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SIGNATURE WILLIAM H. KEOUGH
TITLE TREASURER
EXHIBIT A
PIONEER MANAGEMENT CORPORATION
MULTICLASS PORTFOLIOS PROCEDURES TESTING
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CONTROL OBJECTIVES CONTROL POLICIES & PROCEDURES ARTHUR ANDERSEN TESTING
I. Net Asset Value
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To ensure that the daily 1. Investment securities are recorded on a Reviewed securities on a sample of Fund
net asset value for each trade-date basis and are reflected at their position reports, noting that securities agreed
class of shares within current value, as required by the individual Fund with or reconciled to securities on the custody
the Funds is accurately prospectus, by the applicable Service Provider. report.
calculated. Security holdings are reconciled on a monthly
basis to custodial records to ensure that the
records are complete and accurate.
Reviewed reconciling items on a sample basis,
noting propriety and clearance on a timely basis
2. Short-term investment securities held by a Reviewed the calculation of
Fund are valued on a daily basis using amortized amortized cost on a sample of securities.
cost, which approximates value. Long-term
investment securities are valued at current value Obtained price quotes from pricing services
as determined by a national securities exchange, and brokers to value investment securities.
an independent pricing source or, if required, at
value as determined in good faith using procedures
established by the Board of Trustees.
3. Receivables for shares of beneficial interest Reviewed a judgmentally selected sample
purchased are recorded for each class at the of daily share activity and total shares
applicable net asset value (less applicable sales outstanding per PMC and compared
charge, if any) by the Service Provider and to reports from the Transfer Agent.
reconciled to the Transfer Agent's records to
ensure accuracy.
Verified amounts to the daily trial balance.
4. All other assets are determined and recorded Reviewed a judgmentally selected sample
at their current value in accordance with and traced the activity to the appropriate
generally accepted accounting principles. reports.
Traced the total balances to the trial balance.
5. Payables for shares of beneficial interest Reviewed a judgmentally selected sample
redeemed are recorded for each class at the of daily share activity and total shares
applicable net asset value by the Service outstanding per PMC and compared to reports from
Provider and reconciled to the Transfer Agent's the Transfer Agent.
records to ensure accuracy.
Verified amounts to the daily trial balance.
6. Accrued Fund expenses are recorded by each a Reviewed the detail of daily expense
Fund using pro rata methodology based on the spreadsheets from PMC for agreement
relative aggregate net assets of the Fund, except of daily expense accruals.
in the case of a Fund that has Series, for which
accrued Series expenses are recorded to each
Series based on the relative aggregate net assets Judgmentally vouched expenses paid and
of such Series (or other Board-approved method) recomputed the reimbursable amounts, if
and accrued Class expenses are charged directly applicable.
to each Class of shares to which they relate.
Estimated Fund and Series expenses are accrued
and allocated daily to each Class based on its
pro rata percentage of the total net assets of Reviewed a judgmentally selected sample
the Fund or the Series as of the end of the prior of allocation work sheets and
day, adjusted for the previous day's share recalculated the expense allocation.
activity.
7. All other liabilities are determined and Reviewed a judgmentally selected sample
recorded at their current value in accordance with of the daily rollforwards and traced
generally accepted accounting principles. the activity to the appropriate subsidiary .
records
Traced the total balances to the trial balance.
8. Investment income, unrealized and realized Reviewed a judgmentally selected sample
gains or losses, if any, are recorded and of the allocation work sheets.
allocated daily to each Class based on its
percentage of the total net assets of the Fund Traced daily income to the income
as of the end of the prior day, adjusted for the journals from PMC.
previous day's share activity.
Recomputed all allocation percentages.
9. Fund and Series expenses are accrued and Reviewed a judgmentally selected sample
allocated daily to each Class using a pro rata of the allocation worksheets. Traced daily
methodology based on its previous day's expense to the expense spreadsheet from PMC.
ending net assets invested in each Fund or Series,
adjusted for the previous day's share activity. Recomputed all allocation percentages.
Class expenses are accrued and charged directly
to each Class of shares to which they relate.
10. Shareholder activity is reported for each Reviewed a judgmentally selected sample
Class on a daily basis from the Transfer Agent. of calculations of beneficial interest shares
A Service Provider fund accountant records this prepared by the Transfer Agent.
activity for each Class in order to determine the
shares of beneficial interest outstanding.
Traced the daily activity to the daily reports
from the Transfer Agent.
II. Expenses
To ensure that Fund expenses 1. All expenses are accounted for as being either Reviewed a judgmentally selected sample
are properly allocated among Fund expenses, Series expenses or expenses of allocation work sheets.
multiple Classes of shares. that relate to a specific Class of expenses.
