. |
Response: 1(a) We have received the correspondence from the staff and we have prepared and submitted correspondence to the U.S. Securities and Exchange Commission (“SEC”) via IDEA seeking to withdraw the Securities Act registration statements that were pending for the funds identified by the staff. In addition, we have also identified several others funds for which we filed to withdraw pending registration statements prior to filing a Form N-8F for each of those funds. Finally, we have filed a Form N-8F for each of the funds covered by the staff’s correspondence as well as the additional funds identified by us as detailed in the table below.
Fund Name | CIK | Date withdrawal filed with SEC | Date N-8F filed with SEC | |||
Nuveen North Carolina Municipal Value Fund | 0001461194 | 12-3-2009 | 3-9-2010 | |||
Nuveen High Income Municipal Fund | 0001464620 | 12-3-2009 | 3-9-2010 | |||
Nuveen Virginia Municipal Value Fund | 0001461195 | 12-3-2009 | 3-9-2010 | |||
Nuveen Ohio Municipal Value Fund | 0001461196 | 12-3-2009 | 3-9-2010 | |||
Nuveen Massachusetts Municipal Value Fund | 0001461193 | 12-3-2009 | 3-9-2010 | |||
Nuveen Maryland Municipal Value Fund | 0001461192 | 12-3-2009 | 3-9-2010 | |||
Nuveen Connecticut Municipal Value Fund | 0001461191 | 12-3-2009 | 3-9-2010 | |||
Nuveen High Grade Municipal Income Fund | 0001461189 | 12-3-2009 | 3-9-2010 |
Fund Name | CIK | Date withdrawal filed with SEC | Date N-8F filed with SEC | |||
Nuveen Multistate Shell Trust | 0001018970 | 12-17-2009 | 3-9-2010 | |||
Nuveen Investment Trust IV | 0001071680 | 12-3-2009 | 3-9-2010 | |||
Nuveen Credit Strategies Fund | 0001412349 | 12-3-2009 | 3-9-2010 | |||
Nuveen Symphony Market Neutral Fund | 0001209540 | 12-3-2009 | 3-9-2010 | |||
Nuveen Connecticut Municipal Income Opportunity Fund | 0001424452 | 12-3-2009 | 3-9-2010 | |||
Nuveen Multi-Currency Income Fund | 0001400390 | 12-3-2009 | 3-9-2010 | |||
Nuveen Municipal High Income Advantage Fund, formerly called Nuveen Municipal High Income Opportunity Fund 3 | 0001424214 | 12-3-2009 | 3-9-2010 | |||
Nuveen Washington Premium Income Fund | 0000897420 | N/A | 12/16/2009 | |||
Nuveen Floating Rate Fund | 0001093189 | N/A | 1/27/2010 |
Comment:(b) Two Nuveen funds – Nuveen Floating Rate Fund (Reg. No. 811-09553) and Nuveen Washington Premium Income Municipal Fund (Reg. No. 811-07488) – have apparently ceased operations, but in fact have continued to file their semi-annual reports on Form N-SARs, although they have not continued to file their annual report of proxy votes on Form N-PX. Assuming that these funds in fact have ceased operations, the SEC staff requests that these funds do two things:
| a. | File for termination of their 1940 Act registration on Form N-8F; and |
| b. | File all the missed Form N-PXs. |
Response: 1(b) The SEC staff is correct that each of these funds ceased operations, the former on May 28, 2003, and the latter on September 9, 1999. We have obtained the necessary data and filed a Form N-8F for each of these funds as outlined in the table below. In addition we will also file the Form N-PXs for each fund going back to the date of the first required filing under that Form after its adoption.
Fund Name | CIK | Date N-8F filed with SEC | ||
Nuveen Washington Premium Income Fund | 0000897420 | 12/16/2009 | ||
Nuveen Floating Rate Fund | 0001093189 | 1/27/2010 |
2
| 2) | Comment:Amendments to filings made pursuant to Rule 17g-1 on Form 40-17/G should be identified on EDGAR with the filing type 40-17G/A. |
Response: The funds will identify such filings in the future as requested.
| 3) | Comment:Item 8 of Form N-CSR requires that closed-end funds, in their annual N-CSR filing, describe the compensation structure for all named Portfolio Managers of the fund or funds included in the filing. Specifically, Item 8(a)(3) reads in pertinent part as follows: |
Describe the structure of, and the method used to determine, the compensation of each Portfolio Manager . . . . For each type of compensation (e.g., salary, bonus, deferred compensation, retirement plans and arrangements), describe with specificity the criteria on which that type of compensation is based, for example, whether compensation is fixed, whether (and, if so, how) compensation is based on the registrant’s pre- or after-tax performance over a certain time period, and whether (and, if so, how) compensation is based on the value of assets held in the registrant’s portfolio. For example, if compensation is based solely or in part on performance, identify any benchmark used to measure performance and state the length of the period over which performance is measured.
Instruction 3 to Item 8(a)(3) reads, in pertinent part:
This description must clearly disclose any differences between the method used to determine the Portfolio Manager’s compensation with respect to the registrant and other accounts, e.g., if the Portfolio Manager receives part of an advisory fee that is based on performance with respect to some accounts but not the registrant, this must be disclosed.
The SEC staff stated that the disclosure about the structure of Portfolio Manager compensation for several funds was inadequate, and needed more detail. The staff gave examples of several of those funds, including:
| • | Nuveen Diversified Dividend and Income Fund (JDD) |
| • | Nuveen Tax-Advantaged Total Return Strategy Fund (JTA) |
| • | Nuveen Floating Rate Income Fund (JFR) |
| • | Nuveen Floating Rate Income Opportunity Fund (JRO) |
| • | Nuveen Senior Income Fund (NSL) |
| • | Nuveen Equity Premium Income Fund (JPZ) |
| • | Nuveen Equity Premium Opportunity Fund (JSN) |
| • | Nuveen Equity Premium Advantage Fund (JLA) |
| • | Nuveen Equity Premium and Growth Fund (JPG) |
Response: We have initiated a review of the Portfolio Manager compensation disclosure in our N-CSRs and Statements of Additional Information. As various types of filings for these and other Nuveen funds are made, we have undertaken to revise and expand the Portfolio Manager compensation discussion where appropriate and we will continue to do so as new filings are made.
