10f-3 Transactions
Fund: Value Portfolio
Issuer: Metlife Inc. Convertible Preferred
Ticker: Miu.PP
Principal Amount: $1,006,250,000
Amount Purchased: $1,875,000.00
Trade date: 4/04/2000
Price: $50.00
Broker: GSCO
Underwriting spread 3.50%
Fund: Value Portfolio
Issuer: John Hancock Financial Services
Ticker: JIIF
Principal Amount: $1,994,100,000
Amount Purchased: $3,400.00, $8,500.00, $13,600.00,
$15,300.00,$766,700.00 (Split order)
Trade date: 1/26/2000
Price: $17.00
Broker: TUCK, MERR, FPKI, FBCO, MSCO
Underwriting spread 4.40%
Fund: Focused Value Portfolio
Issuer: John Hancock Financial Serices
Ticker: JHF
Principal Amount: $1,994,100,000
Amount Purchased: $3,400.00, $8,500.00, $15,300.00,
5,300.00,$802,400.00 (Split order)
Trade date: 1/26/2000
Price: $17.00
Broker: TUCK, MERR, FPKI, FBCO, MSCO
Underwriting spread 4.40%
Fund International Equity
Underwriter Deutsche Bank
Name of issuer Amadeus
Title of security Amadeus
Date of offering 10-15-99
Amount of Total Offering $128,260,870
Unit Price 5.75 EUR
Underwriting Spread or Commission 0.0948 EUR
Dollar Amount of Purchased $163,807
Number of Shares Purchased 26,378
Years of Continuous Operation 3+
% of Offering Purchased by Portfolio 0.01
% of Offering Purchased by other Portfolio of the Fund &
other
Investment companies advised by the Adviser or any
Subadvisor
0.59%
Sum 0f (14)and (15) 0.60
% of Portfolio Assets applied to the Purchase .5
Is the adviser, any subadvisor or any person of which the
Adviser or subadvisor is an affiliated person, a manager
or
Comanager of the offering? NO
Were Purchases Designated as Group Sales or otherwise
allocated
To the adviser, any subadvisor or any person of whom the
adviser
Or subadvisor is an affiliated person? NO
Fund International Equity
Underwriter Deutsche Bank
Name of issuer ENEL
Title of security ENEL
Date of offering 11-2-99
Amount of Total Offering $2,400,000,000
Unit Price 4.3 EUR
Underwriting Spread or Commission .04p
Dollar Amount of Purchased $604,802
Number of Shares Purchased 133,820
Years of Continuous Operation 3+
% of Offering Purchased by Portfolio 0.01
% of Offering Purchased by other Portfolio of the Fund &
other
Investment companies advised by the Adviser or any
Subadvisor
0.46
Sum 0f (14)and (15) 0.47
% of Portfolio Assets applied to the Purchase .85
Is the adviser, any subadvisor or any person of which the
Adviser or subadvisor is an affiliated person, a manager or
Comanager of the offering? NO
Were Purchases Designated as Group Sales or otherwise allocated
To the adviser, any subadvisor or any person of whom the adviser
Or subadvisor is an affiliated person? NO
Fund International Equity
Underwriter DB Alex Brown
Name of issuer Thomas Multimedia
Title of security Thomas Multimedia
Date of offering 11-3-99
Amount of Total Offering $21,105,486
Unit Price 21.5 EUR
Underwriting Spread or Commission .3225 EUR
Dollar Amount of Purchased $34,741
Number of Shares Purchased 1,540
Years of Continuous Operation 3+
% of Offering Purchased by Portfolio 0.01
% of Offering Purchased by other Portfolio of the Fund & other
Investment companies advised by the Adviser or any Subadvisor
0.59
Sum 0f (14)and (15) 0.60
% of Portfolio Assets applied to the Purchase 0.05
Is the adviser, any subadvisor or any person of which the
Adviser or subadvisor is an affiliated person, a manager or
Comanager of the offering? NO
Were Purchases Designated as Group Sales or otherwise allocated
To the adviser, any subadvisor or any person of whom the adviser
Or subadvisor is an affiliated person? NO
Fund International Equity
Underwriter Deutsche Bank
Name of issuer EM.TV & Advertising
Title of security EM.TV & Advertising
Date of offering 11-10-99
Amount of Total Offering $11,000,000
Unit Price 45 EUR
Underwriting Spread or Commission .9585 EUR
Dollar Amount of Purchased $68,850
Number of Shares Purchased 1,500
Years of Continuous Operation 3+
% of Offering Purchased by Portfolio 0.05
% of Offering Purchased by other Portfolio of the Fund & other
Investment companies advised by the Adviser or any Subadvisor
1.00
Sum 0f (14)and (15) 1.01
