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November 17, 2008
Securities and Exchange Commission
Office of Filings and Information Services
450 Fifth Street, NW
Washington, D.C. 20549
Re: |
Investment Company Blanket Bond |
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The Central Europe and Russia Fund, Inc. File No. 811-04632 |
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The European Equity Fund, Inc. - File No. 811-05983 |
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The New Germany Fund, Inc.- File No. 811-06041 |
Dear Sir/Madam:
Pursuant to Rule 17-g-1(g) of the Investment Company Act of 1940, as amended, enclosed are the following documents to be filed with the Securities and Exchange Commission:
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1. |
A copy of Investment Company Blanket Bond No. 710-64-69 along with Endorsement No. 1 thru 9 (the Bond) in the amount of $2,750,000 primary coverage issued by National Union Insurance Company of Pittsburgh, PA, covering the above registered investment companies and series thereof for the period August 31, 2008 to August 31, 2009; |
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2. |
Certified resolutions approved by a majority of the Board of Directors who are not interested persons of the registered investment companies, approving the amount, type, form, and coverage of the Bond and the portion of the premium to be paid by such companies, as required by Rule 17g-1(g); |
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A matrix showing: (i) the premiums that each investment company and its series have paid for coverage under the bonds for the period August 31, 2008 to August 31, 2009 and (ii) the amount of the single insured bond which the investment company would have provided and maintained had it not been named as an insured under a joint insured bond; and |
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4. |
A copy of the Funds Insurance Allocation Agreement among the Funds setting forth the criteria by which the premiums for the Bond shall be allocated and the amounts payable under the Bond shall be allocated among the covered parties. |
G:\edgar\40-17G mega\2008\germany funds\FIDELITY BOND SEC letter Germany.htm
If you have any questions or need further information, please call me at 617-295-2572.
Very truly yours,
/s/John Millette
John Millette
Director
Deutsche Asset Management
One Beacon Street
Boston, MA 02108
CERTIFICATE OF THE ASSISTANT SECRETARY
I, John Millette, do hereby certify as follows:
1. That I am the duly elected Assistant Secretary of The Central Europe and Russia Fund, Inc., The European Equity Fund, Inc., and The New Germany Fund, Inc. (the Funds);
2. I further certify that the following is a complete and correct copy of resolutions adopted by the members of the Board of Directors of the Funds and that such resolutions have not been amended and are in full force and effect:
RESOLVED, that the actions taken relating to the Investment Company Blanket Bond, issued by National Union (AIG), in the form and amount of $2,750,000 and a premium of $6,611 covering The Central Europe and Russia Fund, Inc., The European Equity Fund, Inc., and The New Germany Fund, Inc. (collectively, the Funds), are hereby ratified, confirmed and approved in all respects;
FURTHER RESOLVED, that the premiums of the Bond be allocated in the following proportion: each Investment Company shall be allocated a proportion of the premium equal to the proportion that the minimum amount of fidelity bond coverage required for each Investment Company individually under Rule 17g-1 under the Investment Company Act of 1940, as amended (the 1940 Act) bears to the total coverage;
FURTHER RESOLVED, that the officers of the Fund are hereby authorized and directed to begin the renewal process for continuing the existing joint liability policy, providing coverage for each officer and employee of the Fund who may have access to the Funds securities or funds or the power to direct the disposition thereof; and
FURTHER RESOLVED, that the officers of the Fund are hereby authorized to enter into a Fidelity Bond Insurance Allocation Agreement in conformity with paragraph (f) of Rule 17g-1 under the 1940 Act, in substantially the form presented to this meeting, with such changes as may be recommended by counsel, such approval to be conclusively evidenced by execution of the agreement by an officer of the Fund.
IN WITNESS WHEREOF, I hereunto set my hand on November 17, 2008.
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/s/John Millette |
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John Millette |
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Assistant Secretary |
FIDELITY BOND
INSURANCE ALLOCATION AGREEMENT
THIS INSURANCE ALLOCATION AGREEMENT (the Agreement) is made as of August 21, 2008, by and among the investment companies listed as signatories on Schedule A to this Agreement (the Funds) (sometimes individually hereinafter referred to as a party or collectively as parties).
