Compliance Programs of Investment Companies and Investment Advisers
30 Mar 2004

On December 3,2003, the Securities and Exchange Commission ("SEC") adopted new rules under the Investment Advisers Act of 1940 ("Advisers Act") and the Investment Company Act of 1940 ("1940 Act") that require each investment company ("fund") and investment adviser ("adviser") registered with the SEC as such to adopt and implement written policies and procedures reasonably designed to prevent violation of the federal securities laws, review these policies and procedures annually for their adequacy and the effectiveness of their implementation, and designate a chief compliance officer ("CCO") to be responsible for administering the policies and procedures.


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