% of Portfolio Assets applied to the Purchase 0.25
Is the adviser, any subadvisor or any person of which the
Adviser or subadvisor is an affiliated person, a manager or
Comanager of the offering? NO
Were Purchases Designated as Group Sales or otherwise allocated
To the adviser, any subadvisor or any person of whom the adviser
Or subadvisor is an affiliated person? NO
Fund International Equity
Underwriter Deutsche Bank
Name of issuer Buhrmann
Title of security Buhrmann
Date of offering 11-15-99
Amount of Total Offering $19,500,000
Unit Price 15 .75 EUR
Underwriting Spread or Commission .126 EUR
Dollar Amount of Purchased $160,000
Number of Shares Purchased 10,340
Years of Continuous Operation 3+
% of Offering Purchased by Portfolio 0.05
% of Offering Purchased by other Portfolio of the Fund & other
Investment companies advised by the Adviser or any Subadvisor
3.90%
Sum 0f (14)and (15) 3.95
% of Portfolio Assets applied to the Purchase 0.31
Is the adviser, any subadvisor or any person of which the
Adviser or subadvisor is an affiliated person, a manager or
Comanager of the offering? NO
Were Purchases Designated as Group Sales or otherwise allocated
To the adviser, any subadvisor or any person of whom the adviser
Or subadvisor is an affiliated person? NO
Fund International Equity
Underwriter Deutsche Bank
Name of issuer NDS
Title of security NDS
Date of offering 11-23-99
Amount of Total Offering $9,000,000
Unit Price $20.00
Underwriting Spread or Commission $0.72
Dollar Amount of Purchased $170,720
Number of Shares Purchased 8,536
Years of Continuous Operation 3+
% of Offering Purchased by Portfolio 0.09
% of Offering Purchased by other Portfolio of the Fund & other
Investment companies advised by the Adviser or any Subadvisor
0.57
Sum 0f (14)and (15) 0.66
% of Portfolio Assets applied to the Purchase 0.02
Is the adviser, any subadvisor or any person of which the
Adviser or subadvisor is an affiliated person, a manager or
Comanager of the offering? NO
Were Purchases Designated as Group Sales or otherwise allocated
To the adviser, any subadvisor or any person of whom the adviser
Or subadvisor is an affiliated person? NO
Fund International Equity
Underwriter Deutsche Bank
Name of issuer Equant
Title of security Equant
Date of offering 12-3-99
Amount of Total Offering $26,000,000
Unit Price 91 Eur
Underwriting Spread or Commission 2.2294 EUR
Dollar Amount of Purchased $390,000
Number of Shares Purchased 4,250
Years of Continuous Operation 3+
% of Offering Purchased by Portfolio 0.02
% of Offering Purchased by other Portfolio of the Fund & other
Investment companies advised by the Adviser or any Subadvisor
1.20
Sum 0f (14)and (15) 1.22
% of Portfolio Assets applied to the Purchase 0.84
Is the adviser, any subadvisor or any person of which the
Adviser or subadvisor is an affiliated person, a manager or
Comanager of the offering? NO
Were Purchases Designated as Group Sales or otherwise allocated
To the adviser, any subadvisor or any person of whom the adviser
Or subadvisor is an affiliated person? NO
Fund International Equity
Underwriter Deutsche Bank
Name of issuer Infonet
Title of security Infonet
Date of offering 12-16-99
Amount of Total Offering $51,282,300
Unit Price 21 Eur
Underwriting Spread or Commission 0.6 EUR
Dollar Amount of Purchased $140,469
Number of Shares Purchased 6,689
Years of Continuous Operation 3+
% of Offering Purchased by Portfolio 0.01
% of Offering Purchased by other Portfolio of the Fund & other
Investment companies advised by the Adviser or any Subadvisor
1.45
Sum 0f (14)and (15) 1.46
% of Portfolio Assets applied to the Purchase 0.40
Is the adviser, any subadvisor or any person of which the
Adviser or subadvisor is an affiliated person, a manager or
Comanager of the offering? NO
Were Purchases Designated as Group Sales or otherwise allocated
To the adviser, any subadvisor or any person of whom the adviser
Or subadvisor is an affiliated person? NO
Fund International Equity
Underwriter Goldman Sachs
Name of issuer Goldman Sachs
Title of security Infineon
Date of offering 3-13-00