Although we are near the beginning of the twelve-month cycle over which this disclosure will be reviewed and revised, we have found already that it is often not easy to expand the disclosure in a meaningful way, despite the specificity of the Form requirements quoted above. For example, in October we reviewed the Portfolio Manager compensation disclosure for several equity funds managed by Nuveen affiliate, Symphony Asset Management (“SAM”). We held several lengthy
3
discussions with the staff of SAM to better understand their compensation-setting process, and to turn our understanding into disclosure that fully responded to the Form requirements. In that discussion, it became clear to the lawyers responsible for drafting the disclosure that SAM’s actual compensation-setting mechanism was highly subjective, and was not really susceptible to the sort of criteria-specific disclosure required by the Form. For example, investment performance relative to a benchmark is not a specific criterion for compensation-setting by SAM. So, while we did revise and expand the disclosure in an attempt to respond to the Form requirements and to provide the reader with some additional insight into the compensation-setting process, it does not contain all the specific items mentioned in the rule and the instructions thereto, simply because those items do not apply in that case. That disclosure, contained in the post-effective amendment filing on November 2, 2009, for Nuveen Investment Trust, SEC Accession No. 0001193125-09-219820, is as follows:
SAM investment professionals receive competitive base salaries and annual bonus payments. Base salaries are determined by SAM’s senior management and reviewed periodically to ensure competitiveness with comparable positions at similar asset management firms. The bonus pool is based in part on SAM’s aggregate management fees which include asset based fees and, for some firm clients (other than mutual funds) performance fees. An investment professional’s bonus compensation is not based on any fixed formula, but is determined by senior management on a discretionary basis, based on senior management’s assessment of the individual professional’s contribution to the firm’s revenue, as well as his or her individual work performance, contribution to the investment team, strategy performance, and overall firm performance. In addition, SAM’s investment professionals may participate in long-term incentive plans which are tied to ongoing year-over-year firm performance, profitability and growth.
One complicating factor for the Nuveen funds and this Portfolio Manager compensation disclosure is that the Nuveen funds, of which there are over 200, are managed by fourteen different advisory entities, including affiliates Nuveen Asset Management, Symphony Asset Management, Santa Barbara Asset Management, NWQ Investment Management Company, Tradewinds Global Investors, LLC, Winslow Capital Management, Nuveen Investment Solutions, and Nuveen HydePark Group; and non-affiliates Spectrum Asset Management, Institutional Capital Corporation, Gateway Investment Advisers LLC, Wellington Management Company, LLP, Security Capital Research and Management, Inc., and INTECH Investment Management. Each of these entities has their own compensation-setting arrangements, which are in effect entirely independent of each other, and those arrangements vary widely from firm to firm (and sometimes there are variances between or among different investment teams within an organization). Therefore, there will be little or no commonality between and among the compensation disclosures for each of these entities.
| 4) | Comment: In the Annual Investment Management Agreement Approval Process sections of shareholder reports, consider increasing the specificity as to what the Board is approving and whether they believe such approvals to be reasonable/satisfactory. |
Response: In the next annual approval of each fund’s investment management agreement, we will work with counsel to the independent trustees of the funds to prepare and submit with the next shareholder report for each fund more specific information as to the factors considered and deemed
4
relevant by the trustees. The process for the trustees’ consideration of the next annual contract renewals began earlier this spring, with a final determination expected to be made by the Board at a regular scheduled meeting at the end of May. The updated disclosure will then be included in the next succeeding shareholder report issued by each fund.
| 5) | Comment: In the prospectuses for the Nuveen mutual funds, custodian fee credits should not be presented as a separate line item within the fee tables. |
Response: Custodian fee credits have been removed from the fee table presentations.
| 6) | Comment: In the Symphony International Equity Fund prospectus dated November 28, 2009, footnote 9 states that “Other Expenses” have been restated. Please explain what has been restated and why. |
Response:Nuveen Symphony International Equity Fund commenced operations on May 30, 2008; therefore, the expense ratios presented in the annual report represented only 63 days of operations. “Other Expenses” and “Total Annual Fund Operating Expenses” were restated to better reflect anticipated expenses of the Fund. “Custodian Fee Credits” were not presented and “Fee Waivers and Expense Reimbursements” were restated in order to reflect the impact of the restated “Other Expenses” while keeping “Total Annual Fund Operating Expenses – Net” at the Fund’s expense limit of 1.13% (plus class specific 12b-1 fees where applicable) which is in effect through November 30, 2011.
| 7) | Comment: In the prospectuses for the Nuveen mutual funds (for example, on page 3 of the prospectus for the funds that are a series of Nuveen Municipal Trust), the Class C Shares are described, in footnote 10, as being subject to a contingent deferred sales charge (“CDSC”) of 1% if redeemed “within less than one year of purchase,” but in the 1-Year line in the expense example the CDSC is not reflected in the expense figure. Please explain why the 1-Year CDSC is not reflected in the 1-Year expense figure in that table. |
Response: As discussed during the call, the CDSC for the Nuveen mutual funds operates such that if a shareholder’s holding period prior to a redemption is for an entire period in question (in this case, one year), the CDSC percentage that applies to the redemption is reduced to the percentage applicable to the next longest holding period. In the case of Class C Shares, which imposes a CDSC where the holding period is within one year but not for longer periods, once the shares are held for an entire year there is no CDSC.
| 8) | Comment: In the semi-annual report dated January 31, 2009, for Enhanced Multi-Strategy Managed Accounts Portfolio, the Fund’s portfolio of investments has more than 60% invested in mortgage-backed securities. Consider enhancing prospectus disclosures regarding policies around investment concentration. |
Response: The following disclosure was added to the Fund’s prospectus under the heading “Principal Investment Strategies” during the most recently completed annual update (see post-effective amendment filing on November 27, 2009, for Nuveen Managed Accounts Portfolios Trust, SEC Accession No. 0001193125-09-243275):
5
“In addition, the Portfolio may invest a substantial portion of its assets in mortgage-backed securities, including U.S. agency mortgage-backed securities and commercial mortgage-backed securities.”
