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Disclosure of Portfolio Holdings

The Funds publish their portfolio holdings online each month-end. They publish annual and semi-annual reports containing portfolio holdings. They file periodic reports with the SEC containing portfolio holdings (Form N-Q), which may be published on the Internet. They may provide dealers, financial services and reporters with month-end portfolio holdings. The Funds do not disclose mid-month portfolio holdings. However, in occasional circumstances in which he deems it in the best interest of the Funds, the president may disclose portfolio information so long as the recipient agrees not to trade a Fund based on such information. Neither the Adviser, the Funds, nor any affiliated party shall receive any compensation or consideration in connection with the disclosure of portfolio holdings. Information about open trades, strategies, and investment programs is proprietary information of the Adviser and kept confidential.

In view of these Fund policies, it is unlikely that a conflict of interest between the interests of the Funds, the adviser or any affiliated person of the Funds or the adviser may arise. However, should the president become aware that a potential conflict of interest may exist in connection with portfolio disclosures, he will promptly consult with the Board chairman with regard to action to be taken. Periodically the president will report to the Board any mid-month portfolio holdings disclosures.