Sub-Item 77D: Policies with respect to security
investments
Effective June 26, 2000, the Capital Appreciation
Portfolio made a change to its investment policy.
Under normal market conditions the Portfolio intends to
invest at least 80% of its total assets in equity
securities of companies with market capitalizations
generally between $200 million and $2 billion at the
time of purchase, with an average market capitalization
of the Portfolio not to exceed $1.5 billion. Prior to
that date, the Portfolio intended to invest at least
80% of its total assets in equity securities of
companies with market capitalizations generally between
$100 million and $1 billion.
