Oppenheimer Capital LLC (Oppenheimer Capital)
As of April 5, 2010 the following individuals
are part of the derivatives group at Oppenheimer Capital and constitute the
team that has primary responsibility for the day-to-day implementation of
the Index Option Strategy, with Mr. Bond-Nelson serving as head of the team:
Stephen Bond-Nelson
,
Senior Vice President
(Portfolio Manager since February, 2005
(Inception)) Mr. Bond-Nelson is a senior member of the Structured Products
team and is portfolio manager of the Structured Alpha Absolute Yield and Enhanced Index US
Large Cap Core institutional strategies. Prior to joining the firm in 1999,
he spent five years at Prudential Mutual Funds as a research analyst/ associate.
Mr. Bond-Nelson holds an MBA from Rutgers University, a BS from Lehigh University
and NASD Series 7 and 63 licenses.
Valentin Ivanov
,
Vice President
(Portfolio Manager since February, 2005
(Inception)) Mr. Ivanov is a quantitative analyst for Oppenheimer Capitals
Structured Products team and brings 10 years of industry experience to his
position. Prior to joining Oppenheimer Capital in 2005, he served as a portfolio
administrator and trader with Allianz Global Investors Managed Accounts and
Nicholas-Applegate Capital Management. Mr. Ivanov holds a BA from the University
of San Diego.
Michael Purcell
,
Assistant Vice President
(Portfolio Manager since July 2006) Mr.
Purcell is a research analyst for Oppenheimer Capitals Structured Products team and brings 4 years of industry experience to his position. Prior to joining the firm he served as an associate portfolio specialist and marketing analyst with Allianz Global Investors. Mr. Purcell earned a BS in Finance and Accounting from Fairfield Universitys
Dolan School of Business, and holds NASD Series 7 and 66 licenses.
(a) (2)
NACM
The following summarizes information regarding each of the accounts, excluding the Fund, that were managed by the Portfolio Managers as of January 31, 2010 including accounts managed by a team, committee, or other group that includes the Portfolio Managers.
|
|
Other
RICs
|
|
Other
Accounts
|
|
Other
Pooled
|
PM
|
|
#
|
AUM($million)
|
|
#
|
|
AUM($million)
|
|
#
|
|
AUM($million)
|
|
|
|
|
|
|
|
|
|
|
|
|
Douglas G. Forsyth, CFA
|
|
7
|
2,845.6
|
|
10
|
|
1,260.5
|
|
5
|
|
679.5*
|
A-7
*Of these other pooled investment vehicles, two
accounts totaling $418.3 million in assets pay an advisory fee that is
based in part on the performance of the account.
NFJ
The following summarizes information regarding each of the accounts, excluding the Fund, that were managed by the Portfolio Managers as of January 31, 2010 including accounts managed by a team, committee, or other group that
includes the Portfolio Managers.
Portfolio Manager
|
|
Account Type
|
Number
|
|
Assets Under
|
|
|
|
of
|
|
Management
|
|
|
|
accounts
|
|
01/31/10
|
|
Ben Fischer
|
|
Other investment companies
|
3
|
|
$
|
87.4
|
|
|
Other accounts
|
55
|
|
$
|
9,442
|
|
|
Registered Investment
|
18
|
|
$
|
11,334
|
|
Jeff Partenheimer
|
|
Other investment companies
|
1
|
|
$
|
7.6
|
|
|
Other accounts
|
37
|
|
$
|
6,829
|
|
|
Registered Investment
|
12
|
|
$
|
8,363
|
Oppenheimer Capital
The following summarizes information regarding
each of the accounts, excluding the Fund, that were managed by the Portfolio
Managers as of January 31, 2010 including accounts managed by a team, committee,
or other group that includes the Portfolio Managers.
