EX-99.77O RULE 10F-3 3 variablestrategisttenfthree.txt MORGAN STANLEY VARIABLE INVESTMENT SERIES STRATEGIST 10F3 Morgan Stanley Variable Investment Series - Strategist Portfolio Item 77O- Transactions effected pursuant to Rule 10f-3 Securities Purchased: Anheuser-Busch Inbev Worldwide 3.750% due 7/15/2042 Purchase/Trade Date: 7/11/2012 Offering Price of Shares: $99.092 Total Amount of Offering: $1,000,000,000 Amount Purchased by Fund: $25,000 Percentage of Offering Purchased by Fund: 0.003 Percentage of Fund's Total Assets: 0.07 Brokers: BofA Merrill Lynch, Barclays, Deutsche Bank Securities, BNP Paribas, Mitsubishi UFJ Securities, Mizuho Securities, RBS, Societe Generale, ING, Santander, Rabo Securities, SMBC Nikko, TD Securities Purchased from: Deutsche Bank Securities Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: Nippon Telegraph and Telephone 1.400% due 7/18/2017 Purchase/Trade Date: 7/11/2012 Offering Price of Shares: $99.865 Total Amount of Offering: $750,000,000 Amount Purchased by Fund: $50,000 Percentage of Offering Purchased by Fund: 0.007 Percentage of Fund's Total Assets: 0.15 Brokers: BofA Merrill Lynch, Barclays, Morgan Stanley, BNP Paribas, Citigroup, Credit Suisse, Deutsche Bank Securities, Goldman, Sachs & Co., J.P. Morgan, UBS Investment Bank Purchased from: Merrill Lynch Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: Altria Group Inc. 2.850% due 8/9/2022 Purchase/Trade Date: 8/6/2012 Offering Price of Shares: $99.888 Total Amount of Offering: $1,900,000,000 Amount Purchased by Fund: $80,000 Percentage of Offering Purchased by Fund: 0.004 Percentage of Fund's Total Assets: 0.25 Brokers: Citigroup, Deutsche Bank Securities, JP Morgan, Barclays, Credit Suisse, HSBC, Scotiabank, Wells Fargo Securities, Banca IMI, Goldman, Sachs & Co., Loop Capital Markets, Morgan Stanley, RBC, Santander, The Williams Capital Group, L.P., US Bancorp Purchased from: JP Morgan Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: Celgene Corp. 3.250% due 8/15/2022 Purchase/Trade Date: 8/6/2012 Offering Price of Shares: $99.949 Total Amount of Offering: $1,000,000,000 Amount Purchased by Fund: $95,000 Percentage of Offering Purchased by Fund: 0.010 Percentage of Fund's Total Assets: 0.29 Brokers: BofA Merrill Lynch, JP Morgan, Morgan Stanley Purchased from: Merrill Lynch Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: Time Warner Cable Inc. 4.500% due 9/15/2042 Purchase/Trade Date: 8/7/2012 Offering Price of Shares: $99.439 Total Amount of Offering: $1,250,000,000 Amount Purchased by Fund: $15,000 Percentage of Offering Purchased by Fund: 0.001 Percentage of Fund's Total Assets: 0.05 Brokers: BNP Paribas, Citigroup, Morgan Stanley, RNC Capital Markets, Credit Suisse, Barclays, BNY Mellon Capital Markets, LLC, Credit Agricole CIB, Deutsche Bank Securities, Goldman, Sachs & Co., JP Morgan, Lloyds Securities, Mitsubishi UFJ Securities, Mizuho Securities, Ramirez & Co., Inc., RBS, SMBC Nikko, The Williams Capital Group, L.P., UBS Investment Bank, US Bancorp Purchased from: BNP Paribas Securities Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*:YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: Thermo Fisher 3.150% due 1/15/2023 Purchase/Trade Date: 8/15/2012 Offering Price of Shares: $99.475 Total Amount of Offering: $800,000,000 Amount Purchased by Fund: $50,000 Percentage of Offering Purchased by Fund: 0.006 Percentage of Fund's Total Assets: 0.15 Brokers: Goldman, Sachs & Co., J.P. Morgan, RBS, Barclays, BofA Merrill Lynch, Deutsche Bank Securities, Morgan Stanley, BNP Paribas, HSBC, Mitsubishi UFJ Securities, Banca IMI, ING, KeyBanc Capital Markets, Scotia Capital, US Bancorp Purchased from: Royal Bank of