David James
PFPC Inc.
Vice President and Counsel
99 High Street, 27th Floor
Boston, MA 02110
(617) 338-4595
(617) 338-4864 - fax
December 20, 2007
VIA EDGAR
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Securities and Exchange Commission
100 F Street NE
Washington, D.C. 20549
RE: The Gabelli Asset Fund GAMCO International Growth Fund, Inc.
File Nos.: 33-1719/811-4494 File Nos.: 33-79994/811-08560
The Gabelli Blue Chip Value Fund Gabelli Investor Funds, Inc.
File Nos.: 333-80099/811-09377 File Nos.: 33-54016/811-07326
Gabelli Capital Series Funds, Inc. The GAMCO Mathers Fund
File Nos.: 33-61254/811-7644 File Nos.: 002-23727/811-01311
Comstock Funds, Inc. The Gabelli Global Utility & Income Trust
File Nos.: 33-40771/811-05502 File Nos.: 333-113621/811-21529
The Gabelli Convertible and Income Securities Fund Inc.
File Nos.: 333-24541/811-05715
Gabelli Equity Series Funds, Inc. The Gabelli Money Market Funds
File Nos.: 33-41913/811-06367 File Nos.: 33-48220/811-6687
The Gabelli Equity Trust Inc. The Gabelli Dividend & Income Trust
File Nos.: 33-42780/811-4700 File Nos.: 333-126480/811-21423
The Gabelli Global Deal Fund The Gabelli Utilities Fund
File No. 333-138141/811-21969 File Nos.: 333-81209/811-09397
The Gabelli Global Multimedia Trust Inc. The Gabelli Utility Trust
File Nos.: 333-25487/811-08476 File Nos.: 333-72983/811-09243
GAMCO Global Series Funds, Inc. The Gabelli Value Fund Inc.
File Nos.: 33-66262/811-07896 File Nos.: 33-30139/811-5848
GAMCO Gold Fund, Inc. The Westwood Funds
File Nos.: 33-79180/811-08518 File Nos.: 33-06790/811-04719
The GAMCO Growth Fund The Gabelli Healthcare & WellnessRx Trust
File Nos.: 33-10583/811-4873 File Nos.: 333-140966/811-22021
The Gabelli Global Gold, Natural Resources The Gabelli SRI Fund, Inc.
& Income Trust File Nos.: 333-141093/811-22026
FILE Nos.: 333-121998/811-21698 (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 for their joint
fidelity bond (the "Joint Bond") for the policy period from December 7, 2006 to
December 7, 2007, such policy being maintained through National Union Fire
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.
The Joint Bond premium allocation for the increase in coverage for
these Funds has already been paid.
Very truly yours,
/S/ DAVID JAMES
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David James
Assistant Secretary
Enclosures
ASSISTANT SECRETARY'S CERTIFICATE
I, David James, Assistant Secretary of The Gabelli Asset Fund, The Gabelli Blue
Chip Value Fund, Gabelli Capital Series Funds, Inc., Comstock Funds, Inc., The
Gabelli Convertible and Income Securities Fund Inc., The Gabelli Dividend &
Income Trust, Gabelli Equity Series Funds, Inc., The Gabelli Equity Trust Inc.,
The Gabelli Global Deal Fund, The Gabelli Gold, Natural Resources & Income
Trust, The Gabelli Global Multimedia Trust Inc., GAMCO Global Series Funds,
Inc., The Gabelli Global Utility & Income Trust, 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 Fund, Inc., The Gabelli
Utilities Fund, The Gabelli Utility Trust, The Gabelli Value Fund Inc. and The
Gabelli Westwood Funds (the "Funds"), 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 a meeting duly called and held on
November 13, 2007:
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
National Union Fire Insurance Company, and
ratify, confirm and approve an increase in
the amount of coverage under said joint
fidelity bond from $23,025,000 to
$24,600,000 effective as of November 13,
2007; 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 Assistant 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 hand this 20th day of
December, 2007.
/S/ DAVID JAMES
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David James
Assistant Secretary
NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA
Rider No. 13
To be attached to and form part of Investment Company Blanket Bond No. 6214219
in favor of The Gabelli Funds, et al.
1. In consideration of the additional premium of $737.00, it is hereby
understood and agreed that Item 3 of the Declaration Page is deleted in its
entirety and replaced with the following:
ITEM 3 Limit of Liability - Subject to Section 9, 10, and 12 hereof:
Limit of Liability Deductible Amount
Insuring Agreement A - FIDELITY $24,600,000 $0
Insuring Agreement B - AUDIT EXPENSE $25,000 $5,000
Insuring Agreement C - ON PREMISES $24,600,000 $10,000
Insuring Agreement D - IN TRANSIT $24,600,000 $10,000
Insuring Agreement E - FORGERY OR ALTERATION $24,600,000 $10,000
Insuring Agreement F - SECURITIES $24,600,000 $10,000
Insuring Agreement G - COUNTERFEIT CURRENCY $24,600,000 $10,000
Insuring Agreement H - STOP PAYMENT $25,000 $5,000
Insuring Agreement I - UNCOLLECTIBLE ITEMS
OF DEPOSIT $25,000 $5,000
OPTIONAL COVERAGES ADDED BY RIDER:
Insuring Agreement J - COMPUTER SYSTEMS $24,600,000 $10,000
Insuring Agreement K - UNAUTHORIZED SIGNATURES $25,000 $5,000
Insuring Agreement L - AUTOMATED PHONE SYSTEMS $24,600,000 $10,000
Insuring Agreement M - TELEFACSIMILE $24,600,000 $10,000
If "Not Covered" is inserted above opposite any specified Insuring Agreement or
Coverage, such Insuring Agreement or Coverage and any other reference thereto in
this bond shall be deemed to be deleted therefrom.
2. Nothing herein shall be held to vary, alter, waive or extend any of the
terms, limitations, conditions or provisions of the attached bond other than as
above stated.
3. This rider shall become effective as of 12:01 a.m. on 09/30/07 standard time
as specified in the attached bond.
By:
Authorized Representative
AMENDED AND RESTATED
JOINT INSURED AGREEMENT
AGREEMENT dated December 1, 1999, as most recently amended as of May
15, 2007, among the registered investment companies advised by Gabelli Funds,
LLC, Gabelli Advisers, 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
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 SRI Fund, Inc.
President, The Gabelli Utilities Fund
President, The Gabelli Utility Trust
President, The Gabelli Value Fund Inc.
President, The Westwood Funds
Signed: /S/ AGNES MULLADY
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 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
Comstock Strategy Fund
GABELLI EQUITY SERIES FUNDS, INC.:
The Gabelli Equity Income 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
GABELLI INVESTOR FUNDS, INC.:
The Gabelli ABC Fund
THE GABELLI MONEY MARKET FUNDS:
The Gabelli U.S. Treasury Money Market Fund
THE WESTWOOD FUNDS:
Westwood Equity Fund
Westwood Intermediate Bond Fund
Westwood Balanced Fund
Westwood SmallCap Equity Fund
Westwood Income Fund
Westwood Mighty Mites Fund
May 15, 2007