<PAGE>
INVESTMENT COMPANY CAPITAL CORP.
CODE OF ETHICS
APPLICABLE TO THE DEUTSCHE ASSET MANAGEMENT
MUTUAL FUNDS GROUP
* * *
THIS CODE SHOULD BE READ IN CONJUNCTION WITH THE ATTACHED
DEUTSCHE ASSET MANAGEMENT MUTUAL FUNDS GROUP CODE OF ETHICS PROCEDURES
AND DIVISION-SPECIFIC REQUIREMENTS
* * *
JANUARY 1, 2001
A Member of the
DEUTSCHE BANK GROUP [GRAPHIC]
<PAGE>
DEUTSCHE ASSET MANAGEMENT
CODE OF ETHICS
I. OVERVIEW.................................................................1
II. GENERAL RULE.............................................................1
III. DEFINITIONS..............................................................2
IV. RESTRICTIONS.............................................................3
Blackout Period Restrictions............................................3
New Issues (IPOs).......................................................3
Short-Term Trading......................................................4
Restricted List.........................................................4
Private Placements......................................................4
V. COMPLIANCE PROCEDURES....................................................4
Designated Brokerage Accounts...........................................4
Pre-Clearance...........................................................4
Reporting Requirements..................................................5
Confirmation of Compliance with Policies................................5
VI. OTHER PROCEDURES/RESTRICTIONS............................................5
Service on Boards of Directors..........................................5
Gifts...................................................................5
Rules for Dealing with Governmental Officials and Political Candidates..7
Confidentiality.........................................................8
VII. SANCTIONS ...............................................................8
VIII. INTERPRETATIONS AND EXCEPTIONS...........................................8
APPENDIX:
- Acknowledgement Form.........................................................9
- Initial (and Annual) Holdings Report........................................10
<PAGE>
DEUTSCHE ASSET MANAGEMENT - U.S.
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CODE OF ETHICS
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I. OVERVIEW
This Code of Ethics ("Code") sets forth the specialized rules for business
conduct and guidelines for the personal investing activities that generally are
required of employees involved in the United States investment management areas
of the Deutsche Bank Group and its affiliates (collectively "Deutsche Asset
Management" or "DeAM").(1)
The provisions of this Code are effective January 1, 2001, and shall apply to
all employees deemed to be "Access Persons" (SEE DEFINITION ON NEXT PAGE) and
such other employees as the Compliance Department ("Compliance") may determine
from time to time. This Code supplements the Deutsche Bank CODE OF PROFESSIONAL
CONDUCT, and GLOBAL MASTER COMPLIANCE MANUAL (available at
http://compliance.cc.db.com) on the intranet. Each Access Person must observe
those policies, as well as abide by the additional principles and rules set
forth in this Code.
II. GENERAL RULE
DeAM employees will, in varying degrees, participate in or be aware of fiduciary
and investment services provided to registered investment companies,
institutional investment clients, employee benefit trusts and other types of
investment advisory accounts. The fiduciary relationship mandates adherence to
the highest standards of conduct and integrity.
Accordingly, personnel acting in a fiduciary capacity must carry out their
duties for the EXCLUSIVE BENEFIT of the client accounts. Consistent with this
fiduciary duty, the interests of DeAM clients take priority over the investment
desires of DeAM and DeAM personnel. All DeAM personnel must conduct themselves
in a manner consistent with the requirements and procedures set forth in this
Code.
DeAM employees may also be required to comply with other policies imposing
separate requirements. Specifically, they may be subject to laws or regulations
that impose restrictions with respect to personal securities transactions,
including, but not limited to, Section 17(j) and Rule 17j-1 under the Investment
Company Act of 1940 (the "Act"). The purpose of this Code of Ethics is to ensure
that, in connection with his or her personal trading, no Access Person shall
conduct any of the following acts upon a client account:
- To employ any device, scheme or artifice to defraud;
- To make any untrue statement of a material fact, or omit to state a
material fact necessary in order to make the statement not misleading;
- To engage in any act, practice or course of business that operates or
would operate as a fraud or deceit; or
- To engage in any manipulative practice.
