November 29, 2010
VIA EDGAR
Securities and Exchange Commission
100 F Street NE
Washington, D.C. 20549
100 F Street NE
Washington, D.C. 20549
RE:
|
Gabelli 787 Fund, Inc. | |||
| File No.: 811-22041 | ||||
| The Gabelli Asset Fund | ||||
| File No.: 811-04494 | ||||
| The Gabelli Blue Chip Value Fund | ||||
| File No.: 811-09377 | GAMCO International Growth Fund, Inc. | |||
| Gabelli Capital Series Funds, Inc. | File No.: 811-08560 | |||
| File No.: 811-07644 | Gabelli Investor Funds, Inc. | |||
| Comstock Funds, Inc. | File No.: 811-07326 | |||
| File No.: 811-05502 | The GAMCO Mathers Fund | |||
| The Gabelli Convertible and Income Securities Fund Inc. | File No.: 811-01311 | |||
| File No.: 811-05715 | The Gabelli Global Utility & Income Trust | |||
| Gabelli Equity Series Funds, Inc. | File No.: 811-21529 | |||
| File No.: 811-06367 | The Gabelli Money Market Funds | |||
| The Gabelli Equity Trust Inc. | File No.: 811-06687 | |||
| File No.: 811-04700 | The Gabelli Dividend & Income Trust | |||
| The Gabelli Global Deal Fund | File No.: 811-21423 | |||
| File No.: 811-21969 | The Gabelli Utilities Fund | |||
| The Gabelli Global Multimedia Trust Inc. | File No.: 811-09397 | |||
| File No.: 811-08476 | The Gabelli Utility Trust | |||
| GAMCO Global Series Funds, Inc. | File No.: 811-09243 | |||
| File No.: 811-07896 | The Gabelli Value Fund Inc. | |||
| GAMCO Gold Fund, Inc. | File No.: 811-05848 | |||
| File No.: 811-08518 | The GAMCO Westwood Funds | |||
| The GAMCO Growth Fund | File No.: 811-04719 | |||
| File No.: 811-04873 | The Gabelli Healthcare & WellnessRx Trust | |||
| The Gabelli Global Gold, Natural Resources & Income Trust | File No.: 811-22021 | |||
| File No.: 811-21698 | The Gabelli SRI Green Fund, Inc. | |||
| File No.: 811-22026 | ||||
| (the “Funds”) |
Dear Staff Member:
Pursuant to Rule 17g-1(g)(1) under the Investment Company Act of 1940, as amended, enclosed
for filing on behalf of the above-referenced Funds please find (i) one copy of a rider for an
increase in coverage (effective on October 14, 2010) for their joint fidelity bond (the “Joint
Bond”) for the policy period from December 7, 2009 to December 7, 2010, such policy being
maintained through Travelers-St. Paul Fire and Marine Insurance Company, (ii) an Assistant
Secretary’s Certificate certifying the resolutions adopted by each Fund’s Board Members approving
the amount, type, form and coverage of the Joint Bond and the portion of the premium to be paid by
the Funds and (iii) the Amended and Restated Joint Insured Agreement among the Funds and the other
insureds on the Joint Bond.
There is no premium payment associated with this increase in coverage for the policy period.
Very truly yours,
/s/ Helen A. Robichaud
|
||||
Helen A. Robichaud |
||||
Assistant Secretary |
||||
Gabelli 787 Fund, Inc.
|
The Gabelli Blue Chip Value Fund | |||
The Gabelli Asset Fund
|
The Gabelli Convertible and Income Securities Fund Inc. | |||
Gabelli Capital Series Funds, Inc.
|
The Gabelli Dividend & Income Trust | |||
Comstock Funds, Inc.
|
The Gabelli Equity Trust Inc. | |||
Gabelli Equity Series Funds, Inc.
|
The Gabelli Global Deal Fund | |||
GAMCO Global Series Funds, Inc.
|
The Gabelli Global Gold, Natural The Resources & Income Trust | |||
GAMCO Gold Fund, Inc.