Stephen Bond-Nelson:
Other Investment Companies (2) $249,473,494
Other Pooled Investment Vehicles* (5) $732,367,830
Other Accounts (3) - $25,520,367
(*Of these other pooled investment vehicles, five
accounts pay an advisory fee that is based in part on the performance of the
account)
Valentin Ivanov:
Other Investment Companies (2) $249,473,494
Other Pooled Investment Vehicles* (5) $732,367,830
Other Accounts (3) - $25,520,367
(*Of these other pooled investment vehicles, five
accounts pay an advisory fee that is based in part on the performance of the
account)
A-8
Michael Purcell:
Other Investment Companies (2) $249,473,494
Other Pooled Investment Vehicles* (5) $732,367,830
Other Accounts (3) - $25,520,367
(*Of these other pooled investment vehicles, five
accounts pay an advisory fee that is based in part on the performance of the
account)
NACM
Like other investment professionals with multiple clients, a Portfolio Manager for a Fund may face certain potential conflicts of interest in connection with managing both the Fund and other accounts at the same time. The
paragraphs below describe some conflicts faced by investment professionals at most major financial firms.
NACM has adopted compliance policies and procedures that address certain of these potential conflicts. The management of accounts with different advisory fee rates and/or fee structures, including accounts that pay advisory fees
based on account performance may raise potential conflicts of interest by creating an incentive to favor higher-fee accounts. These potential conflicts may include, among others:
-
The most attractive investments could be allocated to higher-fee accounts or
performance fee accounts.
-
The trading of higher-fee accounts could be favored as to timing and/or execution
price. For example, higher-fee accounts could be permitted to sell securities
earlier than other accounts when a prompt sale is desirable or to buy securities at
an earlier and more opportune time.
-
The investment management team could focus their time and efforts primarily on
higher-fee accounts due to a personal stake in compensation.
When NACM considers the purchase or sale of a security
to be in the best interests of a Fund as well as other accounts, NACMs trading desk may, to the extent permitted by applicable laws and regulations, aggregate the
securities to be sold or purchased. Aggregation of trades may create the potential for unfairness to a Fund or another account if one account is favored over another in allocating the securities purchased or soldfor
example, by allocating a disproportionate amount of a security that is likely
to increase in value to a favored account. NACM considers many factors when allocating
securities among accounts, including the accounts investment style,
applicable investment restrictions, availability of securities, available cash
and other current holdings. NACM attempts to allocate investment opportunities
among accounts in a fair and equitable manner. However, accounts are not assured
of participating equally or at all in particular investment allocations due to
such factors as noted above.
Cross trades, in which one Investment
Adviser account sells a particular security to another account (potentially
saving transaction costs for both accounts), may also pose a potential conflict
of interest if, for example, one account is permitted to sell a security to
another account at a higher price than an independent third party would
A-9
pay. NACM has adopted compliance procedures that provide that all cross trades are to be made at an independent current market price, as required by law.
Another potential conflict of interest may arise
from the different investment objectives and strategies of a Fund and other
accounts. For example, another account may have a shorter-term investment horizon
or different investment objectives, policies or restrictions than a Fund. Depending
on another accounts objectives or other factors, a Portfolio Manager
may give advice and make decisions that may differ from advice given, or the
timing or nature of decisions made, with respect to a Fund. In addition, investment
decisions are subject to suitability for the particular account involved. Thus,
a particular security may not be bought or sold for certain accounts even though
it was bought or sold for other accounts at the same time. More rarely, a particular
security may be bought for one or more accounts managed by a Portfolio Manager
when one or more other accounts are selling the security (including short sales).
There may be circumstances when purchases or sales of portfolio securities
for one or more accounts may have an adverse effect on other accounts. NACM maintains trading policies designed to provide portfolio managers an
opportunity to minimize the effect that short sales in one portfolio may have on holdings in other portfolios.
A Portfolio Manager who is responsible for managing multiple accounts may devote unequal time and attention to the management of those accounts. As a result, the Portfolio Manager may not be able to formulate as complete a
strategy or identify equally attractive investment opportunities for each of those accounts as might be the case if he or she were to devote substantially more attention to the management of a single fund. The effects of this potential conflict may
be more pronounced where funds and/or accounts overseen by a particular Portfolio Manager have different investment strategies.
