In re COLUMBIA MANAGEMENT

UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE
COMMISSION

Admin. Proc. File No. 3-11814
In the Matter of
COLUMBIA MANAGEMENT
ADVISORS, INC. AND COLUMBIA
FUNDS DISTRIBUTOR, INC.,
Respondents.

PLAN OF DISTRIBUTION

I.         Background

 1.1.  On February 9, 2005 the Securities and Exchange Commission
(“SEC” or “Commission”) entered an order in this proceeding (the “Order”)
reciting, among other things, that “[f]rom at least 1998 through October 2003,
Columbia [Management] Advisors[, Inc.] and some of its predecessor entities
(“Columbia Advisors”), the investment adviser to over 140 of the mutual funds in
the Columbia mutual fund complex (the “Columbia Funds”), and Columbia
[Funds] Distributor [,Inc.], the principal underwriter and distributor of those funds,
violated antifraud provisions of the securities laws by allowing certain preferred
customers to engage in short-term or excessive trading, contrary to the
restrictions and/or representations set forth in the Columbia Funds’
prospectuses, that was detrimental to Columbia Funds but benefited respondents
without disclosing these trading arrangements to fund shareholders or to fund
trustees.”  (Order ¶1).   The Order required Respondents to pay $70,000,000 in
disgorgement and $70,000,000 in civil money penalties, and established a Fair
Fund consisting of the sum of those payments, for a total fund of $140,000,000.
(Order ¶IV(E)).  The Order required an Independent Distribution Consultant
(“IDC”) to develop a plan (the “Distribution Plan,” or “Plan”) for the distribution of
the Fair Fund, “according to a methodology developed by the IDC in consultation
with Respondents and the independent trustees of the Columbia Funds mutual
funds and acceptable to the staff of the Commission.”  (Order ¶67).  Shortly after
the entry of the Order, Professor Lawrence A. Hamermesh, Ruby R. Vale
Professor of Corporate and Business Law at Widener University School of Law in

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Wilmington, Delaware, was appointed as the IDC in this proceeding.
1
  On
February 25, 2005, Respondents deposited the amount of the Fair Fund
($140,000,000) at the Bureau of Public Debt for investment in government
obligations.  Other than interest from these investments and funds to be received
pursuant to the plan of distribution in the Bank of America/Nations Funds
Proceeding, it is not anticipated that the Fair Fund will receive additional funds.  If
any other funds are received before distributions under this Plan have begun,
such funds will be distributed by means of proportionally increasing distributions
otherwise provided for in this Plan (¶¶7.3 - 7.7), or by such other means
approved by the IDC in consultation with the Respondents, the trustees of the
Columbia Funds, and the Commission or its staff.  After distributions under this
Plan have begun, the Fund does not intend to accept additional funds for
distribution.

 1.2.  This Distribution Plan is the result of extensive consultation.  Among
other efforts, Professor Hamermesh:

•    Met with Navigant Consulting, Inc. to review the analyses it prepared for
the Independent Trustees of the Columbia Funds to assist with their
evaluation of the effects of market timing activity in the Columbia Funds.
•    Met and spoke with Respondents’ economic adviser Lexecon, which has,
at Professor Hamermesh’s request and under his guidance, managed the
trading data and developed and executed the numerical and financial
analyses of that data.
•    Retained Professor Erik R. Sirri, professor of finance at Babson College
and former Chief Economist of the Commission, and consulted him on
issues of financial and economic analysis associated with the
development of the Distribution Plan with respect to distributions to
Columbia Funds shareholders.

1.3.  Before describing how this Distribution Plan allocates and distributes
the Fair Fund, it is helpful to separate into two broad categories the trading
addressed by the Order.  The first category, identified here as “Arrangement
Trading,” involves market timing activity by nine entities with whom Respondent
Columbia Funds Distributor, Inc. (“Columbia Distributor”) was found to have
entered into an arrangement or understanding allowing rapid trading in one or
more of the Columbia Funds.  (Order ¶¶13-40).  The second category involves
market timing activity by persons with whom the Respondents had no

1
 Professor Hamermesh also serves as IDC for the fair fund established under the February 9,
2005 order in In the Matter of Banc of America Capital Management, LLC, BACAP Distributors,
LLC, and Banc of America Securities, LLC (the “Bank of America/Nations Funds Proceeding”).
That proceeding involves a separate fair fund from the fund established with respect to the
Columbia Funds.  As prescribed in the Order in this proceeding involving the Columbia Funds
(¶67), Respondents have agreed to pay all compensation of and expenses incurred by Professor
Hamermesh as IDC for the Columbia Funds Fair Fund.

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arrangement or understanding with respect to short term trading.  Because of the
absence of any such arrangement or understanding, trading by these persons is
described here as “Non-Arrangement Timing.”  The persons who engaged in
Non-Arrangement Timing in turn fall into two distinct categories:  those (identified
as “retail traders”) who traded through accounts held in their own names (“retail
accounts”); and others (“omnibus traders”) who traded through accounts that
aggregated trading and ownership by multiple beneficial owners (“omnibus
accounts”).  (Order ¶41).

II.  Distribution Methodology – In General

2.1.  The methodology for the distribution of the money in the Fair Fund is
designed to provide compensation for dilution and related harm to
contemporaneous long term fund shareholders arising from the two principal
categories of trading identified in the Order.  The term “contemporaneous,” as
used in this Distribution Plan, refers to those persons who were fund
shareholders at the time of the trading identified in the Order, regardless of
whether such persons continued to hold fund shares thereafter.

2.2.  The methodology employed in this Plan attempts to estimate, on a
daily basis over the course of that trading, the extent to which a fund’s net asset
value (NAV) would have been greater or less than the actual NAV had that
trading not occurred.  That difference (where positive) is the estimate of the
dilution and related harm to the contemporaneous holders of the fund on each of
the days on which such trading occurred.  The sum of those daily increments
(both positive and negative) represents the aggregate harm to each fund’s
shareholders during the period in which timing trading occurred.
2

 2.3.  The methods of calculation of each eligible contemporaneous
shareholder’s share of the Fair Fund are intended to result in a payment from the
Fair Fund to each such shareholder that restores the impaired value of such
shareholder’s investment in a particular fund.  The methods of calculation are
intended by the Commission to fairly estimate the impaired value that each
investor has suffered and to make a payment in that amount.  In the view of the
IDC, these methods of calculation are fair and reasonable in the context of this
case, and result in a fair and reasonable allocation of the Fair Fund.

III.  Estimation of Dilution and Related Harm to Contemporaneous Shareholders

2
 There may be instances of accounts for which the effect of timer trading was beneficial (and for
which harm-based compensation would be inappropriate).  Because of this possibility, it may also
be the case that the other account holders’ share of estimated harm would in the aggregate
exceed the aggregate amount estimated for the fund as a whole.  At this point, however, it
appears that such instances are both unusual and small in scope, and are not likely to have a
substantial effect on the ultimate distribution.

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A.  Estimating Dilution

3.1.  The starting point in estimating the dilution arising from timer trading
is a determination of the net gains realized through that trading.  Each timer’s
purchases and sales are formed into buy-sell pairs using a LIFO methodology.
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3.2.  For any given mutual fund, if the funds a timer uses to purchase fund
shares (“timer funds”) were never invested in risky portfolio assets by the
portfolio manager, timer net gains would accurately measure dilution to
contemporaneous shareholders.  To the extent, however, that timer funds were
invested in risky assets, dilution may diverge from timer net gains.  Accordingly, it
is necessary to estimate the extent to which portfolio managers invested in (and
sold) portfolio assets in response to timer investment (and sales).
4

3.3.  For each buy-sell pair, the mutual fund’s incremental investment in
risky assets is estimated by assuming that a constant fraction of the timer funds
is invested in risky assets each day until either the timer funds are invested or the
timer’s shares are redeemed.  When the timer’s shares are redeemed, the
portfolio manager is assumed to sell risky assets at the same rate to fund the
redemption.
5

3.4.  To illustrate, take the case where a timer buys 10 fund shares for
$100 on day 1, sells those 10 shares on day 4 for $110, and the estimated daily
average investment rate is 10 percent per day.  The model assumes the portfolio

3
 Because of the focus on the actual dilutive impact on fund shareholders, aggregate timer gains
and losses in each individual fund are netted through the period in which timer trading occurred.

4
 See Greene, Jason T. and Ciccotello, Conrad S., "Mutual Fund Dilution from Market Timing
Trades" (September 27, 2004).
http://ssrn.com/abstract=596482

5
 Daily average investment rates for use in this cash investment model and for calculating
transaction costs are estimated from data on flows of money during 2002 and 2003 into 15 of the
Columbia Funds and data on portfolio manager investments for those funds.  The 15 funds were
among those with the largest dilution.

Regression analysis is used to estimate the daily average investment rate where investment in
risky assets is regressed on flows.  The daily average investment rate is calculated by averaging
the regression coefficients on the flow variables.  Many regression specifications were tried,
including regressions with lead and contemporaneous variables, and the specification that
produced the highest daily average investment rate was used.

To measure typical portfolio manager reaction to recurring timer flows, outliers in the flow and
investment data are removed.  (For instance, investment rebalancing by large shareholders, such
as pension plans, periodically caused large movements of assets between funds.)

Where flow or portfolio investment data are unavailable for a fund, a weighted average of the
daily investment rates for the funds with available data is used, and a minimum investment rate of
one percent per day is imposed.  The overall dilution estimate is not sensitive to the daily average
investment rate; doubling the rate reduces overall dilution by an insignificant amount.

4

manager invests $10 per day in risky assets on days 2 through 4.  Consequently,
before the redemption on day 4, the fund holds $30 of the timer funds in risky
assets and $70 in cash; and immediately after the redemption on day 4, the fund
holds $30 of the timer funds in risky assets and has a cash deficit of $40 (= $70 -
$110).  On days 5 through 14, the portfolio manager is assumed to sell $40 of
risky assets at the rate of $4 per day to offset the cash deficit and return the fund
to its previous cash level.

3.5.  To estimate the effect of the incremental investment in risky assets,
the fund’s profits and losses on the incremental investment are estimated for
each day, and the total effect is the sum of the daily profits and losses.  The
effect of the incremental investment each day is estimated as the fund’s return
that day multiplied by the incremental investment in risky assets that day.  For
example, continuing the previous illustration, the fund’s investment in risky assets
is $20 higher on day 3 than it would have been absent the timing activity.  If the
fund’s return on day 3 was 1 percent, then the investment of the timer funds
benefited the fund’s shareholders that day by $0.20 (= $20 * .01); and if the
fund’s return on day 3 was -2 percent, then the timing activity harmed the fund’s
shareholders that day by $0.40 (= $20 * .02).

3.6.  Last, the effects of all incremental investments are summed and
added to the total net profits made by the timers ($10 in this example) to arrive at
an estimate of the total dilution harm to shareholders from the timing activity.

B.  Estimating Transaction Costs Related to Timer Trading

3.7.  The Order states that timer trading may have adversely affected the
funds’ NAV’s in an additional way, aside from dilution (Order ¶9).  To the extent
that timer investment and disinvestment resulted in excess portfolio purchases
and sales, the funds may have incurred transaction costs that reduced their
NAV’s.  Such transaction costs can be estimated by comparing estimated
transaction costs due to the funds’ actual inflows and outflows to the estimated
transaction costs that would have occurred had there been no timing activity.
The difference between the two estimates of transaction costs is taken as the
incremental transaction costs attributable to the timing activity.

3.8.  Incremental transactions in response to a given inflow or outflow are
modeled by assuming that the portfolio manager invests (or disinvests) in risky
assets at the estimated daily investment rate until the flow is completely invested
(or disinvested).  For each inflow or outflow, this produces a series of daily
investments or disinvestments.  To get the total investment or disinvestment on
any given day, all investments and disinvestments on that day due to all inflows
and outflows are summed.  Where there is investment due to previous inflows
and disinvestment due to previous outflows, the investments and disinvestments
are netted against each other for that day.  Investments and disinvestments are
not netted against each other across days.

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3.9.  Transaction costs are estimated from the daily series of net
investments by multiplying the investment or disinvestment on each day by the
transaction cost per dollar of investment or disinvestment.  Total transaction
costs are the sum of the daily transaction costs.

3.10.  Transaction costs vary by fund type and time period.  Funds are
classified into four fund groups based on their Morningstar classification: U.S.
Large-Cap, U.S. Small-Cap, International, and Bond.  (When a fund’s category
cannot be identified, the U.S. Small-Cap classification is used.)  Transaction
costs for U.S Large-Cap, U.S. Small-Cap and International funds are from Plexus
and are the sum of “commissions” and “impact costs.”  Bond fund transaction
costs are from Schultz, Paul, 2001, “Corporate Bond Trading Costs: A Peek
Behind the Curtain,” The Journal of Finance 56, 677– 698 at 677.

3.11.  Applying the foregoing methodology to the data available for the
Columbia Funds results in an estimate of transaction costs that is on average
approximately 8% of dilution.

C.  Interest

3.12.  In order to make compensation on an equivalent basis for losses
spread over time, and to provide appropriate compensation to long-term fund
shareholders, it is necessary to make some adjustment for the time value of the
estimated harms.  Therefore, the methodology incorporated in this Distribution
Plan builds in a component of interest on estimates of harm, accruing from the
time of dilution harm through the date of payment into the Fair Fund.  The rate of
interest was selected to approximate Bank of America’s cost of unsecured
borrowing,
6
 and is estimated by reference to the Merrill Lynch index of 1-3 year
A-rated corporate debt over the course of the period in which timer trading
occurred.

IV.  Application of the Methodology to Arrangement Trading

 4.1.  As previously noted, the first category of trading addressed in this
Distribution Plan is the Arrangement Trading (i.e., market timing activity by the
nine entities identified in the Order (¶¶13-40) with whom Respondent Columbia
Distributor was found to have entered into an arrangement or understanding
allowing rapid trading in one or more of the Columbia Funds).  Some of the
entities that engaged in Arrangement Trading made purchases and sales that
involved “sticky” assets (i.e., long term investments) in the very funds in which
the Arrangement Trading occurred (see, e.g., Order ¶¶16, 23, 34, 37).
Accordingly, and to focus the ultimate distribution on contemporaneous fund

6
 See Knoll, Michael S. and Colon, Jeffrey M. Colon Miguel, "The Calculation of Prejudgment
Interest" (May 31, 2005).
http://ssrn.com/abstract=732765.

6

holders adversely affected by excessive rapid trading (as opposed to trading in
“sticky” assets), the methodology for measuring the impact of Arrangement
Trading includes all matched buy and sell pairs except those in which the holding
period exceeded 21 trading days.

4.2.  The result of this approach to Arrangement Trading is a distributional
allocation in the aggregate amount (including transaction costs and interest) of
approximately $32.6 million.  In addition to that allocation, this Distribution Plan
will also return, to contemporaneous holders of the funds affected by such
trading, advisory and administrative fees paid by those funds to Respondents
Columbia Advisors and Columbia Distributors as a result of the investment of
timer funds during the periods in which the Arrangement Trading in those funds
occurred.  Order ¶¶49-50.  Over the 1999-2003 time period, such fees amounted
to approximately $500,000.  Taken together with the allocation attributable to
dilution and related harm, the total allocation proposed with respect to
Arrangement Trading is approximately $33.1 million.

V.  Application of the Methodology to Non-Arrangement Timing

 5.1.  The balance of the Fair Fund will be applied to the Non-Arrangement
Timing.  While such trading is only briefly mentioned in the Order (¶41), it
accounts for the largest portion of the allocation contemplated in the Distribution
Plan, and presents a distinct set of challenges.  Although the Order notes
numbers of round trips in the Columbia Funds in non-omnibus accounts, and
notes that omnibus accounts also made numerous round trips, it does not
specify, for purposes of the distribution of the Fair Fund, which of those round
trips were by market timers and which of these round trips should result in an
allocation from the Fair Fund.

 5.2.  Likewise, although the Order mentions round trips in both omnibus
and retail accounts, there are obvious differences between the two types of
accounts from the perspective of identifying and policing market timing.  The
aggregated nature of omnibus accounts may mask market timing at the sub-
account level.  For example, it might not be apparent to an advisor or distributor
that a buy through an omnibus account is “matched” at the sub-account level with
a subsequent sale through the same omnibus account.  Moreover, while it might
be appropriate to shut down a retail account when there is a pattern of short term
trading, that might not be an appropriate response in the omnibus account
situation due to the consequences to innocent long-term investors holding
through the omnibus account.

 5.3.  Accordingly, in identifying the trading with respect to which dilution
and related harm should be estimated, the IDC requested an examination of the
entire set of trading data in the Columbia Funds over an extended time frame
(1998-2003).  Trading through Banc of America Securities (compensation for
which is being addressed in the Bank of America/Nations Funds distribution plan)

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was then excluded from that data set.  In addition, trading in 1998 was also
excluded for a variety of reasons, including: (1) the data suggest that the short
term trading prior to January 1, 1999 was relatively insignificant, and (2) as
reflected in the Order, nearly all of the Arrangement Trading occurred after
January 1, 2000.

 5.4.  For the remaining trading, certain criteria were selected and applied
to these data to identify the trading in respect of which compensation is to be
made under this Plan.  In the absence of evidence of specific relevant
communications with specific fund holders as to their investment motivations, no
set of criteria for identifying market timing accounts can possibly be completely
accurate.  Accordingly, the application of any set of criteria to the remaining
trading will probably result in the inclusion of some trades that were not driven by
market timing considerations, and the exclusion of some trades that were.  The
criteria selected in this Plan, therefore, seek to draw distinctions among accounts
based on observable behavior, reasonably inferable investment motivation, and
reasonable expectations concerning the Respondents’ ability to have halted
observable market timing activity.  The goal in selecting these criteria is to arrive
at some reasonable way to allocate the Fair Fund so that distributions to
contemporaneous shareholders are directed to the funds and shareholders most
heavily affected by Non-Arrangement Timing.

 5.5.  The criteria selected are:

      (1) Exclude all purchase/sale pairs in which the holding period exceeded
seven trading days, and exclude all trading in any account in which there was
never a purchase/sale pair involving amounts greater than $100,000 and
$50,000 respectively.
7

           (2) For each fund, and for those purchase/sale pairs that satisfy the
criteria in the preceding paragraph, identify the first observance of two round trips
in a retail account in a quarter (on a rolling basis), or, if none, the first five round
trips in a retail account in a year (on a rolling basis), and exclude those trades
and any prior trades.

      (3) Exclude purchase/sale pairs in omnibus accounts where the date of
the purchase does not coincide with a date of a purchase in a buy/sell pair in the
same fund that is identified as Arrangement Trading or trading in a retail account
identified pursuant to the two criteria noted above.
8

7
 The selected period is shorter than the comparable period selected for Arrangement Trading,
because it is intended to retrospectively identify market timing accounts, rather than distinguish
market timing activity from long-term investment activity in the case of known market timers.