|
The Gabelli Global Multimedia Trust Inc. | |||
GAMCO Growth Fund
|
The Gabelli Global Utility & Income Trust | |||
The Gabelli Healthcare & WellnessRx Trust
|
The Gabelli Utilities Fund | |||
GAMCO International Growth Fund, Inc.
|
The Gabelli Utility Trust | |||
Gabelli Investor Funds, Inc.
|
||||
The GAMCO Mathers Fund |
||||
The Gabelli Money Market Funds |
||||
The Gabelli SRI Green Fund, Inc. |
||||
The Gabelli Value Fund Inc. |
||||
The GAMCO Westwood Funds |
Enclosures
|
Blair A Puscas Travelers Bond & Financial Products 485 Lexington Avenue New York, NY 10017 Phone: 917.778.6010 Fax: 877.872.5932 E-Mail: bpuscas@travelers.com |
Date:
|
October 20, 2010 | |
To:
|
Paul J. Bertolotti | |
| Marsh — FINPRO | ||
| 1166 Avenue of the Americas – 37th Floor | ||
| New York, NY 10036 | ||
Re:
|
The Gabelli Funds, LLC | |
| One Corporate Center | ||
| Rye, NY 10580-1422 | ||
| Investment Company Blanket Bond – Bond Change Confirmation |
Paul,
On behalf of Travelers, I am pleased to provide the following confirmation of policy changes for
the Investment Company Blanket Bond.
Current Bond Term:
|
12/7/2009 – 12/7/2010 | |
Premium:
|
$59,300* |
| * | No additional premium has been contemplated in association with the changes outlined in this binder and will not be contemplated prior to expiration of the current Bond |
Company:
|
St. Paul Fire and Marine Insurance Company | |
| (An admitted company rated “A+” by A.M. Best) | ||
Form:
|
ICB001, ICB005 – Investment Company Blanket Bond |
| Insuring Agreements | Single Loss Limit | Deductible | ||||||
A. Fidelity |
$ | 23,300,000 | ** | $ | Nil^ | |||
B. Audit Expense |
$ | 50,000 | $ | 5,000 | ||||
C. Premises |
$ | 23,300,000 | ** | $ | 0 | |||
D. Transit |
$ | 23,300,000 | ** | $ | 0 | |||
E. Forgery or Alteration |
$ | 23,300,000 | ** | $ | 10,000 | |||
F. Securities |
$ | 23,300,000 | ** | $ | 10,000 | |||
G. Counterfeit Currency |
$ | 23,300,000 | ** | $ | 10,000 | |||
H. Stop Payment |
$ | 25,000 | $ | 5,000 | ||||
I. Uncollectible Items of Deposit |
$ | 25,000 | $ | 5,000 | ||||
Optional Coverages Added by Rider: |
||||||||
J. Computer Systems |
$ | 23,300,000 | ** | $ | 25,000 | |||
K. Unauthorized Signatures |
$ | 25,000 | $ | 5,000 | ||||
L. Tele-facsimile |
$ | 23,300,000 | ** | $ | 10,000 | |||
M. Automated Phone Systems |
$ | 23,300,000 | ** | $ | 10,000 | |||
N. Voice Initiated Transactions |
$ | 23,300,000 | ** | $ | 10,000 | |||
| ** | Amended to increase limit to $23,475,000 effective 10/14/2010 |
1
Riders
| 1. | ICB001- Declarations | |||||||
| 2. | ICB010- Named Insured Endorsement to Include: | |||||||
| The Gabelli ABC Fund | ||||||||
| The Gabelli Asset Fund | ||||||||
| The Gabelli Blue Chip Value Fund | ||||||||
| The Gabelli Capital Asset Fund | ||||||||
| Comstock Funds | ||||||||
| Comstock Capital Value Fund | ||||||||