A Funds Portfolio Manager(s) may be able
to select or influence the selection of the broker/dealers that are used to
execute securities transactions for the Fund. In addition to executing trades,
some brokers and dealers provide NACM with brokerage and research services
(as those terms are defined in Section 28(e) of the Securities Exchange Act
of 1934), which may result in the payment of higher brokerage fees than might
have otherwise be available. These services may be more beneficial to certain
funds or accounts than to others. In order to be assured of continuing to receive
services considered of value to its clients, NACM has adopted a brokerage allocation
policy embodying the concepts of Section 28(e) of the Securities Exchange Act
of 1934. NACM allocates the payment of brokerage commissions is subject to
the requirement that the Portfolio Manager determine in good faith that the
commissions are reasonable in relation to the value of the brokerage and research
services provided to the Fund.
A Funds Portfolio Manager(s) may also face
other potential conflicts of interest in managing a Fund, and the description
above is not a complete description of every conflict that could be deemed
to exist in managing both the Fund and other accounts.
A-10
In addition, a Funds Portfolio Manager may also manage other accounts (including their personal assets or the assets of family members) in their personal capacity. The NACMs investment personnel, including each
Funds Portfolio Manager, are subject to restrictions on engaging in personal securities transactions pursuant to the NACMs
Codes of Ethics, which contain provisions and requirements designed to identify
and address conflicts of interest between personal investment activities and
the interests of the Fund.
NFJ
Potential Conflict of Interest
Like other
investment professionals with multiple clients, a portfolio manager for a Fund
may face certain potential conflicts of interest in connection with managing
both the Fund and other accounts at the same time. The paragraphs below describe
some of these potential conflicts, which NFJ believes are faced by investment
professionals at most major financial firms. NFJ, the Adviser and the Trustees
have adopted compliance policies and procedures that attempt to address certain
of these potential conflicts. The management of accounts with different advisory
fee rates and/or fee structures, including accounts that pay advisory fees
based on account performance (performance
fee accounts), may raise potential conflicts of interest by creating an
incentive to favor higher-fee accounts. These potential conflicts may include,
among others:
-
The most attractive investments could be allocated to higher-fee accounts or
performance fee accounts.
-
The trading of higher-fee accounts could be favored as to timing and/or execution
price. For example, higher fee accounts could be permitted to sell securities
earlier than other accounts when a prompt sale is desirable or to buy securities at
an earlier and more opportune time.
-
The investment management team could focus their time and efforts primarily on
higher-fee accounts due to a personal stake in compensation.
A potential
conflict of interest may arise when a Fund and other accounts purchase or sell
the same securities. On occasions when a portfolio manager considers the purchase
or sale of a security to be in the best interest of a Fund as well as other
accounts, the NFJs trading desk may, to the extent by applicable laws and regulations, aggregate the securities to be sold or purchased in order to obtain the best execution and lower brokerage
commissions, if any. Aggregation o trades may create the potential for unfairness to a Fund or another account if one account is favored over another in allocating securities purchased or sold for
example, by allocating a disproportionate amount of a security that is likely
to increase in value to a favored account.
Another potential
conflict of interest may arise based on the different investment objectives
and strategies of a Fund and other accounts. For example, another account may
have a shorter-term investment horizon or different investment objective, policies
or restrictions than a Fund. Depending on another accounts objectives
or other factors, a
A-11
portfolio manager may give advice and make decisions that may differ from advice given, or the timing or nature of decision made, with respect to a Fund. In addition, investment decisions are the product of many factors in
addition to basic suitability for the particular account involved. Thus, a particular security may be bought or sold for certain accounts even though it could have been bought or sold for other accounts at the same time. More rarely, a particular
security may be bought for one or more accounts managed by a portfolio manager when one or more other accounts are selling the security. There may be circumstances when purchased or sales of portfolio securities for one or more accounts may have an
adverse effect on other accounts.
Portfolio managers are responsible for managing multiple funds and/or accounts with unequal time and attention to the management of those funds and/or accounts. As a result, the portfolio manager may
not be able to formulate as complete a strategy or identify equally attractive investment opportunities for ach of those accounts as might be the case if he or she were to devote substantially more attention to the management of a single fund. The
effects of this potential conflict may be more pronounced where funds and/or accounts overseen by a particular portfolio manager have different investment strategies.