8
 In late 2002 the Columbia Funds imposed redemption fees on short-term trading of international
funds by retail accounts, which resulted in a substantial reduction in timing trades by those
accounts.  All omnibus trading pairs that meet criterion 1 above for international funds after those
fees were imposed on retail accounts were included in identifying Non-Arrangement Timing.

8

      (4) For each fund, and for those trades that satisfy the previous criteria,
identify the first observance of five round trips in an omnibus account in a quarter
(on a rolling basis), or, if none, the first ten round trips in an omnibus account in a
year (on a rolling basis), and exclude those trades and any prior trades.

VI.  De Minimis Analysis and Prioritization

6.1.  The foregoing analysis, taken together with the analysis of
Arrangement Trading, yields an estimate of total dilution for each of the Columbia
Funds.  (See Table 2).  This Distribution Plan excludes from the distribution those
Columbia Funds in which the estimate of aggregate dilution harm from 1999
through 2003 was less than either $100,000 or 0.2% of average fund assets.
This approach excludes a large number of the Columbia Funds for which trading
data were studied (see Table 2).  Many of these funds are focused on
investments that do not fluctuate rapidly in value or otherwise do not offer
significant opportunity for profitable market timing activity (e.g., municipal bonds,
or domestic large cap stocks).

6.2.  The remaining Columbia Funds are identified as “Participating
Funds.” (See Table 1). Of these Participating Funds, the first priority for
distribution will be to the funds in which there was estimated dilution on account
of Arrangement Trading.  Distribution in respect of the remaining Participating
Funds will be made, in descending order of estimated dilution as a percentage of
average fund assets, to the point that a minimum of $4 million (plus attributed
interest thereon since February 25, 2005) remains in the Fair Fund as a holdback
described in paragraph 7.8 below.  Table 1 sets forth the Participating Funds in
the order of priority of distribution as explained above.

VII.  Administration of the Distribution

 A.  Allocating the Distributions Among Contemporaneous Shareholders.

7.1.  Application of the methodology described above permits the
calculation of a distribution amount, by date, for each of the funds affected by the
identified timer trading.  In turn, each holder of shares in one or more of those
funds during the period affected by timer trading will be identified in order to
determine that holder’s appropriate allocation of the Fair Fund.  There are a
number of difficulties, however, in simply directing payment of those amounts to
those holders. The balance of this Distribution Plan addresses these and other
aspects of implementation and administration of the Plan.

7.2.  This Fair Fund is not being distributed according to a claims-made
process, so the procedures for providing notice and for making and approving
claims are not applicable.

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7.3.  Under this Distribution Plan there will be no distribution to any of the
nine persons identified in the Order as having engaged in late trading or market
timing.  Similarly, but with the caveat noted below, there will be no distribution to
any person or entity identified as the holder of a retail account identified as a
market timing account using the criteria described above.  Such persons or
entities will be notified that they are not to receive a distribution unless they
present to the IDC, within a 60-day period after notice, evidence demonstrating to
the satisfaction of the IDC that their trading was not motivated by timing
considerations.  The IDC will evaluate and determine the merits of each such
presentation within 30 days after its submission, and will advise the presenter,
the Respondents and the Commission of the determination promptly upon
making it.  The aggregate of amounts excluded on the foregoing basis will be
disbursed in accordance with paragraph 7.8 below.

7.4.  Returns on the Fair Fund that have accrued since its establishment in
February 2005 through the date of approval of the Distribution Plan will be
allocated in proportion to the allocation otherwise contemplated under the Plan.

7.5.  In any given fund there will be holders identified for whom the
estimated distribution is so small that it would be impractical and ineffective to
send a check.  In general, no distribution of less than $10 will be made.  Two
steps will be taken, however, to minimize the number of such de minimis
situations, and maximize the number of individual holders who will be receiving a
distribution:  (i) an effort will be made to identify, by common social security
number or other administratively feasible mechanism, instances in which
distribution amounts attributable to an individual shareholder in multiple affected
funds can be aggregated into a single amount in excess of $10; and (ii) other
accounts for which the distribution would amount to less than $10 will be
aggregated, with the resulting sum distributed in $10 units to the holders of those
accounts, in descending order of attributable dilution harm.

B.  Distributions to Omnibus Accounts, Retirement Accounts and Network
Level Accounts.

7.6.     (a) For distributions with respect to omnibus accounts (but not for
ordinary trusts, pension plans and 529 plans), it will be necessary to evaluate the
cost associated with commercially reasonable best efforts to identify and
distribute funds to contemporaneous beneficial owners.
 (b)  If the aggregate amount of the distribution attributable to a
particular omnibus account is $1,000 or more, the account holder will be
contacted in order to determine an appropriate method for distributing the funds
to contemporaneous beneficial owners holding through the omnibus account.
Unless the account holder agrees to distribute the funds to beneficial owners at
its own expense, in accordance with the specifications supplied by or on behalf of
the IDC, the account holder will be asked to estimate the costs of commercially
reasonable efforts to identify and distribute funds to the beneficial owners.

10

 (c)  If the aggregate amount of the distribution with respect to an
omnibus account exceeds such costs, the omnibus account holder will be asked
to elect, within 45 days after notice of the proposed distribution, whether to (i)
supply to the IDC the sub-account information necessary for the IDC to distribute
funds to the beneficial owners, (ii) supply such information to the IDC, who will
calculate the amount of distributions to beneficial owners so that the account
holder can make such distributions itself, or (iii) distribute the funds itself, using
specifications supplied by or on behalf of the IDC as necessary to determine the
appropriate allocation of the funds among contemporaneous beneficial owners
holding through the omnibus account.  The omnibus account holder may elect
more than one of these options and apply them differently in respect of different
categories of beneficial owners (such as open accounts and closed accounts).  In
any of these three cases, Respondents will reimburse the omnibus account
holder for the reasonable out of pocket costs of gathering and supplying the
necessary sub-account information.  If the omnibus account makes no election
within the time specified in this subparagraph, it will be deemed to have elected
to proceed under subparagraph (i) of this paragraph.  If and to the extent that the
omnibus account holder elects to proceed under subparagraph (c)(i) or (c)(ii), the
holder shall submit the specified information to the IDC within 90 days after
notice of the proposed distribution.
 (d)  If the omnibus account holder elects to proceed under
subparagraph (c)(ii) or (c)(iii), the account holder may either send a check to the
beneficial owner or, if the beneficial owner has a current sub-account, credit that
sub-account.  Except where the omnibus account holder credits current sub-
accounts in lieu of sending checks, it will be required to develop and execute a
program similar to the one described in paragraph 7.5(ii) for dealing with
individual distributions of less than $10.
 (e)  If the aggregate amount of the distribution attributable to a
particular omnibus account is less than either (a) $1,000 or (b) the costs of
commercially reasonable efforts to identify and distribute funds to
contemporaneous beneficial owners, the omnibus account holder will be given
the choice of refusing the distribution or applying any distribution technique, at its
own expense, that the account holder, in the exercise of its reasonable
discretion, deems to be consistent with its fiduciary, contractual or other legal
obligations.  If the omnibus account holder refuses the distribution, the otherwise
distributable amount will be added to the holdback described in paragraph 7.8.
 (f)  For purposes of this paragraph, “commercially reasonable best
efforts” to identify and distribute funds to beneficial owners in omnibus accounts
involve assembly, in appropriate format, of (i) names, addresses and other
necessary identifying information for beneficial owners, and (ii) daily records or
opening account balances and subsequent transaction data (or, if such data are
either unavailable or available only at a cost that would otherwise result in the
application of the previous subsection, the most extensive records (monthly,
quarterly or yearly) that are available) necessary to determine each such owner’s
fund share balance during the period to which the distribution in question relates.
The foregoing information provided by omnibus account holders shall be

11

maintained confidentially and held exclusively by the Fund Administrator, and
Respondents shall not have access to that information.  Respondents and the
Fund Administrator shall maintain records of efforts made to obtain the
cooperation of omnibus account holders, and of the responses to these efforts.
 (g)  If the distribution to an omnibus account holder is less than the
payments to beneficial owners calculated in accordance with the specifications
supplied by the IDC (due to netting at the omnibus account level), the amounts to
be distributed to beneficial owners will be proportionally reduced.
 (h)  Distributions with respect to omnibus accounts shall be
completed within 180 days after receipt by the omnibus account holder of funds
from this Plan (or, within 180 days after receipt by the IDC of the information
specified in subparagraph (c)(i), if applicable), unless the account holder
demonstrates to the satisfaction of the IDC that good cause exists to extend that
deadline.  Omnibus account holders seeking to alter the procedures specified in
this paragraph 7.6 may apply to the Fund Administrator for permission for such
alteration within 90 days of receiving notice of the proposed distribution from the
Fund Administrator, and the IDC will rule on such applications within 60 days
after their submission to the Fund Administrator.  The IDC may grant such
applications if the requested alteration would not materially affect the distribution
of funds to the contemporaneous beneficial owners.  Paragraph 7.9 of this Plan
shall apply to distributions made by omnibus account holders to beneficial
owners, and the amount of undeliverable or unclaimed payments shall be
returned to the Fund Administrator promptly after conclusion of the six month
period specified in paragraph 7.9.

 7.7.   (a)  Retirement Plans.  Plan administrators of retirement
accounts shall be required to distribute the monies received under this Plan in
accordance with their fiduciary and contractual obligations, and consistent with
guidance issued by the Department of Labor, if any.  "Retirement accounts" as
used in the Plan means any account of an employee benefit plan, as such plans
are defined in section 3(3) of ERISA, which is not an Individual Retirement
Account, whether or not the plan is subject to Title I of ERISA.
9
  Plan
administrators of retirement accounts may distribute the monies received under
this Plan to plan participants in accordance with such participants’ account
balances during the period to which the distribution in question relates, using
balance information on a daily, monthly, quarterly or yearly basis.
                            (b)                            Network Level Accounts.  Networking firms associated with
network level accounts (i.e., an account that represents one underlying owner but
for which name, address and other necessary identifying information may be
maintained by an intermediary
) shall distribute the monies received under this
Plan to the underlying owners of such accounts, and will be asked to elect, within
45 days after notice of the proposed distribution, one of the following two options
for completing such distributions:  (i) supplying to the IDC the information
necessary for the IDC to distribute funds to the underlying owners, or (ii)

9
 Distributions with respect to Individual Retirement Accounts are governed by Part VII(A) of this
Plan.

12

distributing the funds themselves, using specifications supplied by or on behalf of
the IDC as necessary to determine the appropriate allocation of the funds among
contemporaneous underlying owners.  In either option, Respondents will
reimburse the networking firm for the reasonable out of pocket costs of gathering
and supplying the information necessary to distribute funds to the underlying
owners of the network level account.  The networking firm may elect more than
one of these options and apply them differently in respect of different categories
of underlying owners (such as open accounts and closed accounts).
  If the
networking firm makes no election within the time specified in this subparagraph,
it will be deemed to have elected to proceed under subparagraph (i) of this
paragraph.
 Distributions with respect to network level accounts shall be
completed within 180 days after receipt by the networking firm of funds from this
Plan (or within 180 days after receipt by the IDC of the information specified in
subparagraph (i), if applicable).  Paragraph 7.9 of this Plan shall apply to
distributions made by networking firms to underlying owners of network level
accounts, and the amount of undeliverable or unclaimed payments shall be
returned to the Fund Administrator promptly after the conclusion of the six month
period specified in paragraph 7.9.

C.  Holdback.

7.8.  The holdback described in paragraph 6.2 above will be applied first
toward any distributions necessary to respond to claims, if any, by shareholders
in the Participating Funds for distributions in addition to those contemplated
under this Plan.  To the extent that there are funds remaining after all such
claims have been resolved, that remainder should be paid to holders of any of
the other Participating Funds to whom no distribution has been made, again in
descending order of estimated dilution as a percentage of average fund assets.
Finally, any additional funds remaining shall be distributed in a manner consistent
with the plan as approved, as determined by the IDC on notice to Respondents,
the Independent Trustees of the Columbia Funds, and the SEC.

D.  Unclaimed Distributions.

7.9.  In situations in which distributions are unclaimed (checks not
cashed), or persons to whom a distribution would otherwise be made cannot be
identified or located, the distributable amounts should be added to the amount
held back pursuant to paragraph 6.2 above.  All distributions should be on terms
providing that checks not cashed within six months after distribution shall be void,
and the issuing financial institution shall be instructed to stop payment on those
checks or otherwise assure that payment on such checks is prevented.

 E.  Fund Administrator and Tax Administrator.

7.10.  Rust Consulting, Inc. (“Rust”), if approved by the Commission, will
serve as the administrator of the Fair Fund (“Fund Administrator”) and will be

13

compensated by the Respondents.  Appendix A to this Plan provides additional
information about the Fund Administrator.  The IDC requests that the
Commission waive, for good cause shown (specifically, the facts set forth in
Appendix A), the requirement that a bond be posted pursuant to Rule 1105(c) of
the Commission’s Rules on Fair Fund and Disgorgement Plans.  Under the
supervision of the IDC, Rust will be responsible for, among other things:
overseeing the administration of the Fair Fund, obtaining accurate mailing
information for shareholders, preparing accountings, cooperating with the Tax
Administrator in providing the information necessary to accomplish the income
tax compliance, distributing money from the Fair Fund to shareholders in
accordance with and subject to approval of this Plan, and setting up and staffing
a call center to address shareholder questions or concerns regarding the
distribution.  The Fund Administrator will provide customer support and
communications programs which will become active at least by the time the first
distribution occurs.  These services will include a toll free number and a website
accessible to the public.  The Commission retains the right to review and approve
any material posted on the website.  While the distribution is being implemented,
the Fund Administrator will submit to the IDC and the staff of the Commission an
accounting during the first ten days of each calendar quarter, and will submit a
final accounting for approval of the Commission before termination of the Fair
Fund and discharge of the Fund Administrator.  The IDC and Rust currently have
an agreement in place requiring Rust to perform certain tasks in preparation for
the forthcoming distribution of the Fair Fund.  To date, Rust has successfully met
its obligations under the agreement and the IDC believes that Rust will perform
satisfactorily as the Fund Administrator.

7.11.  The Commission has appointed Damasco & Associates as the Tax
Administrator (“Tax Administrator”) of the Fund (Order Directing Appointment Of
Tax Administrator, in the Matter of Certain Disgorgement and Fair Funds in
Administrative Proceedings, Exchange Act Rel. No. 51341, March 9, 2005).  The
IDC, Fund Administrator and Respondents will cooperate with the Tax
Administrator in providing information necessary to accomplish the income tax
compliance, ruling and advice work assigned to the Tax Administrator by the
Commission.  The Tax Administrator shall be compensated by the Respondents.

 F.  Payment of Distributions.

7.12.  In order to distribute funds, and promptly after the necessary
information becomes available, the IDC will submit a validated list of payees and
the payment amounts to the assigned Commission staff.  The staff shall obtain
authorization from the Commission to disburse funds pursuant to Rule
1101(b)(6), upon staff receipt and acceptance of a validated payment file or list.
It is anticipated that the entire distribution may not be validated at one time.  As
and when additional payee distribution information becomes available, the IDC
will submit additional validated lists of payees and payment amounts for
distribution as authorized.  In each instance, the payees and amounts will be

14

validated at the IDC’s direction by Rust.  The validation will state that the list was
compiled in accordance with the Plan and provides all information necessary to
make disbursement to each distributee.  Unless otherwise directed by the
Commission, the Commission staff will direct the release of funds to the bank
account established by the Fund Administrator based upon the validated list and
representation by the Fund Administrator that the checks will be issued the next
business day.

 7.13.  All payments shall be preceded or accompanied by a
communication that includes, as appropriate:  (a) a statement characterizing the
distribution; (b) a description of the tax information reporting and other related tax
matters; (c) a statement that checks will be void after 180 days; and (d) the name
of a person to contact, to be used in the event of any questions regarding the
distribution.  Any such information letter or other mailing to recipients
characterizing their distribution shall be submitted to the assigned Commission
staff for review and approval.  Distribution checks, on their face, or in the
accompanying mailing will clearly indicate that the money is being distributed
from an SEC Fair Fund.

              7.14.  In implementing the distribution under this Plan, the Fund
Administrator will prepare a “positive pay file” for clearing checks at a bank (the
“Escrow Bank”), and will provide that file to the Escrow Bank separately from the
physical checks themselves.  The Escrow Bank will be instructed to clear only
checks matching entries in the positive pay file and for the amount in the file.
When checks are printed, a reconciliation report will be provided which lists the
total number of checks and sequenced numbers printed.  These totals will be
compared to the total records from the payment file to confirm all checks were
printed.  Printed checks will be kept in a secured area until they are mailed and
will generally be printed just in time for mailing.  Only authorized individuals will
be allowed access to the check area for printing and performing quality control
procedures.  Processing of the mailing of checks will be subject to appropriate
security procedures.  For wires, the Fund Administrator will provide the Escrow
Bank with wire transfer instructions signed by both the IDC and an authorized
representative of the Fund Administrator. Wire instructions received by the
Escrow Bank will be reviewed by an administrative employee of the Escrow Bank
for content, required signatures and all necessary data. The administrative
employee will input the instructions into the Escrow Bank's computer system, and
an Officer of the Escrow Bank will compare the computer entries to the original
wire instructions before giving final approval on the transfer.

7.15.  If a check is returned as undeliverable, the Fund Administrator will
send the name, current address it has on file, and the tax identification number
for the individual/entity, to a company that has access to credit bureau header
type information.  That company will then search for the most current address
available through its proprietary databases, and will then return each record back
to the Fund Administrator.  If the returned file contains new addresses for records

15

where the company has a more current address, with a date that corresponds
with that address, the Fund Administrator will then update its database for
records with better addresses, with a code that notes that the new address was
obtained through a trace process and the date the new address was obtained.
This new address will then become the current address for that record in its
database.  The Fund Administrator will not overwrite or delete previous
addresses, which it will maintain in an address history with dates and codes that
identify when an address is used and why an address was updated.

7.16.  The IDC and the Fund Administrator shall use their best efforts to
assure that distribution of payments to investors shall be substantially completed
within 90 days following the later of the approval of the Plan by the Commission
or the date of receipt of a private letter ruling from the IRS (the “IRS Ruling”) on
the reporting of payments to investors under this Plan. Notwithstanding the
foregoing, in the event the IRS Ruling requires reporting of all or a portion of the
payments the IDC and the Fund Administrator shall use their best efforts to
assure that distribution of payments shall be substantially completed no later
than six months from the date of that ruling.  The Fair Fund shall terminate
effective upon the later of September 30, 2007 or 60 days after the final
distribution of funds to investors and the resolution of uncashed or unclaimed
funds and the payment or reserve for taxes and the final accounting by the Fund
Administrator has been submitted to and approved by the Commission.  Before
the termination of the Fair Fund, the IDC shall cooperate with the Tax
Administrator to make adequate reserves for tax liability and for the costs of tax
compliance.  Before termination as defined in this paragraph, all undistributed
assets remaining in the Fair Fund, minus any reserves for tax liability and tax
compliance costs, shall be remitted to the United States Treasury or to such
other person or entity as the Commission may direct.

