N-CSR 1 c48838nvcsr.htm FORM N-CSR N-CSR
 
 
UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM N-CSR
CERTIFIED SHAREHOLDER REPORT OF REGISTERED
MANAGEMENT INVESTMENT COMPANIES
Investment Company Act file number 811-01570
Van Kampen Comstock Fund
 
(Exact name of registrant as specified in charter)
522 Fifth Avenue, New York, New York 10036
 
(Address of principal executive offices)     (Zip code)
Edward C. Wood III
522 Fifth Avenue, New York, New York 10036
 
(Name and address of agent for service)
Registrant’s telephone number, including area code: 212-762-4000
Date of fiscal year end: 12/31
Date of reporting period: 12/31/08
 
 

 


 

Item 1. Report to Shareholders.
 
The Fund’s annual report transmitted to shareholders pursuant to Rule 30e-1
under the Investment Company Act of 1940 is as follows:
 
Welcome, Shareholder
 
 
In this report, you’ll learn about how your investment in Van Kampen Comstock Fund performed during the annual period. The portfolio management team will provide an overview of the market conditions and discuss some of the factors that affected investment performance during the reporting period. In addition, this report includes the fund’s financial statements and a list of fund investments as of December 31, 2008.
 
 
This material must be preceded or accompanied by a Class A, B, and C share or Class I and R share prospectus for the fund being offered. The prospectuses contain information about the fund, including the investment objectives, risks, charges and expenses. To obtain an additional prospectus, contact your financial advisor or download one at vankampen.com. Please read the prospectus carefully before investing.
 
Market forecasts provided in this report may not necessarily come to pass. There is no assurance that a mutual fund will achieve its investment objective. Funds are subject to market risk, which is the possibility that the market values of securities owned by the fund will decline and that the value of the fund shares may therefore be less than what you paid for them. Accordingly, you can lose money investing in this fund.
 
             
NOT FDIC INSURED
    OFFER NO BANK GUARANTEE     MAY LOSE VALUE
NOT INSURED BY ANY FEDERAL GOVERNMENT AGENCY
    NOT A DEPOSIT
             


 

Performance Summary as of 12/31/08
 
Performance of a $10,000 investment
 
This chart compares your fund’s performance to that of the Russell 1000® Value Index and the Standard and Poor’s 500® Index from 12/31/98 through 12/31/08. Class A shares, adjusted for sales charges.
 
(LINE GRAPH)
 
                                                                                           
      A Shares
    B Shares
    C Shares
    R Shares
    I Shares
      since 10/07/68     since 10/19/92     since 10/26/93     since 10/01/02     since 10/29/04
          w/max
        w/max
        w/max
           
          5.75%
        5.00%
        1.00%
           
Average Annual
    w/o sales
  sales
    w/o sales
  sales
    w/o sales
  sales
    w/o sales
    w/o sales
Total Returns     charges   charge     charges   charge     charges   charge     charges     charges
                                                                                           
Since Inception       10.31 %       10.15 %         7.82 %       7.82 %         7.07 %       7.07 %         3.62 %         –4.29 %  
                                                                                           
10-year       2.25         1.65           1.64         1.64           1.49         1.49                        
                                                                                           
5-year       –2.21         –3.36           –2.77         –3.00           –2.93         –2.93           –2.46              
                                                                                           
1-year       –35.89         –39.59           –35.93         –39.03           –36.35         –36.97           –36.09           –35.73    
 
 
Performance data quoted represents past performance, which is no guarantee of future results, and current performance may be lower or higher than the figures shown. For the most recent month-end performance figures, please visit vankampen.com or speak with your financial advisor. Investment returns and principal value will fluctuate and fund shares, when redeemed, may be worth more or less than their original cost.
 
The returns shown in this report do not reflect the deduction of taxes that a shareholder would pay on fund distributions or the redemption of fund shares. Performance of share classes will vary due to differences in sales charges and expenses. Average annual total return with sales charges includes payment of the maximum sales charge of 5.75 percent for Class A shares, a contingent deferred sales charge of 5.00 percent for Class B shares (in year one and declining to zero after year five), a contingent deferred sales charge of 1.00 percent for Class C shares in year one and combined Rule 12b-1 fees and service fees of up to 0.25 percent for Class A shares and up to 1.00 percent for Class B and C shares. The since inception and 10-year returns for Class B shares reflect their conversion into Class A shares eight years after purchase. Class R shares are available for purchase by investors through or in tax exempt retirement plans (401(k) plans, 457 plans, defined benefit plans, profit sharing and money purchase pension plans, non-qualified deferred compensation plans, and employer sponsored 403(b) plans). Class R shares are offered without any sales charges on purchases or sales. The combined Rule 12b-1 fees and service fees for Class R shares is up to 0.50 percent. Class I shares are available for purchase exclusively by investors through (i) tax-exempt retirement plans with assets of at least $1 million (including 401(k) plans, 457 plans, employer sponsored 403(b) plans, profit sharing and money purchase plans, defined benefit plans and non-qualified deferred compensation plans), (ii) fee-based investment programs with assets of at least $1 million, (iii) qualified state tuition plan (529 plan) accounts, (iv) institutional clients with assets of at least $1 million and (v) certain Van Kampen investment companies. Class I shares are offered without any sales charges on
 
 
1


 

purchases or sales and do not include combined Rule 12b-1 fees and service fees. Figures shown above assume reinvestment of all dividends and capital gains. Periods of less than one year are not annualized.
 
The Russell 1000® Value Index measures the performance of the large-cap value segment of the U.S. equity universe. It includes those Russell 1000® Index companies with lower price-to-book ratios and lower expected growth values. The Standard & Poor’s 500® Index (S&P 500) measures the performance of the large cap segment of the U.S. equities market, covering approximately 75% of the U.S. equities market. The Index includes 500 leading companies in leading industries of the U.S. economy. The Indexes do not include any expenses, fees or sales charges, which would lower performance. The Indexes are unmanaged and should not be considered an investment. It is not possible to invest directly in an index.
 
 
2


 

Fund Report
For the 12-month period ended December 31, 2008
 
Market Conditions
 
Fear and a major loss of investor confidence drove the stock market to one of its worst years in history. With stock and bond prices in a downward spiral and global recession imminent, risk aversion intensified and investors fled to cash and Treasuries. Stock market volatility registered extreme levels, leaving investors no escape from declining values. In this environment, both value stocks (in which the Fund invests) and growth stocks sustained negative returns, as did all segments of the market capitalization spectrum. Every sector of the market finished the year with double-digit declines.
 
Performance Analysis
 
All share classes of Van Kampen Comstock Fund outperformed the Russell 1000® Value Index (“the Index”) and the S&P 500® Index for the 12 months ended December 31, 2008, assuming no deduction of applicable sales charges.
 
Total returns for the 12-month period ended December 31, 2008
 
                                                                                       
                                  Russell 1000®
         
    Class A     Class B     Class C     Class R     Class I     Value Index     S&P 500® Index    
                                                                                       
      –35.89 %         –35.93 %         –36.35 %         –36.09 %         –35.73 %         –36.85 %         –37.00 %      
 
 
 
The performance for the five share classes varies because each has different expenses. The Fund’s total return figures assume the reinvestment of all distributions, but do not reflect the deduction of any applicable sales charges. Such costs would lower performance. Past performance is no guarantee of future results. See Performance Summary for standardized performance information and index definitions.
 
Relative to the Index, the Fund was bolstered primarily by an overweight in the consumer staples sector, and stock selection and the resulting overweight in the health care sector. Although both consumer staples and health care had negative absolute returns during the period, the sectors sustained smaller declines than other areas of the market, owing to their “defensiveness,” or lower sensitivity to economic conditions. The Fund’s cash position also contributed favorably to relative performance, as it reduced the Fund’s exposure to the market’s decline, whereas the Index holds no cash.
 
The chief detractor from relative performance was the Fund’s significant underweight in energy stocks. Very few energy stocks have looked attractive to us, even with oil prices falling dramatically in recent months, as energy companies for the most part have not yet had to adjust to the less robust economic scenario. The Fund’s minimal exposure to the utilities sector was another area of relative weakness during the period.
 
There is no guarantee that any sectors mentioned will continue to perform as discussed herein or that securities in such sectors will be held by the Fund in the future.
 
 
3


 

         
Top Ten Holdings as of 12/31/08 (Unaudited)
 
Chubb Corp.
    5.1 %
Comcast Corp., Class A
    4.3  
Bristol-Myers Squibb Co.
    3.7  
Verizon Communications, Inc.
    3.6  
Viacom, Inc., Class B
    3.4  
Time Warner, Inc.
    3.1  
International Paper Co.
    3.0  
Wal-Mart Stores, Inc.
    2.8  
Bank of New York Mellon Corp.
    2.7  
General Electric Co.
    2.7  
         
         
Summary of Investments by Industry Classification as of 12/31/08 (Unaudited)
 
Pharmaceuticals
    13.0 %
Property & Casualty Insurance
    8.1  
Movies & Entertainment
    7.7  
Packaged Foods & Meats
    7.5  
Integrated Telecommunication Services
    5.5  
Broadcasting & Cable TV
    5.4  
Other Diversified Financial Services
    4.6  
Computer Hardware
    3.7  
Paper Products
    3.0  
Hypermarkets & Super Centers
    2.8  
Asset Management & Custody Banks
    2.7  
Industrial Conglomerates
    2.7  
Life & Health Insurance
    2.6  
Diversified Banks
    2.6  
Soft Drinks
    2.5  
Internet Software & Services
    2.4  
Integrated Oil & Gas
    1.9  
Health Care Distributors
    1.7  
Home Improvement Retail
    1.6  
Tobacco
    1.5  
Communications Equipment
    1.2  
Diversified Chemicals
    1.1  
Department Stores
    1.1  
Oil & Gas Equipment & Services
    1.1  
Managed Health Care
    1.0  
Drug Retail
    1.0  
Regional Banks
    1.0  
Health Care Equipment
    0.9  
Data Processing & Outsourced Services
    0.8  
Aluminum
    0.8  
Semiconductors
    0.7  
Electrical Components & Equipment
    0.7  
Semiconductor Equipment
    0.6  
Systems Software
    0.6  
Investment Banking & Brokerage
    0.6  
Household Products
    0.3  
Catalog Retail
    0.3  
Electronic Equipment Manufacturers
    0.2  
Airlines
    0.1  
Electronic Manufacturing Services
    0.1  
         
(continued on next page)
 
 
 
4


 

         
Summary of Investments by Industry Classification as of 12/31/08 (Unaudited)
(continued from previous page)
 
Total Long-Term Investments
    97.7 %
Total Repurchase Agreements
    2.4  
         
Total Investments
    100.1  
Liabilities in Excess of Other Assets
    (0.1 )
         
Net Assets
    100.0 %
         
         
 
Subject to change daily. All percentages are as a percentage of net assets. Provided for informational purposes only and should not be deemed as a recommendation to buy or sell the securities mentioned or securities in the industries shown above. Van Kampen is a wholly owned subsidiary of a global securities firm which is engaged in a wide range of financial services including, for example, securities trading and brokerage activities, investment banking, research and analysis, financing and financial advisory services.
 
 
5


 

For More Information About Portfolio Holdings
 
Each Van Kampen fund provides a complete schedule of portfolio holdings in its semiannual and annual reports within 60 days of the end of the fund’s second and fourth fiscal quarters. The semiannual reports and the annual reports are filed electronically with the Securities and Exchange Commission (SEC) on Form N-CSRS and Form N-CSR, respectively. Van Kampen also delivers the semiannual and annual reports to fund shareholders, and makes these reports available on its public Web site, www.vankampen.com. In addition to the semiannual and annual reports that Van Kampen delivers to shareholders and makes available through the Van Kampen public Web site, each fund files a complete schedule of portfolio holdings with the SEC for the fund’s first and third fiscal quarters on Form N-Q. Van Kampen does not deliver the reports for the first and third fiscal quarters to shareholders, nor are the reports posted to the Van Kampen public Web site. You may, however, obtain the Form N-Q filings (as well as the Form N-CSR and N-CSRS filings) by accessing the SEC’s Web site, http://www.sec.gov. You may also review and copy them at the SEC’s Public Reference Room in Washington, DC. Information on the operation of the SEC’s Public Reference Room may be obtained by calling the SEC at (800) SEC-0330. You can also request copies of these materials, upon payment of a duplicating fee, by electronic request at the SEC’s email address (publicinfo@sec.gov) or by writing the Public Reference section of the SEC, Washington, DC 20549-0102.
 
You may obtain copies of a fund’s fiscal quarter filings by contacting Van Kampen Client Relations at (800) 847-2424.
 
 
6


 

Householding Notice
 
To reduce Fund expenses, the Fund attempts to eliminate duplicate mailings to the same address. The Fund delivers a single copy of certain shareholder documents to investors who share an address, even if the accounts are registered under different names. The Fund’s prospectuses and shareholder reports (including annual privacy notices) will be delivered to you in this manner indefinitely unless you instruct us otherwise. You can request multiple copies of these documents by either calling (800) 341-2911 or writing to Van Kampen Investor Services at P.O. Box 219286, Kansas City, MO 64121-9286. Once Investor Services has received your instructions, we will begin sending individual copies for each account within 30 days.
 