| Comstock Strategy Fund | ||||||||
| Gabelli Enterprise Mergers and Acquisitions Fund | ||||||||
| Gabelli Equity Series Funds | ||||||||
| The Gabelli Equity Income Fund | ||||||||
| The Gabelli Small Cap Growth Fund | ||||||||
| The Gabelli Woodland Small Cap Value Fund | ||||||||
| The GAMBCO Global Series Funds | ||||||||
| The GAMCO Global Convertible Securities Fund | ||||||||
| The GAMCO Global Growth Fund | ||||||||
| The GAMCO Global Opportunity Fund | ||||||||
| The GAMCO Global Telecommunications Fund | ||||||||
| GAMCO Gold Fund, Inc. | ||||||||
| The GAMCO Growth Fund | ||||||||
| GAMCO International Growth Fund, Inc. | ||||||||
| The GAMCO Mathers Fund | ||||||||
| Gabelli SRI Green Fund Inc. | ||||||||
| The Gabelli U.S. Treasury Money Market Fund | ||||||||
| The Gabelli Utilities Fund | ||||||||
| The Gabelli Value Fund, Inc. | ||||||||
| GAMCO Westwood Funds | ||||||||
| GAMCO Westwood Balanced Fund | ||||||||
| GAMCO Westwood Equity Fund | ||||||||
| GAMCO Westwood Income Fund | ||||||||
| GAMCO Westwood Intermediate Bond Fund | ||||||||
| GAMCO Westwood Mighty Mites Fund | ||||||||
| GAMCO Westwood SmallCap Equity Fund | ||||||||
| The Gabelli Convertible & Income | ||||||||
| The Gabelli Dividend & Income Trust | ||||||||
| The Gabelli Equity Trust Inc. | ||||||||
| The Gabelli Global Deal Fund | ||||||||
| The Gabelli Global Gold, Natural Resources & Income Trust | ||||||||
| The Gabelli Global Multimedia Trust Inc. | ||||||||
| The Gabelli Healthcare & Wellness Rx Trust | ||||||||
| The Gabelli Utitlity Trust | ||||||||
| The Gabelli Global Utility & Income Trust*** | ||||||||
| 3. | ICB011- Computer Systems | |||||||
| 4. | ICB012- Unauthorized Signatures | |||||||
| 5. | ICB013- Telefacsimile Transactions | |||||||
| 6. | ICB014- Voice Initiated Transactions | |||||||
| 7. | ICB019- Automated Phone Systems | |||||||
| 8. | ICB016- Amend Def of Investment Co | |||||||
| 9. | ICB026- Added Exclusions (n) & (o) | |||||||
| 10. | ICB057- New York | |||||||
2
| 11. | MEL2555- Designated Persons For Discovery of Loss | |||||||
| 12. | MEL3281- Termination “90 days” | |||||||
| 13. | MEL7027- Replace Insuring Agreement (A) Fidelity | |||||||
| 14. | ND044 and ND 059 | |||||||
| *** | Added to policy by amendment with effective date of 12/7/2009 |
As agreed, the Named Insured Endorsement on the current Investment Company Blanket Bond will be
condensed to a single endorsement and include all entities listed above. The effective date will be
12/7/2009.
As the broker, it is your responsibility to arrange for the payment of the state taxes and/or
any stamping fees on this policy.
We thank you for this opportunity to be of service to you. Should you have any questions or
comments regarding this confirmation of changes to the Investment Company Blanket Bond please
contact me at 917.778.6010.