The Fund's Trustees have approved the expense Reviewed for proper identification of
classifications. class-specific expenses.
2. Fund and Series expenses of each Class of Reviewed a judgmentally selected sample
shares are projected and accrued daily. Specific of expense spreadsheets noting that the
expenses for each Class of shares, as well as daily accrual amounts were reasonable in
Fund and Series expenses, which are allocated to relation to the total budgeted expenses.
each Class of shares based on the relative net
assets of each Class, are compared against Based on discussions with PMC personnel,
expense projections. we noted that the expenses are reviewed on a
periodic basis.
3. Advisory fees are charged to the Fund using Reviewed a judgmentally selected sample
a contractual, asset-based methodology. of daily expense spreadsheets noting
Record keeping and administrative personnel and that the proper expense amount was being
services are charged to the Fund using a allocated.
cost-allocation methodology. The components
of the cost-allocation methodology are
reviewed annually by the Fund's Trustees.
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4. Total expenses for each Class of shares are Reviewed a judgmentally selected sample
limited by statutory expense caps, as well as of the expense work sheets prepared by
either voluntary or contractual expense caps. PMC for proper calculation and
At various times, certain Funds will establish consideration of expense caps.
expense reimbursement programs (expense caps)
whereby PMC will notimpose and/or reimburse a
Fund for expenses that exceed defined levels
based on average daily net assets. The expense cap
amounts will be consistent for each class
within a Fund and will be calculated at the
class level. Expense waivers and reimbursements
will be calculated and allocated to each Class
of shares daily based on the pro rata
percentage of the net assets of each Class
to the total net assets of the Fund as of the
end of the prior day, adjusted for the
previous day's share activity.
5. Distribution expenses incurred pursuant to Reviewed a judgmentally selected sample
Rule 12b-1 are charged to certain Classes of of daily expense spreadsheets noting
shares based on a contractual asset-based that the proper expense amount was being
methodology. In addition, Transfer Agent fees allocated.
are charged to certain classes of shares based on
average account methodology.
III. Dividends
To ensure that dividend 1. Interest income is accrued and recorded by the Reviewed the daily income amounts
distributions are Funds on a daily basis by the Service Provider. allocated, noting agreement with income
accurately calculated Dividend income is recorded by the Funds reports generated from PMC.
for each Class of on the ex-date.
shares.
2. Corporate actions related to portfolio Reviewed a judgmentally selected sample
holdings are identified by the custodian of dividend ledger reports noting agreement
and properly reflected by Service Provider fund of corporate actions with independent
accounting. sources.
3. Investment income, including amortization of Reviewed a judgmentally selected
discount and premium, where applicable, is sample of allocation worksheets.
recorded by each Fund and is allocated to each
Class of shares based on its percentage of the Recalculated the income allocation
total net assets of shareholders of the Fund as noting agreement.
of the end of the prior day, adjusted for the
previous day's share activity.
4. For a nondaily dividend, nonmoney market
Funds, the dividend rate for each Class is Reviewed a sample of dividend calculations
determined by calculating the net investment for periodic dividend funds and recalculated
income available for all classes, before the amount of estimated distribution.
expenses unique to any class (or incremental
outstanding on record-date shares for all
classes combined to determine the gross
dividend rate for all shares. From the
gross dividend rate, a class-specific amount
per share for each class (representing the
unique and incrementally higher, if any,
expenses accrued during the period to that
class divided by the record-date shares
outstanding for that class) is subtracted
to determine the applicable class dividend rate.
5. For a money market or daily dividend, Reviewed a sample of dividend calculations
nonmoney market Funds, distributable income is for daily dividend funds and recalculated
calculated by subtracting Class expenses from the amount of estimated distribution.
Class income. The dividend rates are calculated
on a settlement-date basis for Class settled
shares outstanding.
6. Realized capital gains, if any, are Reviewed a judgmentally selected
allocated daily to each Class based on its sample of allocation work sheets.
percentage of the total net assets of the Fund as
of the end of the prior day, adjusted for the Recalculated the income allocation
previous day's share activity. noting agreement.
7. Capital gains, if any, are distributed at Reviewed a judgmentally selected sample
least once every 12 months by the Funds. The of capital gain distributions and
distribution rate is determined on the recalculated the amount of the estimated
ex-date by dividing the total realized gain of distribution.
the Fund by the total shares of beneficial
interest outstanding for the Fund as of the
record date. Capital gains dividends per share
should be identical for the classes of shares
within a Fund.
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ARTHUR ANDERSEN RESULTS OF TESTING: NO EXCEPTIONS NOTED.