--------
(1) Deutsche Asset Management is the marketing name for the asset management
activities of Deutsche Bank AG, Deutsche Funds Management, Bankers Trust
Company, DB Alex.Brown LLC, Deutsche Asset Management Inc. (formerly Morgan
Grenfell Inc.), and Deutsche Asset Management Investment Services Limited.
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III. DEFINITIONS
A. "ACCESS PERSON" SHALL MEAN:
(i) All employees of DeAM, including investment personnel, traders and
portfolio managers who, in connection with their regular functions or
duties, participate in making decisions or obtain information
regarding the purchase or sale of a security by any client accounts,
or whose functions relate to the making of any recommendations with
respect to such purchases or sales;
(ii) All natural persons in a control relationship to DeAM who obtain
information concerning investment recommendations made to any client
account. The term "control" shall have the same meaning as that set
forth in Section 2(a)(9) of the Act; and
(iii) Any other personnel with asset management responsibilities or
frequent interaction with Access Persons as determined by Compliance
(e.g., Legal, Compliance, Risk, Operations, Sales & Marketing, as
well as long-term temporary employees and consultants).
B. "ACCOUNTS" SHALL MEAN all securities accounts, whether brokerage or
otherwise, and securities held directly outside of accounts, but shall not
include open-end mutual fund accounts in which securities transactions
cannot be effected.
C. "EMPLOYEE RELATED ACCOUNT" OF ANY PERSON SUBJECT TO THIS CODE SHALL MEAN:
(i) The employee's own Accounts;
(ii) The employee's spouse's Accounts and the Accounts of minor children
and other members of the household (whether by marriage or similarly
committed status) living in the employee's home;
(iii) Accounts in which the employee, his/her spouse/domestic partner,
minor children or other persons living in their home have a
beneficial interest (i.e., share in the profits even if there is no
influence on voting or disposition of the shares); and
(iv) Accounts (including corporate Accounts and trust Accounts) over which
the employee or his/her spouse/domestic partner exercises investment
discretion or control.
NOTE: ANY PERSON SUBJECT TO THIS CODE IS RESPONSIBLE FOR COMPLIANCE WITH
THESE RULES WITH RESPECT TO ANY EMPLOYEE RELATED ACCOUNT, AS
APPLICABLE.
D. "SECURITIES" SHALL INCLUDE equity or debt securities, derivatives of
securities (such as options, warrants, and ADRs), closed-end mutual funds,
futures, commodities and similar instruments, but DO NOT INCLUDE:
(i) Shares of open-end mutual funds (unless otherwise directed by
Compliance);
(ii) Direct obligations of the United States government; or
(iii) Bankers' acceptances, bank certificates of deposit, commercial paper
and high quality short-term debt instruments, including repurchase
agreements.
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IV. RESTRICTIONS
A. BLACKOUT PERIOD RESTRICTIONS
(i) Access Persons shall not knowingly effect the purchase or sale of a
Security for an Employee Related Account on a day during which any
client account has a "buy" or "sell" order for the same Security,
until that order is executed or withdrawn;
(ii) Access Persons shall not effect the purchase or sale of a Security
for an Employee Related Account within SEVEN CALENDAR DAYS BEFORE OR
SEVEN CALENDAR DAYS AFTER the same Security is traded (or
contemplated to be traded) by a client account with which the Access
Person is associated.
(iii) RUSSELL RECONSTITUTION OF THE INDEX: Effective every June 30th, the
Frank Russell Company reconstitutes the various Russell Indices.