Scotland Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: EOG Resources Inc. 2.625% due 3/15/2023 Purchase/Trade Date: 9/5/2012 Offering Price of Shares: $99.381 Total Amount of Offering: $1,250,000,000 Amount Purchased by Fund: $50,000 Percentage of Offering Purchased by Fund: 0.004 Percentage of Fund's Total Assets: 0.15 Brokers: Barclays, Citigroup, JP Morgan, UBS Investment Bank, Wells Fargo Securities, RBC Capital Markets, Mitsubishi UFJ Securities, Societe Generale, US Bancorp, Allen & Company LLC, ANZ Securities, BB&T Capital Markets, BMO Capital Markets, Comerica Securities, Credit Suisse, Deutsche Bank Securities, DNB Markets, Goldman, Sachs & Co., Scotiabank Purchased from: JP Morgan Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: Waste Management Inc. 2.900% due 9/15/2022 Purchase/Trade Date: 9/5/2012 Offering Price of Shares: $99.681 Total Amount of Offering: $500,000,000 Amount Purchased by Fund: $50,000 Percentage of Offering Purchased by Fund: 0.010 Percentage of Fund's Total Assets: 0.15 Brokers: Barclays, BNP Paribas, BofA Merrill Lynch, Goldman, Sachs & Co., JP Morgan, Morgan Stanley, PNC Capital Markets LLC, Scotiabank, US Bancorp Purchased from: Barclays Capital Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: Wellpoint Inc. 3.300% due 1/15/2023 Purchase/Trade Date: 9/5/2012 Offering Price of Shares: $99.663 Total Amount of Offering: $1,000,000,000 Amount Purchased by Fund: $20,000 Percentage of Offering Purchased by Fund: 0.002 Percentage of Fund's Total Assets: 0.06 Brokers: Citigroup, Credit Suisse, Deutsche Bank Securities, BofA Merrill Lynch, UBS Investment Bank, Wells Fargo Securities, JP Morgan, Morgan Stanley, SunTrust Robinson Humphrey, US Bancorp, BB& T Capital Markets, BNY Mellon Capital Makrets, LLC, Fifth Third Securities, Inc., Huntington Investment Company, Mitsubishi UFJ Securities, Mizuho Securities, PNC Capital Markets LLC, SMBC Nikko Purchased from: Credit Suisse Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: Avalonbay Communities Inc. 2.950% due 9/15/2022 Purchase/Trade Date: 9/6/2012 Offering Price of Shares: $99.785 Total Amount of Offering: $450,000,000 Amount Purchased by Fund: $50,000 Percentage of Offering Purchased by Fund: 0.011 Percentage of Fund's Total Assets: 0.15 Brokers: UBS Securities LLC, Goldman, Sachs & Co., JP Morgan Securities LLC, BNY Mellon Capital Markets, LLC, Mitsubishi UFJ Securities (USA), Inc., SunTrust Robinson Humphrey, Inc. Purchased from: UBS Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: FMC Technologies Inc. 3.450% due 10/1/2022 Purchase/Trade Date: 9/18/2012 Offering Price of Shares: $99.915 Total Amount of Offering: $500,000,000 Amount Purchased by Fund: $20,000 Percentage of Offering Purchased by Fund: 0.004 Percentage of Fund's Total Assets: 0.06 Brokers: JP Morgan, Wells Fargo Securities, DNB Markets, Mitsubishi UFJ Securities, RBS, US Bancorp Purchased from: Wells Fargo Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: Watson Pharmaceuticals Inc. 3.250% due 10/1/2022 Purchase/Trade Date: 9/27/2012 Offering Price of Shares: $99.165 Total Amount of Offering: $1,700,000,000 Amount Purchased by Fund: $15,000 Percentage of Offering Purchased by Fund: 0.001 Percentage of Fund's Total Assets: 0.05 Brokers: BofA Merrill Lynch, Wells Fargo Securities, Barclays, JP Morgan, Deutsche Bank Securities, DNB Markets, HSBC, RBS, US Bancorp Purchased from: Wells Fargo Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: Watson Pharmaceuticals Inc. 4.625% due 10/1/2042 Purchase/Trade Date: 9/27/2012 Offering Price of Shares: $98.516 Total Amount of Offering: $1,000,000,000 Amount Purchased by Fund: $10,000 Percentage of Offering Purchased by Fund: 0.001 Percentage of Fund's Total