The Gabelli Small Cap Growth Fund
4th Quarter 1999
Section 10f-3 Transactions
The following securities were purchased pursuant to Rule 10f-3 and all
requirements of the Affiliated Underwriting Procedures of the Fund. A
folder documenting such compliance for each transaction is available for
inspection by Board Members.
Trade Dates 10-18-99
Issue Martha Stewart Living
Shares 4,000
Price $18
Amount $72,000
Spread Amount 1.26
Spread % 7.0%
Fund's % of Issue 0.05%
% of Issue for all
Gabelli Funds 0.12%
Broker Morgan Stanley Dean Witter
Issues within
90 days 3
Reason (1),(2)
Trade Dates 10-18-99
Issue WWF Entertainment
Shares 1,500
Price $17
Amount $25,500
Spread Amount 1.19
Spread % 7.0%
Fund's % of Issue 0.02%
% of Issue for all
Gabelli Funds 0.05%
Broker Bear Stearns
Issues within
90 days 3
Reason (1),(2)
Trade Dates 11-24-99
Issue PNV Inc.
Shares 15,000
Price $17
Amount $255,000
Spread Amount 1.19
Spread % 7.0%
Fund's % of Issue 0.4%
% of Issue for all
Gabelli Funds 2.13%
Broker CIBC World Markets
Issues within
90 days 3
Reason (1),(2)
The Purchases listed above meet the following requirements of 10f-3
...Part of an issue registered under the Securities Act of 1933.
...Purchased at not more than the offering price.
...Offered pursuant to a firm commitment underwriting.
...The issuer has been in continuos operation for at least 3 years.
All other requirements are presented in the table above.
Reason Key
(1) Does not exceed 125% of the mean offering spread of 3 comparable
Issues underwritten in the last 90 days.
(2) Does not exceed 110% of this underwriting spread of 3 comparable
Issues underwritten in the last 90 days.
Note: If 3 comparable issues are not available within 90 days, a one-year
window is used.
