MANAGED DISTRIBUITON POLICY

The Fund has implemented a managed distribution policy (the Policy) upon receiving approval of an exemptive order application by the Securities and Exchange Commission. The Policy permits the Fund to make quarterly distributions at a rate of 2% of the Fund's net assets to shareholders of record. The Fund intends to use net realized capital gains when making quarterly distributions. Implementation of the policy could result in a return of capital to shareholders if the amount of the distribution exceeds the Fund's net investment income and realized capital gains. Under the Policy realized capital gains in excess of the total distributed  would be included in the December distribution. The Policy is to declare distributions in stock, unless otherwise instructed by the shareholder. The Fund's distribution policy has been established by the Board of Trustees. The distribution policy may be changed by the Board of Trustees without Shareholder approval.

On August 4, 2009, the Fund announced the suspension of the Policy.  The Trustees of the Fund will continue to regularly monitor the conditions and circumstances relating to the suspension of the Policy.

DISTRIBUITONS

Record Date	Payable Date	$ Amount Per Share	Type	Share Issue Price
11/18/96	12/26/96	$1.64	Capital gains	$13.75
11/21/97	12/29/97	$0.74	Capital gains	$12.75
11/24/98	12/30/98	$0.28	Capital gains	$11.8125
11/18/99	12/30/99	$0.08	Income	$19.4375
11/18/99	12/30/99	$1.03	Capital gains	$19.4375
2/22/00	3/27/00	$0.45	Capital gains	$31.1875
5/23/00	6/27/00	$0.62	Capital gains	$28.25
8/23/00	9/27/00	$0.72	Capital gains	$30.75
11/22/00	12/27/00	$2.37	Capital gains	$21.125
2/19/01	3/23/01	$0.54	Capital gains	$16.90
5/10/01	6/20/01	$0.45	Capital gains	$22.89
8/9/01	9/20/01	$0.57	Capital gains	$19.55
11/20/01	12/21/01	$1.58	Capital Gains	$21.80
2/20/02	3/26/02	$0.51	Capital Gains	$19.94
5/23/02	6/27/02	$0.43	Capital Gains	$15.70
8/9/02	9/20/02	$0.34	Capital Gains	$12.49
11/22/02	12/27/02	$0.90	Capital Gains	$12.73
2/20/03	3/26/03	$0.29	Capital Gains	$12.30
5/19/03	6/27/03	$0.28	Capital Gains	$15.73
8/11/03	9/25/03	$0.33	Capital Gains	$15.46
11/26/03	12/31/03	$0.34	Capital Gains	$15.85
2/20/04	3/30/04	$0.34	Capital Gains	$16.52
5/25/04	6/29/04	$0.36	Capital Gains	$15.57
8/20/04	9/28/04	$0.3388	Capital Gains	$15.69
11/22/04	12/30/04	$0.32	Capital Gains	$15.89
2/22/05	3/30/05	$0.33	Capital Gains	$14.65
5/26/05	6/30/05	$0.31	Capital Gains	$15.63
8/22/05	9/30/05	$0.33	Capital Gains	$17.19
11/21/05	12/30/05	$1.09	Capital Gains	$15.43
2/21/06	3/30/06/05	$0.32	Capital Gains	$17.25
6/9/06	6/30/06	$0.35	Capital Gains	$14.35
9/8/2006	9/29/2006	$0.29	Capital Gains	$13.15
11/21/2006	12/29/2006	$0.28	Capital Gains	$13.52
2/22/07	3/30/07	$0.28	Capital Gains	$14.14
5/25/07	6/29/07	$0.29	Capital Gains	$13.69
8/22/07	9/28/07	$0.29	Capital Gains	$13.37
11/21/07	12/31/07	$0.31	Capital Gains	$12.80
2/22/08	3/31/08	$0.31	Capital Gains	$11.53
5/23/08	6/30/08	$0.27	Capital Gains	$11.76
8/22/08	9/30/08	$0.26	Capital Gains	$10.82
11/21/08	12/31/08	$0.26	TBD	$8.20
2/20/09	3/31/09	$0.22	TBD	$7.62
5/20/09	6/30/09	$0.20	TBD	$8.44

Please Note: This information is derived from our financial statements and press releases. These documents can be viewed on this website and/or can be obtained directly from Hambrecht & Quist Capital Management LLC.