In addition, the risk disclosure discussing the risk related to mortgage-backed securities has been revised to indicate that a substantial portion of the fund’s assets may be invested in such securities.
| 9) | Comment: In the semi-annual report dated March 31, 2009, for Nuveen High Yield Bond Fund, the Statement of Operations shows a $9.4 million loss from an interest rate swap. When we reviewed the prospectus for that fund, we did not see the expected high level of disclosure about the risks associated with the fund’s significant exposure to derivatives in general and specifically to interest rate swaps. Please explain how you intend to enhance the prospectus disclosure about the fund’s use of derivatives and the risks associated therewith, or alternatively explain why such enhancements to the existing disclosure is not necessary. |
Response: Disclosure regarding the fund’s use of derivatives and the risks associated therewith was enhanced during the fund’s most recently completed annual update (see post-effective amendment filing on February 1, 2010, for Nuveen Investment Trust III, SEC Accession No. 0001193125-10-017408). The two paragraphs below appear in the fund’s summary prospectus dated January 30, 2010, and are marked to show changes from the prior year’s prospectus dated January 30, 2009:
“In an effort to hedge risk, enhance returns, or as a substitute for a position in the underlying asset, the fund also may invest in futures, options, interest rate or total return swaps, credit derivatives or otherfixed incomederivative instruments.In doing so, the fund may, in certain circumstances, invest a substantial portion of its assets in such derivative instruments.”
“The fund may, in certain circumstances, invest a substantial portion of its assets in derivative instruments, including interest rate swaps. The use of derivatives can lead to losses because of adverse movements in the price or value of the underlying asset, index or rate, which may be magnified by certain features of the derivatives. These risks are heightened when the fund’s management team uses derivatives to enhance a fund’s return or as a substitute for a position or security, rather than solely to hedge (or offset) the risk of a position or security held byathe fund.In doing so, the fund is effectively leveraging its investments, which could result in exaggerated changes in the net asset value of the fund’s shares and can result in losses that exceed the amount originally invested.”
| 10) | Comment:The expense ratio disclosure for the leveraged Nuveen closed-end funds as it appears on the “printable fact sheet” for each such fund on the Nuveen.com website shows expense ratios both as a percentage of the assets attributable to common shares, and also as a percentage of the total fund assets. For example, the fact sheet for Nuveen Insured Premium Income Municipal Fund 2 (NPX) showed an expense ratio with respect to “Common Shares” as 1.83%, and also an expense ratio with respect to “Total Fund Assets” of 1.24%. It is the SEC staff’s position that the only permissible expense ratio for a leveraged closed-end fund to use under generally accepted accounting principles (“GAAP”) accounting rules is the ratio stated as a percentage of common share net assets, and that any ratio stated as a percentage of total fund assets would be inherently misleading because common shareholders pay the former, higher figure, and not the latter, lower figure. Please remove the lower expense figure – the one that is stated as a percentage of total fund assets – from those fact sheets. |
6
Response: We agree that GAAP requires that all expense ratios for leverage closed-end funds included in the financial statements contained in shareholder reports be stated as a percentage of common share net assets, and not as a percentage of total fund assets. However, we also believe that supplemental expense ratios (such as those calculated as a percentage of total fund assets, including the assets attributable to senior equity like preferred shares), clearly described, can provide investors and other readers with important insights into the expense levels experienced by common share investors. Our view is based primarily on the fact that an expense ratio is not used by common share investors merely to determine how much expense they are paying as common shareholders, but it is also used as a means of measuring and comparing funds’ “expense efficiency.” Observe that an unleveraged closed-end fund otherwise identical to the leveraged NPX would show a GAAP expense ratio of 1.24%, while NPX shows a GAAP expense ratio of 1.83%. An unsophisticated investor would think that the unleveraged fund was significantly more “expense efficient” than NPX, when in fact the two funds “as funds” are exactly the same, with the different GAAP expense ratio being due to all of NPX’s expenses being “attributed” to the common shareholders and none to the preferred shareholders. The supplemental expense ratio expressed as a percentage of total fund assets (instead of common share net assets) provides that investor with the ability to compare the “expense efficiency” of a leveraged fund to an unleveraged fund, and two leveraged funds with different leverage levels, on an apples-to-apples basis, and gain a deeper understanding of the leveraged fund’s expenses.
| 11) | Comment:In the industry tabular disclosures within shareholder reports, consider whether “U.S. Guaranteed” should be presented as an industry for reporting purposes. |
Response: Such tabular disclosures for municipal closed-end and open-end shareholder reports are now titled “Portfolio Composition” instead of “Industries.”
| 12) | Comment:In the Financial Highlights section of the annual and semi-annual reports for at least certain Nuveen open-end funds (e.g., Nuveen High Yield Municipal Bond Fund), the funds show a multitude of expense ratios: for example, a given fund will show its total expense ratio (A) before any credits or reimbursements (both including and excluding interest expenses associated with the treatment of the interest expense required by Accounting Standards Codification (“ASC”) 860 Transfers and Servicing (“ASC 860”) 860-10-40-5, previously Financial Accounting Statement 140 (FAS 140) issued in 2007 by the Financial Accounting Standards Board (FASB,) of certain “self-deposited” inverse floating rate municipal obligations); (B) after expense reimbursements from the adviser (again, both including and excluding interest expenses associated with self-deposited inverse floaters); and (C) after both (i) expense reimbursements from the adviser and (ii) custodian credits that a fund may receive from its custodian as a result of having occasionally maintained cash balances with the custodian overnight for the custodian to invest for its own account (again, both including and excluding interest expenses associated with self-deposited inverse floaters). Thus, there are six different expense ratios for the same fund. Please reduce the number of different expense ratios shown in the Financial Highlights tables to only those that are necessary for the investors to understand the expenses they are paying. |
7
Response: We agree that the number of expense ratios shown in the Financial Highlights for those funds is too many, and we have begun reducing the number of such ratios included in annual and semi-annual reports to the following: Ratios of Expenses to Average Net Assets Before Reimbursement (including and excluding interest for self-deposited inverse floaters, where applicable) and Ratios of Expenses to Average Net Assets After Reimbursement (including and excluding interest for self-deposited inverse floaters, where applicable).