Sincerely,
Blair A Puscas
Associate Account Executive
Associate Account Executive
Travelers
Bond & Financial Products
Financial Institutions
485 Lexington Avenue
New York, NY 10017
Phone: 917.778.6010
Fax: 877.872.5932
Bond & Financial Products
Financial Institutions
485 Lexington Avenue
New York, NY 10017
Phone: 917.778.6010
Fax: 877.872.5932
3
SECRETARY’S CERTIFICATE
The undersigned hereby certify that the following resolutions have been adopted first by those
Board Member who are not considered to be “interested persons,” as defined in the Investment
Company Act of 1940, as amended (the “1940 Act”)(“Independent Board Members”) voting separately,
and then by the entire Board of each Fund, at the respective meetings duly called and held on
November 16 and 17, 2010:
| RESOLVED, | That after having given due consideration to all relevant factors, the Board Members, including all of the Independent Board Members, hereby approve the amendment to the existing joint fidelity bond coverage with Travelers-St. Paul Fire & Marine Insurance Company, and ratify, confirm and approve an increase in the amount of coverage under said joint Fidelity Bond from $23,300,000 to $23,475,000 which became effective on October 14, 2010; and further | |||
| RESOLVED, | That the portion of the increased premium for the aforementioned joint insured fidelity bond to be paid by the Fund, if any, is hereby approved, taking into consideration, among other things, the number of parties named as insureds; the nature of the business activities of such other parties; the amount of the joint insured bond; the amount of the premium for such bond; the ratable allocation of the premium among all parties named as insureds; and the extent to which the share of the premium allocated to the Fund is less than the premium the Fund would have had to pay if it had provided and maintained a single insured bond; and further | |||
| RESOLVED, | That the Secretary of the Fund is hereby authorized and directed to prepare, execute and file such supplements to the fidelity bond, and to take such action as may be necessary or appropriate in order to conform the terms of the fidelity bond coverage to the provisions of the 1940 Act, and the rules and regulations promulgated thereunder. |
IN WITNESS WHEREOF, the undersigned has hereunto set his/her hand this 29th day of
November, 2010.
/s/ Bruce N. Alpert
|
/s/ Agnes Mullady | |||
Secretary Gabelli 787 Fund, Inc. The Gabelli Asset Fund Gabelli Capital Series Funds, Inc. Comstock Funds, Inc. |
Secretary The Gabelli Blue Chip Value Fund The Gabelli Convertible and Income Securities Fund Inc. The Gabelli Dividend & Income Trust |
Gabelli Equity Series Funds, Inc. GAMCO Global Series Funds, Inc. GAMCO Gold Fund, Inc. The GAMCO Growth Fund The Gabelli Healthcare & WellnessRx Trust GAMCO International Growth Fund, Inc. Gabelli Investor Funds, Inc. The GAMCO Mathers Fund The Gabelli Money Market Funds The Gabelli SRI Green Fund, Inc. The Gabelli Value Fund Inc. The GAMCO Westwood Funds |
The Gabelli Equity Trust Inc. The Gabelli Global Deal Fund The Gabelli Global Gold, Natural Resources & Income Trust The Gabelli Global Multimedia Trust Inc. The Gabelli Global Utility & Income Trust The Gabelli Utilities Fund The Gabelli Utility Trust |
AMENDED AND RESTATED
JOINT INSURED AGREEMENT
JOINT INSURED AGREEMENT
AGREEMENT dated December 1, 1999, as most recently amended as of November 17, 2009, among the
registered investment companies advised by Gabelli Funds, LLC, Teton Advisors, Inc. and Gabelli
Fixed Income LLC (together, the “Advisers”) which are listed on Schedule A attached hereto
(collectively, the “Funds”).
WHEREAS, each of the Funds is named as an insured in an investment company blanket bond (the
“Fidelity Bond”) which is intended to be in full compliance with Rule 17g-1 under the Investment
Company Act of 1940, as amended; and
WHEREAS, the Funds desire to enter into an agreement in order to meet the requirements of Rule
17g-1 and to assure that premiums payable with respect to the Fidelity Bond and payments by the
Insurer with respect to the Fidelity Bond are allocated in a fair and equitable manner;
Now, THEREFORE, the Funds do hereby agree as follows:
1. Each Fund shall maintain a minimum amount of fidelity insurance one level higher than that
specified for its asset size by the table contained in Rule 17g-1(d) (the “Minimum Insurance”).
Each Fund shall aggregate the assets of all of its series to calculate the amount of coverage
required by Rule 17g-1(d). Notwithstanding the foregoing, no Fund shall be required to increase
the amount of its fidelity insurance unless and until the aggregate amount of fidelity insurance
maintained by the Funds exceeds the aggregate amount of fidelity insurance the Funds are required
to maintain pursuant to the table contained in Rule 17g-1(d) by $2 million or less.