Amount of Total Offering $154,200,000
Unit Price 35 Eur
Underwriting Spread or Commission 0.55 EUR
Dollar Amount of Purchased $9,812
Number of Shares Purchased 289
Years of Continuous Operation 3+
% of Offering Purchased by Portfolio 0.00
% of Offering Purchased by other Portfolio of the Fund & other
Investment companies advised by the Adviser or any Subadvisor
0.12
Sum 0f (14)and (15) 0.12
% of Portfolio Assets applied to the Purchase 0.02
Is the adviser, any subadvisor or any person of which the
Adviser or subadvisor is an affiliated person, a manager or
Comanager of the offering? NO
Were Purchases Designated as Group Sales or otherwise allocated
To the adviser, any subadvisor or any person of whom the adviser
Or subadvisor is an affiliated person? NO
Fund International Equity
Underwriter Morgan Stanley
Name of issuer Morgan Stanley
Title of security LastMinute.com
Date of offering 3-13-00
Amount of Total Offering $33,000,000
Unit Price 3.8 GBP
Underwriting Spread or Commission 0.1596GBP
Dollar Amount of Purchased $8,117
Number of Shares Purchased 1335
Years of Continuous Operation 3+
% of Offering Purchased by Portfolio 0.00
% of Offering Purchased by other Portfolio of the Fund & other
Investment companies advised by the Adviser or any Subadvisor
0.40
Sum 0f (14)and (15) 0.40
% of Portfolio Assets applied to the Purchase 0.01
Is the adviser, any subadvisor or any person of which the
Adviser or subadvisor is an affiliated person, a manager or
Comanager of the offering? NO
Were Purchases Designated as Group Sales or otherwise allocated
To the adviser, any subadvisor or any person of whom the adviser
Or subadvisor is an affiliated person? NO
Fund International Equity
Underwriter CSFB
Name of issuer CSFB
Title of security Sunday Communicatiosn
Date of offering 3-10-00
Amount of Total Offering $690,000,000
Unit Price $14.72
Underwriting Spread or Commission $0.62
Dollar Amount of Purchased $44,151
Number of Shares Purchased 3000
Years of Continuous Operation 3+
% of Offering Purchased by Portfolio 0.00
% of Offering Purchased by other Portfolio of the Fund & other
Investment companies advised by the Adviser or any Subadvisor
0.02
Sum 0f (14)and (15) 0.02
% of Portfolio Assets applied to the Purchase 0.07
Is the adviser, any subadvisor or any person of which the
Adviser or subadvisor is an affiliated person, a manager or
Comanager of the offering? NO
Were Purchases Designated as Group Sales or otherwise allocated
To the adviser, any subadvisor or any person of whom the adviser
Or subadvisor is an affiliated person? NO
Fund Mid-Cap Growth
Security Charter Communications
Date of Transaction 11/18/99
Purchase Price per Unit 19.00
Amount of commission per unit 0.00
Gross Commission as a % of Price 0.00
Total Amount of Offering 3,230,000,000
Total Amount of Purchase 571,900
Purchase as a % of Offering 0.02%
Purchase as a % Fund Assets 1.11%
Name of Affiliated Broker/dealer in Syndicate
Morgan Stanley, Dean Witter
Name of Broker\Dealer whom securities were purchased
Goldman Sachs
Fund Mid-Cap Growth
Security Celestica
Date of Transaction 11/8/99
Purchase Price per Unit 60.63
Amount of commission per unit 0.00
Gross Commission as a % of Price 0.00
Total Amount of Offering 424,375,000
Total Amount of Purchase 218,250
Purchase as a % of Offering 0.05%
Purchase as a % Fund Assets 0.42%
Name of Affiliated Broker/dealer in Syndicate
Morgan Stanley, Dean Witter
Name of Broker\Dealer whom securities were purchased
Merrill Lynch
Fund Mid-Cap Growth
Security Expedia
Date of Transaction 11/9/99
Purchase Price per Unit 14.00
Amount of commission per unit 0.00
Gross Commission as a % of Price 0.00
Total Amount of Offering 58,240,000
Total Amount of Purchase 1,400
Purchase as a % of Offering 0.00%
Purchase as a % Fund Assets 0.00%
Name of Affiliated Broker/dealer in Syndicate
Morgan Stanley, Dean Witter
Name of Broker\Dealer whom securities were purchased
Goldman Sachs
Fund Mid-Cap Growth
Security Cacheflow
Date of Transaction 11/18/99
Purchase Price per Unit 24.00
Amount of commission per unit 0.00