| 13) | Comment:What is the current status and timing of the Nuveen closed-end Florida fund mergers, and when does Nuveen feel shareholders of those funds need to be updated (e.g., new solicitation)? |
Response: On October 16, 2009, the Florida funds merged as follows:
| • | Nuveen Florida Investment Quality Municipal Fund (NQF) and Nuveen Florida Quality Income Municipal Fund (NUF) merged into Nuveen Premium Income Municipal Fund 2, Inc. (NPM); |
| • | Nuveen Insured Florida Premium Income Municipal Fund (NFL) merged into Nuveen Insured Municipal Opportunity Fund, Inc. (NIO); and |
| • | Nuveen Insured Florida Tax-Free Advantage Municipal Fund (NWF) merged into Nuveen Insured Tax-Free Advantage Municipal Fund (NEA). |
With respect to the funds covered by this examination as detailed in Appendix A, each fund makes the following representations:
| • | The fund is responsible for the adequacy and accuracy of the disclosure in the filings; |
| • | Staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filing; and |
| • | The fund may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Sincerely,
Stephen D. Foy
Vice President and Funds’ Controller
8
Appendix A
| CIK | File No. | Name | Symbol | |||||
| 1 | 0001087783 | 811-09459 | NUVEEN ARIZONA DIVIDEND ADVANTAGE MUNI FUND | NFZ | ||||
| 2 | 0001161069 | 811-10553 | NUVEEN ARIZONA DIVIDEND ADVANTAGE MUNI FUND 2 | NKR | ||||
| 3 | 0001177212 | 811-21157 | NUVEEN ARIZONA DIVIDEND ADVANTAGE MUNI FUND 3 | NXE | ||||
| 4 | 0000892992 | 811-07278 | NUVEEN ARIZONA PREMIUM INCOME MUNI FUND, INC. | NAZ | ||||
| 5 | 0000879826 | 811-06425 | NUVEEN CA QUALITY INCOME MUNI FUND, INC. | NUC | ||||
| 6 | 0000862313 | 811-06081 | NUVEEN CAL MUNI MARKET OPPORTUNITY FUND, INC. | NCO | ||||
| 7 | 0001074952 | 811-09161 | NUVEEN CALIFORNIA DIVIDEND ADVANTAGE MUNICIPAL FUND | NAC | ||||
| 8 | 0001127706 | 811-10197 | NUVEEN CALIFORNIA DIVIDEND ADVANTAGE MUNICIPAL FUND 2 | NVX | ||||
| 9 | 0001137888 | 811-10347 | NUVEEN CALIFORNIA DIVIDEND ADVANTAGE MUNICIPAL FUND 3 | NZH | ||||
| 10 | 0000868440 | 811-06177 | NUVEEN CALIFORNIA INV. QUALITY MUNI.FUND,INC. | NQC | ||||
| 11 | 0000818851 | 811-05235 | NUVEEN CALIFORNIA MUNICIPAL VALUE FUND, INC. | NCA | ||||
| 12 | 0001454979 | 811-22272 | NUVEEN CALIFORNIA MUNICIPAL VALUE FUND 2 | NCB | ||||
| 13 | 0000856227 | 811-05930 | NUVEEN CALIFORNIA PERF PLUS MUNI FUND, INC. | NCP | ||||
| 14 | 0000905000 | 811-07720 | NUVEEN CALIFORNIA PREMIUM INCOME MUNICIPAL FUND | NCU | ||||
| 15 | 0000874142 | 811-06294 | NUVEEN CALIFORNIA SELECT QUALITY MUN FUND,INC | NVC | ||||
| 16 | 0000885732 | 811-06623 | NUVEEN CALIFORNIA SELECT TAX-FREE INCOME PORTFOLIO | NXC | ||||
| 17 | 0001090118 | 811-09465 | NUVEEN CONNECTICUT DIVIDEND ADVTAGE MUNI FUND | NFC | ||||
| 18 | 0001166572 | 811-21033 | NUVEEN CONNECTICUT DIVIDEND ADVAN MUNI FUND 2 | NGK | ||||
| 19 | 0001177218 | 811-21154 | NUVEEN CONNECTICUT DIVIDEND ADVANTAGE MUNICIPAL FUND 3 | NGO | ||||
| 20 | 0001424452 | 811-22176 | NUVEEN CONNECTICUT MUNICIPAL INCOME OPPORTUNITY FUND | |||||
| 21 | 0000899752 | 811-07606 | NUVEEN CONNECTICUT PREMIUM INCOME MUNI FUND | NTC | ||||
| 22 | 0001385763 | 811-22003 | NUVEEN CORE EQUITY ALPHA FUND | JCE | ||||
| 23 | 0001412349 | 811-22168 | NUVEEN CREDIT STRATEGIES FUND | |||||
| 24 | 0001255821 | 811-21407 | NUVEEN DIVERSIFIED DIVIDEND AND INCOME FUND | JDD | ||||
| 25 | 0001083839 | 811-09297 | NUVEEN DIVIDEND ADVANTAGE MUNICIPAL FUND | NAD | ||||
| 26 | 0001131062 | 811-10255 | NUVEEN DIVIDEND ADVANTAGE MUNICIPAL FUND 2 | NXZ | ||||
| 27 | 0001137887 | 811-10345 | NUVEEN DIVIDEND ADVANTAGE MUNICIPAL FUND 3 | NZF | ||||
| 28 | 0001338561 | 811-21809 | NUVEEN EQUITY PREMIUM & GROWTH FUND | JPG | ||||
| 29 | 0001320492 | 811-21731 | NUVEEN EQUITY PREMIUM ADVANTAGE FUND | JLA | ||||