Assets: 0.03 Brokers: BofA Merrill Lynch, Wells Fargo Securities, Barclays, JP Morgan, Mizuho Securities, DNB Markets, HSBC, RBS, US Bancorp Purchased from: Merrill Lynch Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: NBC Universal Media LLC 2.875% due 1/15/2023 Purchase/Trade Date: 9/28/2012 Offering Price of Shares: $99.817 Total Amount of Offering: $1,000,000,000 Amount Purchased by Fund: $25,000 Percentage of Offering Purchased by Fund: 0.003 Percentage of Fund's Total Assets: 0.08 Brokers: Credit Suisse, JP Morgan , Morgan Stanley, RBC Capital Markets, Barclays, BNP Paribas, BofA Merrill Lynch, Citigroup, Deutsche Bank Securities, Goldman, Sachs & Co., Lloyds Securities, Mizuho Securities, RBS, SMBC Nikko, UBS Investment Bank, Wells Fargo Securities, Santander, US Bancorp, Allen & Company LLC, Gleacher & Company, DnB NOR Markets, PNC Capital Markets LLC, SunTrust Robinson Humphrey, TD Securities, Loop Capital Markets, The Williams Capital Group, L.P., Drexel Hamilton, Lebenthal Capital Markets, MFR Securities, Inc. Ramirez & Co., Inc. Purchased from: Credit Suisse Securities Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: Unitedhealth Group Incorporated 1.400% due 10/15/2017 Purchase/Trade Date: 10/17/2012 Offering Price of Shares: $99.880 Total Amount of Offering: $625,000,000 Amount Purchased by Fund: $25,000 Percentage of Offering Purchased by Fund: 0.004 Percentage of Fund's Total Assets: 0.08 Brokers: JP Morgan, BofA Merrill Lynch, Goldman, Sachs & Co., Morgan Stanley, UBS Investment Bank, Wells Fargo Securities, Barclays Capital, BNY Mellon Capital Markets, LLC, Citigroup, Deutsche Bank Securities, RBS, US Bancorp, BB&T Capital Markets, BMO Capital Marktes, Credit Suisse, Fifth Third Securities, Inc., KeyBanc Capital Markets, Loop Capital Markets, PNC Capital Markets LLC Purchased from: JP Morgan Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: Unitedhealth Group Incorporated 2.750% due 2/15/2023 Purchase/Trade Date: 10/17/2012 Offering Price of Shares: $99.842 Total Amount of Offering: $625,000,000 Amount Purchased by Fund: $15,000 Percentage of Offering Purchased by Fund: 0.002 Percentage of Fund's Total Assets: 0.05 Brokers: JP Morgan, BofA Merrill Lynch, Goldman, Sachs & Co., Morgan Stanley, UBS Investment Bank, Wells Fargo Securities, Barclays Capital, BNY Mellon Capital Markets, LLC, Citigroup, Deutsche Bank Securities, RBS, US Bancorp, BB&T Capital Markets, BMO Capital Markets, Credit Suisse, Fifth Third Securities, Inc., KeyBanc Capital Markets, Loop Capital Markets, PNC Capital Markets LLC Purchased from: JP Morgan Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: Oracle Systems 1.200% due 10/15/2017 Purchase/Trade Date: 10/18/2012 Offering Price of Shares: $99.827 Total Amount of Offering: $2,500,000,000 Amount Purchased by Fund: $150,000 Percentage of Offering Purchased by Fund: 0.006 Percentage of Fund's Total Assets: 0.47 Brokers: Citigroup, JP Morgan, RBS, Wells Fargo Securities, BNP Paribas, BofA Merrill Lynch, Mitsubishi UFJ Securities, Barclays, Credit Suisse, Deutsche Bank Securities, HSBC, Mizuho Securities, RBC Capital Markets, UBS Investment Bank, US Bancorp Purchased from: Royal Bank of Scotland Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: CR Bard, Inc. 1.375% due 1/15/2018 Purchase/Trade Date: 10/25/2012 Offering Price of Shares: $99.873 Total Amount of Offering: $500,000,000 Amount Purchased by Fund: $65,000 Percentage of Offering Purchased by Fund: 0.013 Percentage of Fund's Total Assets: 0.20 Brokers: BofA Merrill Lynch, Goldman, Sachs & Co., Wells Fargo Securities, Barclays, JP Morgan, PNC Capital Markets LLC, RBC Capital Markets, Mitsubishi UFJ Securities, SunTrust Robinson Humphrey, US