Previously, the fund observed policies that prevented it from investing in IOs or

inverse floaters of collateralized mortgage obligations or in residual interests of REMICS.

With the introduction of more

inverse floaters into our portfolio in the last couple of years they've performed exceptionally well with rates declining and then staying low for a particularly long period of time.

With respect to the investment strategy, the Official Statements failed adequately to disclose that the strategy: 1) was risky; 2) was predicated upon the assumption that prevailing interest rates would remain at relatively low levels; 3) involved a high degree of leverage through the use of reverse repurchase agreements; 4) involved a substantial investment in derivative securities, including

inverse floaters that are negatively affected by a rise in interest rates; and 5) was very sensitive to changes in the prevailing interest rate because of the leverage.

After the big sell-off following the collapse of that market, some of the more exotic and risky strips, such as

inverse floaters, were selling at discounts of up to 26 percent.

The group accused Crews, Hoggard and two out-of-state brokerage firms of being responsible for losses caused by investing BMAA funds in volatile

inverse floaters, a type of derivative investment.

He explained that mortgages, convertibles and callables are similar to

inverse floaters, leveraged swaps, principal-only strips or step-up callable notes.

Inverse floaters are unusual instruments because their interest coupons float in the opposite direction of interest rates in general.

The Fund's management team believes that increasing the Fund's flexibility to invest in IOs,

inverse floaters and residual interests of REMICs may better permit the Fund to react to changes in interest rates and to capitalize on the management team's views on the housing and mortgage markets.

The bulletin also describes the most common types of structured notes, including step-up bonds, index amortizing notes, dual index notes, deleveraged bonds, range bonds and

inverse floaters.

This article will focus on other derivative products:

inverse floaters/floaters,

inverse floaters hedged with swaps, bull/bear floaters and indexed/fixed-rate bonds.

Under normal market conditions, the Fund invests more than half of its assets in mortgage-backed government securities, mortgage-backed securities collateralized by government securities, and privately issued high-grade mortgage-backed securities, including

inverse floaters.

Fitch's criteria also considers the fund's use of economic leverage in the form of secondary market

inverse floaters of tender option bonds, which amounted to $350,000 in par of referenced bond value.