Rivus Bond Fund
Form N-SAR
Item 77Q-2

Section 16(a) Beneficial Ownership Reporting Compliance

Pursuant to Item 405 of Regulation S-K, based solely upon a
review of Forms 3 and 4 and amendments thereto furnished to
the registrant under 17 CFR 240.16a-3(e) during its most
recent fiscal year and Forms 5 and amendments thereto
furnished to the registrant with respect to its most recent
fiscal year, and any written representation referred to in
paragraph (b)(1) of Item 405, there was no person who was
subject to Section 16 of the Securities Exchange Act of
1934 (the "Exchange Act") with respect to the Fund because
of the requirements of Section 30 of the Investment Company
Act of 1940 that failed to file on a timely basis reports
required by Section 16(a) of the Exchange Act during the
most recent fiscal year.