Exhibit 77D
Policies with respect to security investment

The Fund has revised its investment policy regarding
its investments in convertible securities.
Its revised policy provides that the Fund will invest,
under normal circumstances, at least 80% of the value
of its assets (consisting of net assets plus the
amount of any borrowings for investment purposes) in
convertible securities.  This investment policy may
be changed in the future by the Fund's Board of
Directors without shareholder approval. The Fund
will provide shareholders with at least 60 days prior
notice of any change to this investment policy. The
notice will be given in accordance with Investment
Company Act rules.