| 30 | 0001298699 | 811-21619 | NUVEEN EQUITY PREMIUM INCOME FUND | JPZ | ||||
| 31 | 0001308658 | 811-21674 | NUVEEN EQUITY PREMIUM OPPORTUNITY FUND | JSN | ||||
| 32 | 0000870779 | 811-06266 | NUVEEN FL INVESTMENT QUALITY MUNI FUND INC. | NQF | ||||
| 33 | 0001276533 | 811-21494 | NUVEEN FLOATING RATE INCOME FUND | JFR | ||||
| 34 | 0001289213 | 811-21579 | NUVEEN FLOATING RATE INCOME OPPORTUNITY FUND | JRO | ||||
| 35 | 0000878180 | 811-06382 | NUVEEN FLORIDA QUALITY INCOME MUNI FUND INC. | NUF | ||||
| 36 | 0001177219 | 811-21152 | NUVEEN GEORGIA DIVIDEND ADVANTAGE MUNI FUND 2 | NKG | ||||
| 37 | 0001097668 | 811-10351 | NUVEEN GEORGIA DIVIDEND ADVATAGE MUNI FUND | NZX | ||||
| 38 | 0000899758 | 811-07614 | NUVEEN GEORGIA PREMIUM INCOME MUNICIPAL FUND | NPG | ||||
| 39 | 0001359816 | 811-21893 | NUVEEN GLOBAL GOVERNMENT EHNAHCED INCOME FUND | JGG | ||||
| 40 | 0001363421 | 811-21903 | NUVEEN GLOBAL VALUE OPPORTUNITIES FUND | JGV | ||||
| 41 | 0000897422 | 811-07492 | NUVEEN INS CA PREMIUM INCOME MUNI FUND 2, INC | NCL | ||||
| 42 | 0001090117 | 811-09449 | NUVEEN INS CALIFORNIA DIV ADVANTAGE MUNI FUND | NKL | ||||
| 43 | 0000885711 | 811-06620 | NUVEEN INSURED CAL PREM INC MUNI FUND, INC. | NPC | ||||
| 44 | 0001195738 | 811-21212 | NUVEEN INSURED CALIFORNIA TAX-FREE ADVANTAGE MUNICIPAL FUND | NKX | ||||
| 45 | 0001090116 | 811-09475 | NUVEEN INSURED DIVIDEND ADVANTAGE MUNI FUND | NVG | ||||
| 46 | 0000890893 | 811-07120 | NUVEEN INSURED FLORIDA PREMIUM INC. MUNI FUND | NFL | ||||
| 47 | 0001196362 | 811-21215 | NUVEEN INSURED FLORIDA TAX-FREE ADVANTAGE MUNICIPAL FUND | NWF | ||||
| 48 | 0001196366 | 811-21216 | NUVEEN INSURED MASSACHUSETTS TAX-FREE ADVANTAGE MUNICIPAL FUND | NGX | ||||
| 49 | 0000878242 | 811-06379 | NUVEEN INSURED MUNI OPPORTUNITY FUND, INC. | NIO | ||||
| 50 | 0001090123 | 811-09473 | NUVEEN INSURED NEW YORK DIVIDEND ADVANTAGE MUNICIPAL FUND | NKO | ||||
| 51 | 0000885712 | 811-06619 | NUVEEN INSURED NEW YORK PREMIUM INCOME MUNICIPAL FUND | NNF | ||||
| 52 | 0001195739 | 811-21211 | NUVEEN INSURED NEW YORK TAX-FREE ADVANTAGE MUNICIPAL FUND | NRK | ||||
9
Appendix A
| CIK | File No. | Name | Symbol | |||||
| 53 | 0000906959 | 811-07792 | NUVEEN INSURED PREMIUM INCOME MUNI FUND 2 | NPX | ||||
| 54 | 0000869405 | 811-06206 | NUVEEN INSURED QUALITY MUNICIPAL FUND, INC. | NQI | ||||
| 55 | 0001195737 | 811-21213 | NUVEEN INSURED TAX-FREE ADVANTAGE MUNICIPAL FUND | NEA | ||||
| 56 | 0000862716 | 811-06091 | NUVEEN INVESTMENT QUALITY MUNICIPAL FUND,INC. | NQM | ||||
| 57 | 0001013881 | 811-07619 | NUVEEN NWQ LARGE-CAP VALUE FUND | |||||
| 58 | 0001013881 | 811-07619 | NUVEEN NWQ MULTI-CAP VALUE FUND | |||||
| 59 | 0001013881 | 811-07619 | NUVEEN NWQ SMALL-CAP VALUE FUND | |||||
| 60 | 0001013881 | 811-07619 | NUVEEN TRADEWINDS VALUE OPPORTUNITIES FUND | |||||
| 61 | 0001013881 | 811-07619 | NUVEEN MULTI-MANAGER LARGE-CAP VALUE FUND | |||||
| 62 | 0001013881 | 811-07619 | NUVEEN MODERATE ALLOCATION FUND | |||||
| 63 | 0001013881 | 811-07619 | NUVEEN CONSERVATIVE ALLOCATION FUND | |||||
| 64 | 0001013881 | 811-07619 | NUVEEN GROWTH ALLOCATION FUND | |||||
| 65 | 0001013881 | 811-07619 | NUVEEN NWQ SMALL/MID-CAP VALUE FUND | |||||
| 66 | 0001013881 | 811-07619 | NUVEEN ENHANCED CORE EQUITY FUND | |||||
| 67 | 0001013881 | 811-07619 | NUVEEN NWQ EQUITY INCOME FUND | |||||
| 68 | 0001013881 | 811-07619 | NUVEEN U.S. EQUITY COMPLETENESS FUND | |||||
| 69 | 0001013881 | 811-07619 | NUVEEN ENHANCED CORE EQUITY PLUS FUND | |||||
| 70 | 0001013881 | 811-07619 | NUVEEN ENHANCED MID-CAP FUND | |||||
| 71 | 0001041673 | 811-08333 | NUVEEN RITTENHOUSE GROWTH FUND | |||||
| 72 | 0001041673 | 811-08333 | NUVEEN RITTENHOUSE STRATEGIC GROWTH FUND | |||||
| 73 | 0001041673 | 811-08333 | NUVEEN RITTENHOUSE MID-CAP GROWTH FUND | |||||
