SUB-ITEM 77D:  Policies with respect to security investments.

(g) The change in the percentage of total assets that the
IVA International Fund intends to invest, under normal market
conditions, in equity and debt securities issued by foreign
companies and governments is incorporated by reference from
Post-Effective Amendment No. 2 to the Registration Statement
as filed with the Securities and Exchange Commission on
December 18, 2009.