2. The allocation of the premium to each Fund shall be based on the proportionate share of the
sum of the premiums that would have been paid if fidelity insurance was purchased separately by the
Funds, and will be based upon the relative Minimum Insurance percentages of the Funds as of the
quarter ending prior to the beginning of the first month in the period for which the coverage is
obtained, subject to paragraph 4 below.
3. Each Fund is guaranteed a minimum coverage amount with access to the remainder of the total
coverage of the Fidelity Bond. In the event that any recovery is received under the Fidelity Bond
as a result of the loss sustained by two or more Funds, each Fund shall receive an equitable and
proportionate share of the recovery, but in no event less than the amount it would have received
had it maintained a single insured bond with minimum coverage.
4. Each Fund may, at any time, increase its allocation described in paragraph 2 upon payment
of the premium required for such additional insurance provided that the face amount of the Fidelity
Bond can increase accordingly or be supplemented by a policy of excess insurance.
5. Any other registered investment company or additional series of such an investment company
for which the Advisers or their affiliates serves as investment adviser (“Additional Fund”) may
become a party to this Agreement by executing a copy of this Agreement (a copy of which will be
furnished to each of the Funds) and by paying the premium for any required increase in the amount
of the Fidelity Bond if the underwriter of the Fidelity Bond is willing to add such Additional Fund
as an additional insured and increase the amount of total coverage by the amount of the Minimum
Insurance required for such Additional Fund by the provisions hereof.
6. The Agreement shall remain in effect for as long as two or more of the Funds (including any
Additional Fund) are insured under the terms of the Fidelity Bond. Any Fund shall, however, have
the right to terminate, at any time, its participation in the Fidelity Bond and in this Agreement
provided that losses incurred prior to such termination shall be governed by the provision of this
Agreement and the amount of any return premium to which such Fund shall be entitled will be limited
to the amount actually obtained from the underwriter in respect of such termination.
Signed:
|
/s/ Bruce N. Alpert
|
President, The Gabelli Asset Fund
President, The Gabelli Blue Chip Value Fund
President, Gabelli Capital Series Funds, Inc.
Executive Vice President, Comstock Funds, Inc.
President, The Gabelli Convertible and Income Securities Fund Inc.
President, The Gabelli Dividend & Income Trust
President, Gabelli Equity Series Funds, Inc.
President, The Gabelli Equity Trust Inc.
President, The Gabelli Global Deal Fund
President, The Gabelli Global Gold, Natural Resources & Income Trust
President, The Gabelli Global Multimedia Trust Inc.
President, GAMCO Global Series Funds, Inc.
President, The Gabelli Global Utility & Income Trust
President, GAMCO Gold Fund, Inc.
President, The GAMCO Growth Fund
President, GAMCO International Growth Fund, Inc.
President, Gabelli Investor Funds, Inc.
Executive Vice President, The GAMCO Mathers Fund
President, The Gabelli Money Market Funds
President, The Gabelli Natural Resources, Gold & Income Trust
President, The Gabelli SRI Fund, Inc.
President, The Gabelli Utilities Fund
President, The Gabelli Utility Trust
President, The Gabelli Value Fund Inc.
President, The GAMCO Westwood Funds
President, Gabelli 787 Fund, Inc.
President, The Gabelli Blue Chip Value Fund
President, Gabelli Capital Series Funds, Inc.
Executive Vice President, Comstock Funds, Inc.
President, The Gabelli Convertible and Income Securities Fund Inc.
President, The Gabelli Dividend & Income Trust
President, Gabelli Equity Series Funds, Inc.
President, The Gabelli Equity Trust Inc.
President, The Gabelli Global Deal Fund
President, The Gabelli Global Gold, Natural Resources & Income Trust
President, The Gabelli Global Multimedia Trust Inc.
President, GAMCO Global Series Funds, Inc.
President, The Gabelli Global Utility & Income Trust
President, GAMCO Gold Fund, Inc.
