Statement of Additional Info - Gabelli

These Funds may make a short sale in order to hedge against market risks when it believes that the price of a security may
decline, causing a decline in the value of a security owned by the Funds or security convertible into, or exchangeable for,
the security, or when the Funds do not want to sell the security they own, because among other reasons, they wish to defer
recognition of gain or loss for U.S. federal income tax purposes. The Funds may close out a short position by purchasing
and delivering an equal amount of securities sold short, rather than by delivering securities already held by the Funds,
because the Funds may want to continue to receive interest and dividend payments on securities in its portfolio that are
convertible into the securities sold short.
The successful use of short selling may be adversely affected by imperfect correlation between movements in the price of
the security sold short and the securities being hedged.
Lending Portfolio Securities (All Funds). To a limited extent, each Fund may lend its portfolio securities to brokers,
dealers, and other financial institutions, provided it receives cash collateral which at all times is maintained in an amount
equal to at least 102% and 105%, respectively, of the current market value of domestic and international securities
loaned. By lending its portfolio securities, a Fund can increase its income through the investment of the cash collateral.
For the purposes of this policy, the Funds consider collateral consisting of U.S. government or agency securities or
irrevocable letters of credit issued by banks whose securities meet the standards for investment by the Funds to be the
equivalent of cash. Such loans may not exceed 33-1/3% of a Fund's total assets. From time to time, a Fund may return to
the borrower and/or a third party which is unaffiliated with the Fund, and which is acting as a "placing broker," a part of
the interest earned from the investment of collateral received for securities loaned.
The SEC currently requires that the following conditions must be met whenever a Fund's portfolio securities are loaned:
(1) the Fund must receive at least 100% cash collateral from the borrower; (2) the borrower must increase such collateral
whenever the market value of the securities rises above the level of such collateral; (3) the Fund must be able to terminate
the loan at any time; (4) the Fund must receive reasonable interest on the loan, as well as any dividends, interest or other
distributions on the loaned securities, and any increase in market value; (5) the Fund may pay only reasonable custodian
fees approved by the Trust’s Trustees in connection with the loan; (6) while voting rights on the loaned securities may
pass to the borrower, the Trust’s Trustees must terminate the loan and regain the right to vote the securities if a material
event adversely affecting the investment occurs, and (7) the Fund may not loan its portfolio securities so that the value of
the loaned securities is more than one third of its total asset value, including collateral received from such loans. These
conditions may be subject to future modification.
Such loans will be terminable at any time upon specified notice. A Fund might experience the risk of loss if the
institution with which it has engaged in a portfolio loan transaction breaches its agreement with the Fund.
Illiquid Securities and Rule 144A Securities (All Funds). Each Fund may invest its net assets in securities as to which
a liquid trading market does not exist, provided such investments are consistent with the Fund's investment objective.
Such securities may include securities that are not readily marketable, such as certain securities that are subject to legal or
contractual restrictions on resale, repurchase agreements providing for settlement in more than seven days after notice,
and certain privately negotiated, non-exchange traded options and securities used to cover such options. As to these
securities, the Fund is subject to a risk that should the Fund desire to sell them when a ready buyer is not available at a
price the Fund deems representative of their value, the value of the Fund's net assets could be adversely affected. Illiquid
securities do not include securities eligible for resale pursuant to Rule 144A of the Securities Act of 1933, as amended
(the "Securities Act"), or other restricted securities, which have been determined to be liquid in accordance with
procedures established by the Board.
The Funds (except for the Mid-Cap Equity Fund) have adopted fundamental policies with respect to investments in
illiquid securities. Securities that have not been registered under the Securities Act are referred to as private placements
or restricted securities and are purchased directly from the issuer or in the secondary market. Mutual funds do not
typically hold a significant amount of these restricted or illiquid securities because of the potential for delays on resale
and uncertainty in valuation. Limitations on resale may have an adverse effect on the marketability of portfolio securities
and a mutual fund might be unable to dispose of restricted or illiquid securities promptly or at reasonable prices and
might thereby experience difficulty satisfying redemptions within seven days. A mutual fund might also have to register
such restricted securities in order to dispose of them resulting in additional expense and delay. Adverse market
conditions could impede such a public offering of securities.
A large institutional market has developed for certain securities that are not registered under the Securities Act, including
repurchase agreements, commercial paper, foreign securities, municipal securities, and corporate bonds and notes.
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