 7.17.  (a)  The Fair Fund constitutes a Qualified Settlement Fund
(“QSF”) under Section 468B(g) of the Internal Revenue Code, 26 U.S.C.
§468B(g), and related regulations, 26 C.F.R. §§1.468B-1 through 1.468B-5.  The
Commission has custody of the Fair Fund and shall retain control of the assets of
the Fair Fund.  The Fair Fund is currently deposited at the U.S. Treasury Bureau
of Public Debt (“BPD”).  Upon approval of the Plan, the Fund Administrator shall
establish one or more accounts at the Escrow Bank (i.e., Deutsche Bank or such
other bank as shall be selected by the IDC and determined to be acceptable by
the staff of the Commission), in the name of and bearing the Taxpayer
Identification Number of the QSF.  Following approval of the Plan and
submission by the IDC of a list of payees and amounts to the Commission staff,
and to the extent necessary to fund payments as and when contemplated under
paragraph 7.12, and unless otherwise directed by the Commission, the
Commission staff shall cause the balance in the Fair Fund to be deposited in an
escrow account established by the Fund Administrator in the name of and
bearing the Taxpayer Identification Number of the Qualified Settlement Fund
(“QSF account”).  The Fund Administrator shall be the signer on the QSF

16

account, subject to the continuing jurisdiction and control of the Commission.
Funds deposited in the QSF account shall remain in that account until necessary
for distribution as provided in this Plan, at which point they shall be deposited in
one or more disbursement accounts established by the Fund Administrator at the
Escrow Bank.  The Fund Administrator shall authorize the Escrow Bank to
provide account information to the Tax Administrator.  The Fund Administrator
shall use the assets and earnings of the Fair Fund to provide payments to
Investors and to provide the Tax Administrator with assets to pay tax liabilities
and tax compliance fees and costs.  The QSF account shall be invested in direct
obligations of the United States Government of a type and term necessary to
meet the cash requirements of the payments to Investors, tax obligations and
fees.

 (b) The IDC and the Fund Administrator, and/or each of their designees,
agents and assistants, shall be entitled to rely on any Orders issued in this
proceeding by the Commission, the Secretary by delegated authority, or an
Administrative Law Judge, and may not be held liable to any current or
contemporaneous shareholder of any of the Columbia Funds, or any of their
successor funds, for any act or omission in the course of administering the Fair
Fund, except upon a finding that such act or omission is caused by such party's
gross negligence, bad faith or willful misconduct, reckless disregard of duty, or
reckless failure to comply with the terms of the Plan.  This subparagraph (b) is an
expression of the current state of the law and is not intended, nor should it be
deemed to be, a representation to or an indemnification of the IDC or the Fund
Administrator or their designees, agents and assistants, nor should this
subparagraph (b) preclude the Commission or the QSF from seeking redress for
any act or omission in the course of administering the Fair Fund or from seeking
redress from any insurance or bond provided as set forth in this Plan.

7.18.  The Respondents will pay all fees and costs associated with the
administration of the Distribution Plan, except for tax liabilities of the QSF, which
shall be paid in accordance with Rule 1105(e) of the Commission’s Rules on Fair
Fund and Disgorgement Plans.

G. Amendment, Termination and Notices.

7.19.  The IDC will inform the Commission staff of any material changes in
the Plan, and will obtain approval from the Commission prior to their
implementation.  If material changes are required, this Plan may be amended
upon the motion of the Respondents, the Fund Administrator or upon the
Commission’s own motion.  Under this Distribution Plan the IDC has discretion,
again in consultation with the Respondents and the Commission’s staff, to make
supplemental specifications to the Plan of Distribution after its approval that are
not materially inconsistent with the Plan as approved.  There have been
substantial regulatory settlements with several entities (such as CIBC, Calugar
and Bear Stearns) which engaged in or facilitated market timing or late trading in

17

one or more of the Columbia Funds.  The IDC under this Distribution Plan will
attempt to coordinate with the IDCs supervising the plans of distribution for those
settlements, for the purpose of facilitating distribution to holders of Columbia
Funds affected by the pertinent trading.

7.20.  Notices to be given under the terms of this Plan (other than under
paragraph 7.21) shall be given in writing to:

The IDC, to the following address:

 Prof. Lawrence A. Hamermesh
 Widener University School of Law
 4601 Concord Pike
 Wilmington, Delaware 19803
                      --           or           –
 [email protected]

The Commission, to the following addresses:

 Office of Financial Management
 Securities and Exchange Commission
              Operations              Center
 6432 General Green Way Stop 0-3
 Alexandria, VA 22312

 With a copy to:

 David P. Bergers
              District              Administrator
 Boston District Office
 Securities and Exchange Commission
 33 Arch Street
 Boston, MA  02110-1424

H. Notice of the Plan

7.21.  Notice of this Distribution Plan will be published in the SEC Docket,
on the Commission web site, and on the Respondents’ web site.  Any person or
entity wishing to comment on the Plan must do so in writing by submitting their
comments, within thirty days of the date of the Notice:

1.  to the Office of the Secretary, United States Securities and Exchange
Commission, 100 F Street, N.E., Washington, D.C. 20549-1090;
2.  by using the Commission’s Internet comment form
(www.sec.gov/litigation/admin.shtml); or
3.  by sending an e-mail to [email protected].

18

Such comments should include the Administrative Proceeding File Number
(Admin. Proc. File No. 3-11814) in the subject line.  Comments received will be
publicly available.  Persons should submit only information that they wish to
make publicly available.  This Distribution Plan is subject to approval by the
Commission and the Commission retains jurisdiction over the implementation of
the Plan.

Submitted on:  January 29, 2007   By: ____________________________
Lawrence A. Hamermesh,
Independent Distribution
Consultant for the Columbia Fair
Fund

19

Appendix A

The Fund Administrator

The Fund Administrator has provided information regarding the Fund Administrator and
its procedures to the IDC for inclusion in this Appendix.
1.  Custody / Risk Protection

The  Plan  provides  that  money  from  the  Qualified  Settlement  Fund,  which  is
currently  being  held  in  the  U.S.  Treasury  Bureau  of  Public  Debt  (“BPD”),  would  be
transferred  to  one  or  more  escrow  accounts  to  be  established  by  the  Qualified
Settlement Fund at the Escrow Bank, no more than two business days prior to the date
on  which  checks  would  be  mailed  to  shareholders,  and  that  on  behalf  of  the  Qualified
Settlement Fund, Rust Consulting, Inc (“Fund Administrator”) would manage the printing
and  mailing  of  checks  that  would  be  drawn  on  those  escrow  accounts,  subject  to
procedures described below to protect against misappropriation.

The distribution of the Qualified Settlement Fund will take place in multiple steps,
rather than all at once.  The monies will be transferred from the BPD to the Escrow
Bank two business days before each of those steps, thus minimizing the amount of time
that the monies are held pending actual distribution to shareholders.  The Fund
Administrator contemplates that the steps in the distribution of the Qualified Settlement
Fund will include:

•    Distribution of checks to contemporaneous Columbia Funds retail holders and
other direct record owners (“direct accounts”) in successive mailings, beginning
with reliable/clear addresses.
•    Distributions to Omnibus Accounts.  Monies will not be transferred from the
Qualified Settlement Fund to the Escrow Bank until the Omnibus Account is
prepared to complete the distribution of any payment they receive under the Plan
to its Beneficial Shareholders.

As a result, much less than the full amount of the Qualified Settlement Fund will ever be
in the control of the Escrow Bank and/or the Fund Administrator at any given time.
  Once  the  Fund  Administrator  has  completed  calculations  for  the  account  holder
distribution  accounts,  the  IDC  will  take  steps  sufficient  to  satisfy  the  IDC  as  to  the
accuracy of the Fund Administrator’s calculations, including reference to determinations
by   Lexecon   as   to   whether   its   own   calculations   agree   with   those   of   the   Fund
Administrator.    Once  the  IDC  is  satisfied  with  the  accuracy  of  the  calculations,  those
calculations will be the basis on which the positive pay file described in paragraph 7.14
of the Plan and ultimately used to control the distribution is generated.

 The cost of obtaining a bond under the circumstances of this proceeding, in lieu
of the protections described in this Appendix and in the Plan itself, would be prohibitive,
even if such a bond could be obtained at all.
2.  Custody  Procedures

The Fund Administrator specializes in claims administration and the development
and implementation of plans for the distribution of settlement funds, and has
administered more than 500 cases worth billions of dollars with class sizes ranging from
80 class members to more than 100 million.  The Fund Administrator has been in
existence since 1976 and has never had any occurrence of employee or vendor
problems or claims against its Errors & Omissions insurance due to employee theft or
dishonesty.  Over the past three years alone, the Fund Administrator has distributed
approximately $1.8 billion in settlement disbursements to approximately 9.6 million
recipients without incident. The Fund Administrator typically oversees the check printing
process and relies on a third-party check-printing vendor.

The Fund Administrator’s databases are configured so that modifications can
only be made to data through programs; individuals are not allowed direct access to
underlying production databases.  Only designated individuals with security clearances
at the Fund Administrator can access data used in completing the distribution.  If an
individual has security clearance to make changes in data (e.g., to update an address
through an on-line screen), all original data (e.g., the original address) is automatically
maintained by the Fund Administrator’s systems, and the system records the identity of
the individual who made the change.  Individuals cannot alter award amounts. Duties
are segregated: award calculations are separate from the preparation of checks, which
is in turn separate from submission of files to a bank, so that no individual or working
team could affect more than one of these processes.

3.  Additional  Risk  Protection

  The  Escrow  Bank,  which  will  hold  Plan  assets  during  the  check-cashing  period,
maintains  a  Financial  Institutions  (FI)  Bond  including  errors  and  omissions  coverage
with an aggregate limit of 200 MM Euro.  The primary insurer is American International
Group, which, as of its most recent renewal, was rated A+ by A.M. Best.  The Escrow
Bank has 200 MM Euro of E&O insurance.  In addition, the Escrow Bank has a bankers
blanket bond of 250 MM Euro from Chubb (which is rated A++ by A.M. Best), which the
Escrow  Bank  has  advised  the  IDC  includes  coverage  for  wrongful  acts  (i.e.,  an  act,
errors and omissions, misstatement, etc.) or failure to safeguard proprietary information
in connection with rendering of professional services.  The Fund Administrator has $10
million  in  E&O  insurance,  as  well  as  $2  million  fiduciary  insurance.  The  Escrow  Bank
annually  assesses  the  adequacy  of  its  policy  limits  through  extensive  analysis  of
historical loss data, exposure to loss and internal company controls.
The Fund Administrator maintains and will continue to maintain until termination
of Plan, an errors and omissions insurance policy.  The primary insurer, Illinois Union
Insurance Co, is a company which, as of its most recent renewal, was rated A+ by A.M.

Best.  The policy is in the amount of $10 million per occurrence.  The Fund
Administrator also maintains, and will continue to maintain until termination of Plan, a
fiduciary insurance policy. The primary insurer, St. Paul Companies, is a company
which, as of its most recent renewal, was rated A+ by A.M. Best.  The policy is in the
amount of $2 million per occurrence.  The Fund Administrator’s print vendor maintains
and will continue to maintain until termination of Plan, an errors and omissions
insurance policy.  The primary insurer, Illinois Union Insurance Co (ACE USA), is a
company which, as of its most recent renewal, was rated A+ by A.M. Best.  The policy is
in the amount of $25 million per occurrence.  Under the Plan of Distribution, at no time
will there be funds under the custody and control of the Fund Administrator that exceed
the amount covered by insurance.  Certificates of insurance for these policies have
been provided to the assigned SEC staff for review and have been deemed “not
unacceptable.”

Definitions
 “Escrow Bank” means Deutsche Bank or such other bank as shall be selected by the
IDC and determined to be acceptable by the staff of the Commission
“Rust” mean Rust Consulting, Inc., experts in the development and implementation of
plans for the distribution of settlement funds.
“Fund Administrator” means Rust or such other entity as shall be acceptable to the staff
of the Commission.
“Omnibus Account” means an account registered in the name of a broker-dealer or
other financial intermediary which holds shares as the record owner for the benefit of
more than one beneficial shareholder.

Table 1
Participating Funds
(Amounts in $ Millions)
06/28/06
Dilution (Present Value of Hybrid Model)
Present Value of
Estimated
Transaction Costs
                                                           Fund
Fund                                                           Assets
Assets
Trading
Accounts
Accounts
Total
Trading
Accounts
Trading
Fees
Fees
Average
Average Fund
Arrangement
Retail
Omnibus
Arrangement
Other
Arrangement
Costs and
Costs and
Percent of
W/
Transaction
Transactions
Dilution As
Accounts
Dilution,
Dilution,
To
Total
Cumulative
Allocated
Value of
Fees
Present
Management
Net

Funds With Arrangement Trading
1
SR INTERNATIONAL FUND
7.37
169.46
2.04
6.52
3.93
12.49
0.12
0.48
0.03
13.12
13.1
2
COLUMBIA NEWPORT TIGER FUND
6.08
620.98
16.29
5.61
15.87
37.77
0.58
0.77
0.23
39.35
52.5
3
LIBERTY NEWPORT INTL EQUITY FUND
4.91
170.40
2.06
5.86
0.44
8.36
0.11
0.38
0.02
8.87
61.3
4
COLUMBIA INTERNATIONAL EQUITY FUND
3.29
606.48
0.77
13.11
6.05
19.93
0.05
0.88
0.00
20.86
82.2
5
COLUMBIA ACORN INTL SELECT FUND
2.53
61.88
0.29
0.51
0.76
1.57
0.01
0.07
0.01
1.66
83.9
6
COLUMBIA GLOBAL EQUITY FUND
2.10
164.40
0.02
3.43
0.00
3.45
0.00
0.21
0.00
3.66
87.5
7
COLUMBIA ACORN INTERNATIONAL FUND
0.65
1,778.25
2.52
2.31
6.81
11.64
0.16
0.43
0.04
12.27
99.8
8
COLUMBIA SMALL CAP VALUE FUND
0.40
421.02
0.14
1.56
-0.01
1.69
0.11
0.37
0.00
2.17
102.0
9
COLUMBIA GROWTH STOCK FUND
0.39
715.44
2.57
0.02
0.18
2.76
0.37
0.11
0.04
3.28
105.2
10
COLUMBIA YOUNG INVESTOR FUND
0.28
948.86
2.07
0.76
-0.19
2.64
0.51
0.16
0.05
3.36
108.6
11
LIBERTY GROWTH STOCK FUND
0.22
693.36
1.47
0.22
-0.15
1.53
0.11
0.01
0.06
1.71
110.3
Funds Without Arrangement Trading
12
WANGER FOREIGN FORTY
3.39
14.65
0.50
0.50
0.04
0.54
110.8
13
WANGER INTERNATIONAL SMALL CAP FUND
2.43
254.93
6.18
6.18
0.40
6.58
117.4
14
COLUMBIA SMALL COMPANY EQUITY FUND
2.17
411.48
8.23
0.69
8.93
1.62
10.55
128.0
15
COLUMBIA NEWPORT JAPAN OPPS FUND
1.99
40.07
0.21
0.58
0.80
0.04
0.84
128.8
16
1784 INTERNATIONAL EQUITY
1.39
484.80
0.61
6.15
6.76
0.31
7.07
135.9
17
SR CAPITAL OPPORTUNITIES FUND
1.13
390.20
4.22
0.20
4.42
0.62
5.04
140.9
18
1784 GROWTH
0.78
146.43
0.98
0.17
1.15
0.15
1.30
142.2
19
COLUMBIA INTERNATIONAL STOCK FUND
0.65
224.20
0.43
1.02
1.46
0.07
1.53
143.8
20
COLUMBIA NEWPORT GREATER CHINA FUND
0.46
54.26
0.11
0.14
0.25
0.02
0.27
144.0

Table 2
Dilution of Columbia Funds By Descending Dilution As Percent of Fund Assets
(Amounts in $ Millions)
Page 1
06/28/06
Dilution (Present Value of Hybrid Model)
Present Value of
Estimated
Transaction Costs
                                                             Fund
Fund                                                             Assets
Assets
Trading
Accounts
Accounts
Total
Trading
Accounts
Trading
Fees
Fees
Average
Average Fund
Arrangement
Retail
Omnibus
Arrangement
Other
Arrangement
Costs and
Costs and
Percent of
W/
Transaction
Transactions
Dilution As
Accounts
Dilution,
Dilution,
To
Total
Cumulative
Allocated
Value of
Fees
Present
Management
Net

