Common use of Anti-Money Laundering and Red Flag Identity Theft Prevention Programs Clause in Contracts

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust acknowledges that it has had an opportunity to review and consider the written procedures provided by USBGFS describing various tools used by USBGFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program and the Red Flag Identity Theft Prevention program, are reasonably designed to prevent the Trust from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBGFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering and identity theft responsibilities. The Trust acknowledges and agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (b) Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholder; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to the Procedures; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBGFS acknowledges, that USBGFS shall (i) permit federal regulators access to such information and records maintained by USBGFS and relating to USBGFS’ implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBGFS’ implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust Fund acknowledges that it has had an opportunity to review and consider the written procedures provided by USBGFS Fund Services describing various tools processes used by USBGFS Fund Services which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust Fund has determined that the Procedures, as part of the TrustFund’s overall anti-money laundering program and the Red Flag Identity Theft Prevention programidentity theft prevention program responsibilities, are reasonably designed to help: (i) prevent the Trust Fund from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Bank Secrecy Act, the USA Patriot Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, and the implementing regulations thereunderthereunder (together “AML Rules”). Based on this determination, the Trust Fund hereby instructs and directs USBGFS Fund Services to implement the Procedures Procedures, as applicable, on the TrustFund’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is Fund Services and any such amended Procedures will be provided relating to the Trust’s anti-money laundering Fund. Should the Fund desire that Fund Services perform services not provided for in the Procedures, such additional services and identity theft responsibilitiesthe associated cost must be specifically detailed in the attached fee schedule. The Trust Fund acknowledges and agrees that although it is directing USBGFS Fund Services to implement the Procedures on its behalf, USBGFS Fund Services is implementing the Procedures as a service provider to the Trust Fund and the Trust Fund is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003AML Rules, or otherwise, including, without limitationsuch as, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer, as applicable. The Trust Fund further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the TrustFund. The Trust Fund has had the opportunity to discuss the Procedures with USBGFSFund Services, and the Trust Fund understands and agrees which portions of the Procedures may not be implemented on behalf of the TrustFund. Without limitation of the foregoing, USBGFS Fund Services shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national National Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust Fund and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (b) Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholder; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to the Procedures; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust Fund hereby directs, and USBGFS Fund Services acknowledges, that USBGFS Fund Services shall (i) permit federal regulators access to such information and records maintained by USBGFS Fund Services and relating to USBGFSFund Services’ implementation of the Procedures, on behalf of the TrustFund, as they may request, and (ii) permit such federal regulators to inspect USBGFSFund Services’ implementation of the Procedures on behalf of the TrustFund.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust Fund acknowledges that it has had an opportunity to review review, consider and consider comment upon the written procedures provided by USBGFS Fund Services describing various tools used by USBGFS Fund Services which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has Fund and Fund Services have determined that the Procedures, as part of the TrustFund’s overall anti-money laundering program and the Red Flag Identity Theft Prevention program, are reasonably designed to to: (i) prevent the Trust Fund from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and (iii) to achieve compliance with the applicable provisions of the Fair Bank Secrecy Act and Accurate Credit Transactions the USA Patriot Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, 2001 and the implementing regulations thereunder. Based on this determination, the Trust Fund hereby instructs and directs USBGFS Fund Services to implement the Procedures on the TrustFund’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustFund’s anti-money laundering and identity theft responsibilities. The Trust acknowledges and Fund Services agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider provide to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary.: (a) Prompt written notification of any transaction or combination of transactions that USBGFS Fund Services believes, based on the Procedures, evidence money laundering laundering, activity that may warrant a suspicious activity report or identity theft activities in connection with the Trust Fund or any shareholder of the TrustFund; (b) Prompt written notification of any shareholder(scustomer(s) that USBGFS Fund Services reasonably believes, based upon the Procedures, to be engaged in money laundering laundering, activity that may warrant a suspicious activity report or identity theft activities, provided that the Trust Fund agrees not to communicate this information to the shareholdersuch customer; (c) Any reports received by USBGFS Fund Services from any government agency or applicable industry self-regulatory organization pertaining to Fund Services anti-money laundering monitoring or the ProceduresRed Flag Identity Theft Prevention Program on behalf of the Fund; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. Fund, including an annual certification that Fund Services has applied and followed the Procedures during the relevant reporting period; The Trust Fund hereby directs, and USBGFS Fund Services acknowledges, that USBGFS Fund Services shall (i) permit federal regulators access to such information and records maintained by USBGFS Fund Services and relating to USBGFS’ Fund Services implementation of the Procedures, Procedures on behalf of the TrustFund, as they it may request, and (ii) permit such federal regulators to inspect USBGFS’ Fund Services implementation of the Procedures on behalf of the TrustFund.