Gross Commission as a % of Price 0.00
Total Amount of Offering 120,000,000
Total Amount of Purchase 7,200
Purchase as a % of Offering 0.01%
Purchase as a % Fund Assets 0.01%
Name of Affiliated Broker/dealer in Syndicate
Morgan Stanley, Dean Witter
Name of Broker\Dealer whom securities were purchased
CS First Boston
Fund Mid-Cap Growth
Security Freemarkets
Date of Transaction 12/9/99
Purchase Price per Unit 48.00
Amount of commission per unit 0.00
Gross Commission as a % of Price 0.00
Total Amount of Offering 172,800,000
Total Amount of Purchase 4,800
Purchase as a % of Offering 0.00%
Purchase as a % Fund Assets 0.01%
Name of Affiliated Broker/dealer in Syndicate
Morgan Stanley, Dean Witter
Name of Broker\Dealer whom securities were purchased
CS First Boston
Fund Mid-Cap Growth
Security Infonet Serivces
Date of Transaction 12/14/99
Purchase Price per Unit 21.00
Amount of commission per unit 0.00
Gross Commission as a % of Price 0.00
Total Amount of Offering 1,076,928,300
Total Amount of Purchase 71,400
Purchase as a % of Offering 0.01%
Purchase as a % Fund Assets 0.13%
Name of Affiliated Broker/dealer in Syndicate
Morgan Stanley, Dean Witter
Name of Broker\Dealer whom securities were purchased
Merrill Lynch
Fund Mid-Cap Growth
Security Dobson Communications
Date of Transaction 2/3/00
Purchase Price per Unit 22.00
Amount of commission per unit 0.00
Gross Commission as a % of Price 0.00
Total Amount of Offering 550,000,000
Total Amount of Purchase 63,800
Purchase as a % of Offering 0.01%
Purchase as a % Fund Assets 0.11%
Name of Affiliated Broker/dealer in Syndicate
Morgan Stanley, Dean Witter
Name of Broker\Dealer whom securities were purchased
Lehman Brothers
Fund Mid-Cap Growth
Security Sequenom Industrial
Date of Transaction 1/31/00
Purchase Price per Unit 26.00
Amount of commission per unit 0.00
Gross Commission as a % of Price 0.00
Total Amount of Offering 136,500,000
Total Amount of Purchase 23,400
Purchase as a % of Offering 0.02%
Purchase as a % Fund Assets 0.04%
Name of Affiliated Broker/dealer in Syndicate
Morgan Stanley, Dean Witter
Name of Broker\Dealer whom securities were purchased
Robertson Stephens
Fund Mid-Cap Growth
Security Flag Telecom
Date of Transaction 2/11/00
Purchase Price per Unit 24.00
Amount of commission per unit 0.00
Gross Commission as a % of Price 0.00
Total Amount of Offering 760,320,000
Total Amount of Purchase 62,400
Purchase as a % of Offering 0.01%
Purchase as a % Fund Assets 0.10%
Name of Affiliated Broker/dealer in Syndicate
Morgan Stanley, Dean Witter
Name of Broker\Dealer whom securities were purchased
Salomon Smith Barney
Fund Mid-Cap Growth
Security Digitas
Date of Transaction 3/13/00
Purchase Price per Unit 24.00
Amount of commission per unit 0.00
Gross Commission as a % of Price 0.00
Total Amount of Offering 223,200,000
Total Amount of Purchase 16,800
Purchase as a % of Offering 0.01%
Purchase as a % Fund Assets 0.02%
Name of Affiliated Broker/dealer in Syndicate
Morgan Stanley, Dean Witter
Name of Broker\Dealer whom securities were purchased
Salomon Smith Barney
Fund Mid-Cap Growth
Security Savvis Commun
Date of Transaction 2/15/00
Purchase Price per Unit 24.00
Amount of commission per unit 0.00
Gross Commission as a % of Price 0.00
Total Amount of Offering 408,000,000
Total Amount of Purchase 36,000
Purchase as a % of Offering 0.01%
Purchase as a % Fund Assets 0.06%
Name of Affiliated Broker/dealer in Syndicate
Morgan Stanley, Dean Witter
Name of Broker\Dealer whom securities were purchased
Merrill Lynch
Fund Mid-Cap Growth
Security GT Group Telecom
Date of Transaction 3/9/00
Purchase Price per Unit 14.00
Amount of commission per unit 0.00
Gross Commission as a % of Price 0.00
Total Amount of Offering 252,000,000
Total Amount of Purchase 51,800
Purchase as a % of Offering 0.02%
Purchase as a % Fund Assets 0.07%
Name of Affiliated Broker/dealer in Syndicate
Morgan Stanley, Dean Witter
Name of Broker\Dealer whom securities were purchased
Goldman Sachs
Fund Focus Portfolio
Underwriter Morgan Stanley, Goldman Sachs, Merrill Lynch
Name of issuer Untied Parcel Service, Inc.
