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Instruction. No information need be given in response to any paragraph of this item as to publicly distributed certificates of beneficial

participation in mortgages or publicly distributed bonds secured by mortgages.

Item 10. Borrowing Money

(a) Summarize briefly any provision in the charter, other instrument of organization or bylaws of the registrant which specifically

authorizes, or restricts the power of, the registrant to borrow money.

(b) Describe the policy of the registrant with respect to such borrowings.

Instruction. Registrant may reserve freedom of action with respect to borrowings coming within the purview of Section 18(j)(1)(C) of

the Act, but if such freedom of action is reserved, a statement shall be made briefly indicating, insofar as is practicable, the extent to which

it is intended so to borrow. (See Investment Company Act of 1940 release No. 167.)

(c) State, as at the end of each quarter of each of the periods covered by the financial statements filed herewith, the amount of such

borrowings outstanding, and describe to the extent practicable the reasons for the registrant’s borrowings during the three-year

period.

Item 11. Purchase and Sale of Commodities and Commodity Contracts

(a) Summarize briefly any provision in the charter, other instrument of organization or bylaws of the registrant which specifically

authorizes, or restricts the power of, the registrant to engage in the purchase and sale of commodities and commodity contracts.

(b) Describe the policy of the registrant with respect to the purchase and sale of commodities and commodity contracts.

Instruction. The registrant may reserve freedom of action with respect to the purchase and sale of commodities and commodity contracts,

but if such freedom of action is reserved, a statement shall be made briefly indicating, insofar as is practicable, the extent to which it is intended

so to purchase and sell. (See Investment Company Act of 1940 Release No. 167.)

(c) Indicate the types of commodities and commodity contracts purchased or sold, during the periods covered by the financial statements

filed herewith and the approximate dollar amounts of such commodities and commodity contracts purchased and sold during each

such period.

Item 12. Loans to Other Persons

(a) Describe any provision in the charter, other instrument of organization, or bylaws of the registrant which specifically authorizes, or

restricts the power of, the registrant to make loans to other persons.

(b) Describe the policy of the registrant with respect to making loans to other persons.

Instruction. Registrant may reserve freedom of action with respect to making loans to other persons, but if such freedom of action is

reserved, a statement shall be made briefly indicating, insofar as is practicable, the extent to which the registrant intends to make such loans.

(See Investment Company Act of 1940 Release No. 167.)

(d) Indicate, to the extent practicable, the persons to whom loans were made by the registrant during each of the last three fiscal years,

the amount and life of each such loan, the amount thereof outstanding as of the date of the latest balance sheet filed herewith, the

rate of interest paid or charged on the loan and the terms of repayment. Indicate the amount of any loss sustained by the registrant,

during each of the last three fiscal years, the amount of any loss sustained by the registrant, during each of the last three fiscal years,

the amount of the reserve maintained, and the nature and amount of any collateral held by the registrant as security.

Instructions.

For the purpose of this item the term “loans” shall include advances to affiliated persons, affiliated persons of such persons, and sales

personnel, but shall not include (1) the purchase of a portion of an issue of bonds, debentures or other securities issued by a person other

than the registrant, an affiliated person, or an affiliated person of such person, whether or not the purchase was made upon the original

issuance of the securities, (2) the purchase of mortgages upon real estate or loans secured by mortgages or first liens upon real estate,

except where the borrower is the registrant, an affiliated person, or an affiliated person of such person, or (3) loans made upon the security

of outstanding face-amount certificates which do not exceed the reserves applicable to such certificates.

As to any natural persons, other than officers and directors, constituting a class, the information called for by (c) may be furnished for such

class as a unit provided the approximate number of members of the class is stated and the information is clearly presented. Information

with respect to affiliated persons or classes of affiliated persons shall be shown separately.

Form N-8b-4 - Registration Statement Of Face-Amount Certificate Companies - Securities And Exchange Commission Page 6

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