A Funds portfolio managers may be able to select or influence the selection of the brokers and dealers that are used to execute securities transactions for the Funds. In addition to executing
trades, some brokers and dealers provide portfolio managers with brokerage an research services (as those terms are defined in Section 28(e) of the Securities Exchange Act of 1934), which may result in the payment of higher brokerage fees than might
have otherwise been available. These services may be more beneficial to certain funs or accounts than to others. Although the payment of brokerage commissions is subject to the requirement that the portfolio manager determine in good faith and the
commissions are reasonable in relation to the value of the brokerage and research services provided to the Fund and NFJs other clients, a portfolio managers
decision as to the selection of brokers and dealers could yield disproportionate
costs and benefits among the funds and/or accounts that he or she managers.
A Funds portfolio managers may also face other potential conflicts of interest in managing a Fund, and the description above is not complete description of every conflict that could be deemed to
exist in managing both the Funds and other accounts. In addition, a Funds portfolio manger may also manage other accounts (including their personal assets or the assets of family members) in their personal capacity. The management of these
accounts may also involve certain of the potential conflicts described above. Front-running could also exist if a portfolio manager transacted in his own account prior to placing an order for a Fund or other clients. NFJs investment personnel,
including each Funds portfolio manager, are subject to restrictions on
engaging in personal securities transactions, pursuant to a Code of Ethics adopted
by NFJ, which contain provisions and requirements designed to identify and address
certain conflicts of interest between personal investments activities and the
interest of the Funds.
A-12
As part of
NFJs Compliance Program, NFJ has established a Compliance Committee,
a Best Execution Committee, a Proxy Voting Committee and a Pricing Committee
to help develop policies and procedures that help NFJ avoid, mitigate, monitor
and oversee areas that could present potential conflicts of interest.
Oppenheimer Capital
Like other investment professionals with multiple clients, a Portfolio Manager for a Fund may face certain potential conflicts of interest in connection with managing both the Fund and other accounts at the same time. The
paragraphs below describe some conflicts faced by investment professionals at most major financial firms.
Oppenheimer Capital has adopted compliance policies and procedures that address certain of these potential conflicts. The management of accounts with different advisory fee rates and/or fee structures, including accounts that pay
advisory fees based on account performance may raise potential conflicts of interest by creating an incentive to favor higher-fee accounts. These potential conflicts may include, among others:
-
The most attractive investments could be allocated to higher-fee accounts or
performance fee accounts.
-
The trading of higher-fee accounts could be favored as to timing and/or execution
price. For example, higher-fee accounts could be permitted to sell securities
earlier than other accounts when a prompt sale is desirable or to buy securities at
an earlier and more opportune time.
-
The investment management team could focus their time and efforts primarily on
higher-fee accounts due to a personal stake in compensation.
When Oppenheimer Capital considers the purchase
or sale of a security to be in the best interests of a Fund as well as other
accounts, Oppenheimer Capitals trading desk may, to the extent permitted by applicable laws and
regulations, aggregate the securities to be sold or purchased. Aggregation of trades may create the potential for unfairness to a Fund or another account if one account is favored over another in allocating the securities purchased or soldfor
example, by allocating a disproportionate amount of a security that is likely
to increase in value to a favored account. Oppenheimer Capital considers many
factors when allocating securities among accounts, including the accounts
investment style, applicable investment restrictions, availability of securities,
available cash and other current holdings. Oppenheimer Capital attempts to allocate
investment opportunities among accounts in a fair and equitable manner. However,
accounts are not assured of participating equally or at all in particular investment
allocations due to such factors as noted above.
Cross trades, in which one Investment
Adviser account sells a particular security to another account (potentially
saving transaction costs for both accounts), may also pose a potential conflict
of interest if, for example, one account is permitted to sell a
A-13
security to another account at a higher price than an independent third party would pay. Oppenheimer Capital has adopted compliance procedures that provide that all cross trades are to be made at an independent current market
price, as required by law.