Several weeks prior to that date, Frank Russell announces the
changes to the indices (the "Announcement"). A significant portion
of the portfolios which DeAM advises utilize strategies involving
securities included in the various Russell indices, and thus DeAM
trades heavily in these securities. Therefore, for the period
commencing on the day of the Announcement, and continuing until
seven business days after June 30th, all Access Persons are
prohibited from transacting in any Security that is added to or
deleted from the Russell 3000 Index.
(iv) DEUTSCHE BANK SECURITIES: During certain times of the year, all
Deutsche Bank employees are prohibited from conducting transactions
in the equity and debt securities of Deutsche Bank, which affect
their beneficial interest in the firm. Compliance generally imposes
these "blackout" periods around the fiscal reporting of corporate
earnings. Blackouts typically begin two days prior to the expected
quarterly or annual earnings announcement, and end two days after
earnings are released publicly. Additional restricted periods may be
required for certain individuals and events, and Compliance will
announce when such additional restricted periods are in effect.
(v) EXCEPTIONS TO BLACKOUT PERIODS (ABOVE ITEMS i, ii, AND iii ONLY) The
following are exempt from the specified blackout periods:
- Securities that are within the S&P 100 Index;
- Futures and options transactions on indexes;
- ETF's (Exchange Traded Funds - e.g., SPDRs or "Spiders" (S&P 500
Index), DIAs or "Diamonds" (Dow Jones Industrial Average), etc.);
- Shares purchased under an issuer sponsored Dividend Reinvestment
Plan ("DRIPs"), other than optional purchases;
- To the extent acquired from the issuer, purchases effected upon
the exercise of rights issued pro rata to holders of a class of
securities; and
- Securities purchased under an employer sponsored stock purchase
plan or upon the exercise of employee stock options.
B. NEW ISSUES (IPOS)
Access Persons are prohibited from purchasing or subscribing for
Securities pursuant to an initial public offering. This prohibition
applies even if Deutsche Bank (or any affiliate of Deutsche Bank) has
no underwriting role and/or is not involved with the distribution.
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C. SHORT-TERM TRADING
Access Persons are prohibited from transacting in the purchase and sale, or
sale and purchase, of the same (or equivalent) Securities within 30
calendar days. The following are exempted from this restriction:
- Futures and options transactions on indexes;
- ETF's (Exchange Traded Funds - e.g., SPDRs or "Spiders" (S&P 500
Index), DIAs or "Diamonds" (Dow Jones Industrial Average), etc.);
- Shares purchased under an issuer sponsored Dividend Reinvestment
Plan ("DRIPs"), other than optional purchases;
- To the extent acquired from the issuer, purchases effected upon
the exercise of rights issued pro rata to holders of a class of
securities; and
- Securities purchased under an employer sponsored stock purchase
plan.
D. RESTRICTED LIST
All Deutsche Bank employees, including all Access Persons, are prohibited
from buying or selling any securities that are included on the Corporate
Restricted List (available on the intranet) and/or other applicable
departmental restricted lists.
E. PRIVATE PLACEMENTS
Prior to effecting a transaction in private securities (i.e., Securities
not requiring registration with the Securities and Exchange Commission, and
sold directly to the investor), all Access Persons must first obtain the
approval of his/her supervisor and then pre-clear the transaction with the
Compliance Department, including completing a questionnaire. Any person who
has previously purchased privately-placed Securities must disclose such
purchases to the Compliance Department before he or she participates in a
Fund's or an advisory client's subsequent consideration of an investment in
the Securities of the same or a related issuer.
NOTE: Transactions in Securities in derivative instruments, including warrants,
convertible Securities, futures and options, etc. shall be restricted in the
same manner as the underlying Security.
V. COMPLIANCE PROCEDURES
A. DESIGNATED BROKERAGE ACCOUNTS
All Access Persons are required to open and maintain their Employee
Related Accounts in accordance with the Deutsche Bank EMPLOYEE TRADING
AND PRE-CLEARANCE POLICY, as well as additional division-specific
requirements, if any.
