SECTION 16(a) BENEFICIAL OWNERSHIP REPORTING
COMPLIANCE

Section 16(a) of the Exchange Act and Section 30(h) of
the 1940 Act, as applied to the Fund, requires the
Fund's officers and directors, certain officers and
directors of the investment advisers, affiliates of the
investment advisers and persons who own more than
ten percent of a registered class of the Fund's equity
securities, to file reports of ownership and changes in
ownership with the Commission and the NYSE.

Based solely upon the Fund's review of the copies of
such forms filed on EDGAR or written representations
from the trustees and officers of the Fund and the
filings by the beneficial holders of greater than 10% of a
Fund's shares, to the knowledge of the Fund, for the
fiscal year ended October 31, 2010, the filings required
by the Exchange Act were made on a timely basis,
except that Craig MacDonald and Archie Struthers each
filed a late Form 3 filing following their respective
appointments as directors of the fund's sub-adviser,
and Michelle Lopez filed a late Form 3 filing following
her appointment as a director of the fund's investment
adviser.