Another potential conflict of interest may arise
from the different investment objectives and strategies of a Fund and other
accounts. For example, another account may have a shorter-term investment horizon
or different investment objectives, policies or restrictions than a Fund. Depending
on another accounts objectives or other factors, a Portfolio Manager
may give advice and make decisions that may differ from advice given, or the
timing or nature of decisions made, with respect to a Fund. In addition, investment
decisions are subject to suitability for the particular account involved. Thus,
a particular security may not be bought or sold for certain accounts even though
it was bought or sold for other accounts at the same time. More rarely, a particular
security may be bought for one or more accounts managed by a Portfolio Manager
when one or more other accounts are selling the security (including short sales).
There may be circumstances when purchases or sales of portfolio securities
for one or more accounts may have an adverse effect on other accounts. Oppenheimer Capital maintains trading policies designed to provide portfolio
managers an opportunity to minimize the effect that short sales in one portfolio may have on holdings in other portfolios.
A Portfolio Manager who is responsible for managing multiple accounts may devote unequal time and attention to the management of those accounts. As a result, the Portfolio Manager may not be able to formulate as complete a
strategy or identify equally attractive investment opportunities for each of those accounts as might be the case if he or she were to devote substantially more attention to the management of a single fund. The effects of this potential conflict may
be more pronounced where funds and/or accounts overseen by a particular Portfolio Manager have different investment strategies.
A Funds Portfolio Manager(s) may be able
to select or influence the selection of the broker/dealers that are used to
execute securities transactions for the Fund. In addition to executing trades,
some brokers and dealers provide Oppenheimer Capital with brokerage and research
services (as those terms are defined in Section 28(e) of the Securities Exchange
Act of 1934), which may result in the payment of higher brokerage fees than
might have otherwise be available. These services may be more beneficial to
certain funds or accounts than to others. In order to be assured of continuing
to receive services considered of value to its clients, Oppenheimer Capital
has adopted a brokerage allocation policy embodying the concepts of Section
28(e) of the Securities Exchange Act of 1934. Oppenheimer Capital allocates
the payment of brokerage commissions is subject to the requirement that the
Portfolio Manager determine in good faith that the commissions are reasonable
in relation to the value of the brokerage and research services provided to
the Fund.
A-14
A Funds Portfolio Manager(s) may also face other potential conflicts of interest in managing a Fund, and the description above is not a complete description of every conflict that could be deemed to exist in managing both
the Fund and other accounts. In addition, a Funds Portfolio Manager may also manage other accounts (including their personal assets or the assets of family members) in their personal capacity. The Oppenheimer Capitals investment
personnel, including each Funds Portfolio Manager, are subject to restrictions on engaging in personal securities transactions pursuant to the Oppenheimer Capitals
Codes of Ethics, which contain provisions and requirements designed to identify
and address conflicts of interest between personal investment activities and
the interests of the Fund.
(a) (3)
NACM
As of January 31, 2010 the following explains the
compensation structure of each individual (as listed in the Prospectus) that
shares primary responsibility for day-today portfolio management of the Fund
(for the purposes of this section, Portfolio Managers):
Nicholas-Applegate believes that competitive compensation is essential to retaining top industry talent. With that in mind, the firm continually reevaluates its compensation policies against industry benchmarks. Its goal is to
offer portfolio managers and analysts compensation and benefits in the top quartile for comparable experience, as measured by industry benchmarks surveyed by McLagan and ECS (Watson Wyatt Data Services).
Nicholas-Applegates compensation policy features both short-term and long-term components. The firm offers competitive base salaries and bonuses, profit-sharing and generous retirement plans. Investment professionals
annual compensation is directly affected by the performance of their portfolios, their performance as individuals and the success of the firm. Typically, an investment professionals
compensation is comprised of a base salary and a bonus.
Investment professionals are awarded bonuses based
primarily on product performance. A 360-degree qualitative review is also considered.
As part of the 360-degree review, analysts and portfolio managers are reviewed
by the portfolio manager who is responsible for the teams final investment
decisions and other portfolio managers to whose portfolios they contribute.