Proxy Voting Policy and Procedures and Proxy Voting Record
 
You may obtain a copy of the Fund’s Proxy Voting Policy and Procedures without charge, upon request, by calling toll free (800) 847-2424 or by visiting our Web site at www.vankampen.com. It is also available on the Securities and Exchange Commission’s Web site at http://www.sec.gov.
 
You may obtain information regarding how the Fund voted proxies relating to portfolio securities during the most recent twelve-month period ended June 30 without charge by visiting our Web site at www.vankampen.com. This information is also available on the Securities and Exchange Commission’s Web site at http://www.sec.gov.
 
 
7


 

Expense Example
 
As a shareholder of the Fund, you incur two types of costs: (1) transaction costs, including sales charges (loads) on purchase payments of Class A Shares and contingent deferred sales charges on redemptions of Class B and Class C Shares and (2) ongoing costs, including management fees; distribution and service (12b-1) fees; and other Fund expenses. This example is intended to help you understand your ongoing costs (in dollars) of investing in the Fund and to compare these costs with the ongoing costs of investing in other mutual funds.
 
The example is based on an investment of $1,000 invested at the beginning of the period and held for the entire period 7/1/08 - 12/31/08.
 
Actual Expense
 
The first line of the table below provides information about actual account values and actual expenses. You may use the information in this line, together with the amount you invested, to estimate the expenses that you paid over the period. Simply divide your account value by $1,000 (for example, an $8,600 account value divided by $1,000 = 8.6), then multiply the result by the number in the first line under the heading entitled “Expenses Paid During Period” to estimate the expenses you paid on your account during this period.
 
Hypothetical Example for Comparison Purposes
 
The second line of the table below provides information about hypothetical account values and hypothetical expenses based on the Fund’s actual expense ratio and an assumed rate of return of 5% per year before expenses, which is not the Fund’s actual return. The hypothetical account values and expenses may not be used to estimate the actual ending account balance or expenses you paid for the period. You may use this information to compare the ongoing cost of investing in the Fund and other funds. To do so, compare this 5% hypothetical example with the 5% hypothetical examples that appear in the shareholder reports of the other funds.
 
Please note that the expenses shown in the table are meant to highlight your ongoing costs only and do not reflect any transactional costs, such as sales charges (loads) or contingent deferred sales charges. Therefore, the second line of the table is useful in comparing ongoing costs only, and will not help you determine the relative total costs of owning different funds. In addition, if these transactional costs were included, your cost would have been higher.
 
                         
    Beginning
  Ending
  Expenses Paid
    Account Value   Account Value   During Period*
     
    7/1/08   12/31/08   7/1/08-12/31/08
 
Class A
                       
Actual
  $ 1,000.00     $ 765.51     $ 3.91  
Hypothetical
    1,000.00       1,020.71       4.47  
(5% annual return before expenses)
                       
                         
Class B
                       
Actual
    1,000.00       765.51       3.91  
Hypothetical
    1,000.00       1,020.71       4.47  
(5% annual return before expenses)
                       
                         
Class C
                       
Actual
    1,000.00       762.87       7.22  
Hypothetical
    1,000.00       1,016.94       8.26  
(5% annual return before expenses)
                       
                         
Class R
                       
Actual
    1,000.00       764.56       5.01  
Hypothetical
    1,000.00       1,019.46       5.74  
(5% annual return before expenses)
                       
                         
Class I
                       
Actual
    1,000.00       766.98       2.80  
Hypothetical
    1,000.00       1,021.97       3.20  
(5% annual return before expenses)
                       
 
* Expenses are equal to the Fund’s annualized expense ratio of 0.88%, 0.88%, 1.63%, 1.13% and 0.63% for Class A, B, C, R and I Shares, respectively, multiplied by the average account value over the period, multiplied by 184/366 (to reflect the one-half year period). The expense ratio for Class B Shares reflects actual 12b-1 fees of less than 1%.
 
Assumes all dividends and distributions were reinvested.
 
 
8


 

Van Kampen Comstock Fund
Portfolio of Investments  n  December 31, 2008
 
                 
    Number of
   
Description   Shares   Value
 
 
Common Stocks  97.7%
               
Airlines  0.1%
               
Southwest Airlines Co. 
    1,421,900     $ 12,256,778  
                 
                 
Aluminum  0.8%                
Alcoa, Inc.
    5,670,200       63,846,452  
                 
                 
Asset Management & Custody Banks  2.7%                
Bank of New York Mellon Corp. 
    7,972,628       225,864,551  
                 
                 
Broadcasting & Cable TV  5.4%                
Comcast Corp., Class A
    21,056,350       355,431,188  
Liberty Media Corp.—Entertainment, Class A (a)
    5,162,440       90,239,451  
                 
              445,670,639  
                 
Catalog Retail  0.3%                
Liberty Media Corp.—Interactive, Class A (a)
    7,641,475       23,841,402  
                 
                 
Communications Equipment  1.2%                
Cisco Systems, Inc. (a)
    3,873,000       63,129,900  
Ericsson, Class B—ADR (Sweden)
    4,493,456       35,093,891  
                 
              98,223,791  
                 
Computer Hardware  3.7%                
Dell, Inc. (a)
    11,804,900       120,882,176  
Hewlett-Packard Co. 
    2,106,800       76,455,772  
IBM Corp.
    1,264,900       106,453,984  
                 
              303,791,932  
                 
Data Processing & Outsourced Services  0.8%                
Computer Sciences Corp. (a)
    1,332,300       46,817,022  
Western Union Co.
    1,447,900       20,762,886  
                 
              67,579,908  
                 
Department Stores  1.1%                
J.C. Penney Co., Inc.
    2,204,500       43,428,650  
Macy’s, Inc.
    4,735,600       49,013,460  
                 
              92,442,110  
                 
Diversified Banks  2.6%                
Barclays PLC—ADR (United Kingdom)
    657,000       6,438,600  
U.S. Bancorp
    2,376,700       59,441,267  
Wells Fargo & Co. 
    4,968,000       146,456,640  
                 
              212,336,507  
                 
Diversified Chemicals  1.1%                
Du Pont (E.I.) de Nemours & Co. 
    3,721,266       94,148,030  
                 
                 
Drug Retail  1.0%                
CVS Caremark Corp. 
    2,893,300       83,153,442  
                 
                 
Electrical Components & Equipment  0.7%                
Emerson Electric Co. 
    1,489,600       54,534,256  
                 
 
 
9
See Notes to Financial Statements


 

Van Kampen Comstock Fund
Portfolio of Investments  n  December 31, 2008  
continued
 
                 
    Number of
   
Description   Shares   Value
 
 
Electronic Equipment Manufacturers  0.2%                
Cognex Corp.
    1,255,587     $ 18,582,688  
                 
                 
Electronic Manufacturing Services  0.1%                
Flextronics International Ltd. (Singapore) (a)
    3,006,317       7,696,172  
                 
                 
Health Care Distributors  1.7%                
Cardinal Health, Inc.
    4,195,800       144,629,226  
                 
                 
Health Care Equipment  0.9%                
Boston Scientific Corp. (a)
    9,822,900       76,029,246  
                 
                 
Home Improvement Retail  1.6%                
Home Depot, Inc.
    2,750,200       63,309,604  
Lowe’s Cos., Inc.
    3,254,000       70,026,080  
                 
              133,335,684  
                 
Household Products  0.3%                
Kimberly-Clark Corp.
    534,000       28,163,160  
                 
                 
Hypermarkets & Super Centers  2.8%                
Wal-Mart Stores, Inc.
    4,110,800       230,451,448  
                 
                 
Industrial Conglomerates  2.7%                
General Electric Co.
    13,632,400       220,844,880  
                 
                 
Integrated Oil & Gas  1.9%                
BP PLC—ADR (United Kingdom)
    675,500       31,572,870  
ConocoPhillips
    1,219,000       63,144,200  
Total SA—ADR (France)
    1,092,700       60,426,310  
                 
              155,143,380  
                 
Integrated Telecommunication Services  5.5%                
AT&T, Inc.
    5,621,450       160,211,325  
Verizon Communications, Inc. 
    8,780,000       297,642,000  
                 
              457,853,325  
                 
Internet Software & Services  2.4%                
eBay, Inc. (a)
    11,913,100       166,306,876  
Yahoo!, Inc. (a)
    2,513,600       30,665,920  
                 
              196,972,796  
                 
Investment Banking & Brokerage  0.6%                
Goldman Sachs Group, Inc.
    369,700       31,198,983  
Merrill Lynch & Co., Inc.
    1,385,300       16,124,892  
                 
              47,323,875  
                 
Life & Health Insurance  2.6%                
Aflac, Inc.
    818,600       37,524,624  
MetLife, Inc. 
    2,770,700       96,586,602  
Torchmark Corp. 
    1,759,947       78,669,631  
                 
              212,780,857  
                 
 
 
10
See Notes to Financial Statements


 

Van Kampen Comstock Fund
Portfolio of Investments  n  December 31, 2008  
continued
 
                 
    Number of
   
Description   Shares   Value
 
 
Managed Health Care  1.0%                
UnitedHealth Group, Inc.
    1,628,000     $ 43,304,800  
WellPoint, Inc. (a)
    1,005,300       42,353,289  
                 
              85,658,089  
                 
Movies & Entertainment  7.7%                
News Corp., Class B
    10,289,800       98,576,284  
Time Warner, Inc.
    25,879,600       260,348,776  
Viacom, Inc., Class B (a)
    14,721,750       280,596,555  
                 
              639,521,615  
                 
Oil & Gas Equipment & Services  1.1%                
Halliburton Co. 
    5,001,200       90,921,816  
                 
                 
Other Diversified Financial Services  4.6%                
Bank of America Corp.
    13,554,400       190,845,952  
JPMorgan Chase & Co.
    5,985,800       188,732,274  
                 
              379,578,226  
                 
Packaged Foods & Meats  7.5%                
Cadbury PLC—ADR (United Kingdom)
    5,911,724       205,860,418  
Kraft Foods, Inc., Class A
    7,614,743       204,455,849  
Sara Lee Corp.
    4,353,600       42,621,744  
Unilever NV (Netherlands)
    6,793,600       166,782,880  
                 
              619,720,891  
                 
Paper Products  3.0%                
International Paper Co.
    20,696,213       244,215,313  
                 
                 
Pharmaceuticals  13.0%                
Abbott Laboratories
    1,206,000       64,364,220  
Bristol-Myers Squibb Co.
    13,232,100       307,646,325  
Eli Lilly & Co.
    2,542,300       102,378,421  
GlaxoSmithKline PLC—ADR (United Kingdom)
    935,700       34,873,539  
Pfizer, Inc.
    9,781,400       173,228,594  
Roche Holdings AG—ADR (Switzerland)
    692,708       52,879,736  
Schering-Plough Corp.
    12,143,400       206,802,102  
Wyeth
    3,468,800       130,114,688  
                 
              1,072,287,625  
                 
Property & Casualty Insurance  8.1%                
Berkshire Hathaway, Inc., Class A (a)
    705       68,103,000  
Berkshire Hathaway, Inc., Class B (a)
    1,100       3,535,400  
Chubb Corp. 
    8,327,340       424,694,340  
Travelers Cos., Inc.
    3,925,100       177,414,520  
                 
              673,747,260  
                 
Regional Banks  1.0%                
PNC Financial Services Group, Inc.
    1,665,500       81,609,500  
                 
                 
Semiconductor Equipment  0.6%                
KLA–Tencor Corp.
    2,342,700       51,047,433  
                 
 
 
11
See Notes to Financial Statements


 

Van Kampen Comstock Fund
Portfolio of Investments  n  December 31, 2008  
continued
 
                 
    Number of
   
Description   Shares   Value
 
 
                 
Semiconductors  0.7%                
Intel Corp.
    4,114,592     $ 60,319,919  
                 
                 
Soft Drinks  2.5%                
Coca-Cola Co.
    3,567,000       161,478,090  
Dr. Pepper Snapple Group, Inc. (a)
    2,718,244       44,171,465  
                 
              205,649,555  
                 
Systems Software  0.6%                
Microsoft Corp. 
    2,436,800       47,371,392  
                 
                 
Tobacco  1.5%                
Altria Group, Inc.
    3,410,400       51,360,624  
Philip Morris International, Inc. 
    1,761,500       76,642,865  
                 
              128,003,489  
                 
Total Long-Term Investments  97.7%
(Cost $10,676,636,671)
    8,087,148,658  
         
Description       Value
 
 
                 
Repurchase Agreements  2.4%                
Banc of America Securities ($22,677,109 par collateralized by U.S. Government obligations in a pooled cash account, interest rate of 0.01%, dated 12/31/08, to be sold on 01/02/09 at $22,677,121)
  $ 22,677,109  
Banc of America Securities ($62,681,444 par collateralized by U.S. Government obligations in a pooled cash account, interest rate of 0.03%, dated 12/31/08, to be sold on 01/02/09 at $62,681,549)
    62,681,444  
Citigroup Global Markets, Inc. ($67,871,628 par collateralized by U.S. Government obligations in a pooled cash account, interest rate of 0.01%, dated 12/31/08, to be sold on 01/02/09 at $67,871,665)
    67,871,628  
Citigroup Global Markets, Inc. ($23,954,692 par collateralized by U.S. Government obligations in a pooled cash account, interest rate of 0.05%, dated 12/31/08, to be sold on 01/02/09 at $23,954,759)
    23,954,692  
 
 
12
See Notes to Financial Statements


 

Van Kampen Comstock Fund
Portfolio of Investments  n  December 31, 2008  
continued
 
                 
Description       Value
 
 
Repurchase Agreements (Continued)
       
JPMorgan Chase & Co. ($23,954,692 par collateralized by U.S. Government obligations in a pooled cash account, interest rate of 0.02%, dated 12/31/08, to be sold on 01/02/09 at $23,954,719)
  $ 23,954,692  
         
         
Total Repurchase Agreements  2.4%
(Cost $201,139,565)
    201,139,565  
         
         
Total Investments  100.1%
(Cost $10,877,776,236)
    8,288,288,223  
         
Liabilities in Excess of Other Assets  (0.1%)
    (11,660,836 )
         
         
Net Assets  100.0%
  $ 8,276,627,387  
         
Percentages are calculated as a percentage of net assets.
 