Title of security United Parcel Service - Class B
Date of 1st Offering 11/9/99
Amount of Total offering 5,470,000,000
Unit Price $50
Underwriting Spread or commission $1.750
Rating N/A
Maturity N/A
Current Yield N/A
Dollar Amount of Purchases $345,000.00
Number of shares purchased 6,900
Years of continuous operation 3+
%of offering price 0.0063%
%purchased by the other portfolios of the fund and other
investment companies advised by the subadvisor .0008%
sum .0071
% of portfolio assets applied to purchase .14%
Name id underwriter or dealer from whom purchased
Morgan Stanley
Is the adviser, any subadvisor or any person of which
The advisor or subadvisor is an affiliated person, manager
Or co-manager of offering? No
Were purchases designated as group Sales or otherwise
allocated to the advisor, any subadvisor or any other
person of whom the advisor or subadvisor is an affiliated
person? NO
Fund Large-Cap Growth Portfolio
Underwriter JP Morgan, Goldman Sachs, Merrill Lynch, Warburg
Dillon Read, Lehman Bros. Robertson Stephens
Name of issuer Genetech, Inc.
Title of security Genetech, Inc.
Date of 1st Offering 3/23/00
Amount of Total offering 2,819,900,000
Unit Price $163
Underwriting Spread or commission $2.77
Rating N/A
Maturity N/A
Current Yield N/A
Dollar Amount of Purchases $48,900.00
Number of shares purchased 300
Years of continuous operation 3+
%of offering price 0.002%
%purchased by the other portfolios of the fund and other
investment companies advised by the subadvisor 1.73%
sum 0.00
% of portfolio assets applied to purchase 0.10%
Name id underwriter or dealer from whom purchased
JP Morgan
Is the adviser, any subadvisor or any person of which
The advisor or subadvisor is an affiliated person, manager
Or co-manager of offering? No
Were purchases designated as group Sales or otherwise
allocated to the advisor, any subadvisor or any other
person of whom the advisor or subadvisor is an affiliated
person? NO
1. Name of Portfolio SunAmerica Style Select Series, Inc.
Value Portfolio
2. Name of issuer AT&T Wireless Group
3. Date of Purchase 4/26/00
4. Underwriter from whom purchased Merrill Lynch, Pierce,
Fenner & Smith, Inc.
5. Affiliated Underwriter managing or participating in
underwriting syndicate Neuberger Berman LLC
6. Is a list of the underwriting syndicate's number
attached? YES
7. Aggregate principal amount of purchase by all investment
companies advised by the adviser or subadvisor: 958,600
8. Aggregate principal amount of offering: 360,000,000
9. Purchase price ( net of fees and expenses): $29.50
10.Date offering commenced: 4/26/00
11.Offering price at close of first day on which any sales
were made: $29.50
12.Commission, spread or profit: $0.86/per share
13.Have the following conditions been satisfied?
a. The securities are:
Part of a an issue registered under the Securities Act
Of 1933 which is being offered to the public; yes
Eligible Municipal Securities
Sold in an eligible foreign offering; or
Sold in an eligible Rule 144A offering?