Portfolio managers responsible for final investment decisions are reviewed
by the Chief Investment Officer, who evaluates performance both quantitatively
versus benchmarks and peer universes, as well as qualitatively.
Compensation and Account Performance
Compensation pools for investment teams are directly related to the size of the business and the performance of the products. Approximately half of the pool is based on one, three and five year performance relative to benchmarks
and peers. The team pools are
A-15
then subjectively allocated to team members based on individual contributions to client accounts. We believe our compensation system clearly aligns the interests of clients with our people and keeps our compensation competitive
with industry norms.
Long-Term Incentive Plan
A Long-Term Incentive Plan provides rewards to
certain key staff and executives of Nicholas-Applegate and the other Allianz
Global Investors companies to promote long-term growth and profitability. The
Plan provides awards that are based on Nicholas-Applegates operating earnings growth. The plan provides a link between longer term company performance and participant pay, further motivating participants to make a long-term commitment to the companys
success.
Equity Ownership
In September 2006, Allianz SE approved an equity ownership plan for key employees of Nicholas-Applegate. The plan was implemented as of January 31, 2007. Nicholas-Applegate believes this plan is important in retaining and
recruiting key investment professionals, as well as providing ongoing incentives for Nicholas-Applegate employees.
NFJ
The following information is provided as of January 31, 2010.
NFJ believes that its compensation programs are competitively positioned to attract and retain high-caliber investment professionals. As described below, compensation includes a base salary and a variable bonus opportunity or
profit sharing participation and may also include participation in other incentive compensation programs. In addition, a full employee benefit package is offered.
-
Base Salary. Each Portfolio Manager/analyst is paid a base salary. In setting
the base salary, NFJs intention is to be competitive in light of the particular
Portfolio Manager/analysts experience and responsibilities. Management of the firm evaluates competitive market compensation by reviewing
compensation survey results of the investment industryconducted by an independent
third party.
-
Annual Bonus or Profit Sharing. Portfolio Managers who are Managing Directors
of NFJ participate in NFJs Non-Qualified Profit Sharing Plan. Other Portfolio Managers/analysts are eligible to receive an annual bonus which
is tied to such Portfolio Manager/analysts successful job performance.
-
Other Incentive Programs. Portfolio Managers/analysts may be eligible to participate in a non-qualified deferred compensation plan, which allows participating
employees the tax benefits of deferring the receipt of a
A-16
portion of their cash compensation. Portfolio Managers/analysts
may also, from time to time, be granted specific deferred incentive awards.
Portfolio Managers/analysts who are not Managing Directors are also eligible
to participate in the firms Long Term Cash Bonus Plan. Each of the Managing
Directors have also been awarded Allianz SE Restricted Stock Units which reflect
changes in the value of Allianz SE stock. Grants of deferred incentive, Long
Term Cash Bonus awards and Allianz SE Restricted Stock Units all vest over
a period of time which NFJ believes helps align employee and firm interests.
Oppenheimer Capital
The following information is provided as of January
31, 2010. Oppenheimer Capital believes that competitive compensation is essential
to retaining top industry talent. With that in mind, we continually reevaluate
our compensation policies against industry benchmarks. Our goal is to offer
portfolio managers and analysts' compensation and benefits in the top quartile
for top performance, as measured by industry benchmarks.
Oppenheimer Capital's compensation policy features both short-term and long-term components. Our Firm offers competitive base salaries and bonuses, profit-sharing and generous retirement plans. Investment professionals' annual
compensation is directly affected by the performance of their portfolios, their performance as individuals, and the success of the Firm. Typically, an investment professional's cash compensation comprises a base salary and a bonus, plus long-term
equity-like incentive units.
Investment professionals are awarded bonuses primarily based on product performance. A 360-degree qualitative review is also considered. As part of the 360-degree review, analysts and portfolio managers are reviewed by the
portfolio manager who is responsible for the team's final investment decisions and other portfolio managers to whose portfolios they contribute. Portfolio managers responsible for final investment decisions are reviewed by the Chief Investment
Officer, who evaluates performance both quantitatively versus benchmarks and peer universes, as well as qualitatively.
Compensation and Account Performance - Compensation pools for investment teams are directly related to the size of the business and the performance of the products. Approximately half of the pool is based on one, three and five
year performance relative to benchmarks and peers. The team pools are then subjectively allocated to team members based on individual contributions to client accounts. We believe our compensation system clearly aligns the interests of clients with
our people and keeps our structure competitive with industry norms.
Long-Term Incentive Plan - A Long-Term Incentive Plan provides rewards to key staff based on AGI Management Partners' operating earnings growth. The Plan provides a link between the Firm's longer-term performance and employee pay,
further motivating participants to make a long-term commitment to the company's success.
A-17
Equity Ownership - Effective January 2010, Oppenheimer Capital's Managing Directors participate in an equity ownership plan. We believe this plan is important in retaining and recruiting key investment professionals, as well as in providing ongoing incentives.
4) The following information is provided as of January 31, 2010.
NACM
None.
NFJ
NFJ Dividend Interest and Premium Strategy
|
|
PM Ownership
|
Ben Fischer
|
$100,001 - $500,000
|
Jeff Partenheimer
|
None
|
Oppenheimer Capital
None.
ITEM 9.
PURCHASES OF EQUITY SECURITIES BY CLOSED-END MANAGEMENT INVESTMENT COMPANY AND
AFFILIATED COMPANIES-
None
ITEM 10.
SUBMISSION OF MATTERS TO A VOTE OF SECURITY HOLDERS
There have
been no material changes to the procedures by which shareholders may recommend
nominees to the Funds Board of Trustees since the Fund last provided
disclosure in response to this item.
ITEM 11.
CONTROLS AND PROCEDURES
|
|
(a)
|
The
registrants President and Chief Executive Officer and Treasurer, Principal
Financial Accounting Officer have concluded that the registrants disclosure
controls and procedures (as defined in Rule 30a-2(c) under the Act (17 CFR
270.30a-3(c))), as amended are effective based on their evaluation of these
controls and procedures as of a date within 90 days of the filing date of
this document.
|
|
|
(b)
|
There were
no significant changes over financial reporting (as defined in Rule 30a-3(d)
under the Act (17 CFR 270.30a-3 (d))) that that occurred during the second
fiscal quarter of the period covered by this report that materially affected
, or is reasonably likely to affect, the registrants internal control over
financial reporting.
|
ITEM 12.
EXHIBITS
(a) (1)
Exhibit 99.CODE ETH - Code of Ethics
(a) (2)
Exhibit 99 Cert. - Certification pursuant to Section 302 of the Sarbanes-Oxley
Act of 2002
(b) Exhibit
99.906 Cert. - Certification pursuant to Section 906 of the Sarbanes-Oxley Act
of 2002
Signature
Pursuant to
the requirements of the Securities Exchange Act of 1934 and the Investment
Company Act of 1940, the registrant has duly caused this report to be signed on
its behalf by the undersigned, thereunto duly authorized.
|
|
(Registrant)
|
NFJ
Dividend, Interest &
|
|
Premium
Strategy Fund
|
|
|
|
|
By
|
/s/ Brian S.
Shlissel
|
|
|
President
and Chief Executive Officer
|
|
|
By
|
/s/ Lawrence
G. Altadonna
|
|
|
Treasurer,
Principal Financial & Accounting Officer
|
Pursuant to
the requirements of the Securities Exchange Act of 1934 and the Investment
Company Act of 1940, this report has been signed below by the following persons
on behalf of the registrant and in the capacities and on the dates indicated.
|
|
By
|
/s/ Brian S.
Shlissel
|
|
|
President
and Chief Executive Officer
|
|
|
By
|
/s/ Lawrence
G. Altadonna
|
|
|
Treasurer,
Principal Financial & Accounting Officer
|
Virtus Dividend Interest... (NYSE:NFJ)
Historical Stock Chart
From Jun 2024 to Jul 2024
Virtus Dividend Interest... (NYSE:NFJ)
Historical Stock Chart
From Jul 2023 to Jul 2024