ITEM 77.Q2
 
 
Section 16(a) Beneficial Ownership Reporting Compliance

Based on the Fund's review of Forms 3 and 4 and amendments thereto furnished to the Fund during its most recent fiscal year and Forms 5 and amendments thereto furnished to the Fund with respect to its most recent fiscal year, the Fund believes that its directors and officers, and any beneficial owners of more than 10% of the Fund's common stock complied with the filing requirements of Section 16(a) of the Securities Exchange Act of 1934 except with respect to the following:
 
Name of Filer Form Type  Number of Late Reports  Number of Transactions
       
Bassett S. Winmill 5 1 10
       
Irene K. Kawczynski 3 1 0