1
SR INTERNATIONAL FUND
7.37
169.46
2.04
6.52
3.93
12.49
0.12
0.48
0.03
13.12
13.12
2
COLUMBIA NEWPORT TIGER FUND
6.08
620.98
16.29
5.61
15.87
37.77
0.58
0.77
0.23
39.35
52.47
3
LIBERTY NEWPORT INTL EQUITY FUND
4.91
170.40
2.06
5.86
0.44
8.36
0.11
0.38
0.02
8.87
61.33
4
WANGER FOREIGN FORTY
3.39
14.65
0.50
0.50
0.04
0.54
61.87
5
COLUMBIA INTERNATIONAL EQUITY FUND
3.29
606.48
0.77
13.11
6.05
19.93
0.05
0.88
0.00
20.86
82.74
6
COLUMBIA ACORN INTL SELECT FUND
2.53
61.88
0.29
0.51
0.76
1.57
0.01
0.07
0.01
1.66
84.39
7
WANGER INTERNATIONAL SMALL CAP FUND
2.43
254.93
6.18
6.18
0.40
6.58
90.97
8
COLUMBIA SMALL COMPANY EQUITY FUND
2.17
411.48
8.23
0.69
8.93
1.62
10.55
101.52
9
COLUMBIA GLOBAL EQUITY FUND
2.10
164.40
0.02
3.43
0.00
3.45
0.00
0.21
0.00
3.66
105.18
10
COLUMBIA NEWPORT JAPAN OPPS FUND
1.99
40.07
0.21
0.58
0.80
0.04
0.84
106.02
11
1784 INTERNATIONAL EQUITY
1.39
484.80
0.61
6.15
6.76
0.31
7.07
113.09
12
SR CAPITAL OPPORTUNITIES FUND
1.13
390.20
4.22
0.20
4.42
0.62
5.04
118.13
13
COLUMBIA EUROPE FUND
1.01
6.85
0.05
0.02
0.07
0.00
0.07
118.20
14
1784 GROWTH
0.78
146.43
0.98
0.17
1.15
0.15
1.30
119.50
15
COLUMBIA ACORN INTERNATIONAL FUND
0.65
1,778.25
2.52
2.31
6.81
11.64
0.16
0.43
0.04
12.27
131.78
16
COLUMBIA INTERNATIONAL STOCK FUND
0.65
224.20
0.43
1.02
1.46
0.07
1.53
133.30
17
COLUMBIA NEWPORT GREATER CHINA FUND
0.46
54.26
0.11
0.14
0.25
0.02
0.27
133.57
18
COLUMBIA SMALL CAP VALUE FUND
0.40
421.02
0.14
1.56
-0.01
1.69
0.11
0.37
0.00
2.17
135.74
19
COLUMBIA GROWTH STOCK FUND
0.39
715.44
2.57
0.02
0.18
2.76
0.37
0.11
0.04
3.28
139.02
20
SR SMALL COMPANY GROWTH FUND
0.34
21.00
0.08
-0.01
0.07
0.01
0.08
139.10
21
COLUMBIA NEWPORT ASIA PACIFIC FUND
0.29
12.94
0.00
0.03
0.01
0.04
0.00
0.00
0.04
139.14
22
COLUMBIA YOUNG INVESTOR FUND
0.28
948.86
2.07
0.76
-0.19
2.64
0.51
0.16
0.05
3.36
142.50
23
LIBERTY GROWTH STOCK FUND
0.22
693.36
1.47
0.22
-0.15
1.53
0.11
0.01
0.06
1.71
144.21
24
COLUMBIA SMALL COMPANY INDEX FUND
0.13
266.70
0.35
0.01
0.36
0.05
0.41
144.62
25
COLUMBIA LARGE CAP GROWTH FUND
0.09
1,384.32
0.95
0.25
1.19
0.18
1.37
146.00
26
COLUMBIA PA INTERM MUNI BOND FUND
0.07
26.73
0.02
0.02
0.00
0.02
146.02
27
COLUMBIA MID CAP VALUE FUND
0.07
1,123.54
0.13
0.58
0.05
0.77
0.01
0.12
0.00
0.90
146.92
28
GALAXY UTILITY INDEX FUND
0.06
58.80
0.03
0.03
0.00
0.03
146.96
29
LIBERTY CONTRARIAN EQUITY FUND
0.04
97.45
0.04
0.00
0.04
0.01
0.05
147.01
30
COLUMBIA LARGE COMPANY INDEX FUND
0.04
867.06
-0.11
0.02
0.43
0.35
0.01
0.17
0.53
147.54
31
COLUMBIA TAX EXEMPT FUND
0.04
2,070.24
0.09
0.67
0.01
0.76
0.05
0.21
0.01
1.03
148.57
32
COLUMBIA MANAGED MUNICIPALS FUND
0.04
465.40
0.08
0.08
0.17
0.05
0.22
148.78
33
SR DISCIPLINED STOCK FUND
0.03
513.50
0.14
0.04
0.18
0.00
0.18
148.96
34
COLUMBIA DISCIPLINED VALUE FUND
0.03
417.36
0.07
0.08
0.14
0.01
0.15
149.12
35
COLUMBIA GROWTH & INCOME FUND
0.03
1,643.16
0.03
0.32
0.10
0.46
0.03
0.01
0.50
149.61
36
GALAXY CONNECTICUT MUNI BOND FUND
0.02
37.20
0.00
0.01
0.01
0.00
0.01
149.62
37
COLUMBIA OREGON MUNICIPAL BOND FUND
0.02
484.20
0.06
0.01
0.07
0.03
0.10
149.72

Table 2
Dilution of Columbia Funds By Descending Dilution As Percent of Fund Assets
(Amounts in $ Millions)
Page 2
06/28/06
Dilution (Present Value of Hybrid Model)
Present Value of
Estimated
Transaction Costs
                                                             Fund
Fund                                                             Assets
Assets
Trading
Accounts
Accounts
Total
Trading
Accounts
Trading
Fees
Fees
Average
Average Fund
Arrangement
Retail
Omnibus
Arrangement
Other
Arrangement
Costs and
Costs and
Percent of
W/
Transaction
Transactions
Dilution As
Accounts
Dilution,
Dilution,
To
Total
Cumulative
Allocated
Value of
Fees
Present
Management
Net
     38
SR BALANCED FUND
0.01
215.47
0.04
-0.01
0.03
0.01
0.04
149.76
39
COLUMBIA BALANCED FUND
0.01
875.12
0.00
0.10
0.10
0.09
0.19
149.95
40
COLUMBIA INTERM GOVERNMENT INCOME FD
0.01
468.44
0.05
0.01
0.05
0.00
0.05
150.01
41
SR GROWTH AND INCOME FUND
0.01
345.00
0.00
0.03
0.03
0.07
0.10
150.10
42
COLUMBIA HIGH YIELD OPPORTUNITY FUND
0.01
880.38
0.07
0.00
0.08
0.01
0.09
150.19
43
SR INTERMEDIATE MUNICIPALS FUND
0.01
145.07
0.01
0.00
0.01
0.00
0.01
150.21
44
COLUMBIA HIGH YIELD MUNICIPAL FUND
0.01
277.80
0.00
0.02
0.02
0.00
0.02
150.23
45
COLUMBIA LARGE CAP CORE FUND
0.01
661.86
0.06
-0.01
0.04
0.00
0.04
150.28
46
GALAXY TAX EXEMPT BOND FUND
0.00
193.77
0.01
0.00
0.01
0.01
0.02
150.29
47
COLUMBIA SHORT TERM BOND FUND
0.00
199.30
-0.02
0.02
0.00
0.01
0.00
0.00
0.01
150.29
48
COLUMBIA FLORIDA INTERM MUNI BOND FD
0.00
70.48
0.00
0.00
0.00
0.00
0.00
150.30
49
COLUMBIA NY INTERM MUNI BOND FUND
0.00
101.08
0.00
0.00
0.00
0.00
0.00
150.30
50
COLUMBIA MA INTERM MUNI BOND FUND
0.00
280.93
0.01
0.00
0.01
0.01
0.02
150.31
51
1784 US GOVT MED TERM INCOME
0.00
259.60
0.00
0.00
0.00
0.00
0.00
150.32
52
COLUMBIA TAX EXEMPT INSURED FUND
0.00
176.68
0.00
0.00
0.00
0.00
0.00
150.32
53
CMG HIGH YIELD FUND
0.00
359.98
0.00
0.00
0.00
0.00
0.00
150.32
54
COLUMBIA UTILITIES FUND
0.00
814.04
0.00
0.00
0.00
0.00
150.32
55
COLUMBIA ASSET ALLOCATION FUND
0.00
460.50
0.00
0.00
0.00
0.07
0.07
150.40
56
COLUMBIA INTERM TAX EXEMPT BOND FUND
0.00
339.12
-0.01
0.01
0.00
0.00
0.00
0.00
0.00
150.40
57
COLUMBIA US TREASURY INDEX FUND
0.00
173.18
0.00
0.00
0.00
0.00
0.00
150.40
58
CMG STRATEGIC EQUITY FUND
291.50
-0.02
0.00
-0.02
0.00
-0.02
150.40
59
COLUMBIA ACORN FUND
6,387.70
-0.11
-2.20
-2.31
0.01
-2.30
150.41
60
COLUMBIA ACORN SELECT FUND
266.05
0.00
-0.01
-0.01
0.00
-0.01
150.41
61
COLUMBIA ACORN USA FUND
383.33
0.00
-0.13
-0.13
0.01
-0.12
150.43
62
COLUMBIA CALIFORNIA TAX EXEMPT FUND
289.50
0.00
0.00
0.00
0.00
0.00
150.43
63
COLUMBIA COMMON STOCK FUND
654.24
-0.03
-0.35
-0.38
0.05
-0.33
150.48
64
COLUMBIA CONNECTICUT TAX EXEMPT FUND
184.07
0.00
0.00
0.00
0.00
0.00
150.48
65
COLUMBIA CONTRARIAN INCOME FUND
30.28
-0.01
0.00
-0.01
0.00
-0.01
150.48
66
COLUMBIA CORPORATE BOND FUND
134.96
0.00
0.00
0.00
0.00
0.00
150.48
67
COLUMBIA CT INTERM MUNI BOND FUND
149.98
0.00
0.00
0.00
0.00
150.48
68
COLUMBIA EUROPEAN THEMATIC EQUITY FD
-0.01
-0.01
0.00
-0.01
150.48
69
COLUMBIA FEDERAL SECURITIES FUND
903.05
-0.01
-0.01
-0.02
0.00
-0.02
150.49
70
COLUMBIA FIXED INCOME SECURITIES FD
459.28
-0.13
-0.07
-0.20
0.05
-0.15
150.54
71
COLUMBIA FLOATING RATE ADVANTAGE FD
243.33
0.00
0.00
0.00
0.00
0.00
150.54
72
COLUMBIA FLOATING RATE FUND
467.42
0.00
-0.01
-0.01
0.00
0.00
-0.01
150.54
73
COLUMBIA GROWTH FUND
1,387.42
-0.06
-0.29
-0.35
0.07
-0.28
150.61
74
COLUMBIA HIGH YIELD FUND
588.02
0.04
-0.15
-0.16
-0.26
0.00
0.10
-0.16
150.71

Table 2
Dilution of Columbia Funds By Descending Dilution As Percent of Fund Assets
(Amounts in $ Millions)
Page 3
06/28/06
Dilution (Present Value of Hybrid Model)
Present Value of
Estimated
Transaction Costs
                                                             Fund
Fund                                                             Assets
Assets
Trading
Accounts
Accounts
Total
Trading
Accounts
Trading
Fees
Fees
Average
Average Fund
Arrangement
Retail
Omnibus
Arrangement
Other
Arrangement
Costs and
Costs and
Percent of
W/
Transaction
Transactions
Dilution As
Accounts
Dilution,
Dilution,
To
Total
Cumulative
Allocated
Value of
Fees
Present
Management
Net
     75
COLUMBIA INCOME FUND
383.50
0.00
-0.14
-0.15
0.03
-0.12
150.73
76
COLUMBIA INTERMEDIATE BOND FUND
894.20
-0.07
-0.15
-0.22
0.09
-0.13
150.82
77
COLUMBIA LIBERTY FUND
1,198.36
-0.03
0.00
-0.03
0.00
-0.03
150.82
78
COLUMBIA MA TAX EXEMPT FUND
211.90
-0.01
0.00
0.00
-0.01
0.00
0.00
-0.01
150.82
79
COLUMBIA MID CAP GROWTH FUND
857.54
-0.15
-1.19
-1.35
0.52
-0.83
151.34
80
COLUMBIA NEW YORK TAX EXEMPT FUND
105.32
0.00
0.00
0.00
0.00
0.00
151.34
81
COLUMBIA NJ INTERM MUNI BOND FUND
89.10
0.00
0.00
0.00
0.00
0.00
151.34
82
COLUMBIA QUALITY PLUS BOND FUND
723.74
0.00
-0.04
-0.04
0.01
-0.03
151.36
83
COLUMBIA REAL ESTATE EQUITY FUND
592.44
-0.37
-0.97
-1.34
0.20
-1.14
151.55
84
COLUMBIA RI INTERM MUNI BOND FUND
148.80
0.00
0.00
0.00
0.00
0.00
151.55
85
COLUMBIA SMALL CAP FUND
760.64
-0.06
-0.07
-0.14
0.03
-0.11
151.58
86
COLUMBIA SMALL CAP GROWTH FUND
496.08
-0.18
-2.17
-2.35
0.14
-2.21
151.72
87
COLUMBIA STRATEGIC INCOME FUND
1,249.86
0.00
-0.02
-0.02
0.00
-0.02
151.72
88
COLUMBIA STRATEGIC INVESTOR FUND
324.00
-0.25
-0.23
-0.48
0.09
-0.39
151.81
89
COLUMBIA TAX MANAGED GROWTH FUND
464.42
0.00
0.00
0.00
0.00
0.00
151.81
90
COLUMBIA TAX MANAGED VALUE FUND
0.00
0.00
0.00
0.00
151.81
91
COLUMBIA TECHNOLOGY FUND
17.47
-0.02
0.00
-0.02
0.00
-0.02
151.81
92
GALAXY EQUITY INCOME FUND
298.13
0.00
0.00
0.00
0.00
0.00
151.81
93
GALAXY GROWTH AND INCOME FUND
0.02
0.00
0.02
0.00
0.02
151.83
94
GALAXY LARGE CAP GROWTH FUND
172.30
-0.04
-0.04
0.00
-0.04
151.83
95
GALAXY LARGE CAP VALUE FUND
172.50
-0.19
-0.19
0.03
-0.16
151.86
96
GALAXY MUNICIPAL BOND FUND
0.00
0.00
0.00
0.00
151.86
97
GALAXY SHORT TERM BOND FUND
102.60
0.00
0.00
0.00
0.00
0.00
151.87
98
GALAXY VIP ASSET ALLOCATION
0.00
0.00
0.00
0.00
151.87
99
GALAXY VIP EQUITY
-0.01
-0.01
0.00
-0.01
151.87
100
LIBERTY ALL STAR EQUITY FUND
-0.06
-0.06
0.01
-0.05
151.88
101
LIBERTY CONTRARIAN BALANCED FUND
0.00
0.00
0.00
0.00
151.88
102
LIBERTY CONTRARIAN SMALL CAP FUND
41.35
-0.11
-0.03
-0.14
0.00
-0.14
151.88
103
LIBERTY COUNSELOR BALANCED PORTFOLIO
0.00
0.00
0.00
0.00
151.88
104
LIBERTY COUNSELOR GROWTH PORTFOLIO
0.00
0.00
0.00
0.00
151.88
105
LIBERTY EQUITY FUND VS
0.01
0.01
0.00
0.01
151.89
106
LIBERTY FLORIDA TAX EXEMPT FUND
0.00
0.00
0.00
0.00
151.89
107
LIBERTY GROWTH INVESTOR FUND
0.00
0.00
0.00
0.00
151.89
108
LIBERTY HIGH YIELD MUNICIPAL FUND
153.73
-0.01
-0.01
0.00
-0.01
151.89
109
LIBERTY INTERMEDIATE GOVERNMENT FUND
884.58
0.01
-0.01
-0.01
-0.02
0.03
0.04
0.05
151.96
110
LIBERTY INTERMEDIATE TAX EXEMPT FUND
0.00
0.00
0.00
0.00
151.96
111
LIBERTY MIDCAP GROWTH FUND
-0.01
-0.01
0.00
-0.01
151.96

Table 2
Dilution of Columbia Funds By Descending Dilution As Percent of Fund Assets
(Amounts in $ Millions)
Page 4
06/28/06
Dilution (Present Value of Hybrid Model)
Present Value of
Estimated
Transaction Costs
                                                             Fund
Fund                                                             Assets
Assets
Trading
Accounts
Accounts
Total
Trading
Accounts
Trading
Fees
Fees
Average
Average Fund
Arrangement
Retail
Omnibus
Arrangement
Other
Arrangement
Costs and
Costs and
Percent of
W/
Transaction
Transactions
Dilution As
Accounts
Dilution,
Dilution,
To
Total
Cumulative
Allocated
Value of
Fees
Present
Management
Net
   112
LIBERTY NEWPORT TIGER CUB FUND
0.06
0.06
0.00
0.06
152.03
113
LIBERTY OHIO TAX EXEMPT FUND
0.00
0.00
0.00
0.00
152.03
114
LIBERTY REAL ESTATE FUND
0.00
0.00
0.00
0.00
0.00
152.03
115
LIBERTY SHORT TERM GOVERNMENT FUND
24.40
0.00
0.00
0.00
0.00
152.03
116
LIBERTY STRATEGIC BALANCED FUND
0.00
0.00
0.00
0.00
152.03
117
LIBERTY VALUE FUND
0.00
0.00
0.00
0.00
152.03
118
SR ADV HIGH YIELD MUNICIPALS BOND FD
0.00
0.00
0.00
0.00
152.03
119
SR ADVISOR INTERMEDIATE BOND FUND
0.00
0.00
0.00
0.00
152.03
120
SR FOCUS FUND
54.00
0.00
0.00
0.00
0.00
152.03
121
SR HIGH YIELD FUND
31.43
-0.06
-0.01
-0.07
0.01
-0.06
152.04
122
SR MIDCAP GROWTH FUND
41.80
-0.02
0.00
-0.02
0.02
0.00
152.07
123
WANGER TWENTY FUND
19.90
-0.03
-0.03
0.00
-0.03
152.07
124
WANGER US SMALLER COMPANIES FUND
436.93
-0.15
-0.15
0.10
-0.05
152.17
125
1784 ASSET ALLOCATION
0.01
0.00
0.01
0.00
0.01
152.19
126
1784 CT INT TAX EXEMPT INCOME
0.00
0.00
0.00
0.00
0.00
152.19
127
1784 GROWTH AND INCOME
559.00
-0.30
-0.01
-0.31
0.00
-0.31
152.19
128
1784 INCOME FUND
323.00
0.00
-0.05
-0.04
0.06
0.02
152.25
129
1784 MA INT TAX EXEMPT INCOME
245.60
0.00
0.00
0.00
0.00
0.00
152.25
130
1784 RI TAX EXEMPT INCOME
91.40
0.00
0.00
0.00
0.00
152.25
131
1784 SHORT TERM INCOME
144.90
0.00
0.00
0.00
0.00
152.25
Total For Funds With Positive Dilution
30.37
58.81
50.33
139.51
2.26
10.00
0.49
152.3
These calculations include only pairs with holding periods of 1 to 7 trading days for omnibus and retail accounts and1 to 21 trading days for episode accounts.For a given retail account / fund, calculations begin after the first two round-trips in a 90 days, or five round tripsin 365 days.  For omnibus accounts, calculations begin after the first five round trips in 90 days, or ten in 365 days.LIFO pairs for omnibus accounts were restricted to those purchased on the same date that an episode account or a retail accountmeeting the above screens also made a purchase in the same fund, with the exception that all omnibus trades were included afterColumbia imposed redemption fees on retail accounts for short-term trading of international funds.  For Wanger funds,trades were limited to those purchased on the same date as a retail or episode trade, subject to the screens above,in any other Columbia international fund.Fund asset data was obtained from Morningstar.Dilution attributable to timing through Banc of America Securities through Canary and the Introducing Brokers is excluded.
Note:

UNITED STATES OF AMERICA 
Before the 

SECURITIES AND EXCHANGE 
COMMISSION 

 
 
Admin. Proc. File No. 3-11814 

In the Matter of 

COLUMBIA MANAGEMENT 
ADVISORS, INC. AND COLUMBIA 
FUNDS DISTRIBUTOR, INC., 

Respondents. 
 