B. PRE-CLEARANCE
Proposed Securities transactions must be pre-cleared with the Compliance
Department in accordance with the Deutsche Bank EMPLOYEE TRADING AND
PRE-CLEARANCE POLICY. The following are exempted from this restriction:
- Futures and options transactions on indexes;
- ETF's (Exchange Traded Funds - e.g., SPDRs or "Spiders" (S&P 500
Index), DIAs or "Diamonds" (Dow Jones Industrial Average), etc.);
- Shares purchased under an issuer sponsored Dividend Reinvestment
Plan ("DRIPs"), other than optional purchases;
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- To the extent acquired from the issuer, purchases effected upon
the exercise of rights issued pro rata to holders of a class of
securities; and
- Securities purchased under an employer sponsored stock purchase
plan.
C. REPORTING REQUIREMENTS
(i) DISCLOSURE OF EMPLOYEE RELATED ACCOUNTS/PROVISION OF STATEMENTS Upon
joining Deutsche Bank, new employees are required to disclose all of
their Employee Related Accounts to Compliance, and must carry out the
instructions provided to conform such accounts, if necessary, to
Deutsche Bank policies. In addition, pursuant to Rule 17j-1 of the
Act, no later than ten days after an individual becomes an Access
Person, he or she must complete and return an "Initial Holdings
Report" (see Appendix).
(ii) QUARTERLY PERSONAL SECURITIES TRADING REPORTS ("PSTS") Pursuant to
Rule 17j-1 of the Act, within ten (10) days of the end of each
calendar quarter, all Access Persons must sign and return to
Compliance a PST report, unless exempted by a division-specific
requirement, if any. All PSTs that have reportable personal Securities
transactions for the quarter will be reviewed by the appropriate
supervisory and/or compliance person.
(iii)ANNUAL HOLDINGS REPORT Once each year, at a date to be specified by
Compliance, each Access Person must provide to Compliance an Annual
Holdings Report (see Appendix) current as of a date not more than 30
days prior to the date of the report.
D. CONFIRMATION OF COMPLIANCE WITH POLICIES
Annually, each Access Person is required to sign a statement
acknowledging that he or she has received this Code, as amended or
updated, and confirm his or her adherence to it.
VI. OTHER PROCEDURES/RESTRICTIONS
A. SERVICE ON BOARDS OF DIRECTORS
Employees may not maintain outside business affiliations (e.g., officer or
director, governor, trustee, part-time employment, etc.) without the prior
written approval of the appropriate senior officer of their respective
business units. Service on Boards of publicly traded companies should be
limited to a small number of instances. However, such service may be
undertaken based upon a determination that these activities are consistent
with the interests of DeAM and its clients. Employees serving as directors
will not be permitted to participate in the process of making investment
decisions on behalf of clients which involve the subject company.
B. GIFTS
(i) ACCEPTING GIFTS
Employees are prohibited from soliciting or accepting any personal payment
or gift to influence, support or reward any service, transaction or
business involving Deutsche Bank, or that appears to be made or offered in
anticipation of any future service, transaction or business opportunity. A
payment or gift includes any fee, compensation, remuneration or thing of
value. (2) However, subject to the prerequisites of honesty, absolute
fulfillment of fiduciary duty
----------
(2) UNDER THE BANK BRIBERY ACT AND OTHER APPLICABLE LAWS AND REGULATIONS, SEVERE
PENALTIES MAY BE IMPOSED ON ANYONE WHO OFFERS OR ACCEPTS SUCH IMPROPER PAYMENTS
OR GIFTS. IF YOU RECEIVE OR ARE OFFERED AN IMPROPER PAYMENT OR GIFT, OR IF YOU
HAVE ANY QUESTIONS AS TO THE APPLICATION OR INTERPRETATION OF DEUTSCHE BANK'S
RULES REGARDING THE ACCEPTANCE OF GIFTS, YOU MUST BRING THE MATTER TO THE
ATTENTION OF THE COMPLIANCE DEPARTMENT.
