Note 1 – Organization and Significant Accounting Policies
Total Return US Treasury Fund, Inc. (“Total Return”), Managed Municipal Fund, Inc. (“Managed Municipal”), North American Government Bond Fund, Inc. (“North American”) and ISI Strategy Fund, Inc. (“Strategy”) (each a “Fund” and collectively, the “Funds”) are registered under the Investment Company Act of 1940, as amended, as open-end management investment companies. The Funds are organized as corporations under the laws of the State of Maryland.
Total Return’s investment objectives are to provide a high level of total return with relative stability of principal and, secondarily, high current income. Managed Municipal’s investment objectives are to provide a high level of total return with relative stability of principal and, secondarily, high current income exempt from Federal income tax. North American’s investment objective is to provide a high level of current income, consistent with prudent investment risk. Strategy’s investment objective is to maximize total return through a combination of long-term growth of capital and current income.
Total Return and Strategy each currently offer a single class of shares (ISI Shares) to investors. Managed Municipal offers two classes of shares – ISI Class A Shares and ISI Class I Shares. North American offers three classes of shares – ISI Class A Shares, ISI Class C Shares and ISI Class I Shares. ISI Shares and ISI Class A Shares are subject to a maximum front-end sales charge equal to 3.00%. A contingent deferred sales charge of 1.00% is imposed on the sale of ISI Class C Shares if redeemed within the first year of purchase.
Total Return and Strategy are authorized to issue 115,000,000 and 25,000,000 shares, respectively, of ISI Shares at $0.001 par value. Managed Municipal is authorized to issue 50,000,000 ISI Class A Shares and 5,000,000 ISI Class I Shares at $0.001 par value. North American is authorized to issue 50,000,000 ISI Class A Shares, 5,000,000 ISI Class C Shares and 5,000,000 ISI Class I Shares at $0.001 par value.
B.
|
Valuation of Securities
|
Exchange traded securities and over-the-counter securities listed on the NASDAQ National Market System for which market quotations are readily available are valued each Fund business day using the last reported sales price or the NASDAQ Official Closing Price (“NOCP”) provided by independent pricing services as of the close of trading on the New York Stock Exchange (normally 4:00p.m. Eastern time). In the absence of a sale price or NOCP, such securities are valued at the mean of the last bid and the last asked prices. Non-exchange traded securities for which quotations are readily available are generally valued at the mean between the last bid and the last asked prices. Debt securities may be valued at prices supplied by a Fund’s pricing agent based
Notes to Financial Statements (continued)
on broker or dealer supplied valuations or matrix pricing, a method of valuing securities by reference to the value of other securities with similar characteristics such as rating, interest rate, and maturity. Money market instruments that mature in 60 days or less may be valued at amortized cost unless the Fund’s investment advisor believes another valuation is more appropriate.
When valuing securities for which market quotations are not readily available or for which the market quotations that are readily available are considered unreliable, the Funds determine a fair value in good faith under procedures established by and under the general supervision of the Funds’ Boards of Directors (the “Board”). The Funds may use these procedures to establish the fair value of securities when, for example, a significant event occurs between the time the market closes and the calculation of the net asset value per share, and the event is likely to affect the Fund’s net asset value per share. Fair valuation may also be used for securities that are subject to legal or contractual restrictions on resale, securities for which no or limited trading activity has occurred for a period of time, or securities that are otherwise deemed to be illiquid (i.e., securities that cannot be disposed of within seven days at approximately the price at which the security is currently priced by the Funds).
If a fair value is required, the investment advisor, or the sub-advisor in the case of Strategy, determines the value of the security until the Board meets to establish the fair value of the security.
As of April 30, 2013, there were no fair valued securities.
Accounting principles generally accepted in the United States (“GAAP”) establish a single authoritative definition of fair value, set out a frame work for measuring fair value and require additional disclosures about fair value measurements.
Various inputs are used in determining the value of each Fund’s investments. These inputs are summarized in the three broad levels listed below:
Level 1 – quoted prices in active markets for identical securities
Level 2 – other significant observable inputs
Level 3 – significant unobservable inputs
The inputs or methodology used for valuing securities are not necessarily an indication of the risks associated with investing in those securities.