WHEREAS, the Funds have been named as insured parties (Insureds) under joint insured fidelity bonds (hereinafter referred to individually as a Bond and collectively as the Bonds) as may be approved, from time to time, by the Funds respective Boards of Directors (hereinafter referred to individually as a Board and collectively as the Boards);
WHEREAS, the parties desire to establish further (i) the criteria by which the premiums for the Bonds shall be allocated among the parties, (ii) the basis on which additional investment companies for which the Manager or its affiliates may hereafter act as investment adviser may be added as named Insureds under the Bonds, (iii) the criteria by which the amounts payable under the Bonds shall be allocated among the parties covered under same, and (iv) the manner in which the Manager will report to the Funds Board information about claims and payments under any of the Bonds;
NOW, THEREFORE, it is agreed as follows:
1. Each Fund shall pay a portion of the premium of each Bond under which it is covered, which portion shall be determined as of a specified date, which date shall be the same for all Funds, as allocated in such equitable manner as mutually agreed upon by the Funds, subject to the approval of the Board, including a majority of the non-interested directors, which amounts are set forth on Schedule B to this Agreement. From time to time, adjustments may be made by mutual agreement of the Funds to the portion of the balance of the premiums theretofore paid by a Fund, subject to the approval of the Board, including a majority of the non-interested directors, based on a subsequent change or changes in the gross assets of one or more Funds that affects the amount which the Fund would have paid had it provided and maintained a single insured bond with the minimum coverage required by Rule 17g-1(d) under the Investment Company Act of 1940, as amended (the Act) or the addition or withdrawal of a Fund or Funds pursuant to this Agreement.
2. If each of the insurers issuing a Bond (the Insurers) is willing, with or without additional premium, to add, as an Insured under a Bond, any investment company not listed as a signatory to this Agreement for which the Manager or an affiliate thereof is investment adviser, administrator or underwriter, which investment company may be included in the Bond pursuant to Rule 17g-1(b) under the Act, the Funds agree (a) that such addition may be made provided that the non-interested directors of the Funds covered by the Bond shall approve such addition and (b) that such additional entity may become a party to this Agreement and be included within the terms Fund or party, provided that in each case such entity shall have executed and delivered to the Funds its written agreement to become a party hereto and to be bound by the terms of this Agreement.
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3. In the event that the claims of loss of two or more Insureds under the Bonds are so related that the Insurer(s) are entitled to assert that the claims must be aggregated, or in the event that the aggregate recovery by two or more Insureds under the Bonds is less than the aggregate loss incurred by the Insureds that gave rise to the claims, the following rules shall determine, as among the claimants, the priority of satisfaction of the claims under the Bonds:
Each Fund claimant with respect to the same claim shall receive the lesser of (i) proceeds equal to the full amount of its claim or (ii) the amount which it would have received had it provided and maintained a single insured bond with a minimum coverage which such Fund would have been required to carry by Rule 17g-1(d) under the Act at the time the claim arose.
4. The Manager shall provide, on a quarterly basis, a report to the Funds Board which shall include:
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(i) |
a description of any claim made during the preceding calendar quarter under any of the Bonds; and |
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(ii) |
a description of the current status of any matter previously reported by the Manager to the Funds respective Boards pursuant to this Section 4. |
5. This Agreement shall become effective as of the date first above written, and shall remain in full force and effect during the effective period of the Bonds as specified therein. Any party may withdraw from this Agreement and the Bonds upon sixty (60) days written notice to each of the other parties and the Securities and Exchange Commission in accordance with Rule 17g-1 under the Act. The withdrawing party shall be entitled to receive its proportionate share of any premium refund received from the Insurer.
6. This Agreement shall supersede all prior premium sharing and allocation agreements entered into among the Funds. Notwithstanding the foregoing, claims made under a Bond during a period prior to the effective date of this Agreement (and any recoveries related to any such claims) shall be subject to the terms of the premium sharing and allocation agreement in effect during that period.
IN WITNESS WHEREOF the parties have caused this Agreement to be executed by their officers, as appropriate, hereunto duly authorized all as of the day and year first above written.
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By: /s/David Goldman Title: Secretary The European Equity Fund, Inc.
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By: /s/David Goldman The New Germany Fund, Inc.
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By: /s/David Goldman Title: Secretary The Central Europe and Russia Fund, Inc.
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SCHEDULE A: INSUREDS
FUNDS
The European Equity Fund, Inc.
The New Germany Fund, Inc.
The Central Europe and Russia Fund, Inc.
SCHEDULE B
PREMIUM ALLOCATIONS
Fund |
Gross Assets at July 29, 2008 |
Rule 17g-1 Requirement (minimum bond) |
Proposed Bond Minimum |
Allocated % Premium Cost |
Premium Allocated to each Fund |
Estimated Premium Cost for Standalone Policy (1) |
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EEA |
$133,520,950 |
$525,000 |
$600,000 |
23.08% |
$1,525.62 |
$2,100 |
GF |
$334,860,368 |
$750,000 |
$900,000 |
32.97% |
$2,179.45 |
$3,000 |
CEE |
$849,371,462 |
$1,000,000 |
$1,250,000 |
43.95% |
$2,905.93 |
$4,000 |
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$1,317,752,780 |
$2,275,000 |
$2,750,000 |
100.00% |
$6,611.00 |
$9,100 |