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to Deutsche Bank, relevant laws and regulations, and reasonable conduct on the
part of the employee, the acceptance of some types of reasonable business gifts
received by employees may be permissible, and the rules are as follows:
- Cash gifts of any amount are prohibited. This includes cash equivalents
such as gift certificates, bonds, securities or other items that may be
readily converted to cash.
- Acceptance of non-cash gifts, souvenirs, tickets for sporting or
entertainment events, and other items with a value less than U.S. $100 or
its equivalent is generally permitted, when it is clear that they are
unsolicited, unrelated to a transaction and the donor is not attempting to
influence the employee.
- Acceptance of gifts, other than cash, given in connection with special
occasions (e.g., promotions, retirements, weddings, holidays), that are of
reasonable value in the circumstances are permissible.
- Employees may accept reasonable and conventional business courtesies, such
as joining a customer or vendor in attending sporting events, golf outings
or concerts, provided that such activities involve no more than the
customary amenities.
- The cost of working session meals or reasonable related expenses involving
the discussion or review of business matters related to Deutsche Bank may
be paid by the customer, vendor or others, provided that such costs would
have otherwise been reimbursable to the employee by Deutsche Bank in
accordance with its travel and entertainment and expense reimbursement
policies.
(ii) GIFT GIVING (TO PERSONS OTHER THAN GOVERNMENT OFFICIALS)
In appropriate circumstances, it may be acceptable and customary for DeAM
to extend gifts to customers or others who do business with Deutsche Bank.
Employees should be certain that the gift will not give rise to a conflict
of interest, or appearance of conflict, and that there is no reason to
believe that the gift will violate applicable codes of conduct of the
recipient. Employees with appropriate authority to do so may make business
gifts at DeAM's expense, provided that the following requirements are met:
- Gifts in the form of cash or cash equivalents may not be given
regardless of amount.
- The gift must be of reasonable value in the circumstances, and should
not exceed a value of U.S. $100 unless the specific prior approval of
the appropriate Managing Officer(3) is obtained.
- The gift must be lawful and in accordance with generally accepted
business practices of the governing jurisdictions.
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(3) FOR PURPOSES OF THIS POLICY, "MANAGING OFFICER" IS DEFINED AS AN OFFICER OF
AT LEAST THE MANAGING DIRECTOR LEVEL TO WHOM THE EMPLOYEE DIRECTLY OR INDIRECTLY
REPORTS, WHO IS IN CHARGE OF THE EMPLOYEE'S UNIT (E.G., A DEPARTMENT HEAD,
DIVISION HEAD, FUNCTION HEAD, GROUP HEAD, GENERAL MANAGER, ETC).
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- The gift must not be given with the intent to influence or reward any
person regarding any business or transaction involving DeAM.
(iii) GIFTS TO GOVERNMENT OFFICIALS
The Compliance Department must be contacted prior to making any gift to a
governmental employee or official. Various governmental agencies,
legislative bodies and jurisdictions may have rules and regulations
regarding the receipt of gifts by their employees or officials. In some
cases, government employees or officials may be prohibited from accepting
any gifts. (SEE NEXT SECTION FOR ADDITIONAL RULES REGARDING POLITICAL
CONTRIBUTIONS.)
C. RULES FOR DEALING WITH GOVERNMENTAL OFFICIALS AND POLITICAL CANDIDATES
(i) CORPORATE PAYMENTS OR POLITICAL CONTRIBUTIONS
No corporate payments or gifts of value may be made to any outside
party, including any government official or political candidate or
official, for the purpose of securing or retaining business for
Deutsche Bank, or influencing any decision on its behalf.