(a) Non-income producing security.
 
ADR—American Depositary Receipt
 
 
13
See Notes to Financial Statements


 

Van Kampen Comstock Fund
Financial Statements
 
Statement of Assets and Liabilities
December 31, 2008
 
             
Assets:
           
Total Investments (Cost $10,877,776,236)
  $ 8,288,288,223      
Cash
    12,649,772      
Receivables:
           
Dividends
    21,325,942      
Fund Shares Sold
    10,406,269      
Investments Sold
    8,225,887      
Interest
    124      
Other
    634,540      
             
Total Assets
    8,341,530,757      
             
Liabilities:
           
Payables:
           
Fund Shares Repurchased
    52,564,193      
Distributor and Affiliates
    3,519,170      
Investment Advisory Fee
    2,645,188      
Trustees’ Deferred Compensation and Retirement Plans
    862,331      
Accrued Expenses
    5,312,488      
             
Total Liabilities
    64,903,370      
             
Net Assets
  $ 8,276,627,387      
             
Net Assets Consist of:
           
Capital (Par value of $0.01 per share with an unlimited number of shares authorized)
  $ 12,689,634,465      
Accumulated Undistributed Net Investment Income
    3,908,240      
Accumulated Net Realized Loss
    (1,827,427,305 )    
Net Unrealized Depreciation
    (2,589,488,013 )    
             
Net Assets
  $ 8,276,627,387      
             
Maximum Offering Price Per Share:
           
Class A Shares:
           
Net asset value and redemption price per share (Based on net assets of $5,798,794,252 and 534,452,822 shares of beneficial interest issued and outstanding)
  $ 10.85      
Maximum sales charge (5.75%* of offering price)
    0.66      
             
Maximum offering price to public
  $ 11.51      
             
Class B Shares:
           
Net asset value and offering price per share (Based on net assets of $906,301,468 and 83,527,929 shares of beneficial interest issued and outstanding)
  $ 10.85      
             
Class C Shares:
           
Net asset value and offering price per share (Based on net assets of $544,631,217 and 50,164,534 shares of beneficial interest issued and outstanding)
  $ 10.86      
             
Class R Shares:
           
Net asset value and offering price per share (Based on net assets of $130,746,118 and 12,047,947 shares of beneficial interest issued and outstanding)
  $ 10.85      
             
Class I Shares:
           
Net asset value and offering price per share (Based on net assets of $896,154,332 and 82,616,098 shares of beneficial interest issued and outstanding)
  $ 10.85      
             
 
* On sales of $50,000 or more, the sales charge will be reduced.
 
 
14
See Notes to Financial Statements


 

Van Kampen Comstock Fund
Financial Statements  
continued
 
Statement of Operations
For the Year Ended December 31, 2008
 
             
Investment Income:
           
Dividends (Net of foreign withholding taxes of $2,178,580)
  $ 381,343,056      
Interest
    8,884,228      
             
Total Income
    390,227,284      
             
Expenses:
           
Investment Advisory Fee
    48,518,467      
Distribution (12b-1) and Service Fees
           
Class A 
    22,529,344      
Class B
    3,588,152      
Class C
    8,869,928      
Class R
    1,099,660      
Transfer Agent Fees
    23,221,054      
Reports to Shareholders
    1,943,121      
Accounting and Administrative Expenses
    1,656,741      
Professional Fees
    486,127      
Custody
    393,342      
Trustees’ Fees and Related Expenses
    345,842      
Registration Fees
    160,855      
Other
    356,051      
             
Total Expenses
    113,168,684      
Less Credits Earned on Cash Balances
    93,887      
             
Net Expenses
    113,074,797      
             
Net Investment Income
  $ 277,152,487      
             
Realized and Unrealized Gain/Loss:
           
Net Realized Loss
  $ (1,784,093,793 )    
             
Unrealized Appreciation/Depreciation:
           
Beginning of the Period
    1,291,416,434      
End of the Period
    (2,589,488,013 )    
             
Net Unrealized Depreciation During the Period
    (3,880,904,447 )    
             
Net Realized and Unrealized Loss
  $ (5,664,998,240 )    
             
Net Decrease in Net Assets From Operations
  $ (5,387,845,753 )    
             
 
 
15
See Notes to Financial Statements


 

Van Kampen Comstock Fund
Financial Statements  
continued
 
Statements of Changes in Net Assets
 
                 
    For The
  For The
    Year Ended
  Year Ended
    December 31, 2008   December 31, 2007
     
 
From Investment Activities:
               
Operations:
               
Net Investment Income
  $ 277,152,487     $ 336,629,456  
Net Realized Gain/Loss
    (1,784,093,793 )     1,067,189,819  
Net Unrealized Depreciation During the Period
    (3,880,904,447 )     (1,714,466,029 )
                 
Change in Net Assets from Operations
    (5,387,845,753 )     (310,646,754 )
                 
                 
Distributions from Net Investment Income:
               
Class A Shares
    (191,947,804 )     (252,073,477 )
Class B Shares
    (30,503,444 )     (28,567,216 )
Class C Shares
    (12,290,886 )     (16,006,627 )
Class R Shares
    (4,046,903 )     (5,084,837 )
Class I Shares
    (33,487,573 )     (40,729,647 )
                 
      (272,276,610 )     (342,461,804 )
                 
                 
Distributions from Net Realized Gain:
               
Class A Shares
    (101,142,773 )     (721,759,183 )
Class B Shares
    (16,305,317 )     (120,504,311 )
Class C Shares
    (10,061,524 )     (74,890,550 )
Class R Shares
    (2,461,778 )     (17,427,403 )
Class I Shares
    (15,811,520 )     (107,950,318 )
                 
      (145,782,912 )     (1,042,531,765 )
                 
Total Distributions
    (418,059,522 )     (1,384,993,569 )
                 
                 
Net Change in Net Assets from Investment Activities
    (5,805,905,275 )     (1,695,640,323 )
                 
                 
From Capital Transactions:
               
Proceeds from Shares Sold
    1,691,969,719       3,134,353,598  
Net Asset Value of Shares Issued Through Dividend Reinvestment
    376,134,472       1,250,277,892  
Cost of Shares Repurchased
    (5,465,780,077 )     (5,041,485,210 )
                 
Net Change in Net Assets from Capital Transactions
    (3,397,675,886 )     (656,853,720 )
                 
Total Decrease in Net Assets
    (9,203,581,161 )     (2,352,494,043 )
Net Assets:
               
Beginning of the Period
    17,480,208,548       19,832,702,591  
                 
End of the Period (Including accumulated undistributed net investment income of $3,908,240 and $(958,923), respectively)
  $ 8,276,627,387     $ 17,480,208,548  
                 
 
 
16
See Notes to Financial Statements


 

Van Kampen Comstock Fund
Financial Highlights
 
The following schedule presents financial highlights for one share of the Fund outstanding throughout the periods indicated.
 
                                         
    Year Ended December 31,
Class A Shares
  2008   2007   2006   2005   2004
     
 
Net Asset Value, Beginning of the Period
  $ 17.48     $ 19.26     $ 17.81     $ 18.51     $ 15.95  
                                         
Net Investment Income
    0.32 (a)     0.36 (a)     0.35 (a)     0.32 (a)     0.24  
Net Realized and Unrealized Gain/Loss
    (6.48 )     (0.69 )     2.43       0.46       2.54  
                                         
Total from Investment Operations
    (6.16 )     (0.33 )     2.78       0.78       2.78  
                                         
Less:
                                       
Distributions from Net Investment Income
    0.32       0.37       0.38       0.32       0.22  
Distributions from Net Realized Gain
    0.15       1.08       0.95       1.16       -0-  
                                         
Total Distributions
    0.47       1.45       1.33       1.48       0.22  
                                         
Net Asset Value, End of the Period
  $ 10.85     $ 17.48     $ 19.26     $ 17.81     $ 18.51  
                                         
                                         
Total Return (b)
    –35.89%       –1.89%       16.06%       4.19%       17.57%  
Net Assets at End of the Period (In millions)
  $ 5,798.8     $ 12,091.9     $ 13,686.1     $ 12,041.1     $ 10,583.9  
Ratio of Expenses to Average Net Assets
    0.84%       0.78%       0.80%       0.80%       0.84%  
Ratio of Net Investment Income to Average Net Assets
    2.16%       1.82%       1.92%       1.77%       1.47%  
Portfolio Turnover
    19%       22%       26%       30%       34%  
 
(a) Based on average shares outstanding.
 
(b) Assumes reinvestment of all distributions for the period and does not include payment of the maximum sales charge of 5.75% or contingent deferred sales charge (CDSC). On purchases of $1 million or more, a CDSC of 1% may be imposed on certain redemptions made within eighteen months of purchase. If the sales charges were included, total returns would be lower. These returns include combined Rule 12b-1 fees and service fees of up to .25% and do not reflect the deduction of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares.
 
 
17
See Notes to Financial Statements


 

Van Kampen Comstock Fund
Financial Highlights  
continued
 
The following schedule presents financial highlights for one share of the Fund outstanding throughout the periods indicated.
 
                                         
    Year Ended December 31,
Class B Shares
  2008   2007   2006   2005   2004
     
 
Net Asset Value, Beginning of the Period
  $ 17.49     $ 19.26     $ 17.81     $ 18.52     $ 15.95  
                                         
Net Investment Income
    0.32 (a)     0.23 (a)     0.21 (a)     0.18 (a)     0.11  
Net Realized and Unrealized Gain/Loss
    (6.49 )     (0.68 )     2.43       0.46       2.55  
                                         
Total from Investment Operations
    (6.17 )     (0.45 )     2.64       0.64       2.66  
                                         
Less:
                                       
Distributions from Net Investment Income
    0.32       0.24       0.24       0.19       0.09  
Distributions from Net Realized Gain
    0.15       1.08       0.95       1.16       -0-  
                                         
Total Distributions
    0.47       1.32       1.19       1.35       0.09  
                                         
Net Asset Value, End of the Period
  $ 10.85     $ 17.49     $ 19.26     $ 17.81     $ 18.52  
                                         
                                         
Total Return (b)
    –35.93% (c)     –2.46% (c)     15.21%       3.37%       16.76%  
Net Assets at End of the Period (In millions)
  $ 906.3     $ 1,991.6     $ 2,518.3     $ 2,581.5     $ 2,577.7  
Ratio of Expenses to Average Net Assets
    0.84% (c)     1.41% (c)     1.55%       1.56%       1.59%  
Ratio of Net Investment Income to Average Net Assets
    2.16% (c)     1.19% (c)     1.17%       1.01%       0.70%  
Portfolio Turnover
    19%       22%       26%       30%       34%  
 
(a) Based on average shares outstanding.
 
(b) Assumes reinvestment of all distributions for the period and does not include payment of the maximum CDSC of 5%, charged on certain redemptions made within one year of purchase and declining to 0% after the fifth year. If the sales charge was included, total returns would be lower. These returns include combined Rule 12b-1 fees and service fees of up to 1% and do not reflect the deduction of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares.
 
(c) The Total Return, Ratio of Expenses to Average Net Assets and Ratio of Net Investment Income/Loss to Average Net Assets reflect actual 12b-1 fees of less than 1% (See footnote 6).
 
 
18
See Notes to Financial Statements


 

Van Kampen Comstock Fund
Financial Highlights  
continued
 
The following schedule presents financial highlights for one share of the Fund outstanding throughout the periods indicated.
 
                                         
    Year Ended December 31,
Class C Shares
  2008   2007   2006   2005   2004
     
 
Net Asset Value, Beginning of the Period
  $ 17.49     $ 19.27     $ 17.82     $ 18.53     $ 15.96  
                                         
Net Investment Income
    0.21 (a)     0.21 (a)     0.21 (a)     0.18 (a)     0.11  
Net Realized and Unrealized Gain/Loss
    (6.48 )     (0.69 )     2.43       0.46       2.55  
                                         
Total from Investment Operations
    (6.27 )     (0.48 )     2.64       0.64       2.66  
                                         
Less:
                                       
Distributions from Net Investment Income
    0.21       0.22       0.24       0.19       0.09  
Distributions from Net Realized Gain
    0.15       1.08       0.95       1.16       -0-  
                                         
Total Distributions
    0.36       1.30       1.19       1.35       0.09  
                                         
Net Asset Value, End of the Period
  $ 10.86     $ 17.49     $ 19.27     $ 17.82     $ 18.53  
                                         
                                         
Total Return (b)
    –36.35%       –2.63%       15.20%       3.37%       16.75%  
Net Assets at End of the Period (In millions)
  $ 544.6     $ 1,243.1     $ 1,495.8     $ 1,453.0     $ 1,210.7  
Ratio of Expenses to Average Net Assets
    1.59%       1.53%       1.55%       1.56%       1.59%  
Ratio of Net Investment Income to Average Net Assets
    1.41%       1.07%       1.17%       1.01%       0.70%  
Portfolio Turnover
    19%       22%       26%       30%       34%  
 
(a) Based on average shares outstanding.
 