 
 

PLAN OF DISTRIBUTION 
 

I. Background 
 
 1.1.  On February 9, 2005 the Securities and Exchange Commission 
(“SEC” or “Commission”) entered an order in this proceeding (the “Order”) 
reciting, among other things, that “[f]rom at least 1998 through October 2003, 
Columbia [Management] Advisors[, Inc.] and some of its predecessor entities 
(“Columbia Advisors”), the investment adviser to over 140 of the mutual funds in 
the Columbia mutual fund complex (the “Columbia Funds”), and Columbia 
[Funds] Distributor [,Inc.], the principal underwriter and distributor of those funds, 
violated antifraud provisions of the securities laws by allowing certain preferred 
customers to engage in short-term or excessive trading, contrary to the 
restrictions and/or representations set forth in the Columbia Funds’ 
prospectuses, that was detrimental to Columbia Funds but benefited respondents 
without disclosing these trading arrangements to fund shareholders or to fund 
trustees.”  (Order ¶1).   The Order required Respondents to pay $70,000,000 in 
disgorgement and $70,000,000 in civil money penalties, and established a Fair 
Fund consisting of the sum of those payments, for a total fund of $140,000,000.  
(Order ¶IV(E)).  The Order required an Independent Distribution Consultant 
(“IDC”) to develop a plan (the “Distribution Plan,” or “Plan”) for the distribution of 
the Fair Fund, “according to a methodology developed by the IDC in consultation 
with Respondents and the independent trustees of the Columbia Funds mutual 
funds and acceptable to the staff of the Commission.”  (Order ¶67).  Shortly after 
the entry of the Order, Professor Lawrence A. Hamermesh, Ruby R. Vale 
Professor of Corporate and Business Law at Widener University School of Law in 

 1



Wilmington, Delaware, was appointed as the IDC in this proceeding.1  On 
February 25, 2005, Respondents deposited the amount of the Fair Fund 
($140,000,000) at the Bureau of Public Debt for investment in government 
obligations.  Other than interest from these investments and funds to be received 
pursuant to the plan of distribution in the Bank of America/Nations Funds 
Proceeding, it is not anticipated that the Fair Fund will receive additional funds.  If 
any other funds are received before distributions under this Plan have begun, 
such funds will be distributed by means of proportionally increasing distributions 
otherwise provided for in this Plan (¶¶7.3 - 7.7), or by such other means 
approved by the IDC in consultation with the Respondents, the trustees of the 
Columbia Funds, and the Commission or its staff.  After distributions under this 
Plan have begun, the Fund does not intend to accept additional funds for 
distribution. 
 
 1.2.  This Distribution Plan is the result of extensive consultation.  Among 
other efforts, Professor Hamermesh: 
 

• Met with Navigant Consulting, Inc. to review the analyses it prepared for 
the Independent Trustees of the Columbia Funds to assist with their 
evaluation of the effects of market timing activity in the Columbia Funds. 

• Met and spoke with Respondents’ economic adviser Lexecon, which has, 
at Professor Hamermesh’s request and under his guidance, managed the 
trading data and developed and executed the numerical and financial 
analyses of that data. 

• Retained Professor Erik R. Sirri, professor of finance at Babson College 
and former Chief Economist of the Commission, and consulted him on 
issues of financial and economic analysis associated with the 
development of the Distribution Plan with respect to distributions to 
Columbia Funds shareholders. 
 
1.3.  Before describing how this Distribution Plan allocates and distributes 

the Fair Fund, it is helpful to separate into two broad categories the trading 
addressed by the Order.  The first category, identified here as “Arrangement 
Trading,” involves market timing activity by nine entities with whom Respondent 
Columbia Funds Distributor, Inc. (“Columbia Distributor”) was found to have 
entered into an arrangement or understanding allowing rapid trading in one or 
more of the Columbia Funds.  (Order ¶¶13-40).  The second category involves 
market timing activity by persons with whom the Respondents had no 

                                            
1 Professor Hamermesh also serves as IDC for the fair fund established under the February 9, 
2005 order in In the Matter of Banc of America Capital Management, LLC, BACAP Distributors, 
LLC, and Banc of America Securities, LLC (the “Bank of America/Nations Funds Proceeding”).  
That proceeding involves a separate fair fund from the fund established with respect to the 
Columbia Funds.  As prescribed in the Order in this proceeding involving the Columbia Funds 
(¶67), Respondents have agreed to pay all compensation of and expenses incurred by Professor 
Hamermesh as IDC for the Columbia Funds Fair Fund. 

 2



arrangement or understanding with respect to short term trading.  Because of the 
absence of any such arrangement or understanding, trading by these persons is 
described here as “Non-Arrangement Timing.”  The persons who engaged in 
Non-Arrangement Timing in turn fall into two distinct categories:  those (identified 
as “retail traders”) who traded through accounts held in their own names (“retail 
accounts”); and others (“omnibus traders”) who traded through accounts that 
aggregated trading and ownership by multiple beneficial owners (“omnibus 
accounts”).  (Order ¶41).  

 
 

II.  Distribution Methodology – In General 
 
2.1.  The methodology for the distribution of the money in the Fair Fund is 

designed to provide compensation for dilution and related harm to 
contemporaneous long term fund shareholders arising from the two principal 
categories of trading identified in the Order.  The term “contemporaneous,” as 
used in this Distribution Plan, refers to those persons who were fund 
shareholders at the time of the trading identified in the Order, regardless of 
whether such persons continued to hold fund shares thereafter.   

 
2.2.  The methodology employed in this Plan attempts to estimate, on a 

daily basis over the course of that trading, the extent to which a fund’s net asset 
value (NAV) would have been greater or less than the actual NAV had that 
trading not occurred.  That difference (where positive) is the estimate of the 
dilution and related harm to the contemporaneous holders of the fund on each of 
the days on which such trading occurred.  The sum of those daily increments 
(both positive and negative) represents the aggregate harm to each fund’s 
shareholders during the period in which timing trading occurred.2

 
 2.3.  The methods of calculation of each eligible contemporaneous 
shareholder’s share of the Fair Fund are intended to result in a payment from the 
Fair Fund to each such shareholder that restores the impaired value of such 
shareholder’s investment in a particular fund.  The methods of calculation are 
intended by the Commission to fairly estimate the impaired value that each 
investor has suffered and to make a payment in that amount.  In the view of the 
IDC, these methods of calculation are fair and reasonable in the context of this 
case, and result in a fair and reasonable allocation of the Fair Fund. 

 
III.  Estimation of Dilution and Related Harm to Contemporaneous Shareholders 
 
                                            
2 There may be instances of accounts for which the effect of timer trading was beneficial (and for 
which harm-based compensation would be inappropriate).  Because of this possibility, it may also 
be the case that the other account holders’ share of estimated harm would in the aggregate 
exceed the aggregate amount estimated for the fund as a whole.  At this point, however, it 
appears that such instances are both unusual and small in scope, and are not likely to have a 
substantial effect on the ultimate distribution. 
 

 3



A.  Estimating Dilution 
 
3.1.  The starting point in estimating the dilution arising from timer trading 

is a determination of the net gains realized through that trading.  Each timer’s 
purchases and sales are formed into buy-sell pairs using a LIFO methodology.3

 
3.2.  For any given mutual fund, if the funds a timer uses to purchase fund 

shares (“timer funds”) were never invested in risky portfolio assets by the 
portfolio manager, timer net gains would accurately measure dilution to 
contemporaneous shareholders.  To the extent, however, that timer funds were 
invested in risky assets, dilution may diverge from timer net gains.  Accordingly, it 
is necessary to estimate the extent to which portfolio managers invested in (and 
sold) portfolio assets in response to timer investment (and sales).4   

 
3.3.  For each buy-sell pair, the mutual fund’s incremental investment in 

risky assets is estimated by assuming that a constant fraction of the timer funds 
is invested in risky assets each day until either the timer funds are invested or the 
timer’s shares are redeemed.  When the timer’s shares are redeemed, the 
portfolio manager is assumed to sell risky assets at the same rate to fund the 
redemption.5   

 
3.4.  To illustrate, take the case where a timer buys 10 fund shares for 

$100 on day 1, sells those 10 shares on day 4 for $110, and the estimated daily 
average investment rate is 10 percent per day.  The model assumes the portfolio 
                                            
3 Because of the focus on the actual dilutive impact on fund shareholders, aggregate timer gains 
and losses in each individual fund are netted through the period in which timer trading occurred.   
 
4 See Greene, Jason T. and Ciccotello, Conrad S., "Mutual Fund Dilution from Market Timing 
Trades" (September 27, 2004). http://ssrn.com/abstract=596482
 
5 Daily average investment rates for use in this cash investment model and for calculating 
transaction costs are estimated from data on flows of money during 2002 and 2003 into 15 of the 
Columbia Funds and data on portfolio manager investments for those funds.  The 15 funds were 
among those with the largest dilution. 
 
Regression analysis is used to estimate the daily average investment rate where investment in 
risky assets is regressed on flows.  The daily average investment rate is calculated by averaging 
the regression coefficients on the flow variables.  Many regression specifications were tried, 
including regressions with lead and contemporaneous variables, and the specification that 
produced the highest daily average investment rate was used. 
 
To measure typical portfolio manager reaction to recurring timer flows, outliers in the flow and 
investment data are removed.  (For instance, investment rebalancing by large shareholders, such 
as pension plans, periodically caused large movements of assets between funds.)   
 
Where flow or portfolio investment data are unavailable for a fund, a weighted average of the 
daily investment rates for the funds with available data is used, and a minimum investment rate of 
one percent per day is imposed.  The overall dilution estimate is not sensitive to the daily average 
investment rate; doubling the rate reduces overall dilution by an insignificant amount. 
 

 4

http://ssrn.com/abstract=596482


manager invests $10 per day in risky assets on days 2 through 4.  Consequently, 
before the redemption on day 4, the fund holds $30 of the timer funds in risky 
assets and $70 in cash; and immediately after the redemption on day 4, the fund 
holds $30 of the timer funds in risky assets and has a cash deficit of $40 (= $70 - 
$110).  On days 5 through 14, the portfolio manager is assumed to sell $40 of 
risky assets at the rate of $4 per day to offset the cash deficit and return the fund 
to its previous cash level. 
 

3.5.  To estimate the effect of the incremental investment in risky assets, 
the fund’s profits and losses on the incremental investment are estimated for 
each day, and the total effect is the sum of the daily profits and losses.  The 
effect of the incremental investment each day is estimated as the fund’s return 
that day multiplied by the incremental investment in risky assets that day.  For 
example, continuing the previous illustration, the fund’s investment in risky assets 
is $20 higher on day 3 than it would have been absent the timing activity.  If the 
fund’s return on day 3 was 1 percent, then the investment of the timer funds 
benefited the fund’s shareholders that day by $0.20 (= $20 * .01); and if the 
fund’s return on day 3 was -2 percent, then the timing activity harmed the fund’s 
shareholders that day by $0.40 (= $20 * .02). 
 

3.6.  Last, the effects of all incremental investments are summed and 
added to the total net profits made by the timers ($10 in this example) to arrive at 
an estimate of the total dilution harm to shareholders from the timing activity. 

 
B.  Estimating Transaction Costs Related to Timer Trading 
 
3.7.  The Order states that timer trading may have adversely affected the 

funds’ NAV’s in an additional way, aside from dilution (Order ¶9).  To the extent 
that timer investment and disinvestment resulted in excess portfolio purchases 
and sales, the funds may have incurred transaction costs that reduced their 
NAV’s.  Such transaction costs can be estimated by comparing estimated 
transaction costs due to the funds’ actual inflows and outflows to the estimated 
transaction costs that would have occurred had there been no timing activity.  
The difference between the two estimates of transaction costs is taken as the 
incremental transaction costs attributable to the timing activity.   
 

3.8.  Incremental transactions in response to a given inflow or outflow are 
modeled by assuming that the portfolio manager invests (or disinvests) in risky 
assets at the estimated daily investment rate until the flow is completely invested 
(or disinvested).  For each inflow or outflow, this produces a series of daily 
investments or disinvestments.  To get the total investment or disinvestment on 
any given day, all investments and disinvestments on that day due to all inflows 
and outflows are summed.  Where there is investment due to previous inflows 
and disinvestment due to previous outflows, the investments and disinvestments 
are netted against each other for that day.  Investments and disinvestments are 
not netted against each other across days. 

 5



 
3.9.  Transaction costs are estimated from the daily series of net 

investments by multiplying the investment or disinvestment on each day by the 
transaction cost per dollar of investment or disinvestment.  Total transaction 
costs are the sum of the daily transaction costs. 
 

3.10.  Transaction costs vary by fund type and time period.  Funds are 
classified into four fund groups based on their Morningstar classification: U.S. 
Large-Cap, U.S. Small-Cap, International, and Bond.  (When a fund’s category 
cannot be identified, the U.S. Small-Cap classification is used.)  Transaction 
costs for U.S Large-Cap, U.S. Small-Cap and International funds are from Plexus 
and are the sum of “commissions” and “impact costs.”  Bond fund transaction 
costs are from Schultz, Paul, 2001, “Corporate Bond Trading Costs: A Peek 
Behind the Curtain,” The Journal of Finance 56, 677– 698 at 677. 

 
3.11.  Applying the foregoing methodology to the data available for the 

Columbia Funds results in an estimate of transaction costs that is on average 
approximately 8% of dilution.   

 
C.  Interest 
 
3.12.  In order to make compensation on an equivalent basis for losses 

spread over time, and to provide appropriate compensation to long-term fund 
shareholders, it is necessary to make some adjustment for the time value of the 
estimated harms.  Therefore, the methodology incorporated in this Distribution 
Plan builds in a component of interest on estimates of harm, accruing from the 
time of dilution harm through the date of payment into the Fair Fund.  The rate of 
interest was selected to approximate Bank of America’s cost of unsecured 
borrowing,6 and is estimated by reference to the Merrill Lynch index of 1-3 year 
A-rated corporate debt over the course of the period in which timer trading 
occurred. 

 
IV.  Application of the Methodology to Arrangement Trading 
 
 4.1.  As previously noted, the first category of trading addressed in this 
Distribution Plan is the Arrangement Trading (i.e., market timing activity by the 
nine entities identified in the Order (¶¶13-40) with whom Respondent Columbia 
Distributor was found to have entered into an arrangement or understanding 
allowing rapid trading in one or more of the Columbia Funds).  Some of the 
entities that engaged in Arrangement Trading made purchases and sales that 
involved “sticky” assets (i.e., long term investments) in the very funds in which 
the Arrangement Trading occurred (see, e.g., Order ¶¶16, 23, 34, 37).  
Accordingly, and to focus the ultimate distribution on contemporaneous fund 

                                            
6 See Knoll, Michael S. and Colon, Jeffrey M. Colon Miguel, "The Calculation of Prejudgment 
Interest" (May 31, 2005). http://ssrn.com/abstract=732765.  
 

 6

http://ssrn.com/abstract=732765


holders adversely affected by excessive rapid trading (as opposed to trading in 
“sticky” assets), the methodology for measuring the impact of Arrangement 
Trading includes all matched buy and sell pairs except those in which the holding 
period exceeded 21 trading days.   
 

4.2.  The result of this approach to Arrangement Trading is a distributional 
allocation in the aggregate amount (including transaction costs and interest) of 
approximately $32.6 million.  In addition to that allocation, this Distribution Plan 
will also return, to contemporaneous holders of the funds affected by such 
trading, advisory and administrative fees paid by those funds to Respondents 
Columbia Advisors and Columbia Distributors as a result of the investment of 
timer funds during the periods in which the Arrangement Trading in those funds 
occurred.  Order ¶¶49-50.  Over the 1999-2003 time period, such fees amounted 
to approximately $500,000.  Taken together with the allocation attributable to 
dilution and related harm, the total allocation proposed with respect to 
Arrangement Trading is approximately $33.1 million. 
 
V.  Application of the Methodology to Non-Arrangement Timing 
 
 5.1.  The balance of the Fair Fund will be applied to the Non-Arrangement 
Timing.  While such trading is only briefly mentioned in the Order (¶41), it 
accounts for the largest portion of the allocation contemplated in the Distribution 
Plan, and presents a distinct set of challenges.  Although the Order notes 
numbers of round trips in the Columbia Funds in non-omnibus accounts, and 
notes that omnibus accounts also made numerous round trips, it does not 
specify, for purposes of the distribution of the Fair Fund, which of those round 
trips were by market timers and which of these round trips should result in an 
allocation from the Fair Fund. 
 
 5.2.  Likewise, although the Order mentions round trips in both omnibus 
and retail accounts, there are obvious differences between the two types of 
accounts from the perspective of identifying and policing market timing.  The 
aggregated nature of omnibus accounts may mask market timing at the sub-
account level.  For example, it might not be apparent to an advisor or distributor 
that a buy through an omnibus account is “matched” at the sub-account level with 
a subsequent sale through the same omnibus account.  Moreover, while it might 
be appropriate to shut down a retail account when there is a pattern of short term 
trading, that might not be an appropriate response in the omnibus account 
situation due to the consequences to innocent long-term investors holding 
through the omnibus account.   
 
 5.3.  Accordingly, in identifying the trading with respect to which dilution 
and related harm should be estimated, the IDC requested an examination of the 
entire set of trading data in the Columbia Funds over an extended time frame 
(1998-2003).  Trading through Banc of America Securities (compensation for 
which is being addressed in the Bank of America/Nations Funds distribution plan) 

 7



was then excluded from that data set.  In addition, trading in 1998 was also 
excluded for a variety of reasons, including: (1) the data suggest that the short 
term trading prior to January 1, 1999 was relatively insignificant, and (2) as 
reflected in the Order, nearly all of the Arrangement Trading occurred after 
January 1, 2000.   
 
 5.4.  For the remaining trading, certain criteria were selected and applied 
to these data to identify the trading in respect of which compensation is to be 
made under this Plan.  In the absence of evidence of specific relevant 
communications with specific fund holders as to their investment motivations, no 
set of criteria for identifying market timing accounts can possibly be completely 
accurate.  Accordingly, the application of any set of criteria to the remaining 
trading will probably result in the inclusion of some trades that were not driven by 
market timing considerations, and the exclusion of some trades that were.  The 
criteria selected in this Plan, therefore, seek to draw distinctions among accounts 
based on observable behavior, reasonably inferable investment motivation, and 
reasonable expectations concerning the Respondents’ ability to have halted 
observable market timing activity.  The goal in selecting these criteria is to arrive 
at some reasonable way to allocate the Fair Fund so that distributions to 
contemporaneous shareholders are directed to the funds and shareholders most 
heavily affected by Non-Arrangement Timing. 
 
 5.5.  The criteria selected are:  
 
      (1) Exclude all purchase/sale pairs in which the holding period exceeded 
seven trading days, and exclude all trading in any account in which there was 
never a purchase/sale pair involving amounts greater than $100,000 and 
$50,000 respectively.7     
 
       (2) For each fund, and for those purchase/sale pairs that satisfy the 
criteria in the preceding paragraph, identify the first observance of two round trips 
in a retail account in a quarter (on a rolling basis), or, if none, the first five round 
trips in a retail account in a year (on a rolling basis), and exclude those trades 
and any prior trades.   
 
      (3) Exclude purchase/sale pairs in omnibus accounts where the date of 
the purchase does not coincide with a date of a purchase in a buy/sell pair in the 
same fund that is identified as Arrangement Trading or trading in a retail account 
identified pursuant to the two criteria noted above.8   
                                            
7 The selected period is shorter than the comparable period selected for Arrangement Trading, 
because it is intended to retrospectively identify market timing accounts, rather than distinguish 
market timing activity from long-term investment activity in the case of known market timers. 
 