- The Federal Election Campaign Act prohibits corporations and
labor organizations from using their general treasury funds to
make contributions or expenditures in connection with federal
elections, and therefore DEUTSCHE BANK DEPARTMENTS MAY NOT MAKE
CONTRIBUTIONS TO U.S. FEDERAL POLITICAL PARTIES OR CANDIDATES.
- Corporate contributions to political parties or candidates in
jurisdictions not involving U.S. Federal elections are permitted
only when such contributions are made in accordance with
applicable local laws and regulations, and the prior approval of
a member of the DeAM Executive Committee has been obtained, and
the Deutsche Bank Americas Regional Cost Committee has been
notified.
UNDER THE FOREIGN CORRUPT PRACTICES ACT, BANK BRIBERY LAW,
ELECTIONS LAW AND OTHER APPLICABLE REGULATIONS, SEVERE PENALTIES
MAY BE IMPOSED ON DEUTSCHE BANK AND ON INDIVIDUALS WHO VIOLATE
THESE LAWS AND REGULATIONS. SIMILAR LAWS AND REGULATIONS MAY ALSO
APPLY IN VARIOUS COUNTRIES AND LEGAL JURISDICTIONS WHERE DEUTSCHE
BANK DOES BUSINESS.
(ii) PERSONAL POLITICAL CONTRIBUTIONS
No personal payments or gifts of value may be made to any outside party,
including any government official or political candidate or official, for
the purpose of securing business for Deutsche Bank or influencing any
decision on its behalf. Employees should always exercise care and good
judgment to avoid making any political contribution that may give rise to a
conflict of interest, or the appearance of conflict. For example, if a DeAM
business unit engages in business with a particular governmental entity or
official, DeAM employees should avoid making personal political
contributions to officials or candidates who may appear to be in a position
to influence the award of business to Deutsche Bank.
(iii)ENTERTAINMENT OF GOVERNMENT OFFICIALS
Entertainment and other acts of hospitality toward government or political
officials should never compromise or appear to compromise the integrity or
reputation of the official or
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Deutsche Bank. When hospitality is extended, it should be with the
expectation that it will become a matter of public knowledge.
8
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D. CONFIDENTIALITY
Access Persons must not divulge contemplated or completed securities
transactions or trading strategies of DeAM clients to any person, except as
required by the performance of such person's duties, and only on a
need-to-know basis. In addition, the Deutsche Bank policies on confidential
information, which are contained within the CODE OF PROFESSIONAL CONDUCT,
must be observed.
VII. SANCTIONS
Any Access Person who violates this Code may be subject to disciplinary actions,
including possible dismissal. In addition, any Securities transactions executed
in violation of this Code, such as short-term trading or trading during blackout
periods, may subject the employee to a financial penalty, including but not
limited to, unwinding the trade and/or disgorging of the profits. Finally,
violations and suspected violations of criminal laws will be reported to the
appropriate authorities as required by applicable laws and regulations.
VIII. INTERPRETATIONS AND EXCEPTIONS
Compliance shall have the right to make final and binding interpretations of
this Code, and may grant an exception to certain of the above restrictions, as
long as no abuse or potential abuse is involved. Each Access Person must obtain
approval from the Compliance Department before taking action regarding such an
exception. Any questions regarding the applicability, meaning or administration
of this Code shall be referred in advance of any contemplated transaction, to
Compliance.
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DEUTSCHE ASSET MANAGEMENT
ACKNOWLEDGEMENT
In connection with my employment with one or more of the legal entities which
make up Deutsche Asset Management, I acknowledge that I have received, read and
understand the Deutsche Asset Management CODE OF ETHICS effective January 1,
2001, and agree to adhere to and abide by its provisions.
I understand that any violation(s) of this Code of Ethics is grounds for
immediate disciplinary action up to, and including, dismissal.
Signature _______________________________
Print Name _______________________________
Date _______________________________
PLEASE RETURN THIS FORM TO REBECCA FERRELL, DeAM MUTUAL FUNDS COMPLIANCE AT
ONE SOUTH STREET, BALTIMORE, MARYLAND 21202 (MAIL STOP BAL01-1632).
