Comstock’s approach is wide-ranging, including the analysis of specific equities, general stock market strategy, interest rates and real estate as well as long term macroeconomic themes centering on the interaction of inflation, debt, interest rates, economic growth and their effects on the stock, bond, commodity and currency markets. Comstock Partners started implementing these strategies when they began managing the Dreyfus Capital Value Fund (presently the Comstock Partners Capital Value Fund) in 1987 and launched the Comstock Partners Strategy Fund in 1988. In May of 2000 the Shareholders of Comstock Funds voted to join the Gabelli Family of Mutual Funds.

Investment Style

Comstock Partners, Inc. analyzes economic and financial conditions from a long-term macro-economic perspective and makes adjustments based on cyclical and shorter-term considerations. In pursuit of its goals, the firm invests in various asset classes including domestic and foreign stocks, bonds, currencies and derivatives including indices and options. For the Capital Value Fund, Comstock Partners can buy or sell short and make use of leverage in order to maximize returns under various market conditions. In effect, we believe our operation resembles a modern-day hedge fund in its scope of activities.

For each of its asset classes, Comstock adheres to macro-economic themes while also utilizing a disciplined investment philosophy that attempts to remove the emotional element of investing by focusing on data that, in the past, has exhibited a correlation with an asset’s future price movement. Such data may be fundamental or technical and includes indicators relating to the economy, money and credit, valuation, price momentum and investor sentiment. While each of these indicators may provide some degree of insight into the future performance of a particular investment, Comstock believes that an appropriate combination of these tools provides the highest probability of accurate market timing and security selection. Investing, of course, inherently involves subjective judgements and there can be no assurance that Comstock’s investment approach will prove successful.