SUB-ITEM 77D

Effective March 31, 2011, in determining the credit quality of debt instruments,
MFS  will  use  the  following  methodology:   if  three  Nationally  Recognized
Statistical  Rating  Organizations  ("NRSROs")  have assigned a rating to a debt
instrument, MFS will use the middle rating; if two NRSROs have assigned a rating
to a debt  instrument,  MFS will use the  lower  rating;  if only one  NRSRO has
assigned a rating to a debt  instrument,  MFS will use that rating;  and, a debt
instrument  will be  considered  unrated if none of the NRSROs  have  assigned a
rating.