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Statement of Additional Info - Gabelli

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authorized by the Dodd-Frank Act could result in higher Fund costs and expenses. Legislators and regulators in the<br />

United States are currently considering a wide range <strong>of</strong> proposals in addition to the Dodd-Frank Act that, if enacted,<br />

could result in major changes to the way banking operations are regulated. In addition, the recent European debt crisis<br />

and related financial restructuring efforts have contributed to the instability in global credit markets. The strength and<br />

duration <strong>of</strong> any economic recovery will be impacted by the European debt crisis and the reaction to any efforts to address<br />

the crisis.<br />

Government Intervention In Financial Markets Risk<br />

The recent instability in the financial markets has led the U.S. government and foreign governments to take a number <strong>of</strong><br />

unprecedented actions designed to support certain financial institutions and segments <strong>of</strong> the financial markets that have<br />

experienced extreme volatility, and in some cases a lack <strong>of</strong> liquidity. U.S. federal and state governments and foreign<br />

governments, their regulatory agencies or self regulatory organizations may take additional actions that affect the<br />

regulation <strong>of</strong> the securities in which a Fund invests, or the issuers <strong>of</strong> such securities, in ways that are unforeseeable.<br />

Issuers <strong>of</strong> corporate securities might seek protection under the bankruptcy laws. Legislation or regulation may also<br />

change the way in which a Fund itself is regulated. Such legislation or regulation could limit or preclude a Fund's ability<br />

to achieve its investment objective.<br />

Market Disruption and Geopolitical Risk<br />

The terrorist attacks on domestic U.S. targets on September 11, 2001, the wars in Iraq and Afghanistan, instability in the<br />

Middle East, and other geopolitical events have led to, and may in the future lead to, increased short term market<br />

volatility and may have long term effects on U.S. and world economies and markets. The nature, scope and duration <strong>of</strong><br />

the wars and occupations cannot be predicted with any certainty. Similar events in the future or other disruptions <strong>of</strong><br />

financial markets could affect interest rates, securities exchanges, credit risk, inflation, and other factors relating to a<br />

Fund.<br />

INVESTMENT RESTRICTIONS<br />

The Funds’ investment objectives and the following investment restrictions are fundamental and cannot be changed<br />

without the affirmative vote <strong>of</strong> the holders <strong>of</strong> a majority <strong>of</strong> each Fund's outstanding voting securities. The term<br />

“majority,” as defined by the 1940 Act when referring to the approvals to be obtained from shareholders in connection<br />

with changing fundamental policies <strong>of</strong> a Fund, means the vote <strong>of</strong> the lesser <strong>of</strong> (i) 67% <strong>of</strong> the shares <strong>of</strong> the Fund (or class)<br />

represented at a meeting if the holders <strong>of</strong> more than 50% <strong>of</strong> the outstanding shares <strong>of</strong> the Fund (or class) are present in<br />

person or by proxy, or (ii) more than 50% <strong>of</strong> the outstanding shares <strong>of</strong> the Fund (or class). Each Fund (except the Mid-<br />

Cap Equity Fund), except as otherwise indicated, may not:<br />

1. Purchase the securities <strong>of</strong> any issuer if such purchase would cause more than 5% <strong>of</strong> the value <strong>of</strong> its total assets<br />

to be invested in securities <strong>of</strong> such issuer. This restriction applies only with respect to 75% <strong>of</strong> each Fund's total<br />

assets. For purposes <strong>of</strong> this restriction, these limitations do not apply with respect to securities issued by the<br />

U.S. government, its agencies, or instrumentalities.<br />

2. Purchase the securities <strong>of</strong> any issuer if such purchase would cause the Fund to hold more than 10% <strong>of</strong> the<br />

outstanding voting securities <strong>of</strong> such issuer. This restriction applies only with respect to 75% <strong>of</strong> each Fund's<br />

total assets.<br />

3. Each Fund, other than the Mighty Mites Fund, may not purchase securities <strong>of</strong> any company having less than<br />

three years' continuous operations (including operations <strong>of</strong> any predecessors) if such purchase would cause the<br />

value <strong>of</strong> a Fund's investments in all such companies to exceed 5% <strong>of</strong> the value <strong>of</strong> its total assets.<br />

4. Purchase or retain the securities <strong>of</strong> any issuer if the <strong>of</strong>ficers or Trustees <strong>of</strong> the Funds or the <strong>of</strong>ficers or Directors<br />

<strong>of</strong> the Adviser who individually own beneficially more than ½ <strong>of</strong> 1% <strong>of</strong> the securities <strong>of</strong> such issuer together<br />

own beneficially more than 5% <strong>of</strong> the securities <strong>of</strong> such issuer.<br />

5. Purchase, hold, or deal in commodities or commodity contracts, but the Funds may engage in transactions<br />

involving futures contracts and related options, including the futures and related options transactions as<br />

described in this SAI.<br />

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