8 In late 2002 the Columbia Funds imposed redemption fees on short-term trading of international 
funds by retail accounts, which resulted in a substantial reduction in timing trades by those 
accounts.  All omnibus trading pairs that meet criterion 1 above for international funds after those 
fees were imposed on retail accounts were included in identifying Non-Arrangement Timing. 

 8



 
      (4) For each fund, and for those trades that satisfy the previous criteria, 
identify the first observance of five round trips in an omnibus account in a quarter 
(on a rolling basis), or, if none, the first ten round trips in an omnibus account in a 
year (on a rolling basis), and exclude those trades and any prior trades. 

 
VI.  De Minimis Analysis and Prioritization 

 
6.1.  The foregoing analysis, taken together with the analysis of 

Arrangement Trading, yields an estimate of total dilution for each of the Columbia 
Funds.  (See Table 2).  This Distribution Plan excludes from the distribution those 
Columbia Funds in which the estimate of aggregate dilution harm from 1999 
through 2003 was less than either $100,000 or 0.2% of average fund assets.  
This approach excludes a large number of the Columbia Funds for which trading 
data were studied (see Table 2).  Many of these funds are focused on 
investments that do not fluctuate rapidly in value or otherwise do not offer 
significant opportunity for profitable market timing activity (e.g., municipal bonds, 
or domestic large cap stocks).   

 
6.2.  The remaining Columbia Funds are identified as “Participating 

Funds.” (See Table 1). Of these Participating Funds, the first priority for 
distribution will be to the funds in which there was estimated dilution on account 
of Arrangement Trading.  Distribution in respect of the remaining Participating 
Funds will be made, in descending order of estimated dilution as a percentage of 
average fund assets, to the point that a minimum of $4 million (plus attributed 
interest thereon since February 25, 2005) remains in the Fair Fund as a holdback 
described in paragraph 7.8 below.  Table 1 sets forth the Participating Funds in 
the order of priority of distribution as explained above.   

 
VII.  Administration of the Distribution 
 
 A.  Allocating the Distributions Among Contemporaneous Shareholders. 
 

7.1.  Application of the methodology described above permits the 
calculation of a distribution amount, by date, for each of the funds affected by the 
identified timer trading.  In turn, each holder of shares in one or more of those 
funds during the period affected by timer trading will be identified in order to 
determine that holder’s appropriate allocation of the Fair Fund.  There are a 
number of difficulties, however, in simply directing payment of those amounts to 
those holders. The balance of this Distribution Plan addresses these and other 
aspects of implementation and administration of the Plan. 
 

7.2.  This Fair Fund is not being distributed according to a claims-made 
process, so the procedures for providing notice and for making and approving 
claims are not applicable. 

 9



7.3.  Under this Distribution Plan there will be no distribution to any of the 
nine persons identified in the Order as having engaged in late trading or market 
timing.  Similarly, but with the caveat noted below, there will be no distribution to 
any person or entity identified as the holder of a retail account identified as a 
market timing account using the criteria described above.  Such persons or 
entities will be notified that they are not to receive a distribution unless they 
present to the IDC, within a 60-day period after notice, evidence demonstrating to 
the satisfaction of the IDC that their trading was not motivated by timing 
considerations.  The IDC will evaluate and determine the merits of each such 
presentation within 30 days after its submission, and will advise the presenter, 
the Respondents and the Commission of the determination promptly upon 
making it.  The aggregate of amounts excluded on the foregoing basis will be 
disbursed in accordance with paragraph 7.8 below. 

 
7.4.  Returns on the Fair Fund that have accrued since its establishment in 

February 2005 through the date of approval of the Distribution Plan will be 
allocated in proportion to the allocation otherwise contemplated under the Plan. 

 
7.5.  In any given fund there will be holders identified for whom the 

estimated distribution is so small that it would be impractical and ineffective to 
send a check.  In general, no distribution of less than $10 will be made.  Two 
steps will be taken, however, to minimize the number of such de minimis 
situations, and maximize the number of individual holders who will be receiving a 
distribution:  (i) an effort will be made to identify, by common social security 
number or other administratively feasible mechanism, instances in which 
distribution amounts attributable to an individual shareholder in multiple affected 
funds can be aggregated into a single amount in excess of $10; and (ii) other 
accounts for which the distribution would amount to less than $10 will be 
aggregated, with the resulting sum distributed in $10 units to the holders of those 
accounts, in descending order of attributable dilution harm. 

 
B.  Distributions to Omnibus Accounts, Retirement Accounts and Network 
Level Accounts. 

 
7.6.   (a) For distributions with respect to omnibus accounts (but not for 

ordinary trusts, pension plans and 529 plans), it will be necessary to evaluate the 
cost associated with commercially reasonable best efforts to identify and 
distribute funds to contemporaneous beneficial owners.   

 (b)  If the aggregate amount of the distribution attributable to a 
particular omnibus account is $1,000 or more, the account holder will be 
contacted in order to determine an appropriate method for distributing the funds 
to contemporaneous beneficial owners holding through the omnibus account.  
Unless the account holder agrees to distribute the funds to beneficial owners at 
its own expense, in accordance with the specifications supplied by or on behalf of 
the IDC, the account holder will be asked to estimate the costs of commercially 
reasonable efforts to identify and distribute funds to the beneficial owners.   

 10



 (c)  If the aggregate amount of the distribution with respect to an 
omnibus account exceeds such costs, the omnibus account holder will be asked 
to elect, within 45 days after notice of the proposed distribution, whether to (i) 
supply to the IDC the sub-account information necessary for the IDC to distribute 
funds to the beneficial owners, (ii) supply such information to the IDC, who will 
calculate the amount of distributions to beneficial owners so that the account 
holder can make such distributions itself, or (iii) distribute the funds itself, using 
specifications supplied by or on behalf of the IDC as necessary to determine the 
appropriate allocation of the funds among contemporaneous beneficial owners 
holding through the omnibus account.  The omnibus account holder may elect 
more than one of these options and apply them differently in respect of different 
categories of beneficial owners (such as open accounts and closed accounts).  In 
any of these three cases, Respondents will reimburse the omnibus account 
holder for the reasonable out of pocket costs of gathering and supplying the 
necessary sub-account information.  If the omnibus account makes no election 
within the time specified in this subparagraph, it will be deemed to have elected 
to proceed under subparagraph (i) of this paragraph.  If and to the extent that the 
omnibus account holder elects to proceed under subparagraph (c)(i) or (c)(ii), the 
holder shall submit the specified information to the IDC within 90 days after 
notice of the proposed distribution. 

 (d)  If the omnibus account holder elects to proceed under 
subparagraph (c)(ii) or (c)(iii), the account holder may either send a check to the 
beneficial owner or, if the beneficial owner has a current sub-account, credit that 
sub-account.  Except where the omnibus account holder credits current sub-
accounts in lieu of sending checks, it will be required to develop and execute a 
program similar to the one described in paragraph 7.5(ii) for dealing with 
individual distributions of less than $10.   

 (e)  If the aggregate amount of the distribution attributable to a 
particular omnibus account is less than either (a) $1,000 or (b) the costs of 
commercially reasonable efforts to identify and distribute funds to 
contemporaneous beneficial owners, the omnibus account holder will be given 
the choice of refusing the distribution or applying any distribution technique, at its 
own expense, that the account holder, in the exercise of its reasonable 
discretion, deems to be consistent with its fiduciary, contractual or other legal 
obligations.  If the omnibus account holder refuses the distribution, the otherwise 
distributable amount will be added to the holdback described in paragraph 7.8. 

 (f)  For purposes of this paragraph, “commercially reasonable best 
efforts” to identify and distribute funds to beneficial owners in omnibus accounts 
involve assembly, in appropriate format, of (i) names, addresses and other 
necessary identifying information for beneficial owners, and (ii) daily records or 
opening account balances and subsequent transaction data (or, if such data are 
either unavailable or available only at a cost that would otherwise result in the 
application of the previous subsection, the most extensive records (monthly, 
quarterly or yearly) that are available) necessary to determine each such owner’s 
fund share balance during the period to which the distribution in question relates.  
The foregoing information provided by omnibus account holders shall be 

 11



maintained confidentially and held exclusively by the Fund Administrator, and 
Respondents shall not have access to that information.  Respondents and the 
Fund Administrator shall maintain records of efforts made to obtain the 
cooperation of omnibus account holders, and of the responses to these efforts. 

 (g)  If the distribution to an omnibus account holder is less than the 
payments to beneficial owners calculated in accordance with the specifications 
supplied by the IDC (due to netting at the omnibus account level), the amounts to 
be distributed to beneficial owners will be proportionally reduced. 

 (h)  Distributions with respect to omnibus accounts shall be 
completed within 180 days after receipt by the omnibus account holder of funds 
from this Plan (or, within 180 days after receipt by the IDC of the information 
specified in subparagraph (c)(i), if applicable), unless the account holder 
demonstrates to the satisfaction of the IDC that good cause exists to extend that 
deadline.  Omnibus account holders seeking to alter the procedures specified in 
this paragraph 7.6 may apply to the Fund Administrator for permission for such 
alteration within 90 days of receiving notice of the proposed distribution from the 
Fund Administrator, and the IDC will rule on such applications within 60 days 
after their submission to the Fund Administrator.  The IDC may grant such 
applications if the requested alteration would not materially affect the distribution 
of funds to the contemporaneous beneficial owners.  Paragraph 7.9 of this Plan 
shall apply to distributions made by omnibus account holders to beneficial 
owners, and the amount of undeliverable or unclaimed payments shall be 
returned to the Fund Administrator promptly after conclusion of the six month 
period specified in paragraph 7.9. 

 
 7.7.   (a)  Retirement Plans.  Plan administrators of retirement 
accounts shall be required to distribute the monies received under this Plan in 
accordance with their fiduciary and contractual obligations, and consistent with 
guidance issued by the Department of Labor, if any.  "Retirement accounts" as 
used in the Plan means any account of an employee benefit plan, as such plans 
are defined in section 3(3) of ERISA, which is not an Individual Retirement 
Account, whether or not the plan is subject to Title I of ERISA.9  Plan 
administrators of retirement accounts may distribute the monies received under 
this Plan to plan participants in accordance with such participants’ account 
balances during the period to which the distribution in question relates, using 
balance information on a daily, monthly, quarterly or yearly basis.  
  (b)  Network Level Accounts.  Networking firms associated with 
network level accounts (i.e., an account that represents one underlying owner but 
for which name, address and other necessary identifying information may be 
maintained by an intermediary) shall distribute the monies received under this 
Plan to the underlying owners of such accounts, and will be asked to elect, within 
45 days after notice of the proposed distribution, one of the following two options 
for completing such distributions:  (i) supplying to the IDC the information 
necessary for the IDC to distribute funds to the underlying owners, or (ii) 
                                            
9 Distributions with respect to Individual Retirement Accounts are governed by Part VII(A) of this 
Plan. 

 12



distributing the funds themselves, using specifications supplied by or on behalf of 
the IDC as necessary to determine the appropriate allocation of the funds among 
contemporaneous underlying owners.  In either option, Respondents will 
reimburse the networking firm for the reasonable out of pocket costs of gathering 
and supplying the information necessary to distribute funds to the underlying 
owners of the network level account.  The networking firm may elect more than 
one of these options and apply them differently in respect of different categories 
of underlying owners (such as open accounts and closed accounts).  If the 
networking firm makes no election within the time specified in this subparagraph, 
it will be deemed to have elected to proceed under subparagraph (i) of this 
paragraph. Distributions with respect to network level accounts shall be 
completed within 180 days after receipt by the networking firm of funds from this 
Plan (or within 180 days after receipt by the IDC of the information specified in 
subparagraph (i), if applicable).  Paragraph 7.9 of this Plan shall apply to 
distributions made by networking firms to underlying owners of network level 
accounts, and the amount of undeliverable or unclaimed payments shall be 
returned to the Fund Administrator promptly after the conclusion of the six month 
period specified in paragraph 7.9. 
 

C.  Holdback. 
 
7.8.  The holdback described in paragraph 6.2 above will be applied first 

toward any distributions necessary to respond to claims, if any, by shareholders 
in the Participating Funds for distributions in addition to those contemplated 
under this Plan.  To the extent that there are funds remaining after all such 
claims have been resolved, that remainder should be paid to holders of any of 
the other Participating Funds to whom no distribution has been made, again in 
descending order of estimated dilution as a percentage of average fund assets.  
Finally, any additional funds remaining shall be distributed in a manner consistent 
with the plan as approved, as determined by the IDC on notice to Respondents, 
the Independent Trustees of the Columbia Funds, and the SEC.   

 
D.  Unclaimed Distributions. 
 
7.9.  In situations in which distributions are unclaimed (checks not 

cashed), or persons to whom a distribution would otherwise be made cannot be 
identified or located, the distributable amounts should be added to the amount 
held back pursuant to paragraph 6.2 above.  All distributions should be on terms 
providing that checks not cashed within six months after distribution shall be void, 
and the issuing financial institution shall be instructed to stop payment on those 
checks or otherwise assure that payment on such checks is prevented.   

 
 E.  Fund Administrator and Tax Administrator. 
  

7.10.  Rust Consulting, Inc. (“Rust”), if approved by the Commission, will 
serve as the administrator of the Fair Fund (“Fund Administrator”) and will be 

 13



compensated by the Respondents.  Appendix A to this Plan provides additional 
information about the Fund Administrator.  The IDC requests that the 
Commission waive, for good cause shown (specifically, the facts set forth in 
Appendix A), the requirement that a bond be posted pursuant to Rule 1105(c) of 
the Commission’s Rules on Fair Fund and Disgorgement Plans.  Under the 
supervision of the IDC, Rust will be responsible for, among other things:  
overseeing the administration of the Fair Fund, obtaining accurate mailing 
information for shareholders, preparing accountings, cooperating with the Tax 
Administrator in providing the information necessary to accomplish the income 
tax compliance, distributing money from the Fair Fund to shareholders in 
accordance with and subject to approval of this Plan, and setting up and staffing 
a call center to address shareholder questions or concerns regarding the 
distribution.  The Fund Administrator will provide customer support and 
communications programs which will become active at least by the time the first 
distribution occurs.  These services will include a toll free number and a website 
accessible to the public.  The Commission retains the right to review and approve 
any material posted on the website.  While the distribution is being implemented, 
the Fund Administrator will submit to the IDC and the staff of the Commission an 
accounting during the first ten days of each calendar quarter, and will submit a 
final accounting for approval of the Commission before termination of the Fair 
Fund and discharge of the Fund Administrator.  The IDC and Rust currently have 
an agreement in place requiring Rust to perform certain tasks in preparation for 
the forthcoming distribution of the Fair Fund.  To date, Rust has successfully met 
its obligations under the agreement and the IDC believes that Rust will perform 
satisfactorily as the Fund Administrator. 
 

7.11.  The Commission has appointed Damasco & Associates as the Tax 
Administrator (“Tax Administrator”) of the Fund (Order Directing Appointment Of 
Tax Administrator, in the Matter of Certain Disgorgement and Fair Funds in 
Administrative Proceedings, Exchange Act Rel. No. 51341, March 9, 2005).  The 
IDC, Fund Administrator and Respondents will cooperate with the Tax 
Administrator in providing information necessary to accomplish the income tax 
compliance, ruling and advice work assigned to the Tax Administrator by the 
Commission.  The Tax Administrator shall be compensated by the Respondents. 
 
 F.  Payment of Distributions. 
 

7.12.  In order to distribute funds, and promptly after the necessary 
information becomes available, the IDC will submit a validated list of payees and 
the payment amounts to the assigned Commission staff.  The staff shall obtain 
authorization from the Commission to disburse funds pursuant to Rule 
1101(b)(6), upon staff receipt and acceptance of a validated payment file or list.  
It is anticipated that the entire distribution may not be validated at one time.  As 
and when additional payee distribution information becomes available, the IDC 
will submit additional validated lists of payees and payment amounts for 
distribution as authorized.  In each instance, the payees and amounts will be 

 14



validated at the IDC’s direction by Rust.  The validation will state that the list was 
compiled in accordance with the Plan and provides all information necessary to 
make disbursement to each distributee.  Unless otherwise directed by the 
Commission, the Commission staff will direct the release of funds to the bank 
account established by the Fund Administrator based upon the validated list and 
representation by the Fund Administrator that the checks will be issued the next 
business day. 
 
 7.13.  All payments shall be preceded or accompanied by a 
communication that includes, as appropriate:  (a) a statement characterizing the 
distribution; (b) a description of the tax information reporting and other related tax 
matters; (c) a statement that checks will be void after 180 days; and (d) the name 
of a person to contact, to be used in the event of any questions regarding the 
distribution.  Any such information letter or other mailing to recipients 
characterizing their distribution shall be submitted to the assigned Commission 
staff for review and approval.  Distribution checks, on their face, or in the 
accompanying mailing will clearly indicate that the money is being distributed 
from an SEC Fair Fund. 
 
 7.14.  In implementing the distribution under this Plan, the Fund 
Administrator will prepare a “positive pay file” for clearing checks at a bank (the 
“Escrow Bank”), and will provide that file to the Escrow Bank separately from the 
physical checks themselves.  The Escrow Bank will be instructed to clear only 
checks matching entries in the positive pay file and for the amount in the file. 
When checks are printed, a reconciliation report will be provided which lists the 
total number of checks and sequenced numbers printed.  These totals will be 
compared to the total records from the payment file to confirm all checks were 
printed.  Printed checks will be kept in a secured area until they are mailed and 
will generally be printed just in time for mailing.  Only authorized individuals will 
be allowed access to the check area for printing and performing quality control 
procedures.  Processing of the mailing of checks will be subject to appropriate 
security procedures.  For wires, the Fund Administrator will provide the Escrow 
Bank with wire transfer instructions signed by both the IDC and an authorized 
representative of the Fund Administrator. Wire instructions received by the 
Escrow Bank will be reviewed by an administrative employee of the Escrow Bank 
for content, required signatures and all necessary data. The administrative 
employee will input the instructions into the Escrow Bank's computer system, and 
an Officer of the Escrow Bank will compare the computer entries to the original 
wire instructions before giving final approval on the transfer. 
 

7.15.  If a check is returned as undeliverable, the Fund Administrator will 
send the name, current address it has on file, and the tax identification number 
for the individual/entity, to a company that has access to credit bureau header 
type information.  That company will then search for the most current address 
available through its proprietary databases, and will then return each record back 
to the Fund Administrator.  If the returned file contains new addresses for records 

 15



where the company has a more current address, with a date that corresponds 
with that address, the Fund Administrator will then update its database for 
records with better addresses, with a code that notes that the new address was 
obtained through a trace process and the date the new address was obtained.  
This new address will then become the current address for that record in its 
database.  The Fund Administrator will not overwrite or delete previous 
addresses, which it will maintain in an address history with dates and codes that 
identify when an address is used and why an address was updated. 
 