A Member of the
DEUTSCHE BANK GROUP [GRAPHIC]
<PAGE>
DEUTSCHE ASSET MANAGEMENT
INITIAL/ANNUAL HOLDINGS REPORT
TO: Employees of the Deutsche Asset Management Mutual Funds Group
FROM: Deutsche Asset Management Mutual Funds Compliance
RE: Initial/Annual Holdings Report - Personal Securities Accounts
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Rule 17j-1 under the Investment Company Act of 1940 requires you to provide DeAM
Mutual Funds Group Compliance with this "INITIAL HOLDINGS REPORT" within 10 days
of becoming an employee and with an "ANNUAL HOLDINGS REPORT" on an annual basis
thereafter. INFORMATION ON THE "ANNUAL HOLDINGS REPORT" MUST BE CURRENT AS OF A
DATE NO MORE THAN 30 DAYS BEFORE THE DATE THE REPORT IS SUBMITTED.
Accordingly, please fill in the following requested information (or attach a
copy of your most recent statement) for each broker, dealer or bank with which
you maintain an EMPLOYEE RELATED ACCOUNT and all SECURITIES(4) held directly
by you or in such accounts. "EMPLOYEE RELATED ACCOUNTS" include (i) your own
accounts; (ii) the your spouse's accounts and the accounts of minor children
and other members of the household (whether by marriage or similarly committed
status) living in your home; (iii) accounts in which you, your spouse/domestic
partner, minor children or other persons living in their home have a
beneficial interest (i.e., share in the profits even if there is no influence
on voting or disposition of shares); and (iv) accounts (including corporate
accounts and trust accounts) over which you or your spouse/domestic partner
exercises investment discretion or control. (PLEASE NOTE: OPEN-END MUTUAL FUND
ACCOUNTS(5) AND ACCOUNTS OVER WHICH YOU EXERCISE NO INVESTMENT DISCRETION OR
CONTROL SHOULD BE LISTED ON THE FOLLOWING PAGE.)
<TABLE>
<CAPTION>
NO. SHARES OR
NAME OF BROKER, DEALER OR PRINCIPAL AMOUNT
NAME OF ACCOUNT HOLDER BANK AND ACCOUNT NO. NAME OF ISSUER (IF DEBT)
<S> <C> <C> <C>
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</TABLE>
PLEASE ATTACH ADDITIONAL PAGES IF NECESSARY
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(4) SECURITIES do NOT include direct obligations of the Government of the United
States, bankers' acceptances, bank certificates of deposit, commercial paper and
high quality short-term debt instruments, including repurchase agreements, and
shares issued by registered, open-end mutual funds.
(5) OPEN-END MUTUAL FUND ACCOUNTS include accounts that, by their terms, permit
holders to purchase shares of open-end mutual funds ONLY. They do not include
accounts that permit holders to purchase both shares of open-end mutual funds
and shares of other issuers.
<PAGE>
Please fill out the following requested information for any broker, dealer or
bank with which you maintain an OPEN-END MUTUAL FUND ACCOUNT (as defined on the
preceding page) or an ACCOUNT OVER WHICH YOU EXERCISE NO INVESTMENT DISCRETION
OR CONTROL.
<TABLE>
<CAPTION>
NAME OF ACCOUNT HOLDER NAME OF BROKER, DEALER OR BANK AND ACCOUNT NO.
<S> <C>
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</TABLE>
PLEASE ATTACH ADDITIONAL PAGES IF NECESSARY
Signature: ___________________________ Date: _____________________
Print Name: ___________________________
** PLEASE COMPLETE AND RETURN TO REBECCA FERRELL, DeAM MUTUAL FUNDS COMPLIANCE,
ONE SOUTH STREET, BALTIMORE, MARYLAND 21202, MAIL STOP BAL01-1632 **
12