President, The GAMCO Growth Fund
President, GAMCO International Growth Fund, Inc.
President, Gabelli Investor Funds, Inc.
Executive Vice President, The GAMCO Mathers Fund
President, The Gabelli Money Market Funds
President, The Gabelli Natural Resources, Gold & Income Trust
President, The Gabelli SRI Fund, Inc.
President, The Gabelli Utilities Fund
President, The Gabelli Utility Trust
President, The Gabelli Value Fund Inc.
President, The GAMCO Westwood Funds
President, Gabelli 787 Fund, Inc.
Signed:
|
/s/ Agnes Mullady
|
President, The Gabelli Healthcare & Wellness(Rx) Trust
Schedule A
List of Registered Investment Companies
The Gabelli Asset Fund
The Gabelli Blue Chip Value Fund
The Gabelli Convertible Securities and Income Securities Fund Inc.
The Gabelli Dividend & Income Trust
The Gabelli Equity Trust Inc.
The Gabelli Global Deal Fund
The Gabelli Global Gold, Natural Resources & Income Trust
The Gabelli Healthcare & Wellness(Rx) Trust
The Gabelli Global Multimedia Trust Inc.
The Gabelli Global Utility & Income Trust
GAMCO Gold Fund, Inc.
The GAMCO Growth Fund
GAMCO International Growth Fund, Inc.
The GAMCO Mathers Fund
The Gabelli Natural Resources, Gold & Income Trust
The Gabelli SRI Fund, Inc.
The Gabelli Utilities Fund
The Gabelli Utility Trust
The Gabelli Value Fund Inc.
The Gabelli Blue Chip Value Fund
The Gabelli Convertible Securities and Income Securities Fund Inc.
The Gabelli Dividend & Income Trust
The Gabelli Equity Trust Inc.
The Gabelli Global Deal Fund
The Gabelli Global Gold, Natural Resources & Income Trust
The Gabelli Healthcare & Wellness(Rx) Trust
The Gabelli Global Multimedia Trust Inc.
The Gabelli Global Utility & Income Trust
GAMCO Gold Fund, Inc.
The GAMCO Growth Fund
GAMCO International Growth Fund, Inc.
The GAMCO Mathers Fund
The Gabelli Natural Resources, Gold & Income Trust
The Gabelli SRI Fund, Inc.
The Gabelli Utilities Fund
The Gabelli Utility Trust
The Gabelli Value Fund Inc.
Gabelli Capital Series Funds, Inc.:
The Gabelli Capital Asset Fund
Comstock Funds, Inc.
Comstock Capital Value Fund
Gabelli Equity Series Funds, Inc.:
The Gabelli Equity Income Fund
The Gabelli Small Cap Growth Fund
The Gabelli Woodland Small Cap Value Fund
The Gabelli Small Cap Growth Fund
The Gabelli Woodland Small Cap Value Fund
GAMCO Global Series Funds, Inc.:
The GAMCO Global Telecommunications Fund
The GAMCO Global Convertible Securities Fund
The GAMCO Global Growth Fund
The GAMCO Global Opportunity Fund
The GAMCO Global Convertible Securities Fund
The GAMCO Global Growth Fund
The GAMCO Global Opportunity Fund
Gabelli Investor Funds, Inc.:
The Gabelli ABC Fund
The Gabelli Money Market Funds:
The Gabelli U.S. Treasury Money Market Fund
The GAMCO Westwood Funds:
GAMCO Westwood Equity Fund
GAMCO Westwood Intermediate Bond Fund
GAMCO Westwood Balanced Fund
GAMCO Westwood SmallCap Equity Fund
GAMCO Westwood Income Fund
GAMCO Westwood Mighty Mites Fund
GAMCO Westwood Intermediate Bond Fund
GAMCO Westwood Balanced Fund
GAMCO Westwood SmallCap Equity Fund
GAMCO Westwood Income Fund
GAMCO Westwood Mighty Mites Fund
Gabelli 787 Fund, Inc.
Gabelli Enterprise Mergers and Acquisitions Fund
November 17, 2009