7.16.  The IDC and the Fund Administrator shall use their best efforts to 
assure that distribution of payments to investors shall be substantially completed 
within 90 days following the later of the approval of the Plan by the Commission 
or the date of receipt of a private letter ruling from the IRS (the “IRS Ruling”) on 
the reporting of payments to investors under this Plan. Notwithstanding the 
foregoing, in the event the IRS Ruling requires reporting of all or a portion of the 
payments the IDC and the Fund Administrator shall use their best efforts to 
assure that distribution of payments shall be substantially completed no later 
than six months from the date of that ruling.  The Fair Fund shall terminate 
effective upon the later of September 30, 2007 or 60 days after the final 
distribution of funds to investors and the resolution of uncashed or unclaimed 
funds and the payment or reserve for taxes and the final accounting by the Fund 
Administrator has been submitted to and approved by the Commission.  Before 
the termination of the Fair Fund, the IDC shall cooperate with the Tax 
Administrator to make adequate reserves for tax liability and for the costs of tax 
compliance.  Before termination as defined in this paragraph, all undistributed 
assets remaining in the Fair Fund, minus any reserves for tax liability and tax 
compliance costs, shall be remitted to the United States Treasury or to such 
other person or entity as the Commission may direct.   
 
 7.17.  (a)  The Fair Fund constitutes a Qualified Settlement Fund 
(“QSF”) under Section 468B(g) of the Internal Revenue Code, 26 U.S.C. 
§468B(g), and related regulations, 26 C.F.R. §§1.468B-1 through 1.468B-5.  The 
Commission has custody of the Fair Fund and shall retain control of the assets of 
the Fair Fund.  The Fair Fund is currently deposited at the U.S. Treasury Bureau 
of Public Debt (“BPD”).  Upon approval of the Plan, the Fund Administrator shall 
establish one or more accounts at the Escrow Bank (i.e., Deutsche Bank or such 
other bank as shall be selected by the IDC and determined to be acceptable by 
the staff of the Commission), in the name of and bearing the Taxpayer 
Identification Number of the QSF.  Following approval of the Plan and 
submission by the IDC of a list of payees and amounts to the Commission staff, 
and to the extent necessary to fund payments as and when contemplated under 
paragraph 7.12, and unless otherwise directed by the Commission, the 
Commission staff shall cause the balance in the Fair Fund to be deposited in an 
escrow account established by the Fund Administrator in the name of and 
bearing the Taxpayer Identification Number of the Qualified Settlement Fund 
(“QSF account”).  The Fund Administrator shall be the signer on the QSF 

 16



account, subject to the continuing jurisdiction and control of the Commission.  
Funds deposited in the QSF account shall remain in that account until necessary 
for distribution as provided in this Plan, at which point they shall be deposited in 
one or more disbursement accounts established by the Fund Administrator at the 
Escrow Bank.  The Fund Administrator shall authorize the Escrow Bank to 
provide account information to the Tax Administrator.  The Fund Administrator 
shall use the assets and earnings of the Fair Fund to provide payments to 
Investors and to provide the Tax Administrator with assets to pay tax liabilities 
and tax compliance fees and costs.  The QSF account shall be invested in direct 
obligations of the United States Government of a type and term necessary to 
meet the cash requirements of the payments to Investors, tax obligations and 
fees.  
 
 (b) The IDC and the Fund Administrator, and/or each of their designees, 
agents and assistants, shall be entitled to rely on any Orders issued in this 
proceeding by the Commission, the Secretary by delegated authority, or an 
Administrative Law Judge, and may not be held liable to any current or 
contemporaneous shareholder of any of the Columbia Funds, or any of their 
successor funds, for any act or omission in the course of administering the Fair 
Fund, except upon a finding that such act or omission is caused by such party's 
gross negligence, bad faith or willful misconduct, reckless disregard of duty, or 
reckless failure to comply with the terms of the Plan.  This subparagraph (b) is an 
expression of the current state of the law and is not intended, nor should it be 
deemed to be, a representation to or an indemnification of the IDC or the Fund 
Administrator or their designees, agents and assistants, nor should this 
subparagraph (b) preclude the Commission or the QSF from seeking redress for 
any act or omission in the course of administering the Fair Fund or from seeking 
redress from any insurance or bond provided as set forth in this Plan.   
 

7.18.  The Respondents will pay all fees and costs associated with the 
administration of the Distribution Plan, except for tax liabilities of the QSF, which 
shall be paid in accordance with Rule 1105(e) of the Commission’s Rules on Fair 
Fund and Disgorgement Plans. 
 

G. Amendment, Termination and Notices. 
 

7.19.  The IDC will inform the Commission staff of any material changes in 
the Plan, and will obtain approval from the Commission prior to their 
implementation.  If material changes are required, this Plan may be amended 
upon the motion of the Respondents, the Fund Administrator or upon the 
Commission’s own motion.  Under this Distribution Plan the IDC has discretion, 
again in consultation with the Respondents and the Commission’s staff, to make 
supplemental specifications to the Plan of Distribution after its approval that are 
not materially inconsistent with the Plan as approved.  There have been 
substantial regulatory settlements with several entities (such as CIBC, Calugar 
and Bear Stearns) which engaged in or facilitated market timing or late trading in 

 17



one or more of the Columbia Funds.  The IDC under this Distribution Plan will 
attempt to coordinate with the IDCs supervising the plans of distribution for those 
settlements, for the purpose of facilitating distribution to holders of Columbia 
Funds affected by the pertinent trading.  

 
7.20.  Notices to be given under the terms of this Plan (other than under 

paragraph 7.21) shall be given in writing to: 
 
The IDC, to the following address: 
 
 Prof. Lawrence A. Hamermesh 
 Widener University School of Law 
 4601 Concord Pike 
 Wilmington, Delaware 19803 
  -- or – 
 [email protected]
 
The Commission, to the following addresses: 
 

 Office of Financial Management 
 Securities and Exchange Commission 
 Operations Center 
 6432 General Green Way Stop 0-3 
 Alexandria, VA 22312 
 
 With a copy to: 
 
 David P. Bergers 
 District Administrator 
 Boston District Office 
 Securities and Exchange Commission 
 33 Arch Street 
 Boston, MA  02110-1424 

  
H. Notice of the Plan 

 
7.21.  Notice of this Distribution Plan will be published in the SEC Docket, 

on the Commission web site, and on the Respondents’ web site.  Any person or 
entity wishing to comment on the Plan must do so in writing by submitting their 
comments, within thirty days of the date of the Notice: 

 
1. to the Office of the Secretary, United States Securities and Exchange 

Commission, 100 F Street, N.E., Washington, D.C. 20549-1090; 
2. by using the Commission’s Internet comment form 

(www.sec.gov/litigation/admin.shtml); or 
3. by sending an e-mail to [email protected].    

 18

mailto:[email protected]
http://www.sec.gov/litigation/admin.shtml


 
Such comments should include the Administrative Proceeding File Number 
(Admin. Proc. File No. 3-11814) in the subject line.  Comments received will be 
publicly available.  Persons should submit only information that they wish to 
make publicly available.  This Distribution Plan is subject to approval by the 
Commission and the Commission retains jurisdiction over the implementation of 
the Plan. 
 
Submitted on:  January 29, 2007  By: ____________________________ 

Lawrence A. Hamermesh, 
Independent Distribution 
Consultant for the Columbia Fair 
Fund 

 19



Appendix A 
 

The Fund Administrator 
 

The Fund Administrator has provided information regarding the Fund Administrator and 
its procedures to the IDC for inclusion in this Appendix. 

1. Custody / Risk Protection 
 

The Plan provides that money from the Qualified Settlement Fund, which is 
currently being held in the U.S. Treasury Bureau of Public Debt (“BPD”), would be 
transferred to one or more escrow accounts to be established by the Qualified 
Settlement Fund at the Escrow Bank, no more than two business days prior to the date 
on which checks would be mailed to shareholders, and that on behalf of the Qualified 
Settlement Fund, Rust Consulting, Inc (“Fund Administrator”) would manage the printing 
and mailing of checks that would be drawn on those escrow accounts, subject to 
procedures described below to protect against misappropriation.   

 
The distribution of the Qualified Settlement Fund will take place in multiple steps, 

rather than all at once.  The monies will be transferred from the BPD to the Escrow 
Bank two business days before each of those steps, thus minimizing the amount of time 
that the monies are held pending actual distribution to shareholders.  The Fund 
Administrator contemplates that the steps in the distribution of the Qualified Settlement 
Fund will include: 

 
• Distribution of checks to contemporaneous Columbia Funds retail holders and 

other direct record owners (“direct accounts”) in successive mailings, beginning 
with reliable/clear addresses. 

• Distributions to Omnibus Accounts.  Monies will not be transferred from the 
Qualified Settlement Fund to the Escrow Bank until the Omnibus Account is 
prepared to complete the distribution of any payment they receive under the Plan 
to its Beneficial Shareholders. 

 
As a result, much less than the full amount of the Qualified Settlement Fund will ever be 
in the control of the Escrow Bank and/or the Fund Administrator at any given time.  

 Once the Fund Administrator has completed calculations for the account holder 
distribution accounts, the IDC will take steps sufficient to satisfy the IDC as to the 
accuracy of the Fund Administrator’s calculations, including reference to determinations 
by Lexecon as to whether its own calculations agree with those of the Fund 
Administrator.  Once the IDC is satisfied with the accuracy of the calculations, those 
calculations will be the basis on which the positive pay file described in paragraph 7.14 
of the Plan and ultimately used to control the distribution is generated. 

 Page 1 of 3The cost of obtaining a bond under the circumstances of this proceeding, in lieu 
of the protections described in this Appendix and in the Plan itself, would be prohibitive, 
even if such a bond could be obtained at all. 

2. Custody Procedures 
 

The Fund Administrator specializes in claims administration and the development 
and implementation of plans for the distribution of settlement funds, and has 
administered more than 500 cases worth billions of dollars with class sizes ranging from 
80 class members to more than 100 million.  The Fund Administrator has been in 
existence since 1976 and has never had any occurrence of employee or vendor 
problems or claims against its Errors & Omissions insurance due to employee theft or 
dishonesty.  Over the past three years alone, the Fund Administrator has distributed 
approximately $1.8 billion in settlement disbursements to approximately 9.6 million 
recipients without incident. The Fund Administrator typically oversees the check printing 
process and relies on a third-party check-printing vendor.   
 

The Fund Administrator’s databases are configured so that modifications can 
only be made to data through programs; individuals are not allowed direct access to 
underlying production databases.  Only designated individuals with security clearances 
at the Fund Administrator can access data used in completing the distribution.  If an 
individual has security clearance to make changes in data (e.g., to update an address 
through an on-line screen), all original data (e.g., the original address) is automatically 
maintained by the Fund Administrator’s systems, and the system records the identity of 
the individual who made the change.  Individuals cannot alter award amounts. Duties 
are segregated: award calculations are separate from the preparation of checks, which 
is in turn separate from submission of files to a bank, so that no individual or working 
team could affect more than one of these processes. 

 
3. Additional Risk Protection 

 
 The Escrow Bank, which will hold Plan assets during the check-cashing period, 
maintains a Financial Institutions (FI) Bond including errors and omissions coverage 
with an aggregate limit of 200 MM Euro.  The primary insurer is American International 
Group, which, as of its most recent renewal, was rated A+ by A.M. Best.  The Escrow 
Bank has 200 MM Euro of E&O insurance.  In addition, the Escrow Bank has a bankers 
blanket bond of 250 MM Euro from Chubb (which is rated A++ by A.M. Best), which the 
Escrow Bank has advised the IDC includes coverage for wrongful acts (i.e., an act, 
errors and omissions, misstatement, etc.) or failure to safeguard proprietary information 
in connection with rendering of professional services.  The Fund Administrator has $10 
million in E&O insurance, as well as $2 million fiduciary insurance. The Escrow Bank 
annually assesses the adequacy of its policy limits through extensive analysis of 
historical loss data, exposure to loss and internal company controls.  

The Fund Administrator maintains and will continue to maintain until termination 
of Plan, an errors and omissions insurance policy.  The primary insurer, Illinois Union 
Insurance Co, is a company which, as of its most recent renewal, was rated A+ by A.M. 

 Page 2 of 3 
 



Best.  The policy is in the amount of $10 million per occurrence.  The Fund 
Administrator also maintains, and will continue to maintain until termination of Plan, a 
fiduciary insurance policy. The primary insurer, St. Paul Companies, is a company 
which, as of its most recent renewal, was rated A+ by A.M. Best.  The policy is in the 
amount of $2 million per occurrence.  The Fund Administrator’s print vendor maintains 
and will continue to maintain until termination of Plan, an errors and omissions 
insurance policy.  The primary insurer, Illinois Union Insurance Co (ACE USA), is a 
company which, as of its most recent renewal, was rated A+ by A.M. Best.  The policy is 
in the amount of $25 million per occurrence.  Under the Plan of Distribution, at no time 
will there be funds under the custody and control of the Fund Administrator that exceed 
the amount covered by insurance.  Certificates of insurance for these policies have 
been provided to the assigned SEC staff for review and have been deemed “not 
unacceptable.”  

 
Definitions 

 “Escrow Bank” means Deutsche Bank or such other bank as shall be selected by the 
IDC and determined to be acceptable by the staff of the Commission  

“Rust” mean Rust Consulting, Inc., experts in the development and implementation of 
plans for the distribution of settlement funds. 

“Fund Administrator” means Rust or such other entity as shall be acceptable to the staff 
of the Commission. 

“Omnibus Account” means an account registered in the name of a broker-dealer or 
other financial intermediary which holds shares as the record owner for the benefit of 
more than one beneficial shareholder.   

 Page 3 of 3 
 



Table 1

Participating Funds
(Amounts in $ Millions)

06/28/06

Dilution (Present Value of Hybrid Model)

Present Value of
Estimated

Transaction Costs

 Fund Fund Assets Assets Trading Accounts Accounts Total Trading Accounts Trading Fees Fees
Average Average Fund Arrangement Retail Omnibus Arrangement Other Arrangement Costs and Costs and

Percent of W/ Transaction Transactions
Dilution As Accounts Dilution, Dilution,

To Total Cumulative
Allocated Value of

Fees Present
Management

Net

 Funds With Arrangement Trading

1 SR INTERNATIONAL FUND 7.37 169.46 2.04 6.52 3.93 12.49 0.12 0.48 0.03 13.12 13.1

2 COLUMBIA NEWPORT TIGER FUND 6.08 620.98 16.29 5.61 15.87 37.77 0.58 0.77 0.23 39.35 52.5

3 LIBERTY NEWPORT INTL EQUITY FUND 4.91 170.40 2.06 5.86 0.44 8.36 0.11 0.38 0.02 8.87 61.3

4 COLUMBIA INTERNATIONAL EQUITY FUND 3.29 606.48 0.77 13.11 6.05 19.93 0.05 0.88 0.00 20.86 82.2

5 COLUMBIA ACORN INTL SELECT FUND 2.53 61.88 0.29 0.51 0.76 1.57 0.01 0.07 0.01 1.66 83.9

6 COLUMBIA GLOBAL EQUITY FUND 2.10 164.40 0.02 3.43 0.00 3.45 0.00 0.21 0.00 3.66 87.5

7 COLUMBIA ACORN INTERNATIONAL FUND 0.65 1,778.25 2.52 2.31 6.81 11.64 0.16 0.43 0.04 12.27 99.8

8 COLUMBIA SMALL CAP VALUE FUND 0.40 421.02 0.14 1.56 -0.01 1.69 0.11 0.37 0.00 2.17 102.0

9 COLUMBIA GROWTH STOCK FUND 0.39 715.44 2.57 0.02 0.18 2.76 0.37 0.11 0.04 3.28 105.2

10 COLUMBIA YOUNG INVESTOR FUND 0.28 948.86 2.07 0.76 -0.19 2.64 0.51 0.16 0.05 3.36 108.6

11 LIBERTY GROWTH STOCK FUND 0.22 693.36 1.47 0.22 -0.15 1.53 0.11 0.01 0.06 1.71 110.3

Funds Without Arrangement Trading

12 WANGER FOREIGN FORTY 3.39 14.65 0.50 0.50 0.04 0.54 110.8

13 WANGER INTERNATIONAL SMALL CAP FUND 2.43 254.93 6.18 6.18 0.40 6.58 117.4

14 COLUMBIA SMALL COMPANY EQUITY FUND 2.17 411.48 8.23 0.69 8.93 1.62 10.55 128.0

15 COLUMBIA NEWPORT JAPAN OPPS FUND 1.99 40.07 0.21 0.58 0.80 0.04 0.84 128.8

16 1784 INTERNATIONAL EQUITY 1.39 484.80 0.61 6.15 6.76 0.31 7.07 135.9

17 SR CAPITAL OPPORTUNITIES FUND 1.13 390.20 4.22 0.20 4.42 0.62 5.04 140.9

18 1784 GROWTH 0.78 146.43 0.98 0.17 1.15 0.15 1.30 142.2

19 COLUMBIA INTERNATIONAL STOCK FUND 0.65 224.20 0.43 1.02 1.46 0.07 1.53 143.8

20 COLUMBIA NEWPORT GREATER CHINA FUND 0.46 54.26 0.11 0.14 0.25 0.02 0.27 144.0



Table 2

Dilution of Columbia Funds By Descending Dilution As Percent of Fund Assets
(Amounts in $ Millions)

Page 1
06/28/06

Dilution (Present Value of Hybrid Model)

Present Value of
Estimated

Transaction Costs

 Fund Fund Assets Assets Trading Accounts Accounts Total Trading Accounts Trading Fees Fees
Average Average Fund Arrangement Retail Omnibus Arrangement Other Arrangement Costs and Costs and

