Statement of Additional Info - Gabelli

18. Issue senior securities.
If a percentage restriction is adhered to at the time of investment, a later increase in percentage resulting from a
change in values of portfolio securities or amount of total net assets will not be considered a violation of any of
the foregoing restrictions, except that there is an ongoing asset coverage requirement in the case of borrowings.
If the value of the Funds’ holdings of illiquid securities at any time exceeds the percentage limitation applicable
at the time of acquisition due to subsequent fluctuations in value or other reasons, the Funds’ Board will
consider what actions, if any, are appropriate to maintain adequate liquidity.
The Mid-Cap Equity Fund, except as otherwise indicated, may not:
1. Issue senior securities, except as otherwise permitted by its fundamental policy on borrowing or by applicable
law.
2. The Mid-Cap Equity Fund shall invest at least 75% of its total assets in some combination of the following: (a)
cash and cash items, (b) Government Securities (as defined in the 1940 Act), (c) securities of other investment
companies, and (d) other securities. With regard to (d), other securities (acquired pursuant to this policy) are
limited as to any single issuer to an amount not greater than 5% of the Fund’s total assets and not more than
10% of the outstanding voting securities of any such issuer, or as otherwise permitted by applicable law.
3. Make investments that will result in the concentration (as that term is used in the 1940 Act) of its assets in
securities of issuers in any one industry.
4. Purchase or sell real estate, or direct or indirect interests in real estate, except as otherwise permitted by
applicable law.
5. Lend its assets or money to other persons, except (a) by purchasing debt obligations (including privately placed
debt obligations), (b) by lending cash or securities as permitted by applicable law, (c) by entering into
repurchase agreements, (d) by investing in permitted leveraged investments, or (e) as otherwise permitted by
applicable law.
6. Borrow money, except that the Fund may (a) borrow from banks (as defined in the 1940 Act) and through
reverse repurchase agreements in amounts up to 33 1/3% of its total assets (including the amount borrowed), (b)
borrow amounts equal to an additional 5% of its total assets for temporary purposes, (c) invest in permitted
leveraged investments, (d) engage in transactions in mortgage dollar rolls and other similar transactions, and (e)
engage in other transactions that may entail borrowing or otherwise borrow money to the extent permitted by
applicable law.
7. Underwrite securities of other issuers except insofar as the Fund may be deemed an underwriter under the 1933
Act, in selling portfolio securities.
8. Purchase or sell commodities or commodity contracts, except as otherwise permitted by applicable law.
PORTFOLIO HOLDINGS INFORMATION
Employees of the Adviser and Sub-Adviser and their affiliates will often have access to information concerning the
portfolio holdings of the Funds. The Trust, the Adviser, and Sub-Adviser have adopted policies and procedures that
require all employees to safeguard proprietary information of the Funds, which includes information relating to the
Funds’ portfolio holdings as well as portfolio trading activity of the Adviser and Sub-Adviser with respect to the Funds
(collectively, “Portfolio Holdings Information”). In addition, the Trust, the Adviser, and the Sub-Adviser have adopted
policies and procedures providing that Portfolio Holdings Information may not be disclosed except to the extent that it is
(a) made available to the general public by posting on the Trust’s website or filed as part of a required filing on Form N-
Q or N-CSR, or (b) provided to a third party for legitimate business purposes or regulatory purposes, which has agreed to
keep such information confidential under terms approved by the Adviser’s/Sub-Adviser’s legal department or outside
counsel, as described below. The Adviser or the Sub-Adviser will examine each situation under (b) with a view to
determine that release of the information is in the best interest of the Funds and their shareholders and, if a potential
conflict between the Adviser’s or Sub-Adviser’s interests and the Funds’ interests arises, to have such conflict resolved
by the Chief Compliance Officer or those Trustees who are not considered “interested persons”, as defined in the 1940
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