EX-99.77Q2 ITEM 405 5 bcvfq2.htm BLUE CHIP VALUE FUND, INC

BLUE CHIP VALUE FUND, INC.


SUB-ITEM 77Q2: Section 16(a) Beneficial Ownership Reporting Compliance



Section 30(h) of the Investment Company Act of 1940 and Section 16(a) of the Securities Exchange Act of 1934 require that the directors and officers of Blue Chip Value Fund, Inc. (the "Company"), its investment adviser, affiliated persons of its investment adviser, and persons who own more than ten percent of the Company's shares file with the Securities and Exchange Commission initial reports of ownership and reports of changes in ownership of shares of the Company.  To the Fund's knowledge, all of these filing requirements were satisfied during 2002, except as follows:  Mr. John N. Roberts, an affiliated person of the investment adviser, did not file on a timely basis one report relating to one transaction; and Mr. Mark M. Adelmann, an officer of the Fund, did not file on a timely basis one report relating to his initial statement of beneficial ownership.  In making these disclosures, the Fund has relied on copies of reports that were furnished to it and written representations of its directors, officers and investment adviser.