(b) Assumes reinvestment of all distributions for the period and does not include payment of the maximum CDSC of 1%, charged on certain redemptions made within one year of purchase. If the sales charge was included, total returns would be lower. These returns include combined Rule 12b-1 fees and service fees of up to 1% and do not reflect the deduction of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares.
 
 
19
See Notes to Financial Statements


 

Van Kampen Comstock Fund
Financial Highlights  
continued
 
The following schedule presents financial highlights for one share of the Fund outstanding throughout the periods indicated.
 
                                         
    Year Ended December 31,
Class R Shares
  2008   2007   2006   2005   2004
     
 
Net Asset Value, Beginning of the Period
  $ 17.49     $ 19.26     $ 17.81     $ 18.52     $ 15.95  
                                         
Net Investment Income
    0.28 (a)     0.31 (a)     0.30 (a)     0.28 (a)     0.19  
Net Realized and Unrealized Gain/Loss
    (6.49 )     (0.68 )     2.43       0.45       2.56  
                                         
Total from Investment Operations
    (6.21 )     (0.37 )     2.73       0.73       2.75  
                                         
Less:
                                       
Distributions from Net Investment Income
    0.28       0.32       0.33       0.28       0.18  
Distributions from Net Realized Gain
    0.15       1.08       0.95       1.16       -0-  
                                         
Total Distributions
    0.43       1.40       1.28       1.44       0.18  
                                         
Net Asset Value, End of the Period
  $ 10.85     $ 17.49     $ 19.26     $ 17.81     $ 18.52  
                                         
                                         
Total Return (b)
    –36.09%       –2.09%       15.78%       3.88%       17.34%  
Net Assets at End of the Period (In millions)
  $ 130.7     $ 296.2     $ 274.3     $ 213.9     $ 111.4  
Ratio of Expenses to Average Net Assets
    1.09%       1.03%       1.05%       1.06%       1.09%  
Ratio of Net Investment Income to Average Net Assets
    1.91%       1.56%       1.67%       1.51%       1.28%  
Portfolio Turnover
    19%       22%       26%       30%       34%  
                                         
 
(a) Based on average shares outstanding.
 
(b) Assumes reinvestment of all distributions for the period. These returns include combined Rule 12b-1 fees and service fees of up to .50% and do not reflect the deduction of taxes that a shareholder would pay on Fund distributions or the redemption on Fund shares.
 
 
20
See Notes to Financial Statements


 

Van Kampen Comstock Fund
Financial Highlights  
continued
 
The following schedule presents financial highlights for one share of the Fund outstanding throughout the periods indicated.
 
                                         
                    October 29, 2004
                    (Commencement of
    Year Ended December 31,   Operations) to
Class I Shares
  2008   2007   2006   2005   December 31, 2004
     
 
Net Asset Value, Beginning of the Period
  $ 17.48     $ 19.25     $ 17.80     $ 18.51     $ 17.73  
                                         
Net Investment Income
    0.35 (a)     0.40 (a)     0.40 (a)     0.35 (a)     0.06  
Net Realized and Unrealized Gain/Loss
    (6.48 )     (0.68 )     2.43       0.47       0.79  
                                         
Total from Investment Operations
    (6.13 )     (0.28 )     2.83       0.82       0.85  
                                         
Less:
                                       
Distributions from Net Investment Income
    0.35       0.41       0.43       0.37       0.07  
Distributions from Net Realized Gain
    0.15       1.08       0.95       1.16       -0-  
                                         
Total Distributions
    0.50       1.49       1.38       1.53       0.07  
                                         
Net Asset Value, End of the Period
  $ 10.85     $ 17.48     $ 19.25     $ 17.80     $ 18.51  
                                         
Total Return (b)
    –35.73%       –1.59%       16.36%       4.39%       8.38% *
Net Assets at End of the Period (In millions)
  $ 896.2     $ 1,857.4     $ 1,858.2     $ 1,304.1     $ 3.5  
Ratio of Expenses to Average Net Assets
    0.59%       0.53%       0.55%       0.56%       0.61%  
Ratio of Net Investment Income to Average Net Assets
    2.41%       2.07%       2.16%       1.99%       1.70%  
Portfolio Turnover
    19%       22%       26%       30%       34%  
 
(a) Based on average shares outstanding.
 
(b) Assumes reinvestment of all distributions for the period. These returns do not reflect the deduction of taxes that a shareholder would pay on Fund distributions or the redemption on Fund shares.
 
* Non-Annualized
 
 
21
See Notes to Financial Statements


 

Van Kampen Comstock Fund
Notes to Financial Statements  n  December 31, 2008
 
1. Significant Accounting Policies
Van Kampen Comstock Fund (the “Fund”) is organized as a Delaware statutory trust and is registered as a diversified, open-end management investment company under the Investment Company Act of 1940, as amended (the “1940 Act”). The Fund’s investment objective is to seek capital growth and income through investments in equity securities, including common stocks, preferred stocks, and securities convertible into common and preferred stocks. The Fund commenced investment operations on October 7, 1968. The Fund offers Class A Shares, Class B Shares, Class C Shares, Class R Shares and Class I Shares. Each class of shares differs by its initial sales load, contingent deferred sales charges, the allocation of class-specific expenses and voting rights on matters affecting a single class.
The following is a summary of significant accounting policies consistently followed by the Fund in the preparation of its financial statements. The preparation of financial statements in conformity with U.S. generally accepted accounting principles requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates.
 
A. Security Valuation Investments in securities listed on a securities exchange are valued at their last sale price as of the close of such securities exchange. Equity securities traded on NASDAQ are valued at the NASDAQ Official Closing Price. Fixed income investments are stated at value using market quotations or indications of value obtained from an independent pricing service. Unlisted and listed securities for which the last sale price is not available are valued at the mean of the last reported bid and asked prices. For those securities where quotations or prices are not readily available, valuations are determined in accordance with procedures established in good faith by the Board of Trustees. Factors considered in making this determination may include, but are not limited to, information obtained by contacting the issuer, analysts, or the appropriate stock exchange (for exchange-traded securities), analysis of the issuer’s financial statements or other available documents and, if necessary, available information concerning other securities in similar circumstances. Short-term securities with remaining maturities of 60 days or less are valued at amortized cost, which approximates market value.
The Fund adopted Financial Accounting Standards Board Statement of Financial Accounting Standards No. 157, Fair Value Measurements (FAS 157), effective January 1, 2008. In accordance with FAS 157, fair value is defined as the price that the Fund would receive to sell an investment or pay to transfer a liability in an orderly transaction with an independent buyer in the principal market, or in the absence of a principal market the most advantageous market for the investment or liability. FAS 157 establishes a three-tier hierarchy to distinguish between (1) inputs that reflect the assumptions market participants would use in pricing an asset or liability developed based on market data obtained from sources independent of the reporting entity (observable inputs) and (2) inputs that reflect the reporting entity’s own assumptions about the assumptions market participants would use in pricing an asset or liability developed based on the best information available in the circumstances (unobservable inputs) and to establish classification of fair value measurements for disclosure purposes.
 
 
22


 

Van Kampen Comstock Fund
Notes to Financial Statements  
n  December 31, 2008  continued
 
Various inputs are used in determining the value of the Fund’s investments. The inputs are summarized in the three broad levels listed below.
 
Level 1— quoted prices in active markets for identical investments
Level 2— other significant observable inputs (including quoted prices for similar investments, interest rates, prepayment speeds, credit risk, etc.)
Level 3— significant unobservable inputs (including the Fund’s own assumptions in determining the fair value of investments)
 
The inputs or methodology used for valuing securities are not necessarily an indication of the risk associated with investing in those securities.
The following is a summary of the inputs used as of December 31, 2008 in valuing the Funds’s investments carried at value:
 
         
    Investments in
Valuation Inputs   Securities
 
Level 1—Quoted Prices
  $ 7,828,408,504  
Level 2—Other Significant Observable Inputs
    459,879,719  
Level 3—Significant Unobservable Inputs
    -0-  
         
Total
  $ 8,288,288,223  
         
 
B. Security Transactions Security transactions are recorded on a trade date basis. Realized gains and losses are determined on an identified cost basis.
The Fund may invest in repurchase agreements, which are short-term investments in which the Fund acquires ownership of a debt security and the seller agrees to repurchase the security at a future time and specified price. The Fund may invest independently in repurchase agreements, or transfer uninvested cash balances into a pooled cash account along with other investment companies advised by Van Kampen Asset Management (the “Adviser”) or its affiliates, the daily aggregate of which is invested in repurchase agreements. Repurchase agreements are fully collateralized by the underlying debt security. The Fund will make payment for such securities only upon physical delivery or evidence of book entry transfer to the account of the custodian bank. The seller is required to maintain the value of the underlying security at not less than the repurchase proceeds due the Fund.
 
C. Income and Expenses Dividend income net of applicable withholding taxes is recorded on the ex-dividend date and interest income is recorded on an accrual basis. Discounts are accreted and premiums are amortized over the expected life of each applicable security. Income and expenses of the Fund are allocated on a pro rata basis to each class of shares, except for distribution and service fees and incremental transfer agency costs which are unique to each class of shares.
 
D. Federal Income Taxes It is the Fund’s policy to comply with the requirements of Subchapter M of the Internal Revenue Code applicable to regulated investment companies and to distribute substantially all of its taxable income to its shareholders. Therefore, no provision for federal income taxes is required. The Fund may be subject to taxes imposed by countries in which it invests. Such taxes are generally based on income earned or gains realized or
 
 
23


 

Van Kampen Comstock Fund
Notes to Financial Statements  
n  December 31, 2008  continued
 
repatriated. Taxes are accrued and applied to net investment income, net realized capital gains and net unrealized appreciation, as applicable, as the income is earned or capital gains are recorded. Financial Accounting Standards Board Interpretation No. 48 Accounting for Uncertainty in Income Taxes (FIN 48) sets forth a minimum threshold for financial statement recognition of the benefit of a tax position taken or expected to be taken in a tax return. Management has concluded there are no significant uncertain tax positions that would require recognition in the financial statements. If applicable, the Fund recognizes interest accrued related to unrecognized tax benefits in “Interest Expense” and penalties in “Other” expenses on the Statement of Operations. The Fund files tax returns with the U.S. Internal Revenue Service. Generally, each of the tax years in the four year period ended December 31, 2008, remains subject to examination by taxing authorities.
The Fund intends to utilize provisions of federal income tax laws which allow it to carry a realized capital loss forward for eight years following the year of the loss and offset such losses against any future realized capital gains. At December 31, 2008, the Fund had an accumulated capital loss carryforward for tax purposes of $997,276,941 which will expire according to the following schedule:
 
                 
Amount       Expiration
 
$ 679,152           December 31, 2010  
  996,597,789           December 31, 2016  
 
At December 31, 2008, the cost and related gross unrealized appreciation and depreciation were as follows:
 
             
Cost of investments for tax purposes
  $ 10,944,561,083      
             
Gross tax unrealized appreciation
  $ 566,375,046      
Gross tax unrealized depreciation
    (3,222,647,906 )    
             
Net tax unrealized depreciation on investments
  $ (2,656,272,860 )    
             
 
E. Distribution of Income and Gains The Fund declares and pays dividends quarterly from net investment income. Net realized gains, if any, are distributed at least annually. Distributions from net realized gains for book purposes may include short-term capital gains which are included as ordinary income for tax purposes. Distributions from the Fund are recorded on the ex-distribution date.
The tax character of distributions paid during the years ended December 31, 2008 and 2007 were as follows:
 
                 
    2008   2007
 
Distributions paid from:
               
Ordinary income
  $ 283,185,523     $ 417,645,863  
Long-term capital gain
    134,873,999       967,347,706  
                 
    $ 418,059,522     $ 1,384,993,569  
                 
 
 
24


 

Van Kampen Comstock Fund
Notes to Financial Statements  
n  December 31, 2008  continued
 
Permanent differences, primarily due to a deferred compensation plan reclass, resulted in the following reclassifications among the Fund’s components of net assets at December 31, 2008:
 
                     
Accumulated Undistributed
  Accumulated
   
Net Investment Income   Net Realized Loss   Capital
 
$ (8,714 )   $ 8,714     $ -0-  
 
As of December 31, 2008, the components of distributable earnings on a tax basis were as follows:
 
         
Undistributed ordinary income
  $ 5,089,567  
 
Net realized gains or losses may differ for financial reporting and tax purposes primarily as a result of the deferral of losses relating to wash sale transactions and post-October losses of $763,365,515 which are not recognized for tax purposes until the first day of the following fiscal year.
 
