Unless otherwise determined by the Board of Directors (the "Board"), the Compliance Committee of General American Investors Company, Inc. (the "Company") shall be comprised of at least three directors, none of whom shall be an "interested person," as defined in Section 2(a)19 of the Investment Company Act of 1940, as amended (the "1940 Act") of the Company.

Committee Purpose:

The purpose of the Committee is to assist the Board in fulfilling its oversight responsibilities under the provisions of Rule 270.38a-1 under the Investment Company Act of 1940 (the "Compliance Rule"), including the responsibility of the Board to approve the Company's written compliance policies and procedures and those of its transfer agent, based on a finding by the Board that the policies and procedures are reasonably designed to prevent violation of the federal securities laws by the Company and its transfer agent.

Committee Responsibilities:

The Committee shall have the following duties and responsibilities:

1. Review with management compliance policies and procedures and assist management with a presentation of the policies and procedures to the Board.
   
   
2. At least annually, receive from and review with the chief compliance officer the "Annual Review" of the adequacy of the compliance policies and procedures of the Company and its transfer agent and the effectiveness of the implementation of the policies and procedures.
   
   
3. At least annually, receive from and review with the chief compliance officer a written report to the Board regarding the operation of the compliance policies and procedures, any material changes to the policies and procedures, any material changes recommended and each material compliance matter (i.e., violation of federal securities laws or the policies and procedures or weaknesses in the policies and procedures).
   
   
4. Report to the Board on a regular basis, and not less than once per year.
   
   
5. In conjunction with the annual self-assessment performed by the Board of Directors, the Committee's performance under this Compliance Committee Charter will be evaluated and the adequacy of the Compliance Committee Charter will be considered.
   
   
6. Perform any other duties or responsibilities delegated to the Committee by the Board.
   
   

Committee Structure and Operations:

The Board shall designate one member of the Committee as its chairperson. The Committee shall meet at least once a year at a time and place determined by the Committee chairperson, with further meetings to occur, or actions to be taken by unanimous written consent, when deemed necessary or desirable by the Committee or its chairperson. The Committee may request any officer or employee of the Company or the Company's outside counsel, independent auditors or other consultants to attend a meeting of the Committee or to meet with any members of, or consultants to, the Committee. Members of the Committee may participate in a meeting of the Committee by means of conference call or similar communications equipment by means of which all persons participating in the meeting can hear each other.

Delegation to Subcommittees:

The Committee may, in its discretion, delegate all or a portion of its duties and responsibilities to subcommittees of the Committee.

Resources and Authority of the Committee:

The Committee shall have the resources and authority appropriate to discharge its duties and responsibilities, including the authority to select, retain, terminate, and approve the fees and other retention terms of special counsel or other experts or consultants, as it deems appropriate, without seeking approval of the Board or management.

October 11, 2006