| 74 | 0001041673 | 811-08333 | NUVEEN TRADEWINDS INTERNATIONAL VALUE FUND | |||||
| 75 | 0001041673 | 811-08333 | NUVEEN TRADEWINDS GLOBAL ALL-CAP FUND | |||||
| 76 | 0001041673 | 811-08333 | NUVEEN SYMPHONY ALL-CAP CORE FUND | |||||
| 77 | 0001041673 | 811-08333 | NUVEEN SYMPHONY SMALL-MID CAP CORE FUND | |||||
| 78 | 0001041673 | 811-08333 | NUVEEN SYMPHONY OPTIMIZED ALPHA FUND | |||||
| 79 | 0001041673 | 811-08333 | NUVEEN SYMPHONY INTERNATIONAL EQUITY FUND | |||||
| 80 | 0001041673 | 811-08333 | NUVEEN SYMPHONY LARGE-CAP GROWTH FUND | |||||
| 81 | 0001041673 | 811-08333 | NUVEEN TRADEWINDS GLOBAL RESOURCES FUND | |||||
| 82 | 0001041673 | 811-08333 | NUVEEN TRADEWINDS JAPAN FUND | |||||
| 83 | 0001041673 | 811-08333 | NUVEEN TRADEWINDS EMERGING MARKETS FUND | |||||
| 84 | 0001041673 | 811-08333 | NUVEEN TRADEWINDS GLOBAL ALL-CAP PLUS FUND | |||||
| 85 | 0001041673 | 811-08333 | NUVEEN SYMPHONY LARGE-CAP VALUE FUND | |||||
| 86 | 0001041673 | 811-08333 | NUVEEN SYMPHONY MID-CAP CORE FUND | |||||
| 87 | 0001041673 | 811-08333 | NUVEEN SANTA BARBARA DIVIDEND GROWTH FUND | |||||
| 88 | 0001041673 | 811-08333 | NUVEEN SANTA BARBARA GROWTH FUND | |||||
| 89 | 0001041673 | 811-08333 | NUVEEN SANTA BARBARA GROWTH OPPORTUNITIES FUND | |||||
| 90 | 0001041673 | 811-08333 | NUVEEN SANTA BARBARA INTERNATIONAL EQUITY FUND | |||||
| 91 | 0001041673 | 811-08333 | NUVEEN SANTA BARBARA GLOBAL EQUITY FUND | |||||
| 92 | 0001041673 | 811-08333 | NUVEEN WINSLOW LARGE-CAP GROWTH FUND | |||||
| 93 | 0001041673 | 811-08333 | NUVEEN SANTA BARBARA GROWTH PLUS FUND | |||||
| 94 | 0001041673 | 811-08333 | NUVEEN SANTA BARBARA ECOLOGIC EQUITY FUND | |||||
| 95 | 0001071336 | 811-09037 | NUVEEN MULTI-STRATEGY INCOME FUND | |||||
| 96 | 0001071336 | 811-09037 | NUVEEN HIGH YIELD BOND FUND | |||||
| 97 | 0001071336 | 811-09037 | NUVEEN SHORT DURATION BOND FUND | |||||
| 98 | 0001380786 | 811-21979 | NUVEEN PREFERRED SECURITIES FUND | |||||
| 99 | 0001390204 | 811-22023 | MUNICIPAL TOTAL RETURN MANAGED ACCOUNTS PORTFOLIO | |||||
| 100 | 0001390204 | 811-22023 | INTERNATIONAL INCOME MANAGED ACCOUNTS PORTFOLIO | |||||
| 101 | 0001390204 | 811-22023 | ENHANCED MULTI-STRATEGY INCOME MANAGED ACCOUNTS PORTFOLIO | |||||
| 102 | 0001090119 | 811-09471 | NUVEEN MARYLAND DIVIDEND ADVATAGE MUNI FUND | NFM | ||||
| 103 | 0001137885 | 811-10349 | NUVEEN MARYLAND DIVIDEND ADVATAGE MUNI FUND 2 | NZR | ||||
| 104 | 0001177214 | 811-21153 | NUVEEN MARYLAND DIVIDEND ADVATAGE MUNI FUND 3 | NWI | ||||
10
Appendix A
| CIK | File No. | Name | Symbol | |||||
| 105 | 0000897424 | 811-07486 | NUVEEN MARYLAND PREMIUM INCOME MUNI FUND | NMY | ||||
| 106 | 0001090120 | 811-09451 | NUVEEN MASSACHUSETTS DIV ADVATAGE MUNI FUND | NMB | ||||
| 107 | 0000897419 | 811-07484 | NUVEEN MASSACHUSETTS PREMIUM INCOME MUNI FUND | NMT | ||||
| 108 | 0001087785 | 811-09453 | NUVEEN MICHIGAN DIVIDEND ADVANTAGE MUNI FUND | NZW | ||||
| 109 | 0000890897 | 811-07116 | NUVEEN MICHIGAN PREMIUM INCOME MUNI FUND, INC | NMP | ||||
| 110 | 0000878198 | 811-06383 | NUVEEN MICHIGAN QUALITY INCOME MUNI FUND, INC | NUM | ||||
| 111 | 0000899782 | 811-07616 | NUVEEN MISSOURI PREMIUM INCOME MUNICIPAL FUND | NOM | ||||
| 112 | 0001400390 | 811-22071 | NUVEEN MULTI-CURRENCY INCOME FUND | |||||
| 113 | 0001390109 | 811-22018 | NUVEEN MULTI-CURRENCY SHORT-TERM GOVERNMENT INCOME FUND | JGT | ||||
| 114 | 0001018972 | 811-07747 | NUVEEN ARIZONA MUNICIPAL BOND FUND | |||||
| 115 | 0001018972 | 811-07747 | NUVEEN COLORADO MUNICIPAL BOND FUND | |||||
| 116 | 0001018972 | 811-07747 | NUVEEN FLORIDA PREFERENCE MUNICIPAL BOND FUND | |||||
| 117 | 0001018972 | 811-07747 | NUVEEN MARYLAND MUNICIPAL BOND FUND | |||||
| 118 | 0001018972 | 811-07747 | NUVEEN NEW MEXICO MUNICIPAL BOND FUND | |||||