F. Credits Earned on Cash Balances During the year ended December 31, 2008, the Fund’s custody fee was reduced by $93,887 as a result of credits earned on cash balances.
 
2. Investment Advisory Agreement and Other Transactions with Affiliates
Under the terms of the Fund’s Investment Advisory Agreement, the Adviser will provide investment advice and facilities to the Fund for an annual fee payable monthly as follows:
 
         
Average Daily Net Assets   % Per Annum
 
First $1 billion
    .50%  
Next $1 billion
    .45%  
Next $1 billion
    .40%  
Over $3 billion
    .35%  
 
For the year ended December 31, 2008, the Fund recognized expenses of approximately $445,200 representing legal services provided by Skadden, Arps, Slate, Meagher & Flom LLP, of which a trustee of the Fund is a partner of such firm and he and his law firm provide legal services as legal counsel to the Fund.
Under separate Accounting Services and Chief Compliance Officer (CCO) Employment agreements, the Adviser provides accounting services and the CCO provides compliance services to the Fund. The costs of these services are allocated to each fund. For the year ended December 31, 2008, the Fund recognized expenses of approximately $668,400 representing Van Kampen Investments Inc.’s or its affiliates’ (collectively “Van Kampen”) cost of providing accounting services to the Fund, as well as the salary, benefits and related costs of the CCO and related support staff paid by Van Kampen. Services provided pursuant to the Legal Services agreement are reported as part of “Professional Fees” on the Statement of Operations. Services provided pursuant to the Accounting Services and CCO Employment agreement are reported as part of “Accounting and Administrative Expenses” on the Statement of Operations.
Van Kampen Investor Services Inc. (VKIS), an affiliate of the Adviser, serves as the shareholder servicing agent for the Fund. For the year ended December 31, 2008, the Fund
 
 
25


 

Van Kampen Comstock Fund
Notes to Financial Statements  
n  December 31, 2008  continued
 
recognized expenses of approximately $8,115,100 representing transfer agency fees paid to VKIS and its affiliates. Transfer agency fees are determined through negotiations with the Fund’s Board of Trustees.
Certain officers and trustees of the Fund are also officers and directors of Van Kampen. The Fund does not compensate its officers or trustees who are also officers of Van Kampen.
The Fund provides deferred compensation and retirement plans for its trustees who are not officers of Van Kampen. Under the deferred compensation plan, trustees may elect to defer all or a portion of their compensation. Amounts deferred are retained by the Fund, and to the extent permitted by the 1940 Act, may be invested in the common shares of those funds selected by the trustees. Investments in such funds of approximately $505,300 are included in “Other” assets on the Statement of Assets and Liabilities at December 31, 2008. Appreciation/depreciation and distributions received from these investments are recorded with an offsetting increase/decrease in the deferred compensation obligation and do not affect the net asset value of the Fund. Benefits under the retirement plan are payable upon retirement for a ten-year period and are based upon each trustee’s years of service to the Fund. The maximum annual benefit per trustee under the plan is $2,500.
For the year ended December 31, 2008, the Fund paid brokerage commissions to Morgan Stanley & Co., Inc., an affiliate of the Adviser, totaling $104,056.
For the year ended December 31, 2008, Van Kampen, as Distributor for the Fund, received net commissions on sales of the Fund’s Class A Shares of approximately $1,592,200 and contingent deferred sales charge (CDSC) on redeemed shares of approximately $2,169,700. Sales charges do not represent expenses of the Fund.
 
 
26


 

Van Kampen Comstock Fund
Notes to Financial Statements  
n  December 31, 2008  continued
 
3. Capital Transactions
For the years ended December 31, 2008 and 2007, transactions were as follows:
 
                                     
    For The
  For The
   
    Year Ended
  Year Ended
   
    December 31, 2008   December 31, 2007    
    Shares   Value   Shares   Value    
 
Sales:
                                   
Class A
    85,567,693     $ 1,215,791,539       111,465,495     $ 2,175,702,297      
Class B
    4,280,067       61,121,961       6,685,714       130,481,639      
Class C
    3,510,454       50,192,126       7,067,828       137,432,298      
Class R
    5,755,383       84,295,666       8,034,845       156,504,313      
Class I
    19,716,282       280,568,427       27,493,128       534,233,051      
                                     
Total Sales
    118,829,879     $ 1,691,969,719       160,747,010     $ 3,134,353,598      
                                     
                                     
Dividend Reinvestment:
                                   
Class A
    18,335,648     $ 266,827,014       48,761,711     $ 891,360,351      
Class B
    3,040,070       44,265,292       7,686,719       139,901,206      
Class C
    1,242,298       18,218,050       4,033,792       73,481,198      
Class R
    421,035       6,164,251       1,163,044       21,224,359      
Class I
    2,798,835       40,659,865       6,799,321       124,310,778      
                                     
Total Dividend Reinvestment
    25,837,886     $ 376,134,472       68,444,587     $ 1,250,277,892      
                                     
                                     
Repurchases:
                                   
Class A
    (261,072,441 )   $ (3,737,891,416 )     (179,356,813 )   $ (3,483,313,088 )    
Class B
    (37,692,538 )     (545,487,023 )     (31,251,931 )     (609,780,417 )    
Class C
    (25,643,367 )     (371,339,540 )     (17,671,684 )     (344,098,763 )    
Class R
    (11,064,542 )     (162,161,230 )     (6,501,382 )     (126,783,280 )    
Class I
    (46,163,966 )     (648,900,868 )     (24,541,546 )     (477,509,662 )    
                                     
Total Repurchases
    (381,636,854 )   $ (5,465,780,077 )     (259,323,356 )   $ (5,041,485,210 )    
                                     
 
4. Redemption Fee
Until November 3, 2008, the Fund assessed a 2% redemption fee on the proceeds of Fund shares that are redeemed (either by sale or exchange) within seven days of purchase. The redemption fee was paid directly to the Fund and allocated on a pro rata basis to each class of shares. For the year ended December 31, 2008, the Fund received redemption fees of approximately $43,900 which are reported as part of “Cost of Shares Repurchased” on the Statements of Changes in Net Assets. The per share impact from redemption fees paid to the Fund was less than $0.01. Effective November 3, 2008, the redemption fee is no longer applied.
 
5. Investment Transactions
During the period, the cost of purchases and proceeds from sales of investments, excluding short-term investments, were $2,411,397,478 and $5,221,390,731, respectively.
 
 
27


 

Van Kampen Comstock Fund
Notes to Financial Statements  
n  December 31, 2008  continued
 
6. Distribution and Service Plans
Shares of the Fund are distributed by Van Kampen Funds Inc. (the “Distributor”), an affiliate of the Adviser. The Fund has adopted a distribution plan pursuant to Rule 12b-1 under the 1940 Act, and a service plan (collectively, the “Plans”) for Class A Shares, Class B Shares, Class C Shares and Class R Shares to compensate the Distributor for the sale, distribution, shareholder servicing and maintenance of shareholder accounts for these shares. Under the Plans, the Fund will incur annual fees of up to .25% of Class A average daily net assets, up to 1.00% each of Class B and Class C average daily net assets and up to .50% of Class R average daily net assets. These fees are accrued daily and paid to the Distributor monthly.
The amount of distribution expenses incurred by the Distributor and not yet reimbursed (“unreimbursed receivable”) was approximately $0 and $279,100 for Class B and Class C Shares, respectively. These amounts may be recovered from future payments under the distribution plan or CDSC. To the extent the unreimbursed receivable has been fully recovered, the distribution fee is reduced.
 
7. Indemnifications
The Fund enters into contracts that contain a variety of indemnifications. The Fund’s maximum exposure under these arrangements is unknown. However, the Fund has not had prior claims or losses pursuant to these contracts and expects the risk of loss to be remote.
 
8. Accounting Pronouncement
On March 19, 2008, Financial Accounting Standards Board released Statement of Financial Accounting Standards No. 161, Disclosures about Derivative Instruments and Hedging Activities (FAS 161). FAS 161 requires qualitative disclosures about objectives and strategies for using derivatives, quantitative disclosures about fair value amounts of and gains and losses on derivative instruments, and disclosures about credit-risk-related contingent features in derivative agreements. The application of FAS 161 is required for fiscal years and interim periods beginning after November 15, 2008. At this time, management does not believe the adoption of FAS 161 will impact the financial statement amounts; however, additional footnote disclosures may be required about the use of derivative instruments and hedging items.
 
 
28


 

Van Kampen Comstock Fund
Report of Independent Registered Public Accounting Firm
 
To the Shareholders and Board of Trustees of Van Kampen Comstock Fund
 
We have audited the accompanying statement of assets and liabilities of Van Kampen Comstock Fund (the Fund), including the portfolio of investments, as of December 31, 2008, and the related statement of operations for the year then ended, the statements of changes in net assets for each of the two years in the period then ended, and the financial highlights for each of the five years in the period then ended. These financial statements and financial highlights are the responsibility of the Fund’s management. Our responsibility is to express an opinion on these financial statements and financial highlights based on our audits.
We conducted our audits in accordance with the standards of the Public Company Accounting Oversight Board (United States). Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements and financial highlights are free of material misstatement. We were not engaged to perform an audit of the Fund’s internal control over financial reporting. Our audits included consideration of internal control over financial reporting as a basis for designing audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the Fund’s internal control over financial reporting. Accordingly, we express no such opinion. An audit also includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements and financial highlights, assessing the accounting principles used and significant estimates made by management, and evaluating the overall financial statement presentation. Our procedures included confirmation of securities owned as of December 31, 2008, by correspondence with the custodian and brokers or by other appropriate auditing procedures where replies from brokers were not received. We believe that our audits provide a reasonable basis for our opinion.
In our opinion, the financial statements and financial highlights referred to above present fairly, in all material respects, the financial position of Van Kampen Comstock Fund as of December 31, 2008, the results of its operations for the year then ended, the changes in its net assets for each of the two years in the period then ended, and the financial highlights for each of the five years in the period then ended, in conformity with U.S. generally accepted accounting principles.
 
-s- Ernst & Young LLP
Chicago, Illinois
February 19, 2009
 
 
29


 

Van Kampen Comstock Fund
Board of Trustees, Officers and Important Addresses
 
     
Board of Trustees
David C. Arch
Jerry D. Choate
Rod Dammeyer
Linda Hutton Heagy
R. Craig Kennedy
Howard J Kerr
Jack E. Nelson
Hugo F. Sonnenschein
Wayne W. Whalen*
– Chairman
Suzanne H. Woolsey
 
Officers
Edward C. Wood III
President and Principal Executive Officer
Kevin Klingert
Vice President
Amy R. Doberman
Vice President
Stefanie V. Chang Yu
Vice President and Secretary
John L. Sullivan
Chief Compliance Officer
Stuart N. Schuldt
Chief Financial Officer and Treasurer
  Investment Adviser
Van Kampen Asset Management
522 Fifth Avenue
New York, New York 10036
 
Distributor
Van Kampen Funds Inc.
522 Fifth Avenue
New York, New York 10036

Shareholder Servicing Agent
Van Kampen Investor Services Inc.
P.O. Box 219286
Kansas City, Missouri 64121-9286

Custodian
State Street Bank
and Trust Company
One Lincoln Street
Boston, Massachusetts 02111

Legal Counsel
Skadden, Arps, Slate,
Meagher & Flom LLP
333 West Wacker Drive
Chicago, Illinois 60606

Independent Registered
Public Accounting Firm
Ernst & Young LLP
233 South Wacker Drive
Chicago, Illinois 60606
 
 
 
(Unaudited)
For federal income tax purposes, the following information is furnished with the respect to the distributions paid by the Fund during its taxable year ended December 31, 2008. For corporate shareholders 100% of the distributions qualify for the dividends received deduction. The Fund designated and paid $134,873,999 as a long term capital gain distribution. Certain ordinary dividends paid by the Fund may be treated as qualified dividends income and will therefore be subject to a maximum tax rate of 15%. The Fund intends to designate up to a maximum of $382,428,981 as taxed at a maximum rate of 15%. In January, the Fund provides tax information to shareholders for the preceding calendar year.
 
 
* “Interested persons” of the Fund, as defined in the Investment Company Act of 1940, as amended.
 
 
30


 

Van Kampen Comstock Fund
Trustee and Officer Information
 
 
The business and affairs of the Fund are managed under the direction of the Fund’s Board of Trustees and the Fund’s officers appointed by the Board of Trustees. The tables below list the trustees and executive officers of the Fund and their principal occupations during the last five years, other directorships held by trustees and their affiliations, if any, with Van Kampen Investments, the Adviser, the Distributor, Van Kampen Advisors Inc., Van Kampen Exchange Corp. and Investor Services. The term “Fund Complex” includes each of the investment companies advised by the Adviser as of the date of this Annual Report. Trustees serve until reaching their retirement age or until their successors are duly elected and qualified. Officers are annually elected by the trustees.
 