The following is a summary of the inputs used to value each Fund’s investments as of April 30, 2013:
Total Return
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
US Treasury Obligations
|
|
$
|
—
|
|
|
$
|
71,117,825
|
|
|
$
|
—
|
|
|
$
|
71,117,825
|
|
Total
|
|
$
|
—
|
|
|
$
|
71,117,825
|
|
|
$
|
—
|
|
|
$
|
71,117,825
|
|
Notes to Financial Statements (continued)
Managed Municipal
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Municipal Bonds
|
|
$
|
—
|
|
|
$
|
103,985,583
|
|
|
$
|
—
|
|
|
$
|
103,985,583
|
|
US Treasury Obligations
|
|
|
—
|
|
|
|
10,602,987
|
|
|
|
—
|
|
|
|
10,602,987
|
|
Total
|
|
$
|
—
|
|
|
$
|
114,588,570
|
|
|
$
|
—
|
|
|
$
|
114,588,570
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
North American
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Canadian Securities
|
|
$
|
—
|
|
|
$
|
27,421,292
|
|
|
$
|
—
|
|
|
$
|
27,421,292
|
|
Mexican Securities
|
|
|
—
|
|
|
|
22,815,614
|
|
|
|
—
|
|
|
|
22,815,614
|
|
US Treasury Obligations
|
|
|
—
|
|
|
|
105,281,028
|
|
|
|
—
|
|
|
|
105,281,028
|
|
Total
|
|
$
|
—
|
|
|
$
|
155,517,934
|
|
|
$
|
—
|
|
|
$
|
155,517,934
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Strategy
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Common Stocks
|
|
$
|
54,447,557
|
|
|
$
|
—
|
|
|
$
|
—
|
|
|
$
|
54,447,557
|
|
US Treasury Obligations
|
|
|
—
|
|
|
|
14,554,941
|
|
|
|
—
|
|
|
|
14,554,941
|
|
Total
|
|
$
|
54,447,557
|
|
|
$
|
14,554,941
|
|
|
$
|
—
|
|
|
$
|
69,002,498
|
|
See Strategy’s Schedule of Investments for a listing of the common stocks valued using Level 1 inputs by industry type.
The Funds’ policy is to disclose significant transfers between Levels based on valuations at the end of the reporting period. The Funds may hold securities which are periodically fair valued in accordance with the Funds’ Fair Value Procedures. This may result in movements between Level 1 and Level 2 throughout the period. There were no significant transfers between Level 1, 2, or 3 as of April 30, 2013, based on the valuation input Levels on October 31, 2012 for the Funds.
C.
|
Securities Transactions and Investment Income
|
Securities transactions are recorded on trade date. Realized gains and losses are determined by comparing the proceeds of a sale or the cost of a purchase with a specific offsetting transaction. Dividend income is recorded on the ex-dividend date. Interest income, including amortization of premiums and accretion of discounts, is accrued daily. Estimated expenses are also accrued daily. With respect to North American and Managed Municipal, income, gains (losses) and common expenses are allocated to each class based on its respective net assets. Class specific expenses are charged directly to each class.
Notes to Financial Statements (continued)
Total Return declares distributions daily, and North American declares monthly distributions at fixed rates approved by the Board. These distributions are paid monthly. To the extent that a Fund’s net investment income is less than an approved fixed rate, some of its distributions may be designated as a return of capital. Managed Municipal declares and pays dividends monthly from its net investment income. Strategy declares and pays dividends quarterly from its net investment income. Net realized capital gains, if any, are distributed at least annually. The Funds record dividends and distributions on the ex-dividend date.
Each Fund has a policy to qualify as a regulated investment company under subchapter M of the Internal Revenue Code. As provided therein in any fiscal year in which a Fund so qualifies and distributes at least 90% of its net taxable income, the Fund (but not its shareholders) will be relieved of Federal income tax on the income distributed. In addition, by distributing in each calendar year substantially all of its net investment income and net realized capital gains, a Fund will not be subject to Federal excise taxes. Accordingly, no Federal income or excise taxes have been accrued.
