On July 19, 2012, the staff of the Division of Investment Management of the U.S. Securities and Exchange Commission (the “Staff”) updated its Form PF Frequently Asked Questions (the “FAQs”) to include significant new interpretive guidance on Form PF. The FAQs are available on the SEC’s website at http://www.sec.gov/divisions/investment/pfrd/pfrdfaq.shtml.

The FAQs address a number