                         
Independent Trustees:
                Number of
   
        Term of
      Funds in
   
        Office and
      Fund
   
    Position(s)
  Length of
      Complex
   
Name, Age and Address
  Held with
  Time
  Principal Occupation(s)
  Overseen
  Other Directorships
of Independent Trustee   Fund   Served   During Past 5 Years   By Trustee   Held by Trustee
 
David C. Arch (63)
Blistex Inc.
1800 Swift Drive
Oak Brook, IL 60523
  Trustee   Trustee
since 2003
  Chairman and Chief Executive Officer of Blistex Inc., a consumer health care products manufacturer.     84     Trustee/Director/Managing General Partner of funds in the Fund Complex. Director of the Heartland Alliance, a nonprofit organization serving human needs based in Chicago. Board member of the Illinois Manufacturers’ Association. Member of the Board of Visitors, Institute for the Humanities, University of Michigan.
                         
 
 
31


 

                         
Van Kampen Comstock Fund
Trustee and Officer Information  continued
                Number of
   
        Term of
      Funds in
   
        Office and
      Fund
   
    Position(s)
  Length of
      Complex
   
Name, Age and Address
  Held with
  Time
  Principal Occupation(s)
  Overseen
  Other Directorships
of Independent Trustee   Fund   Served   During Past 5 Years   By Trustee   Held by Trustee
 
Jerry D. Choate (70)
33971 Selva Road
Suite 130
Dana Point, CA 92629
  Trustee   Trustee
since 1999
  Prior to January 1999, Chairman and Chief Executive Officer of the Allstate Corporation (“Allstate”) and Allstate Insurance Company. Prior to January 1995, President and Chief Executive Officer of Allstate. Prior to August 1994, various management positions at Allstate.     84     Trustee/Director/Managing General Partner of funds in the Fund Complex. Director of Amgen Inc., a biotechnological company, and Valero Energy Corporation, an independent refining company.
                         
                         
Rod Dammeyer (68)
CAC, LLC
4370 La Jolla Village Drive
Suite 685
San Diego, CA 92122-1249
  Trustee   Trustee
since 2003
  President of CAC, LLC, a private company offering capital investment and management advisory services.     84     Trustee/Director/Managing General Partner of funds in the Fund Complex. Director of Quidel Corporation, Stericycle, Inc., and Trustee of The Scripps Research Institute. Prior to February 2008, Director of Ventana Medical Systems, Inc. Prior to April 2007, Director of GATX Corporation. Prior to April 2004, Director of TheraSense, Inc. Prior to January 2004, Director of TeleTech Holdings Inc. and Arris Group, Inc.
                         
 
 
32


 

                         
Van Kampen Comstock Fund
Trustee and Officer Information  continued
                Number of
   
        Term of
      Funds in
   
        Office and
      Fund
   
    Position(s)
  Length of
      Complex
   
Name, Age and Address
  Held with
  Time
  Principal Occupation(s)
  Overseen
  Other Directorships
of Independent Trustee   Fund   Served   During Past 5 Years   By Trustee   Held by Trustee
 
Linda Hutton Heagy† (60)
4939 South Greenwood
Chicago, IL 60615
  Trustee   Trustee
since 1995
  Prior to February 2008, Managing Partner of Heidrick & Struggles, an international executive search firm. Prior to 1997, Partner of Ray & Berndtson, Inc., an executive recruiting firm. Prior to 1995, Executive Vice President of ABN AMRO, N.A., a bank holding company. Prior to 1990, Executive Vice President of The Exchange National Bank.     84     Trustee/Director/Managing General Partner of funds in the Fund Complex. Trustee on the University of Chicago Medical Center Board, Vice Chair of the Board of the YMCA of Metropolitan Chicago and a member of the Women’s Board of the University of Chicago.
                         
                         
R. Craig Kennedy (57)
1744 R Street, NW
Washington, DC 20009
  Trustee   Trustee
since 1995
  Director and President of the German Marshall Fund of the United States, an independent U.S. foundation created to deepen understanding, promote collaboration and stimulate exchanges of practical experience between Americans and Europeans. Formerly, advisor to the Dennis Trading Group Inc., a managed futures and option company that invests money for individuals and institutions. Prior to 1992, President and Chief Executive Officer, Director and member of the Investment Committee of the Joyce Foundation, a private foundation.     84     Trustee/Director/Managing General Partner of funds in the Fund Complex. Director of First Solar, Inc.
                         
                         
Howard J Kerr (73)
14 Huron Trace
Galena, IL 61036
  Trustee   Trustee
since 2003
  Prior to 1998, President and Chief Executive Officer of Pocklington Corporation, Inc., an investment holding company.     84     Trustee/Director/Managing General Partner of funds in the Fund Complex. Director of the Lake Forest Bank & Trust. Director of the Marrow Foundation.
                         
 
 
33


 

                         
Van Kampen Comstock Fund
Trustee and Officer Information  continued
                Number of
   
        Term of
      Funds in
   
        Office and
      Fund
   
    Position(s)
  Length of
      Complex
   
Name, Age and Address
  Held with
  Time
  Principal Occupation(s)
  Overseen
  Other Directorships
of Independent Trustee   Fund   Served   During Past 5 Years   By Trustee   Held by Trustee
 
Jack E. Nelson (73)
423 Country Club Drive
Winter Park, FL 32789
  Trustee   Trustee
since 1995
  President of Nelson Investment Planning Services, Inc., a financial planning company and registered investment adviser in the State of Florida. President of Nelson Ivest Brokerage Services Inc., a member of the Financial Industry Regulatory Authority (“FINRA”), Securities Investors Protection Corp. and the Municipal Securities Rulemaking Board. President of Nelson Sales and Services Corporation, a marketing and services company to support affiliated companies.     84     Trustee/Director/Managing General Partner of funds in the Fund Complex.
                         
                         
Hugo F. Sonnenschein (68)
1126 E. 59th Street
Chicago, IL 60637
  Trustee   Trustee
since 2003
  President Emeritus and Honorary Trustee of the University of Chicago and the Adam Smith Distinguished Service Professor in the Department of Economics at the University of Chicago. Prior to July 2000, President of the University of Chicago.     84     Trustee/Director/Managing General Partner of funds in the Fund Complex. Trustee of the University of Rochester and a member of its investment committee. Member of the National Academy of Sciences, the American Philosophical Society and a fellow of the American Academy of Arts and Sciences.
                         
 
 
34


 

                         
Van Kampen Comstock Fund
Trustee and Officer Information  continued
                Number of
   
        Term of
      Funds in
   
        Office and
      Fund
   
    Position(s)
  Length of
      Complex
   
Name, Age and Address
  Held with
  Time
  Principal Occupation(s)
  Overseen
  Other Directorships
of Independent Trustee   Fund   Served   During Past 5 Years   By Trustee   Held by Trustee
 
Suzanne H. Woolsey, Ph.D. (67)
815 Cumberstone Road
Harwood, MD 20776
  Trustee   Trustee
since 1999
  Chief Communications Officer of the National Academy of Sciences/National Research Council, an independent, federally chartered policy institution, from 2001 to November 2003 and Chief Operating Officer from 1993 to 2001. Prior to 1993, Executive Director of the Commission on Behavioral and Social Sciences and Education at the National Academy of Sciences/National Research Council. From 1980 through 1989, Partner of Coopers & Lybrand.     84     Trustee/Director/Managing General Partner of funds in the Fund Complex. Trustee of Changing World Technologies, Inc., an energy manufacturing company, since July 2008. Director of Fluor Corp., an engineering, procurement and construction organization, since January 2004. Director of Intelligent Medical Devices, Inc., a symptom based diagnostic tool for physicians and clinical labs. Director of the Institute for Defense Analyses, a federally funded research and development center, Director of the German Marshall Fund of the United States, Director of the Rocky Mountain Institute and Trustee of California Institute of Technology and the Colorado College.
                         
 
 
35


 

                         
Van Kampen Comstock Fund
Trustee and Officer Information  continued
Interested Trustees:*
                Number of
   
        Term of
      Funds in
   
        Office and
      Fund
   
    Position(s)
  Length of
      Complex
   
Name, Age and Address
  Held with
  Time
  Principal Occupation(s)
  Overseen
  Other Directorships
of Interested Trustee   Fund   Served   During Past 5 Years   By Trustee   Held by Trustee
 
Wayne W. Whalen* (69)
333 West Wacker Drive
Chicago, IL 60606
  Trustee   Trustee
since 1995
  Partner in the law firm of Skadden, Arps, Slate, Meagher & Flom LLP, legal counsel to funds in the Fund Complex.     84     Trustee/Director/Managing General Partner of funds in the Fund Complex. Director of the Abraham Lincoln Presidential Library Foundation.
 
As indicated above, prior to February 2008, Ms. Heagy was an employee of Heidrick and Struggles, an international executive search firm (“Heidrick”). Heidrick has been (and may continue to be) engaged by Morgan Stanley from time to time to perform executive searches. Such searches have been done by professionals at Heidrick without any involvement by Ms. Heagy. Ethical wall procedures exist to ensure that Ms. Heagy will not have any involvement with any searches performed by Heidrick for Morgan Stanley. Ms. Heagy does not receive any compensation, directly or indirectly, for searches performed by Heidrick for Morgan Stanley.
 
* Mr. Whalen is an “interested person” (within the meaning of Section 2(a)(19) of the 1940 Act) of certain funds in the Fund Complex by reason of he and his firm currently providing legal services as legal counsel to such funds in the Fund Complex.
 
 
36


 

Van Kampen Comstock Fund
Trustee and Officer Information  continued
 
             
Officers:
        Term of
   
        Office and
   
    Position(s)
  Length of
   
Name, Age
  Held with
  Time
  Principal Occupation(s)
and Address of Officer   Fund   Served   During Past 5 Years
 
Edward C. Wood III (53)
1 Parkview Plaza - Suite 100
Oakbrook Terrace, IL 60181
  President and
Principal Executive
Officer
  Officer
since 2008
  President and Principal Executive Officer of funds in the Fund Complex since November 2008. Managing Director of Van Kampen Investments Inc., the Adviser, the Distributor, Van Kampen Advisors Inc. and Van Kampen Exchange Corp. since December 2003. Chief Administrative Officer of Van Kampen Investments Inc., the Adviser, Van Kampen Advisors Inc. and Van Kampen Exchange Corp. since December 2002. Chief Operating Officer of the Distributor since December 2002. Director of Van Kampen Advisors Inc., the Distributor and Van Kampen Exchange Corp. since March 2004. Director of the Adviser since August 2008. Director of Van Kampen Investments Inc. and Van Kampen Investor Services Inc. since June 2008. Previously, Director of the Adviser and Van Kampen Investments Inc. from March 2004 to January 2005.
             
             
Kevin Klingert (45)
522 Fifth Avenue
New York, NY 10036
  Vice President   Officer
since 2008
  Vice President of funds in the Fund Complex since May 2008. Global Head, Chief Operating Officer and acting Chief Investment Officer of the Global Fixed Income Group of Morgan Stanley Investment Management Inc. and Morgan Stanley Investment Advisors Inc. since April 2008. Head of Global Liquidity Portfolio Management and co-Head of Liquidity Credit Research of Morgan Stanley Investment Management since December 2007. Managing Director of Morgan Stanley Investment Management Inc. and Morgan Stanley Investment Advisors Inc. from December 2007 to March 2008. Previously, Managing Director on the Management Committee and head of Municipal Portfolio Management and Liquidity at BlackRock from October 1991 to January 2007.
             
             
Amy R. Doberman (46)
522 Fifth Avenue
New York, NY 10036
  Vice President   Officer
since 2004
  Managing Director of Morgan Stanley Investment Management Inc., Morgan Stanley Investment Advisors Inc. and the Adviser since July 2004. Vice President of the Morgan Stanley Institutional and Retail Funds since July 2004 and Vice President of funds in the Fund Complex since August 2004. Previously, Managing Director and General Counsel of Americas, UBS Global Asset Management from July 2000 to July 2004.
             
             
Stefanie V. Chang Yu (42)
522 Fifth Avenue
New York, NY 10036
  Vice President
and Secretary
  Officer
since 2003
  Managing Director of Morgan Stanley Investment Management Inc. Vice President and Secretary of funds in the Fund Complex.
             
 
 
37


 

             
Van Kampen Comstock Fund
Trustee and Officer Information  continued
        Term of
   
        Office and
   
    Position(s)
  Length of
   
Name, Age
  Held with
  Time
  Principal Occupation(s)
and Address of Officer   Fund   Served   During Past 5 Years
 
John L. Sullivan (53)
1 Parkview Plaza - Suite 100
Oakbrook Terrace, IL 60181
  Chief Compliance
Officer
  Officer
since 1996
  Chief Compliance Officer of funds in the Fund Complex since August 2004. Prior to August 2004, Director and Managing Director of Van Kampen Investments, the Adviser, Van Kampen Advisors Inc. and certain other subsidiaries of Van Kampen Investments, Vice President, Chief Financial Officer and Treasurer of funds in the Fund Complex and head of Fund Accounting for Morgan Stanley Investment Management Inc. Prior to December 2002, Executive Director of Van Kampen Investments, the Adviser and Van Kampen Advisors Inc.
             
             
Stuart N. Schuldt (47)
1 Parkview Plaza - Suite 100
Oakbrook Terrace, IL 60181
  Chief Financial Officer
and Treasurer
  Officer
since 2007
  Executive Director of Morgan Stanley Investment Management Inc. since June 2007. Chief Financial Officer and Treasurer of funds in the Fund Complex since June 2007. Prior to June 2007, Senior Vice President of Northern Trust Company, Treasurer and Principal Financial Officer for Northern Trust U.S. mutual fund complex.
 