(see Appendix B to the Rule 10f-3 Procedures for
definitions of the capitalized terms herein.)
b. (1) The securities were purchased prior to the end of
the first day on which any sales were made, at a price
that is not more than the price paid by each other
purchaser of securities in that offering or in any
concurrent offering of the securities (except, in the case
of an eligible foreign offering, for any rights to purchase
that are required by law to be granted to existing security
holders of the issuer); OR YES
(2) If the securities to be purchased were offered for
subscription upon exercise of rights, such securities were
purchased on or before the fourth day preceding the day
on which the rights offering terminates?
c. The underwriting was a firm commitment underwriting? yes
d. The commission, spread or profit was reasonable and
Fair in relation to that being received by others for
Underwriting similar securities during the same period (see
Attachement for comparison of spread with comparable recent
Offerings)? yes
e. The issuer of the securities, except for the eligible
Municipal Securities, and its predecessors have been in
Continuous operation for not less than three years? yes
f. (1) The amount of the securities, other than those sold
an Eligible Rule 144A Offering(see below), purchased by
all of the investment companies advised by the adviser
did not exceed 25% of the principal amount of the offering;
OR yes
2) If the securities purchased were sold in an eligible
144A Offering, the amount of such securities purchased by
all of the investment companies advised by the Adviser or
Subadvisor did not exceed 25% of the total of:
(i)The principal amount of the offering of such class sold
by underwriters or members of the selling syndicate to
qualified institutional buyers, as defined in Rule 144A(a)(1)
plus
(ii) The principal amount of the offering of such class in
any concurrent public offering?
g. (1) No affiliated underwriter of the Trust was a direct or
indirect participant in a benefiaciary of the sale; OR yes
(2) With respect to the purchase of Eligible Municpal Securities
Such purchase was not designated as a group sale or otherwise
Allocated to the account of an affiliated underwriter?
h. Information has or will be timely supplied to the appropraite
Officer of the Trust for inclusion on SEC Form N-SAR and
Quarterly reports to the Trustees? yes
1. Name of Portfolio SunAmerica Style Select Series, Inc.
Value Portfolio
2. Name of issuer Dobson Communications
3. Date of Purchase 2/03/00
4. Underwriter from whom purchased Lehman Brothes
5. Affiliated Underwriter managing or participating in
underwriting syndicate Neuberger Berman LLC
6. Is a list of the underwriting syndicate's number
attached? YES
7. Aggregate principal amount of purchase by all investment
companies advised by the adviser or subadvisor: 38,900
8. Aggregate principal amount of offering: 25,000,000
9. Purchase price ( net of fees and expenses): $22.00
10.Date offering commenced: 2/3/00
11.Offering price at close of first day on which any sales
were made: $22.00
12.Commission, spread or profit: $1.265/per share
13.Have the following conditions been satisfied?
a. The securities are:
Part of a an issue registered under the Securities Act
Of 1933 which is being offered to the public; yes
Eligible Municipal Securities
Sold in an eligible foreign offering; or
Sold in an eligible Rule 144A offering?
(see Appendix B to the Rule 10f-3 Procedures for
definitions of the capitalized terms herein.)
b. (1) The securities were purchased prior to the end of
the first day on which any sales were made, at a price
that is not more than the price paid by each other
purchaser of securities in that offering or in any
concurrent offering of the securities (except, in the case
of an eligible foreign offering, for any rights to purchase
that are required by law to be granted to existing security
holders of the issuer); OR YES
(2) If the securities to be purchased were offered for
subscription upon exercise of rights, such securities were
purchased on or before the fourth day preceding the day
on which the rights offering terminates?
c. The underwriting was a firm commitment underwriting? yes
d. The commission, spread or profit was reasonable and
Fair in relation to that being received by others for
Underwriting similar securities during the same period (see
Attachement for comparison of spread with comparable recent
Offerings)? yes
e. The issuer of the securities, except for the eligible
Municipal Securities, and its predecessors have been in
Continuous operation for not less than three years? yes
f. (1) The amount of the securities, other than those sold
an Eligible Rule 144A Offering(see below), purchased by
all of the investment companies advised by the adviser
did not exceed 25% of the principal amount of the offering;
OR yes
2) If the securities purchased were sold in an eligible
144A Offering, the amount of such securities purchased by
all of the investment companies advised by the Adviser or
Subadvisor did not exceed 25% of the total of:
(i)The principal amount of the offering of such class sold
by underwriters or members of the selling syndicate to
qualified institutional buyers, as defined in Rule 144A(a)(1)
plus
(ii) The principal amount of the offering of such class in
any concurrent public offering?
g. (1) No affiliated underwriter of the Trust was a direct or
indirect participant in a benefiaciary of the sale; OR yes
(2) With respect to the purchase of Eligible Municpal Securities
Such purchase was not designated as a group sale or otherwise
Allocated to the account of an affiliated underwriter?
h. Information has or will be timely supplied to the appropraite
Officer of the Trust for inclusion on SEC Form N-SAR and
Quarterly reports to the Trustees? yes
