
This matter involves a materially deceptive statement by SCM, and the failure of SCM to fully and effectively disclose material facts in the Fund’s 2002-2003 shareholder reports concerning forbearance agreements that the Fund entered into with two obligors on bonds in the Fund’s portfolio. During the period of 2001-03, the Fund entered into these forbearance agreements, under which the Fund agreed to temporarily accept partial payment of the original coupon interest rates. The projects for which the bonds were issued were in financial distress and requested temporary interest rate relief. The two bonds that were subject to these forbearance agreements together comprised between 9% and 15% of the Fund’s net assets during the relevant period. The Fund and other mutual funds in the Strong Funds Complex were the sole or majority owners of these bonds. One of the bonds was the Fund’s largest single holding during the relevant period. Absent these forbearance agreements, the bonds would have been in default for failure to make required interest payments.