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Item 13. Portfolio Turnover

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

the registrant’s portfolio turnover.

(b) Describe the policy of the registrant with respect to portfolio turnover.

Instruction. The registrant may reserve freedom of action with respect to portfolio turnover, 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 engage therein. (See Investment

Company Act of 1940 Release No. 167.)

(c) Furnish the following information with respect to transactions by the registrant in portfolio securities (exclusive of government

securities) for each of the periods covered by the financial statements filed herewith.

(1) Aggregate dollar amount of portfolio securities purchased.

(2) Aggregate dollar amount of the proceeds from portfolio securities sold.

(3) The percentage of the dollar amount in (1) represented by the dollar amount in (2).

(d) Furnish, for the last fiscal year covered by the financial statements filed herewith, the approximate aggregate brokerage commissions

paid by registrant to all brokers for effecting securities transactions for the account of the registrant.

Item 14. Other Fundamental Policies

(a) Describe any other policy of the registrant which it deems a matter of fundamental policy and elects to treat as such pursuant to

Sections 8(b)(2) and 13(a)(3) of the Act.

(b) Describe the practice followed by the registrant during the last fiscal year covered by the financial statements filed herewith with

respect to each of the matters, if any, described under (a).

SECURITIES AUTHORIZED

Item 15. Face-Amount Certificates

For each series of authorized face-amount certificates of the registrant furnish the following information:

As of ________________________________

(Date)

Col. A

Col. B

Col. C

Col. D

Gross payments by certificate holders

Title of

Face-amount

on certificates in default for the maximum

the series

authorized

outstanding

period and having no cash surrender value

Instructions.

1. The information shall be given as of the date of the most recent balance sheet filed for the registrant. Indicate in a note any material

change since that date.

2. State separately in Column (C), (i) the amount of certificates in default for the “maximum period,” as defined in Instruction 3 below,

and having no cash surrender value, and (ii) the amount of other certificates outstanding.

3. The term “maximum period” in Columns C and D means a period of six months when used with respect to certificates meeting the

requirements of Section 28(f) of the Act, when used with respect to other certificates, the term means the maximum period provided

in the certificate. The period shall be specified. Column D shall be totaled.

4. The information required by Column D need not be furnished with respect to any company which has not made a public offering of

face-amount certificates since December 31, 1940.

Form N-8b-4 - Registration Statement Of Face-Amount Certificate Companies - Securities And Exchange Commission Page 7

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