Frequently Asked Questions:
EDGAR Filing of Certified Shareholder Reports by Registered Management Investment Companies

What is the SEC requiring?

On January 22, 2003, the SEC adopted rule and form amendments that require mutual funds and other registered management investment companies to file shareholder reports on new Form N-CSR and require each registered management investment company's principal executive and financial officers to certify the information contained in these reports in the manner specified by Section 302 of the Sarbanes-Oxley Act of 2002. These certified shareholder reports are designated as reports required under Sections 13(a) and 15(d) of the Securities Exchange Act of 1934. On June 5, 2003, the SEC amended Form N-CSR to add certifications required by Section 906 of the Sarbanes-Oxley Act as a required exhibit to the form.

Are registered investment companies still required to file certifications with their reports on Form N-SAR?

The certification requirement of Form N-SAR is being removed for all registered investment companies. A registered management investment company other than a small business investment company ("SBIC") that has a fiscal annual or semi-annual period ending on or before March 31, 2003, may choose either to file Form N-CSR or to continue to comply with the certification requirements of Form N-SAR for that period. A registered management investment company other than an SBIC that has a fiscal annual or semi-annual period ending on or after April 1, 2003, is required to file Form N-CSR for that period. Beginning immediately, a unit investment trust or an SBIC is no longer required to comply with the certification requirements of Form N-SAR.

Are registered investment companies still required to file reports on Form N-SAR?

Yes.

How do I file my Form N-CSR on EDGAR?

The EDGAR submission types used in connection with Form N-CSR are as follows; use the appropriate submission type according to whether the N-CSR is an annual or semi-annual report:*

Form N-CSR	Certified annual shareholder reports for management investment companies     Initial Filing     Amendments	N-CSR N-CSR/A
Form N-CSR	Certified semi-annual shareholder reports for management investment companies     Initial Filing     Amendments	N-CSRS* N-CSRS/A*
Rule 12b-25	Notification of inability to timely file Form N-CSR     Initial Filing     Amendments	NT-NCSR NT-NCSR/A

*Separate submission types N-CSRS and N-CSRS/A for semi-annual report Form N-CSR filings will be available August 2003; until available, use N-CSR and N-CSR/A.

Do I still submit an EDGAR N-30D?

If you choose to continue to comply with the certification requirements of Form N-SAR for periods ending on or before March 31, 2003, you should continue to submit shareholder reports required under Rule 30e-1 on EDGAR as N-30D submissions.

Once you begin filing Form N-CSR, you will no longer submit shareholder reports on EDGAR as N-30D submissions. Instead, you will include your shareholder report as part of your N-CSR submission. It is designated as Item 1 of Form N-CSR; include it in your main EDGAR "N-CSR" or "N-CSRS" document.

What do I name my certification exhibit document contained in my N-CSR or N-CSRS EDGAR submission?

The EDGAR exhibit document for the certification under Section 302 of the Sarbanes-Oxley Act must be named EX-99.CERT.

The EDGAR exhibit document for the certification under Section 906 of the Sarbanes-Oxley Act must be named EX-99.906CERT.

If I have more than one certification for the same filing on Form N-CSR, how many EDGAR exhibit documents should I include?

All certifications under Section 302 should be included in one EX-99.CERT exhibit document in the N-CSR or N-CSRS submission on EDGAR.

All certifications under Section 906 should be included in one EX-99.906CERT exhibit document in the N-CSR or N-CSRS submission on EDGAR.

How do I attach and name my Form N-CSR certification exhibit document(s)?

Beginning August 2003, the "EX-99.CERT" and "EX-99.906CERT" exhibit document labels will be available on EDGAR pull down menus. Until then, follow these steps to label your exhibit documents:

1. First, complete the Main Page of Submission Template 3.  

2. Next, select Document Button from Main Page.  

3. Then, add your N-CSR or N-CSRS document and select type.  

4. Add exhibit and select EX.99 from Type pull down menu.  

5. Click in type field after EX-99 and add the period (.) and the additional text, i.e., ".CERT" or ".906CERT."

I understand that for fiscal years ending on or after July 15, 2003, I may need to file a code of ethics exhibit to my annual report on Form N-CSR. What do I name a code of ethics exhibit included as part of Item 10(a) of Form N-CSR?

Include a code of ethics or amendment to a code of ethics filed under Item 10(a) of Form N-CSR in a single EDGAR exhibit named EX-99.CODE ETH.

What if I need help to make sure my exhibit document has the correct name?

Contact Filer Support at 202-942-8900 and ask to speak with someone in the technical support unit.

Should the report to shareholders and other information required by Form N-CSR be filed as an exhibit to Form N-CSR?

No. The only information that you should place in EDGAR exhibit documents are the exhibits listed in Item 10 of Form N-CSR. You should place the remaining information required by Form N-CSR, including the shareholder report, in the main EDGAR document named "N-CSR" or "N-CSRS."

Do BDC's and face-amount certificate companies have to file on Form N-CSR?

No. Business development companies and face-amount certificate companies file periodic reports on Forms 10-K and 10-Q under the Exchange Act, and they are required to comply with the certification requirements applicable to these forms.

Where do I get more information about the rules, including additional requirements for the contents of Form N-CSR?

See Release Nos. 34-47262, IC-25914 (Jan. 27, 2003), adopting Form N-CSR, available on our website at:

http://www.sec.gov/rules/final/34-47262.htm

Form N-CSR was amended to require disclosure of information related to audit and non-audit services provided by, and fees paid to, the auditor of the financial statements of a management investment company. For details concerning these requirements, see Release Nos. 33-8183, 34-47265, 35-27642, IC-25915, IA-2103, FR-68 (Jan. 28, 2003), available on our website at:

http://www.sec.gov/rules/final/33-8183.htm

Form N-CSR was amended to require disclosure regarding proxy voting policies and procedures of closed-end management investment companies. For details concerning these requirements, see Release Nos. 33-8188, 34-47304, IC-25922 (Jan. 31, 2003), available on our website at:

http://www.sec.gov/rules/final/33-8188.htm

Form N-CSR was amended to require disclosure regarding audit committees of listed registrants subject to Rule 10A-3 under the Exchange Act. For details concerning these requirements, see Release Nos. 33-8220, 34-47654, IC-26001 (Apr. 9, 2003), available on our website at:

http://www.sec.gov/rules/final/33-8220.htm

Form N-CSR was amended to add the certifications required by Section 906 of the Sarbanes-Oxley Act of 2002 [18 U.S.C. 1350] as a required exhibit to reports on Form N-CSR filed under Section 13(a) or 15(d) of the Exchange Act, and to make technical changes to the Section 302 certification of Form N-CSR. For details concerning these requirements, see Release Nos. 33-8238, 34-47986; IC-26068 (June 5, 2003), available on our website at:

http://www.sec.gov/rules/final/33-8238.htm

http://www.sec.gov/info/edgar/certinvco.htm