Securities and Exchange Commission April 3, 2009 – Federal Register Recent Federal Regulation Documents

Applicant seeks an order declaring that it has ceased to be an investment company. On September 26, 2008, applicant transferred its assets to Dunham Funds, based on net asset value. Expenses of $315,500 incurred in connection with the reorganization were paid by applicant and Dunham & Associates Holdings, Inc., the parent company of the investment adviser to the acquiring fund.