Exhibit 77(d)


                POLICIES WITH RESPECT TO SECURITIES INVESTMENTS

On February 26,  2002,  the Board of Directors  of the  Registrant  adopted,  on
behalf of the Fund, and in accordance with the requirements of Rule 35d-1 of the
Investment  Company  Act of 1940,  non-fundamental  investment  policies  to (1)
invest at least 80% of the Fund's assets in the type of investment  suggested by
its name, and (2) give  shareholders  60 days' prior notice before any change in
the 80% investment policy is implemented.