Statement of Additional Info - Gabelli

Act (the “Independent Trustees”). These policies further provide that no officer of the Trust or employee of the Adviser
or Sub-Adviser shall communicate with the media about the Funds without obtaining the advance consent of the Chief
Executive Officer, Chief Operating Officer, or General Counsel of the parent company of the Adviser.
Under the foregoing policies, the Funds may disclose Portfolio Holdings Information in the circumstances outlined
below. Disclosure generally may be either on a monthly or quarterly basis with no time lag in some cases and with a
time lag of up to sixty days in other cases (with the exception of proxy voting services which require a regular download
of data):
1. To regulatory authorities in response to requests for such information and with the approval of the Chief
Compliance Officer of the Trust;
2. To mutual fund rating and statistical agencies and to persons performing similar functions where there is a
legitimate business purpose for such disclosure and such entity has agreed to keep such data confidential until at
least it has been made public by the Adviser or Sub-Adviser;
3. To service providers of the Funds, as necessary for the performance of their services to the Funds and to the
Board, where such entity has agreed to keep such data confidential until at least it has been made public by the
Adviser or Sub-Adviser. The Funds’ current service providers that may receive such information are the
administrator, sub-administrator, custodian, independent registered public accounting firm, legal counsel, and
financial printers;
4. To firms providing proxy voting and other proxy services provided such entity has agreed to keep such data
confidential until at least it has been made public by the Adviser or Sub-Adviser;
5. To certain brokers, dealers, investment advisers, and other financial intermediaries for purposes of their
performing due diligence on the Funds and not for dissemination of this information to their clients or use of
this information to conduct trading for their clients. Disclosure of Portfolio Holdings Information in these
circumstances requires the broker, dealer, investment adviser, investment sub-adviser, or financial intermediary
to agree to keep such information confidential until at least it has been made public by the Adviser or Sub-
Adviser and is further subject to prior approval of the Chief Compliance Officer of the Trust and shall be
reported to the Board at the next quarterly meeting; and
6. To consultants for purposes of performing analysis of the Funds, which analysis may be used by the consultant
with its clients or disseminated to the public provided that such entity shall have agreed to keep such
information confidential until at least it has been made public by the Adviser or Sub-Adviser.
As of the date of this SAI, the Funds make information about their portfolio securities available to their administrator,
sub-administrator, custodian and proxy voting service on a daily basis, with no time lag, to their typesetter on a quarterly
basis with a ten day time lag, to their financial printers on a quarterly basis with a forty-five day time lag, and to their
independent registered public accounting firm and legal counsel on an as needed basis with no time lag. The names of
the Funds’ sub-administrator, custodian, independent registered public accounting firm, and legal counsel are set forth in
this SAI. The Funds’ proxy voting service is ADP Investor Communication Services. R.R. Donnelley and Data
Communiqué provide typesetting services for the Funds, and the Funds select from a number of financial printers who
have agreed to keep such information confidential until at least it has been made public by the Adviser or Sub-Adviser.
Other than these arrangements with the Funds’ service providers and proxy voting service, the Funds have no ongoing
arrangements to make available information about the Funds’ portfolio securities prior to such information being
disclosed in a publicly available filing with the SEC that is required to include the information.
Disclosures made pursuant to a confidentiality agreement are subject to periodic confirmation by the Chief Compliance
Officer of the Trust that the recipient has utilized such information solely in accordance with the terms of the agreement.
Neither the Trust, nor the Adviser or Sub-Adviser, nor any of the Adviser’s or Sub-Adviser’s affiliates, will accept on
behalf of itself, its affiliates, or the Funds, any compensation or other consideration in connection with the disclosure of
portfolio holdings of the Funds. The Board will review such arrangements annually with the Trust’s Chief Compliance
Officer.
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