Statement of Additional Info - Gabelli

matures. The precise projection of short term currency market movements is not possible, and short term hedging
provides a means of fixing the dollar value of only a portion of the Fund's foreign assets.
The Funds will not enter into forward contracts or maintain a net exposure to such contracts where the consummation of
the contracts would obligate a Fund to deliver an amount of foreign currency in excess of the value of the Fund's portfolio
securities or other assets denominated in that currency. The Funds will “earmark” on the records of the Adviser or the
Funds' custodian will place cash or other liquid high grade debt securities into a segregated account of a Fund in an
amount equal to the value of the Fund's total assets committed to the consummation of forward foreign currency exchange
contracts requiring the Fund to purchase foreign currencies or forward contracts entered into for non-hedging purposes.
If the value of the securities placed in the segregated account declines, additional cash or securities will be placed in the
account on a daily basis so that the value of the account will equal the amount of a Fund's commitments with respect to
such contracts.
The Funds generally will not enter into a forward contract with a term of greater than one year. Using forward contracts
to protect the value of a Fund's portfolio securities against a decline in the value of a currency does not eliminate
fluctuations in the underlying prices of the securities. It simply establishes a rate of exchange which a Fund can achieve
at some future point in time.
While the Funds will enter into forward contracts to reduce currency exchange rate risks, transactions in such contracts
involve certain other risks. Thus, while a Fund may benefit from such transactions, unanticipated changes in currency
prices may result in a poorer overall performance for a Fund than if it had not engaged in any such transactions.
Moreover, there may be imperfect correlation between a Fund's portfolio holdings of securities denominated in a
particular currency and forward contracts entered into by the Fund. Such imperfect correlation may prevent a Fund from
achieving a complete hedge or may expose the Fund to risk of foreign exchange loss.
Regulation of Certain Options, Currency Transactions and Other Derivative Transactions as Swaps or Security-Based
Swaps. The U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act, enacted in July 2010, (the “Dodd-Frank
Act”) includes provisions that comprehensively regulate the over-the-counter (i.e., not exchange-traded) derivatives
markets for the first time. This regulation requires that certain of the options, currency transactions and other derivative
transactions entered into by the Funds are regulated as swaps by the CFTC or regulated as security-based swaps by the
SEC.
The Dodd-Frank Act generally requires swaps and security-based swaps to be submitted for clearing to regulated clearing
organization (the so-called "clearing mandate"), unless an exemption from clearing applies. Swaps and security-based
swaps that are submitted for clearing will be subject to minimum initial and variation margin requirements set by the
relevant clearing organization, as well as possible SEC- or CFTC-mandated margin requirements. Accordingly, dealers
of swaps and security-based swaps (usually large commercial banks or other financial institutions) as well as other market
participants will be required to post margin to the clearing organizations through which their swaps and/or security-based
swaps are cleared. The SEC, CFTC and other U.S. regulators also are required to impose margin requirements on
uncleared swap and uncleared security-based swap transactions. These changes with respect to clearing and margin
likely will increase a dealer's costs, and those increased costs are expected to be passed through, at least partially, to
market participants, including any Fund that uses swaps or security-based swaps.
The Dodd-Frank Act also requires many swaps and security-based swaps that are currently executed on a bilateral basis
in the over-the-counter market to be executed through a regulated securities, futures, or swap exchange or execution
facility if those transactions are subject to the clearing mandate. Once such requirements become effective, it may be
more difficult and costly for the Funds to continue to enter into customized swap or security-based swap transactions on a
bilateral basis.
In addition, dealers and major participants in the over-the-counter market are required to register with the SEC and/or
CFTC. Registered dealers and major participants are subject to minimum capital and margin requirements, business
conduct standards, disclosure requirements, reporting and recordkeeping requirements, position limits, limitations on
conflicts of interest, and other regulatory burdens. These requirements may increase the overall costs for dealers and
major participants in the over-the-counter market, and such increased costs are likely to be passed through, at least
partially, to market participants, including any Fund that utilizes these instruments.
The cumulative effects of the Dodd-Frank Act on swap and security-based swap transactions and on participants in the
derivatives market remain uncertain.
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