| 119 | 0001018972 | 811-07747 | NUVEEN PENNSYLVANIA MUNICIPAL BOND FUND | |||||
| 120 | 0001018972 | 811-07747 | NUVEEN VIRGINIA MUNICIPAL BOND FUND | |||||
| 121 | 0001018975 | 811-07755 | NUVEEN CALIFORNIA HIGH YIELD MUNICIPAL BOND FUND | |||||
| 122 | 0001018975 | 811-07755 | NUVEEN CALIFORNIA INSURED MUNICIPAL BOND FUND | |||||
| 123 | 0001018975 | 811-07755 | NUVEEN CALIFORNIA MUNICIPAL BOND FUND | |||||
| 124 | 0001018975 | 811-07755 | NUVEEN CONNECTICUT MUNICIPAL BOND FUND | |||||
| 125 | 0001018975 | 811-07755 | NUVEEN MASSACHUSETTS INSURED MUNICIPAL BOND FUND | |||||
| 126 | 0001018975 | 811-07755 | NUVEEN MASSACHUSETTS MUNICIPAL BOND FUND | |||||
| 127 | 0001018975 | 811-07755 | NUVEEN NEW JERSEY MUNICIPAL BOND FUND | |||||
| 128 | 0001018975 | 811-07755 | NUVEEN NEW YORK INSURED MUNICIPAL BOND FUND | |||||
| 129 | 0001018975 | 811-07755 | NUVEEN NEW YORK MUNICIPAL BOND FUND | |||||
| 130 | 0001020661 | 811-07943 | NUVEEN GEORGIA MUNICIPAL BOND FUND | |||||
| 131 | 0001020661 | 811-07943 | NUVEEN LOUISIANA MUNICIPAL BOND FUND | |||||
| 132 | 0001020661 | 811-07943 | NUVEEN NORTH CAROLINA MUNI BOND FUND | |||||
| 133 | 0001020661 | 811-07943 | NUVEEN TENNESSEE MUNICIPAL BOND FUND | |||||
| 134 | 0001018973 | 811-07751 | NUVEEN KANSAS MUNICIPAL BOND FUND | |||||
| 135 | 0001018973 | 811-07751 | NUVEEN KENTUCKY MUNICIPAL BOND FUND | |||||
| 136 | 0001018973 | 811-07751 | NUVEEN MICHIGAN MUNICIPAL BOND FUND | |||||
| 137 | 0001018973 | 811-07751 | NUVEEN MISSOURI MUNICIPAL BOND FUND | |||||
| 138 | 0001018973 | 811-07751 | NUVEEN OHIO MUNICIPAL BOND FUND | |||||
| 139 | 0001018973 | 811-07751 | NUVEEN WISCONSIN MUNICIPAL BOND FUND | |||||
| 140 | 0000857361 | 811-05957 | NUVEEN MUNICIPAL ADVANTAGE FUND | NMA | ||||
| 141 | 0001266585 | 811-21449 | NUVEEN MUNICIPAL HIGH INCOME OPPORTUNITY FUND | NMZ | ||||
| 142 | 0001424214 | 811-22173 | NUVEEN MUNICIPAL HIGH INCOME OPPORTUNITY FUND 3 | |||||
| 143 | 0001412495 | 811-22123 | NUVEEN MUNICIPAL HIGH INCOME OPPORTUNITY FUND 2 | NMD | ||||
| 144 | 0000830271 | 811-05488 | NUVEEN MUNICIPAL INCOME FUND | NMI | ||||
| 145 | 0000860188 | 811-06040 | NUVEEN MUNICIPAL MARKET OPPORTUNITY FUND, INC | NMO | ||||
| 146 | 0001020660 | 811-07873 | NUVEEN ALL-AMERICAN MUNICIPAL BOND FUND | |||||
| 147 | 0001020660 | 811-07873 | NUVEEN HIGH YIELD MUNICIPAL BOND FUND | |||||
| 148 | 0001020660 | 811-07873 | NUVEEN INSURED MUNICIPAL BOND FUND | |||||
| 149 | 0001020660 | 811-07873 | NUVEEN INTERMEDIATE DURATION MUNICIPAL BOND FUND | |||||
| 150 | 0001020660 | 811-07873 | NUVEEN LIMITED TERM MUNICIPAL BOND FUND | |||||
| 151 | 0001450445 | 811-22253 | NUVEEN MUNICIPAL VALUE FUND 2 | |||||
| 152 | 0000812801 | 811-05120 | NUVEEN MUNICIPAL VALUE FUND,INC. | NUV | ||||
| 153 | 0001161070 | 811-10551 | NUVEEN NEW JERSEY DIV ADVANTAGE MUNI FD 2 | NUJ | ||||
| 154 | 0001087786 | 811-09455 | NUVEEN NEW JERSEY DIVIDEND ADVANTAGE MUNI FD | NXJ | ||||
| 155 | 0001454980 | 811-22274 | NUVEEN NEW JERSEY MUNICIPAL VALUE FUND | NJV | ||||
| 156 | 0000890898 | 811-07118 | NUVEEN NEW JERSEY PREM INCOME MUNI FUND, INC. | NNJ | ||||
11
Appendix A
| CIK | File No. | Name | Symbol | |||||
| 157 | 0001074769 | 811-09135 | NUVEEN NEW YORK DIVIDEND ADVANTAGE MUNICIPAL FUND | NAN | ||||
| 158 | 0001131063 | 811-10253 | NUVEEN NEW YORK DIVIDEND ADVANTAGE MUNICIPAL FUND 2 | NXK | ||||
| 159 | 0000868449 | 811-06178 | NUVEEN NEW YORK INVESTMENT QUALITY MUNICIPAL FUND | NQN | ||||
| 160 | 0000818850 | 811-05238 | NUVEEN NEW YORK MUNICIPAL VALUE FUND, INC. | NNY | ||||
| 161 | 0001454981 | 811-22271 | NUVEEN NEW YORK MUNICIPAL VALUE FUND 2 | NYV | ||||
| 162 | 0000879819 | 811-06424 | NUVEEN NEW YORK QUALITY INCOME MUNICIPAL FUND | NUN | ||||
| 163 | 0000874143 | 811-06295 | NUVEEN NEW YORK SELECT QUALITY MUNICIPAL FUND | NVN | ||||