F.
|
Foreign Currency Translation
|
The Funds maintain their accounting records in U.S. dollars. North American determines the U.S. dollar value of foreign currency-denominated assets, liabilities and transactions by using prevailing exchange rates. In valuing security transactions, the receipt of income and the payment of expenses, North American uses the prevailing exchange rate on the transaction date.
Net realized gains and losses on foreign currency transactions shown on North American’s financial statements result from the sale of foreign currencies, currency gains or losses realized between the trade and settlement dates on securities transactions, and from the difference between the amounts of interest recorded on North American’s books and the U.S. dollar equivalent of the amounts actually received or paid. That portion of realized gains (losses) from security transactions that results from fluctuation in foreign currency exchange rates relating to the sale of foreign securities is not separately disclosed but is included in net realized gains (losses) from security transactions. That portion of unrealized gains and losses on investments that results from fluctuations in foreign currency exchange rates is not separately disclosed but is included in the net change in unrealized appreciation/depreciation on investments.
G.
|
Forward Foreign Currency Contracts
|
North American may use forward foreign currency contracts to manage foreign exchange rate risk. The Fund may use these contracts to fix the U.S. dollar value of securities transactions for the period between the date of the transaction and the date
Notes to Financial Statements (continued)
the security is received or delivered or to hedge the U.S. dollar value of securities that it already owns. The use of forward foreign currency contracts does not eliminate fluctuations in the prices of the underlying securities, but does establish a rate of exchange that can be achieved in the future. North American determines the net U.S. dollar value of the forward foreign currency contracts using prevailing exchange rates.
Each Fund may make short-term investments in repurchase agreements that are fully collateralized by U.S. government securities. Under the terms of a repurchase agreement, a financial institution sells U.S. government securities to a Fund and agrees to buy them back on a specified day in return for the principal amount of the original sale plus accrued interest. The custodial bank holds the collateral in a separate account until the agreement matures. If the value of the securities falls below the principal amount of the repurchase agreement plus accrued interest, the financial institution deposits additional collateral by the following business day. If the financial institution either fails to deposit the required additional collateral or fails to repurchase the securities as agreed, a Fund has the right to sell the securities and recover any resulting loss from the financial institution. If the financial institution enters into bankruptcy, a Fund’s claim on the collateral may be subject to legal proceedings.
In preparing its financial statements in conformity with GAAP, management makes estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the period. Actual results may be different.
Note 2 – Fees and Transactions with Affiliates
International Strategy & Investment Inc. (“ISI”) is the Funds’ investment advisor. As compensation for ISI’s advisory services, Total Return pays ISI an annual fee based on the Fund’s average daily net assets, which is calculated daily and paid monthly at the following annual rates: 0.20% of the first $100 million, 0.18% of the next $100 million, 0.16% of the next $100 million, 0.14% of the next $200 million and 0.12% of the amount over $500 million. In addition, Total Return pays ISI 1.50% of the Fund’s gross interest income. As compensation for ISI’s advisory services, Managed Municipal, North American and Strategy each pay ISI a fee, which is calculated daily and paid monthly, at the annual rate of 0.40% of such Fund’s average daily net assets.
ISI has contractually agreed to reimburse expenses with respect to Class C Shares of North American through February 28, 2014 to the extent necessary to limit the annual ordinary operating expenses of ISI Class C Shares to 1.85% of the average daily net assets attributable to such shares. During the six months ended April 30, 2013, no expenses were reimbursed by ISI under the expense limitation agreement.
Notes to Financial Statements (continued)
Los Angeles Capital Management and Equity Research, Inc. is Strategy’s Sub-Advisor and is responsible for managing the common stocks in Strategy’s portfolio. The Sub-Advisor is paid by ISI, not Strategy.
International Strategy & Investment Group LLC (“ISI Group”), an affiliate of ISI, is the distributor for the Funds. Total Return, Managed Municipal (ISI Class A Shares, only) and Strategy each pay ISI Group a distribution/shareholder service fee, pursuant to Rule 12b-1, that is calculated daily and paid monthly at the annual rate of 0.25% of average daily net assets. North American’s ISI Class A Shares and ISI Class C Shares pay ISI Group a distribution/shareholder service fee, pursuant to Rule 12b-1, that is calculated daily and paid monthly at the annual rates of 0.40% and 1.00% (which may include up to 0.25% for shareholder servicing fees for each class) of their average daily net assets, respectively.