Percent of W/ Transaction Transactions
Dilution As Accounts Dilution, Dilution,

To Total Cumulative
Allocated Value of

Fees Present
Management

Net

 1 SR INTERNATIONAL FUND 7.37 169.46 2.04 6.52 3.93 12.49 0.12 0.48 0.03 13.12 13.12

2 COLUMBIA NEWPORT TIGER FUND 6.08 620.98 16.29 5.61 15.87 37.77 0.58 0.77 0.23 39.35 52.47

3 LIBERTY NEWPORT INTL EQUITY FUND 4.91 170.40 2.06 5.86 0.44 8.36 0.11 0.38 0.02 8.87 61.33

4 WANGER FOREIGN FORTY 3.39 14.65 0.50 0.50 0.04 0.54 61.87

5 COLUMBIA INTERNATIONAL EQUITY FUND 3.29 606.48 0.77 13.11 6.05 19.93 0.05 0.88 0.00 20.86 82.74

6 COLUMBIA ACORN INTL SELECT FUND 2.53 61.88 0.29 0.51 0.76 1.57 0.01 0.07 0.01 1.66 84.39

7 WANGER INTERNATIONAL SMALL CAP FUND 2.43 254.93 6.18 6.18 0.40 6.58 90.97

8 COLUMBIA SMALL COMPANY EQUITY FUND 2.17 411.48 8.23 0.69 8.93 1.62 10.55 101.52

9 COLUMBIA GLOBAL EQUITY FUND 2.10 164.40 0.02 3.43 0.00 3.45 0.00 0.21 0.00 3.66 105.18

10 COLUMBIA NEWPORT JAPAN OPPS FUND 1.99 40.07 0.21 0.58 0.80 0.04 0.84 106.02

11 1784 INTERNATIONAL EQUITY 1.39 484.80 0.61 6.15 6.76 0.31 7.07 113.09

12 SR CAPITAL OPPORTUNITIES FUND 1.13 390.20 4.22 0.20 4.42 0.62 5.04 118.13

13 COLUMBIA EUROPE FUND 1.01 6.85 0.05 0.02 0.07 0.00 0.07 118.20

14 1784 GROWTH 0.78 146.43 0.98 0.17 1.15 0.15 1.30 119.50

15 COLUMBIA ACORN INTERNATIONAL FUND 0.65 1,778.25 2.52 2.31 6.81 11.64 0.16 0.43 0.04 12.27 131.78

16 COLUMBIA INTERNATIONAL STOCK FUND 0.65 224.20 0.43 1.02 1.46 0.07 1.53 133.30

17 COLUMBIA NEWPORT GREATER CHINA FUND 0.46 54.26 0.11 0.14 0.25 0.02 0.27 133.57

18 COLUMBIA SMALL CAP VALUE FUND 0.40 421.02 0.14 1.56 -0.01 1.69 0.11 0.37 0.00 2.17 135.74

19 COLUMBIA GROWTH STOCK FUND 0.39 715.44 2.57 0.02 0.18 2.76 0.37 0.11 0.04 3.28 139.02

20 SR SMALL COMPANY GROWTH FUND 0.34 21.00 0.08 -0.01 0.07 0.01 0.08 139.10

21 COLUMBIA NEWPORT ASIA PACIFIC FUND 0.29 12.94 0.00 0.03 0.01 0.04 0.00 0.00 0.04 139.14

22 COLUMBIA YOUNG INVESTOR FUND 0.28 948.86 2.07 0.76 -0.19 2.64 0.51 0.16 0.05 3.36 142.50

23 LIBERTY GROWTH STOCK FUND 0.22 693.36 1.47 0.22 -0.15 1.53 0.11 0.01 0.06 1.71 144.21

24 COLUMBIA SMALL COMPANY INDEX FUND 0.13 266.70 0.35 0.01 0.36 0.05 0.41 144.62

25 COLUMBIA LARGE CAP GROWTH FUND 0.09 1,384.32 0.95 0.25 1.19 0.18 1.37 146.00

26 COLUMBIA PA INTERM MUNI BOND FUND 0.07 26.73 0.02 0.02 0.00 0.02 146.02

27 COLUMBIA MID CAP VALUE FUND 0.07 1,123.54 0.13 0.58 0.05 0.77 0.01 0.12 0.00 0.90 146.92

28 GALAXY UTILITY INDEX FUND 0.06 58.80 0.03 0.03 0.00 0.03 146.96

29 LIBERTY CONTRARIAN EQUITY FUND 0.04 97.45 0.04 0.00 0.04 0.01 0.05 147.01

30 COLUMBIA LARGE COMPANY INDEX FUND 0.04 867.06 -0.11 0.02 0.43 0.35 0.01 0.17 0.53 147.54

31 COLUMBIA TAX EXEMPT FUND 0.04 2,070.24 0.09 0.67 0.01 0.76 0.05 0.21 0.01 1.03 148.57

32 COLUMBIA MANAGED MUNICIPALS FUND 0.04 465.40 0.08 0.08 0.17 0.05 0.22 148.78

33 SR DISCIPLINED STOCK FUND 0.03 513.50 0.14 0.04 0.18 0.00 0.18 148.96

34 COLUMBIA DISCIPLINED VALUE FUND 0.03 417.36 0.07 0.08 0.14 0.01 0.15 149.12

35 COLUMBIA GROWTH & INCOME FUND 0.03 1,643.16 0.03 0.32 0.10 0.46 0.03 0.01 0.50 149.61

36 GALAXY CONNECTICUT MUNI BOND FUND 0.02 37.20 0.00 0.01 0.01 0.00 0.01 149.62

37 COLUMBIA OREGON MUNICIPAL BOND FUND 0.02 484.20 0.06 0.01 0.07 0.03 0.10 149.72



Table 2

Dilution of Columbia Funds By Descending Dilution As Percent of Fund Assets
(Amounts in $ Millions)

Page 2
06/28/06

Dilution (Present Value of Hybrid Model)

Present Value of
Estimated

Transaction Costs

 Fund Fund Assets Assets Trading Accounts Accounts Total Trading Accounts Trading Fees Fees
Average Average Fund Arrangement Retail Omnibus Arrangement Other Arrangement Costs and Costs and

Percent of W/ Transaction Transactions
Dilution As Accounts Dilution, Dilution,

To Total Cumulative
Allocated Value of

Fees Present
Management

Net

 38 SR BALANCED FUND 0.01 215.47 0.04 -0.01 0.03 0.01 0.04 149.76

39 COLUMBIA BALANCED FUND 0.01 875.12 0.00 0.10 0.10 0.09 0.19 149.95

40 COLUMBIA INTERM GOVERNMENT INCOME FD 0.01 468.44 0.05 0.01 0.05 0.00 0.05 150.01

41 SR GROWTH AND INCOME FUND 0.01 345.00 0.00 0.03 0.03 0.07 0.10 150.10

42 COLUMBIA HIGH YIELD OPPORTUNITY FUND 0.01 880.38 0.07 0.00 0.08 0.01 0.09 150.19

43 SR INTERMEDIATE MUNICIPALS FUND 0.01 145.07 0.01 0.00 0.01 0.00 0.01 150.21

44 COLUMBIA HIGH YIELD MUNICIPAL FUND 0.01 277.80 0.00 0.02 0.02 0.00 0.02 150.23

45 COLUMBIA LARGE CAP CORE FUND 0.01 661.86 0.06 -0.01 0.04 0.00 0.04 150.28

46 GALAXY TAX EXEMPT BOND FUND 0.00 193.77 0.01 0.00 0.01 0.01 0.02 150.29

47 COLUMBIA SHORT TERM BOND FUND 0.00 199.30 -0.02 0.02 0.00 0.01 0.00 0.00 0.01 150.29

48 COLUMBIA FLORIDA INTERM MUNI BOND FD 0.00 70.48 0.00 0.00 0.00 0.00 0.00 150.30

49 COLUMBIA NY INTERM MUNI BOND FUND 0.00 101.08 0.00 0.00 0.00 0.00 0.00 150.30

50 COLUMBIA MA INTERM MUNI BOND FUND 0.00 280.93 0.01 0.00 0.01 0.01 0.02 150.31

51 1784 US GOVT MED TERM INCOME 0.00 259.60 0.00 0.00 0.00 0.00 0.00 150.32

52 COLUMBIA TAX EXEMPT INSURED FUND 0.00 176.68 0.00 0.00 0.00 0.00 0.00 150.32

53 CMG HIGH YIELD FUND 0.00 359.98 0.00 0.00 0.00 0.00 0.00 150.32

54 COLUMBIA UTILITIES FUND 0.00 814.04 0.00 0.00 0.00 0.00 150.32

55 COLUMBIA ASSET ALLOCATION FUND 0.00 460.50 0.00 0.00 0.00 0.07 0.07 150.40

56 COLUMBIA INTERM TAX EXEMPT BOND FUND 0.00 339.12 -0.01 0.01 0.00 0.00 0.00 0.00 0.00 150.40

57 COLUMBIA US TREASURY INDEX FUND 0.00 173.18 0.00 0.00 0.00 0.00 0.00 150.40

58 CMG STRATEGIC EQUITY FUND 291.50 -0.02 0.00 -0.02 0.00 -0.02 150.40

59 COLUMBIA ACORN FUND 6,387.70 -0.11 -2.20 -2.31 0.01 -2.30 150.41

60 COLUMBIA ACORN SELECT FUND 266.05 0.00 -0.01 -0.01 0.00 -0.01 150.41

61 COLUMBIA ACORN USA FUND 383.33 0.00 -0.13 -0.13 0.01 -0.12 150.43

62 COLUMBIA CALIFORNIA TAX EXEMPT FUND 289.50 0.00 0.00 0.00 0.00 0.00 150.43

63 COLUMBIA COMMON STOCK FUND 654.24 -0.03 -0.35 -0.38 0.05 -0.33 150.48

64 COLUMBIA CONNECTICUT TAX EXEMPT FUND 184.07 0.00 0.00 0.00 0.00 0.00 150.48

65 COLUMBIA CONTRARIAN INCOME FUND 30.28 -0.01 0.00 -0.01 0.00 -0.01 150.48

66 COLUMBIA CORPORATE BOND FUND 134.96 0.00 0.00 0.00 0.00 0.00 150.48

67 COLUMBIA CT INTERM MUNI BOND FUND 149.98 0.00 0.00 0.00 0.00 150.48

68 COLUMBIA EUROPEAN THEMATIC EQUITY FD -0.01 -0.01 0.00 -0.01 150.48

69 COLUMBIA FEDERAL SECURITIES FUND 903.05 -0.01 -0.01 -0.02 0.00 -0.02 150.49

70 COLUMBIA FIXED INCOME SECURITIES FD 459.28 -0.13 -0.07 -0.20 0.05 -0.15 150.54

71 COLUMBIA FLOATING RATE ADVANTAGE FD 243.33 0.00 0.00 0.00 0.00 0.00 150.54

72 COLUMBIA FLOATING RATE FUND 467.42 0.00 -0.01 -0.01 0.00 0.00 -0.01 150.54

73 COLUMBIA GROWTH FUND 1,387.42 -0.06 -0.29 -0.35 0.07 -0.28 150.61

74 COLUMBIA HIGH YIELD FUND 588.02 0.04 -0.15 -0.16 -0.26 0.00 0.10 -0.16 150.71



Table 2

Dilution of Columbia Funds By Descending Dilution As Percent of Fund Assets
(Amounts in $ Millions)

Page 3
06/28/06

Dilution (Present Value of Hybrid Model)

Present Value of
Estimated

Transaction Costs

 Fund Fund Assets Assets Trading Accounts Accounts Total Trading Accounts Trading Fees Fees
Average Average Fund Arrangement Retail Omnibus Arrangement Other Arrangement Costs and Costs and

Percent of W/ Transaction Transactions
Dilution As Accounts Dilution, Dilution,

To Total Cumulative
Allocated Value of

Fees Present
Management

Net

 75 COLUMBIA INCOME FUND 383.50 0.00 -0.14 -0.15 0.03 -0.12 150.73

76 COLUMBIA INTERMEDIATE BOND FUND 894.20 -0.07 -0.15 -0.22 0.09 -0.13 150.82

77 COLUMBIA LIBERTY FUND 1,198.36 -0.03 0.00 -0.03 0.00 -0.03 150.82

78 COLUMBIA MA TAX EXEMPT FUND 211.90 -0.01 0.00 0.00 -0.01 0.00 0.00 -0.01 150.82

79 COLUMBIA MID CAP GROWTH FUND 857.54 -0.15 -1.19 -1.35 0.52 -0.83 151.34

80 COLUMBIA NEW YORK TAX EXEMPT FUND 105.32 0.00 0.00 0.00 0.00 0.00 151.34

81 COLUMBIA NJ INTERM MUNI BOND FUND 89.10 0.00 0.00 0.00 0.00 0.00 151.34

82 COLUMBIA QUALITY PLUS BOND FUND 723.74 0.00 -0.04 -0.04 0.01 -0.03 151.36

83 COLUMBIA REAL ESTATE EQUITY FUND 592.44 -0.37 -0.97 -1.34 0.20 -1.14 151.55

84 COLUMBIA RI INTERM MUNI BOND FUND 148.80 0.00 0.00 0.00 0.00 0.00 151.55

85 COLUMBIA SMALL CAP FUND 760.64 -0.06 -0.07 -0.14 0.03 -0.11 151.58

86 COLUMBIA SMALL CAP GROWTH FUND 496.08 -0.18 -2.17 -2.35 0.14 -2.21 151.72

87 COLUMBIA STRATEGIC INCOME FUND 1,249.86 0.00 -0.02 -0.02 0.00 -0.02 151.72

88 COLUMBIA STRATEGIC INVESTOR FUND 324.00 -0.25 -0.23 -0.48 0.09 -0.39 151.81

89 COLUMBIA TAX MANAGED GROWTH FUND 464.42 0.00 0.00 0.00 0.00 0.00 151.81

90 COLUMBIA TAX MANAGED VALUE FUND 0.00 0.00 0.00 0.00 151.81

91 COLUMBIA TECHNOLOGY FUND 17.47 -0.02 0.00 -0.02 0.00 -0.02 151.81

92 GALAXY EQUITY INCOME FUND 298.13 0.00 0.00 0.00 0.00 0.00 151.81

93 GALAXY GROWTH AND INCOME FUND 0.02 0.00 0.02 0.00 0.02 151.83

94 GALAXY LARGE CAP GROWTH FUND 172.30 -0.04 -0.04 0.00 -0.04 151.83

95 GALAXY LARGE CAP VALUE FUND 172.50 -0.19 -0.19 0.03 -0.16 151.86

96 GALAXY MUNICIPAL BOND FUND 0.00 0.00 0.00 0.00 151.86

97 GALAXY SHORT TERM BOND FUND 102.60 0.00 0.00 0.00 0.00 0.00 151.87

98 GALAXY VIP ASSET ALLOCATION 0.00 0.00 0.00 0.00 151.87

99 GALAXY VIP EQUITY -0.01 -0.01 0.00 -0.01 151.87

100 LIBERTY ALL STAR EQUITY FUND -0.06 -0.06 0.01 -0.05 151.88

101 LIBERTY CONTRARIAN BALANCED FUND 0.00 0.00 0.00 0.00 151.88

102 LIBERTY CONTRARIAN SMALL CAP FUND 41.35 -0.11 -0.03 -0.14 0.00 -0.14 151.88

103 LIBERTY COUNSELOR BALANCED PORTFOLIO 0.00 0.00 0.00 0.00 151.88

104 LIBERTY COUNSELOR GROWTH PORTFOLIO 0.00 0.00 0.00 0.00 151.88

105 LIBERTY EQUITY FUND VS 0.01 0.01 0.00 0.01 151.89

106 LIBERTY FLORIDA TAX EXEMPT FUND 0.00 0.00 0.00 0.00 151.89

107 LIBERTY GROWTH INVESTOR FUND 0.00 0.00 0.00 0.00 151.89

108 LIBERTY HIGH YIELD MUNICIPAL FUND 153.73 -0.01 -0.01 0.00 -0.01 151.89

109 LIBERTY INTERMEDIATE GOVERNMENT FUND 884.58 0.01 -0.01 -0.01 -0.02 0.03 0.04 0.05 151.96

110 LIBERTY INTERMEDIATE TAX EXEMPT FUND 0.00 0.00 0.00 0.00 151.96

111 LIBERTY MIDCAP GROWTH FUND -0.01 -0.01 0.00 -0.01 151.96



Table 2

Dilution of Columbia Funds By Descending Dilution As Percent of Fund Assets
(Amounts in $ Millions)

Page 4
06/28/06

Dilution (Present Value of Hybrid Model)

Present Value of
Estimated

Transaction Costs

 Fund Fund Assets Assets Trading Accounts Accounts Total Trading Accounts Trading Fees Fees
Average Average Fund Arrangement Retail Omnibus Arrangement Other Arrangement Costs and Costs and

Percent of W/ Transaction Transactions
Dilution As Accounts Dilution, Dilution,

To Total Cumulative
Allocated Value of

Fees Present
Management

Net

 112 LIBERTY NEWPORT TIGER CUB FUND 0.06 0.06 0.00 0.06 152.03

113 LIBERTY OHIO TAX EXEMPT FUND 0.00 0.00 0.00 0.00 152.03

114 LIBERTY REAL ESTATE FUND 0.00 0.00 0.00 0.00 0.00 152.03

115 LIBERTY SHORT TERM GOVERNMENT FUND 24.40 0.00 0.00 0.00 0.00 152.03

116 LIBERTY STRATEGIC BALANCED FUND 0.00 0.00 0.00 0.00 152.03

117 LIBERTY VALUE FUND 0.00 0.00 0.00 0.00 152.03

118 SR ADV HIGH YIELD MUNICIPALS BOND FD 0.00 0.00 0.00 0.00 152.03

119 SR ADVISOR INTERMEDIATE BOND FUND 0.00 0.00 0.00 0.00 152.03

120 SR FOCUS FUND 54.00 0.00 0.00 0.00 0.00 152.03

121 SR HIGH YIELD FUND 31.43 -0.06 -0.01 -0.07 0.01 -0.06 152.04

122 SR MIDCAP GROWTH FUND 41.80 -0.02 0.00 -0.02 0.02 0.00 152.07

123 WANGER TWENTY FUND 19.90 -0.03 -0.03 0.00 -0.03 152.07

124 WANGER US SMALLER COMPANIES FUND 436.93 -0.15 -0.15 0.10 -0.05 152.17

125 1784 ASSET ALLOCATION 0.01 0.00 0.01 0.00 0.01 152.19

126 1784 CT INT TAX EXEMPT INCOME 0.00 0.00 0.00 0.00 0.00 152.19

127 1784 GROWTH AND INCOME 559.00 -0.30 -0.01 -0.31 0.00 -0.31 152.19

128 1784 INCOME FUND 323.00 0.00 -0.05 -0.04 0.06 0.02 152.25

129 1784 MA INT TAX EXEMPT INCOME 245.60 0.00 0.00 0.00 0.00 0.00 152.25

130 1784 RI TAX EXEMPT INCOME 91.40 0.00 0.00 0.00 0.00 152.25

131 1784 SHORT TERM INCOME 144.90 0.00 0.00 0.00 0.00 152.25

Total For Funds With Positive Dilution 30.37 58.81 50.33 139.51 2.26 10.00 0.49 152.3

These calculations include only pairs with holding periods of 1 to 7 trading days for omnibus and retail accounts and
1 to 21 trading days for episode accounts.

For a given retail account / fund, calculations begin after the first two round-trips in a 90 days, or five round trips
in 365 days.  For omnibus accounts, calculations begin after the first five round trips in 90 days, or ten in 365 days.

LIFO pairs for omnibus accounts were restricted to those purchased on the same date that an episode account or a retail account
meeting the above screens also made a purchase in the same fund, with the exception that all omnibus trades were included after
Columbia imposed redemption fees on retail accounts for short-term trading of international funds.  For Wanger funds,
trades were limited to those purchased on the same date as a retail or episode trade, subject to the screens above,
in any other Columbia international fund.

Fund asset data was obtained from Morningstar.

Dilution attributable to timing through Banc of America Securities through Canary and the Introducing Brokers is excluded.

Note: