Exhibit


SUB-ITEM
77Q3(a)

          (i)  Based on an evaluation of the Disclosure Controls as of a date
               within 90 days of the Filing Date, the Disclosure Controls are
               effectively designed to ensure that information required to be
               disclosed by the Fund in the Report is recorded, processed,
               summarized and reported by the Filing Date, including ensuring
               that information required to be disclosed in the Report is
               accumulated and communicated to the Fund's management, including
               the Fund Officers, as appropriate to allow timely decisions
               regarding required disclosure.


          (ii) There were no significant changes in the Fund's internal controls
               or in other factors that could significantly affect these
               controls subsequent to the date of their evaluation, and there
               were no corrective actions with regard to significant
               deficiencies and material weaknesses.


          (iii)Certification  of principal  executive  officer  (see  attached).
               Certification of principal financial officer (see attached).