During the six months ended April 30, 2013, ISI Group earned commissions on sales of ISI Shares of Total Return, Managed Municipal and Strategy of $1,055, $1,631 and $3,363, respectively, and earned commissions of $1,189 on sales of ISI Class A Shares of North American. ISI Group retained $815 of contingent deferred sales charges on redemptions of ISI Class C Shares of North American during the six months ended April 30, 2013.
State Street Bank and Trust Company (“State Street”) is the administrator of the Funds. State Street is responsible for providing certain administrative services to the Funds, and assists in managing and supervising all aspects of the general day-to-day business activities and operations of the Fund other than investment advisory activities, including maintaining the books and records of the Fund, and preparing certain reports and other documents required by federal and/or state laws and regulations. For the performance of these services, the Funds pay State Street an annual fee of $300,000. This fee is allocated among the Funds based on the relative net assets of each Fund.
State Street is the fund accountant and fund custodian, and State Street is responsible for safeguarding and controlling the Funds’ cash and securities, handling the delivery of securities and collecting interest and dividends on the Funds’ investments. State Street as fund accounting agent is responsible for maintaining the books and records and calculating the daily net asset values of the Funds. For Fund accounting services, the Funds pay State Street an annual base fee of $180,000. This fee is allocated among the Funds based on the relative net assets of each Fund. For Fund custodian services, the Funds pay State Street an annual base fee of 1 (one) basis point on net assets, plus other asset-based fees that vary according to the number of positions and transactions, plus out-of-pocket fees.
State Street also serves as transfer agent for the Funds and is responsible for the issuance, transfer and redemption of shares and the opening, maintenance and servicing of shareholder accounts. For these services State Street receives an annual amount of $130,000, allocated among the Funds based on the relative net assets of each Fund and
Notes to Financial Statements (continued)
a monthly fee from each Fund at an annual rate of $20 for each direct account and $15 for certain accounts established through financial intermediaries. In addition, the Funds reimburse State Street for its out-of-pocket expenses including, but not limited to, postage and supplies.
EJV Financial Services, LLC (“EJV”) provides certain compliance services to the Funds. Edward J. Veilleux, Vice President and Chief Compliance Officer (“CCO”) of the Funds, is also a principal of EJV. The Funds pay EJV $18,750 quarterly for providing CCO services. This fee is allocated among the Funds based on the relative net assets of each Fund. In addition, the Funds reimburse EJV for any reasonable out-of-pocket expenses relating to these compliance services.
Effective January 1, 2012, the Funds pay each independent Director an annual fee of $21,000. The Audit Committee Chairman and Chairman of the Board receive an additional annual fee of $2,000 and $4,000, respectively. The Funds also reimburse each of the Directors for out-of-pocket expenses incurred in connection with attending the Board of Directors’ meetings. Certain officers of the Funds are also officers or employees of the above named service providers, and during their terms of office, receive no compensation from the Funds.
Note 3 – Federal Income Tax
The Funds may periodically make reclassifications among certain capital accounts as a result of differences in the characterization and allocation of certain income and capital gain distributions determined annually in accordance with Federal tax regulations, which may differ from GAAP. These book/tax differences may be either temporary or permanent in nature. To the extent they are permanent, they are charged or credited to paid-in-capital, undistributed net investment income or accumulated net realized gains, as appropriate, in the period that the differences arose. The reclassifications have no impact on the net assets or net asset value per share of the Funds.
The Funds determine their net investment income and capital gain distributions in accordance with income tax regulations, which may differ from GAAP.
