Date Shares Price Per Share
06/05/09 (125) $5.47
06/10/09 (195) $5.52
06/11/09 2350 $5.60
06/12/09 650 $5.61
06/23/09 (40) $5.46
06/24/09 (180) $5.56
06/25/09 (90) $5.51
06/30/09 (40) $5.58
07/27/09 (125) $6.08
07/31/09 820 $6.22
08/03/09 250 $6.39
The Accounts have the right to receive all dividends from, and any proceeds from the sale of the Shares. None of the Accounts has an interest in Shares constituting more than 5% of the Shares outstanding.
Item 6. Contracts, Arrangements, Understandings, or Relationships with Respect to Securities of the Issuer.
Except as described above, there are no contracts, arrangements, understandings or relationships of any kind among the Principals and KIM and between any of them and any other person with respect to any of the SNF securities.
Item 7. Materials to be Filed as Exhibits.
As is indicated in Item 4, above, KIM has purchased SNF for the Accounts for investment purposes. However, KIM has reserved the right to contact management with regard to concerns that they have with respect to the Fund, including letters to the Board and/or other communications with fund management. Accordingly, KIM sent a letter to the Fund on August 5, 2009. A copy of the letter is attached as Exhibit 1.
SIGNATURE
After reasonable inquiry and to the best of my knowledge and belief, I certify that the information set forth in this statement is true, complete, and correct.
Karpus Management, Inc.
By: /s/
Name: Cody B. Bartlett Jr., CFA
Title: Managing Director of Investments
Date: August 6, 2009
EXHIBIT 1
Letter to the Fund
Transmitted August 5, 2009
The Board of Directors August 5, 2009
The Spain Fund, Inc.
1345 Avenue of the Americas, 41st Floor
New York, New York 10105
Attn: Emilie D. Wrapp, Secretary
Re: The Spain Fund, Inc. (the "Fund" NYSE: SNF)
Dear Board Members:
We have read your press release of July 31, 2009 and are extremely disappointed with your decision to approve the suspension of the Fund's managed distribution policy, effective after the distribution in the third quarter of 2009.
Your original premise to install this policy gave shareholders both capital appreciation and income validation, as well as the inference that the Fund was concerned with continually enhancing shareholder value. With these effects no longer being provided, our concern going forward is that current shareholders will be penalized by a widening discount to net asset value.
As a validation for our concerns, history has displayed that tampering with a fund's distribution policy disheartens shareholders and pressures the price of the security. For example, the Zweig family of funds went from a fixed 10% annual distribution to a variable distribution policy. This impacted both the Zweig Fund and the Zweig Total Return Fund. In fact, on July 14, 2003 (shortly after the announcement) ZF was trading at net asset value and within three weeks the ZF discount to net asset value fell to 14% on August 6, 2003. ZF took three and a half years before it recovered to trading at net asset value after KIM influenced management to reinstate the distribution. We do not want to witness similar effects with the discount to net asset value of SNF.
Consequently, we strongly urge you consider these facts before you proceed with the revocation of the managed distribution policy for the Fund.
Sincerely,
/s/
Mitchell Thomas
International Equities Analyst/Portfolio Manager