 
38


 

Van Kampen Comstock Fund
An Important Notice Concerning Our
U.S. Privacy Policy
 
We are required by federal law to provide you with a copy of our Privacy Policy annually.
 
This Policy applies to current and former individual clients of Van Kampen Investments Inc., Van Kampen Asset Management, Van Kampen Advisors Inc., Van Kampen Funds Inc., Van Kampen Investor Services Inc. and Van Kampen Exchange Corp., as well as current and former individual investors in Van Kampen mutual funds, unit investment trusts, and related companies.
 
This Policy is not applicable to partnerships, corporations, trusts or other non-individual clients or account holders, nor is this Policy applicable to individuals who are either beneficiaries of a trust for which we serve as trustee or participants in an employee benefit plan administered or advised by us. This Policy is, however, applicable to individuals who select us to be a custodian of securities or assets in individual retirement accounts, 401(k) accounts, 529 Educational Savings Accounts, accounts subject to the Uniform Gifts to Minors Act, or similar accounts. Please note that we may amend this Policy at any time, and will inform you of any changes to this Policy as required by law.
 
We Respect Your Privacy
 
We appreciate that you have provided us with your personal financial information and understand your concerns about safeguarding such information. We strive to maintain the privacy of such information while we help you achieve your financial objectives. This Policy describes what nonpublic personal information we collect about you, how we collect it, when we may share it with others, and how others may use it. It discusses the steps you may take to limit our sharing of information about you with affiliated Van Kampen companies (“affiliated companies”). It also discloses how you may limit our affiliates’ use of shared information for marketing purposes. Throughout this Policy, we refer to the nonpublic information that personally identifies you or your accounts as “personal information.”
 
1. What Personal Information Do We Collect About You?
 
To better serve you and manage our business, it is important that we collect and maintain accurate information about you. We obtain this information from applications and other forms you submit to us, from your dealings with us, from consumer reporting agencies and from third parties and other sources. For example:
 
  •   We collect information such as your name, address, e-mail address, phone number and account title.  
 
(continued on next page)
 


 


Van Kampen Comstock Fund
An Important Notice Concerning Our
U.S. Privacy Policy  continued
 
  •   We may obtain information about account balances, your use of account(s) and the types of products and services you prefer to receive from us through your dealings and transactions with us and other sources.  
 
  •   We may obtain information about your creditworthiness and credit history from consumer reporting agencies.  
 
  •   We may collect background information from and through third-party vendors to verify representations you have made and to comply with various regulatory requirements.  
 
  •   If you interact with us through our public and private Web sites, we may collect information that you provide directly through online communications (such as an e-mail address). We may also collect information about your Internet service provider, your domain name, your computer’s operating system and Web browser, your use of our Web sites and your product and service preferences, through the use of ”cookies.” ”Cookies” recognize your computer each time you return to one of our sites, and help to improve our sites’ content and personalize your experience on our sites by, for example, suggesting offerings that may interest you. Please consult the Terms of Use of these sites for more details on our use of cookies.  
 
2. When Do We Disclose Personal Information We Collect About You?
 
To provide you with the products and services you request, to better serve you, to manage our business and as otherwise required or permitted by law, we may disclose personal information we collect about you to other affiliated companies and to nonaffiliated third parties.
 
A. Information We Disclose to Our Affiliated Companies. In order to manage your account(s) effectively, including servicing and processing your transactions, to let you know about products and services offered by us and affiliated companies, to manage our business, and as otherwise required or permitted by law, we may disclose personal information to other affiliated companies. Offers for products and services from affiliated companies are developed under conditions designed to safeguard your personal information.
 
B. Information We Disclose to Third Parties. We do not disclose personal information that we collect about you to nonaffiliated third parties except to enable them to provide marketing services on our behalf, to perform joint marketing agreements with other financial institutions, and as otherwise required or permitted by law. For example, some instances where we may disclose information about you to third
 
(continued on next page)
 


 


Van Kampen Comstock Fund
An Important Notice Concerning Our
U.S. Privacy Policy  continued
 
parties include: for servicing and processing transactions, to offer our own products and services, to protect against fraud, for institutional risk control, to respond to judicial process or to perform services on our behalf. When we share personal information with a nonaffiliated third party, they are required to limit their use of personal information to the particular purpose for which it was shared and they are not allowed to share personal information with others except to fulfill that limited purpose.
 
3. How Do We Protect the Security and Confidentiality of Personal Information We Collect About You?
 
We maintain physical, electronic and procedural security measures to help safeguard the personal information we collect about you. We have internal policies governing the proper handling of client information. Third parties that provide support or marketing services on our behalf may also receive personal information, and we require them to adhere to confidentiality standards with respect to such information.
 
4. How Can You Limit the Sharing of Certain Types of Personal Information With Affiliated Companies?
 
We respect your privacy and offer you choices as to whether we share with affiliated companies personal information that was collected to determine your eligibility for products and services you request (“eligibility information”). Please note that, even if you direct us not to share eligibility information with affiliated companies (“opt-out”), we may still share personal information, including eligibility information, with those companies in circumstances excluded from the opt-out under applicable law, such as to process transactions or to service your account. We may also share certain other types of personal information with affiliated companies—such as your name, address, telephone number, e-mail address and account number(s), and information about your transactions and experiences with us.
 
5. How Can You Limit the Use of Certain Types of Personal Information by Affiliated Companies for Marketing?
 
You may limit affiliated companies from marketing their products or services to you based on your personal information that they receive from affiliated companies. This information includes your income, assets and account history. Your choice to limit marketing offers from affiliated companies will apply until you tell us to change your choice.
 
(continued on next page)
 


 


Van Kampen Comstock Fund
An Important Notice Concerning Our
U.S. Privacy Policy  continued
 
If you wish to opt-out of sharing and to limit marketing offers, you may do so by:
 
  •   Calling us at (800) 847-2424
Monday-Friday between 8 a.m. and 8 p.m. (ET)
 
 
  •   Writing to us at the following address:
Van Kampen Privacy Department
Harborside Financial Center, Plaza Two, 3rd Floor
Jersey City, NJ 07311
 
 
If you choose to write to us, your written request should include your name, address, telephone number and account number(s) to which the opt-out applies and should not be sent with any other correspondence. In order to process your request, we require that the request be provided by you directly and not through a third party.
 
If you have previously notified us about your privacy preferences, it is not necessary to do so again unless you decide to change your preferences. Your opt-out preference will remain in effect with respect to this Policy (as it may be amended) until you notify us otherwise in writing. If you have a joint account, your direction for us not to share this information with other affiliated companies and for those affiliated companies not to use your personal information for marketing will be applied to all account holders on that account.
 
Please understand that if you opt-out, you and any joint account holders may not receive information about affiliated company products and services that could help you manage your financial resources and achieve your investment objectives.
 
If you hold more than one account with Van Kampen, you may receive multiple privacy policies from us, and would need to follow the directions stated in each particular policy for each account you have with us.
 
SPECIAL NOTICE TO RESIDENTS OF VERMONT
 
This section supplements our Policy with respect to our individual clients who have a Vermont address and supersedes anything to the contrary in the above Policy with respect to those clients only.
 
The State of Vermont requires financial institutions to obtain your consent prior to sharing personal information that they collect about you with affiliated companies and nonaffiliated third parties other than in certain limited circumstances. Except as permitted by law, we will not share personal information we collect about you with nonaffiliated third parties or other affiliated companies unless you provide us with your written consent to share such information (“opt-in”).
 
(continued on back)
 


 


Van Kampen Comstock Fund
An Important Notice Concerning Our
U.S. Privacy Policy  continued
 
If you wish to receive offers for investment products and services offered by or through other affiliated companies, please notify us in writing at the following address:
 
      Van Kampen Privacy Department
Harborside Financial Center, Plaza Two, 3rd Floor
Jersey City, NJ 07311
 
 
Your authorization should include your name, address, telephone number and account number(s) to which the opt-in applies and should not be sent with any other correspondence. In order to process your authorization, we require that the authorization be provided by you directly and not through a third-party.
 
 
The Statement of Additional Information includes additional information about Fund trustees and is available, without charge, upon request by calling 1-800-847-2424.
 
Van Kampen Funds Inc.
522 Fifth Avenue
New York, New York 10036
www.vankampen.com
 
Copyright ©2009 Van Kampen Funds Inc.
All rights reserved. Member FINRA/SIPC
 
13, 113, 213, 313, 613
COMANN 2/09
IU09-00553P-Y12/08
(VAN KAMPEN INVESTMENTS LOGO)


 

Item 2. Code of Ethics.
(a) The Fund has adopted a code of ethics (the “Code of Ethics”) that applies to its principal executive officer, principal financial officer, principal accounting officer or controller, or persons performing similar functions, regardless of whether these individuals are employed by the Fund or a third party.
(b)   No information need be disclosed pursuant to this paragraph.
 
(c)   Due to personnel changes at the Adviser, the list of covered officers set forth in Exhibit B was amended in June 2008 and November 2008 and the general counsel’s designee set forth in Exhibit C was amended in January 2008. All three editions of Exhibit B and both editions of Exhibit C are attached.
 
(d)   Not applicable.
 
(e)   Not applicable.
 
(f)    
  (1)   The Fund’s Code of Ethics is attached hereto as Exhibit 12(1).
 
  (2)   Not applicable.
 
  (3)   Not applicable.
Item 3. Audit Committee Financial Expert.
The Fund’s Board of Trustees has determined that it has three “audit committee financial experts” serving on its audit committee, each of whom are “independent” Trustees : Rod Dammeyer, Jerry D. Choate and R. Craig Kennedy. Under applicable securities laws, a person who is determined to be an audit committee financial expert will not be deemed an “expert” for any purpose, including without limitation for the purposes of Section 11 of the Securities Act of 1933, as a result of being designated or identified as an audit committee financial expert. The designation or identification of a person as an audit committee financial expert does not impose on such person any duties, obligations, or liabilities that are greater than the duties, obligations, and liabilities imposed on such person as a member of the audit committee and Board of Trustees in the absence of such designation or identification.

 


 

Item 4. Principal Accountant Fees and Services.
(a)(b)(c)(d) and (g). Based on fees billed for the periods shown:
2008
                 
    Registrant     Covered Entities(1)
Audit Fees
  $ 37,300       N/A  
 
               
Non-Audit Fees
               
Audit-Related Fees
  $ 0     $ 300,200 (2)
Tax Fees
  $ 2,800 (3)   $ 99,522 (4)
All Other Fees
  $ 0     $ 688,963 (5)
Total Non-Audit Fees
  $ 2,800     $ 1,088,685  
 
               
Total
  $ 40,100     $ 1,088,685  
2007
                 
    Registrant   Covered Entities(1)
Audit Fees
  $ 33,600       N/A  
 
               
Non-Audit Fees
               
Audit-Related Fees
  $ 0     $ 731,800 (2)
Tax Fees
  $ 2,575 (3)   $ 59,185 (4)
All Other Fees
  $ 0     $ 211,105 (6)
Total Non-Audit Fees
  $ 2,575     $ 1,002,090  
 
               
Total
  $ 36,175     $ 1,002,090  
 
N/A-   Not applicable, as not required by Item 4.
 
(1)   Covered Entities include the Adviser (excluding sub-advisors) and any entity controlling, controlled by or under common control with the Adviser that provides ongoing services to the Registrant.
 
(2)   Audit-Related Fees represent assurance and related services provided that are reasonably related to the performance of the audit of the financial statements of the Covered Entities’ and funds advised by the Adviser or its affiliates, specifically attestation services provided in connection with a SAS 70 Report.
 
(3)   Tax Fees represent tax advice and compliance services provided in connection with the review of the Registrant’s tax.
 
(4)   Tax Fees represent tax advice services provided to Covered Entities, including research and identification of PFIC entities.
 
(5)   All Other Fees represent attestation services provided in connection with performance presentation standards, and a regulatory compliance project performed.