During the periods ended April 30, 2013 and October 31, 2012, the tax character of distributions paid by each of the Funds was as follows:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Return
|
|
$
|
984,756
|
*
|
|
$
|
1,646,163
|
*
|
|
$
|
—
|
|
|
$
|
—
|
|
Managed Municipal
|
|
|
8,969
|
|
|
|
21,808
|
|
|
|
1,250,844
|
|
|
|
2,679,806
|
|
North American
|
|
|
1,911,822
|
*
|
|
|
4,060,711
|
*
|
|
|
—
|
|
|
|
—
|
|
Strategy
|
|
|
445,637
|
|
|
|
632,521
|
|
|
|
—
|
|
|
|
—
|
|
Notes to Financial Statements (continued)
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Return
|
|
$
|
1,065,847
|
|
|
$
|
1,046,949
|
|
|
$
|
—
|
|
|
$
|
—
|
|
Managed Municipal
|
|
|
492,954
|
|
|
|
—
|
|
|
|
—
|
|
|
|
—
|
|
North American
|
|
|
—
|
|
|
|
278,869
|
|
|
|
—
|
|
|
|
62,034
|
|
Strategy
|
|
|
2,703,899
|
|
|
|
—
|
|
|
|
—
|
|
|
|
—
|
|
*
|
A portion of the ordinary income is short-term gains that are taxed as ordinary income for tax purposes. However, these short-term gains may be offset by losses incurred through October 31, 2013 and therefore could be treated as return of capital.
|
The Funds recognize the tax benefits or expenses of uncertain tax positions only when the position is “more likely than not” to be sustained assuming examination by tax authorities. Management has reviewed each Fund’s tax positions taken on Federal and state income tax returns for all open tax years (tax years ended October 31, 2009 through October 31, 2012) and concluded that no provision for unrecognized tax benefits or expenses is required in these financial statements.
As of October 31, 2012, the components of distributable earnings on a tax basis were as follows:
|
|
|
|
|
|
|
|
|
|
|
|
|
Undistributed ordinary income
|
|
$
|
326,047
|
|
|
$
|
826
|
|
|
$
|
—
|
|
|
$
|
20,463
|
|
Undistributed tax-exempt income
|
|
|
—
|
|
|
|
111,744
|
|
|
|
—
|
|
|
|
—
|
|
Accumulated undistributed
long-term capital gains
|
|
|
1,065,587
|
|
|
|
491,839
|
|
|
|
—
|
|
|
|
2,703,604
|
|
Capital loss carryforwards
|
|
|
—
|
|
|
|
—
|
|
|
|
—
|
|
|
|
—
|
|
Net unrealized appreciation (depreciation)
|
|
|
4,983,388
|
|
|
|
8,146,069
|
|
|
|
6,889,548
|
|
|
|
9,811,184
|
|
Other temporary differences
|
|
|
(36,173
|
)
|
|
|
(112,944
|
)
|
|
|
(136,355
|
)
|
|
|
—
|
|
Total
|
|
$
|
6,338,849
|
|
|
$
|
8,637,534
|
|
|
$
|
6,753,193
|
|
|
$
|
12,535,251
|
|
Notes to Financial Statements (continued)
As of October 31, 2012, the Funds recorded the following reclassifications primarily due to foreign exchange gains/losses, passive foreign investment company losses, REIT adjustments to increase (decrease) the accounts listed below:
|
|
Undistributed
Net Investment Income/(Loss)
|
|
|
Accumulated
Net Realized Gain/(Loss)
|
|
|
|
|
Total Return US Treasury Fund
|
|
$
|
—
|
|
|
$
|
—
|
|
|
$
|
—
|
|
Managed Municipal Fund
|
|
|
—
|
|
|
|
—
|
|
|
|
—
|
|
North American Government Bond Fund
|
|
|
171,223
|
|
|
|
(171,223
|
)
|
|
|
—
|
|
ISI Strategy Fund
|
|
|
(13,973
|
)
|
|
|
13,973
|
|
|
|
—
|
|
As of October 31, 2011, Managed Municipal had capital loss carryforwards of $41,257 and Strategy had capital loss carryforwards of $3,371,617, which were utilized in the year ended October 31, 2012.
The difference between the federal income tax cost of portfolio investments and the financial statement cost for Strategy is due to certain timing differences in the recognition of capital gains or losses under income tax reporting regulations and GAAP. These “book/tax” differences are temporary in nature and are primarily due to the tax deferral of losses on wash sales.