Bancorp Purchased from: Goldman Sachs Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: Aetna Inc. 2.750% due 11/15/2022 Purchase/Trade Date: 11/2/2012 Offering Price of Shares: $98.309 Total Amount of Offering: $1,000,000,000 Amount Purchased by Fund: $70,000 Percentage of Offering Purchased by Fund: 0.007 Percentage of Fund's Total Assets: 0.21 Brokers: Goldman, Sachs & Co., UBS Investment Bank, JP Morgan, Morgan Stanley, RBS, Barclays, BofA Merrill Lynch, Citigroup, Credit Suisse, Mitsubishi UFJ Securities, SunTrust Robinson Humphrey, US Bancorp, Wells Fargo Securities, BNY Mellon Capital Markets, LLC, HSBC, Fifth Third Securities, Inc., PNC Capital Markets LLC Purchased from: Goldman Sachs Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: Aetna Inc. 4.125% due 11/7/2024 Purchase/Trade Date: 11/2/2012 Offering Price of Shares: $98.457 Total Amount of Offering: $500,000,000 Amount Purchased by Fund: $15,000 Percentage of Offering Purchased by Fund: 0.003 Percentage of Fund's Total Assets: 0.05 Brokers: Goldman, Sachs & Co., UBS Investment Bank, JP Morgan, Morgan Stanley, RBS, Barclays, BofA Merrill Lynch, Citigroup, Credit Suisse, Mitsubishi UFJ Securities, SunTrust Robinson Humphrey, US Bancorp, Wells Fargo Securities, BNY Mellon Capital Markets, LLC, HSBC, Fifth Third Securities, Inc., PNC Capital Markets LLC Purchased from: UBS Securities Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: Verizon Communications Inc. 3.850% due 11/1/2042 Purchase/Trade Date: 11/2/2012 Offering Price of Shares: $99.859 Total Amount of Offering: $1,250,000,000 Amount Purchased by Fund: $95,000 Percentage of Offering Purchased by Fund: 0.008 Percentage of Fund's Total Assets: 0.30 Brokers: Barclays, BofA Merrill Lynch, JP Morgan, RBS, Citigroup, Goldman, Sachs & Co., RBC Capital Markets, Wells Fargo Securities, Credit Suisse, Deutsche Bank Securities, Mitsubishi UFJ Securities, Mizuho Securities, Santander, UBS Investment Bank, Lloyds Securities, SMBC Nikko, US Bancorp Purchased from: JP Morgan Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: Abbvie Inc. 4.400% due 11/6/2042 Purchase/Trade Date: 11/5/2012 Offering Price of Shares: $98.964 Total Amount of Offering: $2,600,000,000 Amount Purchased by Fund: $45,000 Percentage of Offering Purchased by Fund: 0.002 Percentage of Fund's Total Assets: 0.14 Brokers: Morgan Stanley, Barclays, BofA Merrill Lynch, JP Morgan, Deutsche Bank Securities, RBS, BNP Paribas, Societe Generale, Banca IMI, Goldman, Sachs & Co., Handelsbanken Capital Markets, HSBC, ING, Loop Capital Markets, Mitsubishi UFJ Securities, Mizuho Securities, RBC Capital Markets, Santander, Standard Chartered Bank, UBS Investment Bank, US Bancorp, The Williams Capital Group, L.P. Purchased from: Barclays Capital Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: Turlock Corporation (to be merged with and into Eaton) 2.750% due 11/2/2022 Purchase/Trade Date: 11/14/2012 Offering Price of Shares: $99.664 Total Amount of Offering: $1,600,000,000 Amount Purchased by Fund: $55,000 Percentage of Offering Purchased by Fund: 0.003 Percentage of Fund's Total Assets: 0.17 Brokers: Citigroup, Morgan Stanley, BofA Merrill Lynch, Deutsche Bank Securities, JP Morgan Purchased from: JP Morgan Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: British Sky Broadcasting Group PLC 3.125% due 11/26/2022 Purchase/Trade Date: 11/19/2012 Offering Price of Shares: $99.566 Total Amount of Offering: $800,000,000 Amount Purchased by Fund: $50,000 Percentage of Offering Purchased by Fund: 0.006 Percentage of Fund's Total Assets: 0.16 Brokers: Barclays, JP Morgan, BNP Paribas, Morgan Stanley, Societe Generale Purchased from: JP Morgan Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: Amazon.com Inc. 1.200% due 11/29/2017 Purchase/Trade Date: 11/26/2012 Offering Price of Shares: $99.513 Total Amount of Offering: $1,000,000,000 Amount Purchased by Fund: $55,000 Percentage of Offering Purchased by Fund: 0.006 Percentage of Fund's Total Assets: 0.17 Brokers: Morgan Stanley, Goldman, Sachs & Co., HSBC, BofA Merrill Lynch Purchased from: Goldman Sachs Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: Cox Communications Inc. 3.250% due 12/15/2022 Purchase/Trade Date: 11/26/2012 Offering Price of Shares: $99.846 Total Amount of Offering: $1,000,000,000 Amount Purchased by Fund: $25,000 Percentage of Offering Purchased by Fund: 0.003 Percentage of Fund's Total Assets: 0.08 Brokers: JP Morgan, Wells Fargo Securities, Barclays, Citigroup, BofA Merrill Lynch, Goldman, Sachs & Co., Morgan Stanley, RBC Capital Markets, SunTrust Robinson Humphrey, Credit Agricole CIB, Deutsche Bank Securities, Fifth Third Securities, Inc., Mizuho Securities, RBS, SMBC Nikko Purchased from: JP Morgan Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: Murphy Oil Corporation 3.700% due 12/1/2022 Purchase/Trade Date: 11/27/2012 Offering Price of Shares: $99.594 Total Amount of Offering: $600,000,000 Amount Purchased by Fund: $50,000 Percentage of Offering Purchased by Fund: 0.008 Percentage of Fund's Total Assets: 0.16 Brokers: JP Morgan, BofA Merrill Lynch, Deutsche Bank Securities, RBC Capital Markets, Wells Fargo Securities, Citigroup, DNB Markets, Mitsubishi UFJ Securities, Capital One Southcoast, Comerica Securities, Fifth Third Securities, Inc., Raymond James Morgan Keegan, Scotiabank, US Bancorp Purchased from: JP Morgan Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: McKesson Corporation 2.700% due 12/4/2015 Purchase/Trade Date: 11/29/12 Offering Price of Shares: $99.886 Total Amount of Offering: $400,000,000 Amount Purchased by Fund: $55,000 Percentage of Offering Purchased by Fund: 0.014 Percentage of Fund's Total Assets: 0.17 Brokers: BofA Merrill Lynch, JP Morgan, Mitsubishi UFJ Securities, Scotiabank, PNC Capital Markets LLC, Fifth Third Securities, Inc., Rabo Securities, Wells Fargo Securities, HSBC, Lloyds Securities, TD Securities, US Bancorp Purchased from: Merrill Lynch Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: Intel Corp. 2.750% due 12/15/2022 Purchase/Trade Date: 12/4/12 Offering Price of Shares: $99.573 Total Amount of Offering: $1,500,000,000 Amount Purchased by Fund: $50,000 Percentage of Offering Purchased by Fund: 0.003 Percentage of Fund's Total Assets: 0.16 Brokers: BofA Merrill Lynch, JP Morgan, Credit Suisse, Morgan Stanley, Needham & Company, Wells Fargo Securities Purchased from: Merrill Lynch Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO. Securities Purchased: NetApp Inc. 2.000% due 12/15/2017 Purchase/Trade Date: 12/5/2012 Offering Price of Shares: $99.494 Total Amount of Offering: $750,000,000 Amount Purchased by Fund: $25,000 Percentage of Offering Purchased by Fund: 0.003 Percentage of Fund's Total Assets: 0.08 Brokers: JP Morgan, Morgan Stanley, BofA Merrill Lynch, Citigroup, Goldman, Sachs & Co., Wells Fargo Securities Purchased from: JP Morgan Firm Commitment Underwriting: YES Issuer has over three years of continuous operations*: YES Percent of offering purchased by Fund and all other accounts advised by the adviser is less than 25%: YES The underwriting commission, spread and profit is reasonable and fair compared to the underwritings of similar securities: YES * Muni issuers must also have an investment grade rating from at least one NRSRO; or if less than three years of continuous operations, must have one of the three highest rating categories from at least one NRSRO.