 


 

(e)(1) The audit committee’s pre-approval policies and procedures are as follows:
JOINT AUDIT COMMITTEE
AUDIT AND NON-AUDIT SERVICES
PRE-APPROVAL POLICY AND PROCEDURES
OF THE
VAN KAMPEN FUNDS
AS ADOPTED JULY 23, 2003 AND AMENDED MAY 26, 20041
1. STATEMENT OF PRINCIPLES
     The Audit Committee of the Board is required to review and, in its sole discretion, pre-approve all Covered Services to be provided by the Independent Auditors to the Fund and Covered Entities in order to assure that services performed by the Independent Auditors do not impair the auditor’s independence from the Fund.2
     The SEC has issued rules specifying the types of services that an independent auditor may not provide to its audit client, as well as the audit committee’s administration of the engagement of the independent auditor. The SEC’s rules establish two different approaches to pre-approving services, which the SEC considers to be equally valid. Proposed services either: may be pre-approved without consideration of specific case-by-case services by the Audit Committee (“general pre-approval”); or require the specific pre-approval of the Audit Committee (“specific pre-approval”). The Audit Committee believes that the combination of these two approaches in this Policy will result in an effective and efficient procedure to pre-approve services performed by the Independent Auditors. As set forth in this Policy, unless a type of service has received general pre-approval, it will require specific pre-approval by the Audit Committee (or by any member of the Audit Committee to which pre-approval authority has been delegated) if it is to be provided by the Independent Auditors. Any proposed services exceeding pre-approved cost levels or budgeted amounts will also require specific pre-approval by the Audit Committee.
     For both types of pre-approval, the Audit Committee will consider whether such services are consistent with the SEC’s rules on auditor independence. The Audit Committee will also consider whether the Independent Auditors are best positioned to provide the most effective and efficient services, for reasons such as its familiarity with the Fund’s business, people, culture, accounting systems, risk profile and other factors, and whether the service might enhance the Fund’s ability to manage or control risk or improve audit quality. All such factors will be considered as a whole, and no one factor should necessarily be determinative.
     The Audit Committee is also mindful of the relationship between fees for audit and non-audit services in deciding whether to pre-approve any such services and may determine for each fiscal year, the appropriate ratio between the total amount of fees for Audit, Audit-related and Tax services for the Fund (including any Audit-related or Tax service fees for Covered Entities that were subject to pre-approval), and the total amount of fees for certain permissible non-audit services classified as All Other services for the Fund (including any such services for Covered Entities subject to pre-approval).
     The appendices to this Policy describe the Audit, Audit-related, Tax and All Other services that have the general pre-approval of the Audit Committee. The term of any general pre-approval is 12 months from the date of pre-approval, unless the Audit Committee considers and provides a different period and states otherwise. The Audit Committee will annually review and pre-approve the services that may be provided by the Independent Auditors without obtaining specific pre-approval from the Audit Committee. The Audit Committee will add to or subtract from the list of general pre-approved services from time to time, based on subsequent determinations.
     The purpose of this Policy is to set forth the policy and procedures by which the Audit Committee intends to fulfill its responsibilities. It does not delegate the Audit Committee’s responsibilities to pre-approve services performed by the Independent Auditors to management.
 
1   This Joint Audit Committee Audit and Non-Audit Services Pre-Approval Policy and Procedures (the “Policy”), amended as of the date above, supercedes and replaces all prior versions that may have been amended from time to time.
 
2   Terms used in this Policy and not otherwise defined herein shall have the meanings as defined in the Joint Audit Committee Charter.

 


 

     The Fund’s Independent Auditors have reviewed this Policy and believes that implementation of the Policy will not adversely affect the Independent Auditors’ independence.
2. Delegation
     As provided in the Act and the SEC’s rules, the Audit Committee may delegate either type of pre-approval authority to one or more of its members. The member to whom such authority is delegated must report, for informational purposes only, any pre-approval decisions to the Audit Committee at its next scheduled meeting.
3. Audit Services
     The annual Audit services engagement terms and fees are subject to the specific pre-approval of the Audit Committee. Audit services include the annual financial statement audit and other procedures required to be performed by the Independent Auditors to be able to form an opinion on the Fund’s financial statements. These other procedures include information systems and procedural reviews and testing performed in order to understand and place reliance on the systems of internal control, and consultations relating to the audit. The Audit Committee will monitor the Audit services engagement as necessary, but no less than on a quarterly basis, and will also approve, if necessary, any changes in terms, conditions and fees resulting from changes in audit scope, Fund structure or other items.
     In addition to the annual Audit services engagement approved by the Audit Committee, the Audit Committee may grant general pre-approval to other Audit services, which are those services that only the Independent Auditors reasonably can provide. Other Audit services may include statutory audits and services associated with SEC registration statements (on Forms N-1A, N-2, N-3, N-4, etc.), periodic reports and other documents filed with the SEC or other documents issued in connection with securities offerings.
     The Audit Committee has pre-approved the Audit services in Appendix B.1. All other Audit services not listed in Appendix B.1 must be specifically pre-approved by the Audit Committee (or by any member of the Audit Committee to which pre-approval has been delegated).
4. Audit-related Services
     Audit-related services are assurance and related services that are reasonably related to the performance of the audit or review of the Fund’s financial statements or, to the extent they are Covered Services, the Covered Entities’ financial statements, or that are traditionally performed by the Independent Auditors. Because the Audit Committee believes that the provision of Audit-related services does not impair the independence of the auditor and is consistent with the SEC’s rules on auditor independence, the Audit Committee may grant general pre-approval to Audit-related services. Audit-related services include, among others, accounting consultations related to accounting, financial reporting or disclosure matters not classified as “Audit services”; assistance with understanding and implementing new accounting and financial reporting guidance from rulemaking authorities; agreed-upon or expanded audit procedures related to accounting and/or billing records required to respond to or comply with financial, accounting or regulatory reporting matters; and assistance with internal control reporting requirements under Forms N-SAR and/or N-CSR.
     The Audit Committee has pre-approved the Audit-related services in Appendix B.2. All other Audit-related services not listed in Appendix B.2 must be specifically pre-approved by the Audit Committee (or by any member of the Audit Committee to which pre-approval has been delegated).
5. Tax Services
     The Audit Committee believes that the Independent Auditors can provide Tax services to the Fund and, to the extent they are Covered Services, the Covered Entities, such as tax compliance, tax planning and tax advice without impairing the auditor’s independence, and the SEC has stated that the Independent Auditors may provide such services. Hence, the Audit Committee believes it may grant general pre-approval to those Tax services that have historically been provided by the Independent Auditors, that the Audit Committee has reviewed and believes would not impair the independence of the Independent Auditors, and that are consistent with the SEC’s rules on auditor independence. The Audit Committee will not permit the retention of the

 


 

Independent Auditors in connection with a transaction initially recommended by the Independent Auditors, the sole business purpose of which may be tax avoidance and the tax treatment of which may not be supported in the Internal Revenue Code and related regulations. The Audit Committee will consult with Director of Tax or outside counsel to determine that the tax planning and reporting positions are consistent with this policy.
     Pursuant to the preceding paragraph, the Audit Committee has pre-approved the Tax Services in Appendix B.3. All Tax services involving large and complex transactions not listed in Appendix B.3 must be specifically pre-approved by the Audit Committee (or by any member of the Audit Committee to which pre-approval has been delegated), including tax services proposed to be provided by the Independent Auditors to any executive officer or trustee/director/managing general partner of the Fund, in his or her individual capacity, where such services are paid for by the Fund (generally applicable only to internally managed investment companies).
6. All Other Services
     The Audit Committee believes, based on the SEC’s rules prohibiting the Independent Auditors from providing specific non-audit services, that other types of non-audit services are permitted. Accordingly, the Audit Committee believes it may grant general pre-approval to those permissible non-audit services classified as All Other services that it believes are routine and recurring services, would not impair the independence of the auditor and are consistent with the SEC’s rules on auditor independence.
     The Audit Committee has pre-approved the All Other services in Appendix B.4. Permissible All Other services not listed in Appendix B.4 must be specifically pre-approved by the Audit Committee (or by any member of the Audit Committee to which pre-approval has been delegated).
     A list of the SEC’s prohibited non-audit services is attached to this policy as Appendix B.5. The SEC’s rules and relevant guidance should be consulted to determine the precise definitions of these services and the applicability of exceptions to certain of the prohibitions.
7. Pre-Approval Fee Levels or Budgeted Amounts
     Pre-approval fee levels or budgeted amounts for all services to be provided by the Independent Auditors will be established annually by the Audit Committee. Any proposed services exceeding these levels or amounts will require specific pre-approval by the Audit Committee. The Audit Committee is mindful of the overall relationship of fees for audit and non-audit services in determining whether to pre-approve any such services. For each fiscal year, the Audit Committee may determine the appropriate ratio between the total amount of fees for Audit, Audit-related, and Tax services for the Fund (including any Audit-related or Tax services fees for Covered Entities subject to pre-approval), and the total amount of fees for certain permissible non-audit services classified as All Other services for the Fund (including any such services for Covered Entities subject to pre-approval).
8. Procedures
     All requests or applications for services to be provided by the Independent Auditors that do not require specific approval by the Audit Committee will be submitted to the Fund’s Chief Financial Officer and must include a detailed description of the services to be rendered. The Fund’s Chief Financial Officer will determine whether such services are included within the list of services that have received the general pre-approval of the Audit Committee. The Audit Committee will be informed on a timely basis of any such services rendered by the Independent Auditors. Requests or applications to provide services that require specific approval by the Audit Committee will be submitted to the Audit Committee by both the Independent Auditors and the Fund’s Chief Financial Officer, and must include a joint statement as to whether, in their view, the request or application is consistent with the SEC’s rules on auditor independence.
     The Audit Committee has designated the Fund’s Chief Financial Officer to monitor the performance of all services provided by the Independent Auditors and to determine whether such services are in compliance with this Policy. The Fund’s Chief Financial Officer will report to the Audit Committee on a periodic basis on the results of its monitoring. A sample report is included as Appendix B.7. Both the Fund’s Chief Financial Officer and management will immediately report to the chairman of the Audit Committee any breach of this Policy that comes to the attention of the Fund’s Chief Financial Officer or any member of management.

 


 

9. Additional Requirements
     The Audit Committee has determined to take additional measures on an annual basis to meet its responsibility to oversee the work of the Independent Auditors and to assure the auditor’s independence from the Fund, such as reviewing a formal written statement from the Independent Auditors delineating all relationships between the Independent Auditors and the Fund, consistent with Independence Standards Board No. 1, and discussing with the Independent Auditors its methods and procedures for ensuring independence.
10. Covered Entities
     Covered Entities include the Fund’s investment adviser(s) and any entity controlling, controlled by or under common control with the Fund’s investment adviser(s) that provides ongoing services to the Fund(s). Beginning with non-audit service contracts entered into on or after May 6, 2003, the Fund’s audit committee must pre-approve non-audit services provided not only to the Fund but also to the Covered Entities if the engagements relate directly to the operations and financial reporting of the Fund. This list of Covered Entities would include:
  -   Van Kampen Investments Inc.
 
  -   Van Kampen Asset Management
 
  -   Van Kampen Advisors Inc.
 
  -   Van Kampen Funds Inc.
 
  -   Van Kampen Investor Services Inc.
 
  -   Morgan Stanley Investment Management Inc.
 
  -   Morgan Stanley Trust Company
 
  -   Morgan Stanley Investment Management Ltd.
 
  -   Morgan Stanley Investment Management Company
 
  -   Morgan Stanley Asset & Investment Trust Management Company Ltd.
(e)(2) Beginning with non-audit service contracts entered into on or after May 6, 2003, the audit committee also is required to pre-approve services to Covered Entities to the extent that the services are determined to have a direct impact on the operations or financial reporting of the Registrant. 100% of such services were pre-approved by the audit committee pursuant to the Audit Committee’s pre-approval policies and procedures (included herein).
(f) Not applicable.
(g) See table above.
(h) The audit committee of the Board of Trustees has considered whether the provision of services other than audit services performed by the auditors to the Registrant and Covered Entities is compatible with maintaining the auditors’ independence in performing audit services.
Item 5. Audit Committee of Listed Registrants.
(a) The Fund has a separately-designated standing audit committee established in accordance with Section 3(a)(58)(A) of the Exchange Act whose members are: R. Craig Kennedy, Jerry D. Choate, Rod Dammeyer.   (b) Not applicable.
Item 6. Schedule of Investments.
(a) Please refer to Item #1.
(b) Not applicable.

 


 

Item 7. Disclosure of Proxy Voting Policies and Procedures for Closed-End Management Investment Companies.
Not applicable.
Item 8. Portfolio Managers of Closed-End Management Investment Companies.
Not applicable.
Item 9. Purchases of Equity Securities by Closed-End Management Investment Company and Affiliated Purchasers.
Not applicable.
Item 10. Submission of Matters to a Vote of Security Holders.
Not applicable.
Item 11. Controls and Procedures.
(a) The Fund’s principal executive officer and principal financial officer have concluded that the Fund’s disclosure controls and procedures are sufficient to ensure that information required to be disclosed by the Fund in this Form N-CSR was recorded, processed, summarized and reported within the time periods specified in the Securities and Exchange Commission’s rules and forms, based upon such officers’ evaluation of these controls and procedures as of a date within 90 days of the filing date of the report.
(b) There were no changes in the registrant’s internal control over financial reporting that occurred during the second fiscal quarter of the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting.
Item 12. Exhibits.
(1) The Code of Ethics for Principal Executive and Senior Financial Officers is attached hereto.
(2)(a) A certification for the Principal Executive Officer of the registrant is attached hereto as part of EX-99.CERT.
(2)(b) A certification for the Principal Financial Officer of the registrant is attached hereto as part of EX-99.CERT.

 


 

SIGNATURES
Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.
(Registrant) Van Kampen Comstock Fund
By: /s/ Edward C. Wood III               
Name: Edward C. Wood III
Title: Principal Executive Officer
Date: February 19, 2009
Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed by the following persons on behalf of the registrant and in the capacities and on the dates indicated.
By: /s/ Edward C. Wood III               
Name: Edward C. Wood III
Title: Principal Executive Officer
Date: February 19, 2009
By: /s/ Stuart N. Schuldt               
Name: Stuart N. Schuldt
Title: Principal Financial Officer
Date: February 19, 2009