Note 4 – Investment Transactions
The aggregate cost of purchases and proceeds from sales of investments, other than short-term obligations, for the six months ended April 30, 2013 were as follows:
|
|
Non-US Government Obligations
|
|
|
US Government Obligations
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total Return
|
|
$
|
—
|
|
|
$
|
—
|
|
|
$
|
—
|
|
|
$
|
3,908,902
|
|
Managed Municipal
|
|
|
12,157,797
|
|
|
|
10,615,422
|
|
|
|
—
|
|
|
|
—
|
|
North American
|
|
|
8,409,883
|
|
|
|
8,653,783
|
|
|
|
—
|
|
|
|
4,416,215
|
|
Strategy
|
|
|
10,192,010
|
|
|
|
10,358,728
|
|
|
|
—
|
|
|
|
1,040,605
|
|
Note 5 – Market and Credit Risk
North American invests in Canadian and Mexican government securities. Investing in Canadian and Mexican government securities may have different risks than investing in U.S. government securities. An investment in Canada or Mexico may be affected by developments unique to those countries. These developments may not affect the U.S. economy or the prices of U.S. government securities in the same manner. In addition, the value of bonds issued by non-U.S. governments may be affected by adverse international political and economic developments that may not impact the value of U.S. government securities.
Notes to Financial Statements (continued)
Note 6 – Contractual Obligations
In the ordinary course of business, the Funds enter into contracts that contain a variety of indemnifications. Each Fund’s maximum exposure under these arrangements is unknown. However, the Funds have not had prior claims or losses pursuant to these indemnification provisions and believe the risk of loss thereunder to be remote.
Note 7 – Subsequent Events
GAAP requires the Funds to recognize in the financial statements the effects of all subsequent events that provide additional evidence about conditions that existed as of the date of the Statements of Assets and Liabilities. For non-recognized subsequent events that must be disclosed to keep the financial statements from being misleading, the Funds are required to disclose the nature of the event as well as an estimate of its financial effect, or a statement that such an estimate cannot be made. Management has evaluated subsequent events through the issuance of these financial statements and has determined no disclosure is necessary other than as noted below.
On May 31, 2013, the Funds paid the following per share net investment income distributions related to the period ended May 31, 2013:
|
|
Net Investment Income per share
May 31, 2013
|
|
Total Return US Treasury
|
|
$
|
—
|
|
Managed Municipal Fund - Class A
|
|
|
—
|
|
Managed Municipal Fund - Class I
|
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North American Government Bond Fund - Class A
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North American Government Bond Fund - Class C
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North American Government Bond Fund - Class I
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ISI Strategy Fund
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Notice to Shareholders (Unaudited)
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Proxy Voting Policies and Procedures
A description of the policies and procedures that Strategy uses to determine how to vote proxies relating to securities held in Strategy’s portfolio is available, without charge and upon request, by calling (800) 955-7175. Information regarding how Strategy voted proxies relating to portfolio securities during the most recent twelve-month period ended June 30 is available, without charge, upon request, by calling (800) 955-7175 or on the SEC’s website at http://www.sec.gov.
Availability of Quarterly Portfolio Schedule
The Funds file their complete schedule of portfolio holdings with the SEC for the first and third quarters of each fiscal year on Form N-Q. Each Fund’s Form N-Q is available on the SEC’s website at http://www.sec.gov or may be reviewed and copied at the SEC’s Public Reference Room in Washington, DC. Information on the operation of the Public Reference Room may be obtained by calling 800-SEC-0330.
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Louis E. Levy
Chairman
W. Murray Jacques
Director
Edward A. Kuczmarski
Director
R. Alan Medaugh
President
Director
Carrie L. Butler
Vice President
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Edward J. Veilleux
Vice President
Chief Compliance Officer
Thomas D. Stevens*
Vice President
Stephen V. Killorin
Vice President
Treasurer
Margaret M. Beeler
Vice President
Secretary
Edward S. Hyman
Senior Economic Advisor
* Thomas D. Stevens is an officer
for only the ISI Strategy Fund.
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Investment Advisor
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ISI, Inc.
666 Fifth Avenue, 11th Floor
New York, NY 10103
(800) 955-7175
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Shareholder Servicing Agent
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State Street Bank & Trust Company
One Lincoln Street
Boston, MA 02111
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Distributor
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ISI Group LLC
666 Fifth Avenue, 11th Floor
New York, NY 10103
(800) 955-7175
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