| 164 | 0000885731 | 811-06624 | NUVEEN NEW YORK SELECT TAX-FREE INCOME PORT | NXN | ||||
| 165 | 0000870778 | 811-06264 | NUVEEN NJ INVESTMENT QUALITY MUNI. FUND INC. | NQJ | ||||
| 166 | 0001090121 | 811-09461 | NUVEEN NORTH CAROLINA DIV. ADV. MUNI FUND | NRB | ||||
| 167 | 0001158730 | 811-10525 | NUVEEN NORTH CAROLINA DIV. ADV. MUNI FUND 2 | NNO | ||||
| 168 | 0001177216 | 811-21158 | NUVEEN NORTH CAROLINA DIV. ADV. MUNI FUND 3 | NII | ||||
| 169 | 0000899761 | 811-07608 | NUVEEN NORTH CAROLINA PREMIUM INC MUNI FUND | NNC | ||||
| 170 | 0000856226 | 811-05931 | NUVEEN NY PERFORMANCE PLUS MUNI FUND, INC. | NNP | ||||
| 171 | 0001165383 | 811-10637 | NUVEEN OHIO DIVIDEND ADVATAGE MUNI FUND 3 | NVJ | ||||
| 172 | 0001087788 | 811-09463 | NUVEEN OHIO DIVIDEND ADVATAGE MUNICIPAL FUND | NXI | ||||
| 173 | 0001145728 | 811-10445 | NUVEEN OHIO DIVIDEND ADVATAGE MUNICIPAL FUND 2 | NBJ | ||||
| 174 | 0000878200 | 811-06385 | NUVEEN OHIO QUALITY INCOME MUNI FUND, INC. | NUO | ||||
| 175 | 0000870780 | 811-06265 | NUVEEN PENN INVESTMENT QUALITY MUNI FUND INC. | NQP | ||||
| 176 | 0000897427 | 811-07482 | NUVEEN PENNSYLVANIA PREMIUM INCOME MUNI FD 2 | NPY | ||||
| 177 | 0001158729 | 811-10549 | NUVEEN PENNSYLVANIA DIV ADVATAGE MUNI FD 2 | NVY | ||||
| 178 | 0001087787 | 811-09457 | NUVEEN PENNSYLVANIA DIVIDEND ADVANTAGE MUNICIPAL FUIND | NXM | ||||
| 179 | 0001454978 | 811-22273 | NUVEEN PENNSYLVANIA MUNICIPAL VALUE FUND | NPN | ||||
| 180 | 0000849998 | 811-05809 | NUVEEN PERFORMANCE PLUS MUNICIPAL FUND, INC. | NPP | ||||
| 181 | 0001216583 | 811-21293 | NUVEEN MULTI-STRATEGY INCOME AND GROWTH FUND | JPC | ||||
| 182 | 0001227476 | 811-21333 | NUVEEN MULTI-STRATEGY INCOME AND GROWTH FUND 2 | JQC | ||||
| 183 | 0000880843 | 811-06457 | NUVEEN PREMIER INSURED MUNI INCOME FUND, INC. | NIF | ||||
| 184 | 0000880845 | 811-06456 | NUVEEN PREMIER MUNICIPAL INCOME FUND, INC. | NPF | ||||
| 185 | 0000896061 | 811-07432 | NUVEEN PREMIUM INCOME MUNI FUND 4, INC. | NPT | ||||
| 186 | 0000885734 | 811-06621 | NUVEEN PREMIUM INCOME MUNICIPAL FUND 2, INC. | NPM | ||||
| 187 | 0000833251 | 811-05570 | NUVEEN PREMIUM INCOME MUNICIPAL FUND, INC. | NPI | ||||
| 188 | 0000874506 | 811-06303 | NUVEEN QUALITY INCOME MUNICIPAL FUND,INC. | NQU | ||||
| 189 | 0001172168 | 811-21082 | NUVEEN QUALTITY PREFERRED INCOME FUND | JTP | ||||
| 190 | 0001176433 | 811-21137 | NUVEEN QUALTITY PREFERRED INCOME FUND 2 | JPS | ||||
| 191 | 0001200446 | 811-21242 | NUVEEN QUALTITY PREFERRED INCOME FUND 3 | JHP | ||||
| 192 | 0001158289 | 811-10491 | NUVEEN REAL ESTATE INCOME FUND | JRS | ||||
| 193 | 0000890119 | 811-07056 | NUVEEN SELECT MATURITIES MUNICIPAL FUND | NIM | ||||
| 194 | 0000872064 | 811-06240 | NUVEEN SELECT QUALITY MUNICIPAL FUND, INC. | NQS | ||||
| 195 | 0000883618 | 811-06548 | NUVEEN SELECT TAX-FREE INCOME PORTFOLIO | NXP | ||||
| 196 | 0000885733 | 811-06622 | NUVEEN SELECT TAX-FREE INCOME PORTFOLIO 2 | NXQ | ||||
| 197 | 0000888411 | 811-06693 | NUVEEN SELECT TAX-FREE INCOME PORTFOLIO 3 | NXR | ||||
| 198 | 0001093428 | 811-09571 | NUVEEN SENIOR INCOME FUND | NSL | ||||
| 199 | 0001209540 | 811-21264 | NUVEEN SYMPHONY MARKET NEURTAL FUND | |||||
| 200 | 0001313259 | 811-21705 | NUVEEN TAX-ADVANTAGED FLOATING RATE FUND | JFP | ||||
| 201 | 0001265708 | 811-21471 | NUVEEN TAX-ADVANTAGED TOTAL RETURN STARTEGY FUND | JTA | ||||
| 202 | 0001397173 | 811-22058 | NUVEEN TAX-ADVANTAGED DIVIDEND GROWTH FUND | JTD | ||||
| 203 | 0000878201 | 811-06384 | NUVEEN TEXAS QUALITY INCOME MUNI FUND | NTX | ||||
| 204 | 0001090122 | 811-09469 | NUVEEN VIRGINIA DIVIDEND ADVATAGE MUNI FUND | NGB | ||||
| 205 | 0001158728 | 811-10523 | NUVEEN VIRGINIA DIVIDEND ADVATAGE MUNI FUND 2 | NNB | ||||
| 206 | 0000897421 | 811-07490 | NUVEEN VIRGINIA PREMIUM INCOME MUNI FUND | NPV | ||||
12