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust acknowledges that it has had an opportunity to review review, consider and consider comment upon the written procedures provided by USBGFS USBFS describing various tools used by USBGFS which USBFS that are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity activity, as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has and USBFS have each determined that the Procedures, as part of the Trust’s overall anti-money laundering program and the Red Flag Identity Theft Prevention program, are reasonably designed to to: (i) prevent the Trust Fund from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), Fair and Accurate Credit Transactions Act of 2003 and the USA PATRIOT Patriot Act of 2001, 2001 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBGFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering and identity theft responsibilities. The Trust acknowledges and agrees that although it is directing USBGFS USBFS to implement the Procedures on its behalf, USBGFS USBFS is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the TrustFund. The Trust Fund has had the opportunity to discuss the Procedures with USBGFSUSBFS, and the Trust Fund understands and agrees which portions of the Procedures may not be implemented on behalf of the TrustFund. Without limitation of the foregoing, USBGFS USBFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary.. Based on this determination, the Trust hereby instructs and directs USBFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering and identity theft responsibilities. USBFS agrees to provide to the Trust: (a) A. Prompt written notification of any transaction or combination of transactions that USBGFS USBFS believes, based on the Procedures, evidence money laundering laundering, activity that may warrant a suspicious activity report or identity theft activities in connection with the Trust or any shareholder of the TrustFund; (b) B. Prompt written notification of any shareholder(scustomer(s) that USBGFS USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering laundering, activity that may warrant a suspicious activity report or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholdercustomer; (c) C. Any reports received by USBGFS USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring or the ProceduresRed Flag Identity Theft Prevention Program on behalf of the Trust; (d) D. Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a)subsections 5.A, (b) B or (c); andC above; (e) E. Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust; and F. Prompt written notification of any material changes to the Procedures. The Trust hereby directs, and USBGFS USBFS acknowledges, that USBGFS shall USBFS shall: (i) permit federal regulators access to such information and records maintained by USBGFS USBFS and relating to USBGFS’ USBFS’s implementation of the Procedures, on behalf of the Trust, as they may request, ; and (ii) permit such federal regulators to inspect USBGFS’ USBFS’s implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. Fund Services acknowledges and represents that (1) it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (“USA Patriot”) Act of 2001 and the Bank Secrecy Act (collectively the “AML Acts”) and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the “Applicable AML Laws”) in all relevant respects; and (2) it is subject to a rule implementing 31 U.S.C. 5318(h) (the anti-money laundering program provision of the USA Patriot Act) and is regulated by a federal functional regulator such as a federal banking regulator or the SEC. The Trust acknowledges that it has had an opportunity to review review, consider and consider comment upon the written procedures provided by USBGFS Fund Services describing various tools used by USBGFS Fund Services which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has and Fund Services have each determined that the Procedures, as part of the Trust’s overall antiAnti-money laundering program Money Laundering Program and the Red Flag Identity Theft Prevention programProgram, are reasonably designed to to: (i) prevent the Trust each Fund from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Bank Secrecy Act, Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), 2003 and the USA PATRIOT Patriot Act of 2001, 2001 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBGFS Fund Services to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering and identity theft responsibilities. The Trust acknowledges and Fund Services agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect provide to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary.: (a) Prompt written notification of any transaction or combination of transactions that USBGFS Fund Services believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the TrustFund shareholder; (b) Prompt written notification of any shareholder(scustomer(s) that USBGFS Fund Services reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholdercustomer; (c) Any reports received by USBGFS Fund Services from any government agency or applicable industry self-regulatory organization pertaining to Fund Services’ Anti-Money Laundering Program or the ProceduresRed Flag Identity Theft Prevention Program on behalf of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c)) immediately above; and (e) Certified annual and quarterly reports of its monitoring and customer identification activities pursuant to the Procedures on behalf of the Trust. The Trust hereby directs, and USBGFS Fund Services acknowledges, that USBGFS Fund Services shall (i) permit federal regulators access to such information and records maintained by USBGFS Fund Services and relating to USBGFSFund Services’ implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBGFSFund Services’ implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust acknowledges that it has had an opportunity to review review, consider and consider comment upon the written procedures provided by USBGFS Fund Services describing various tools used by USBGFS Fund Services which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program and the Red Flag Identity Theft Prevention program, are reasonably designed to prevent the Trust from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), 2003 and the USA PATRIOT Patriot Act of 2001, 2001 and the implementing regulations thereunderthereunder (together “AML Rules”). Based on this determination, the Trust hereby instructs and directs USBGFS Fund Services to implement the Procedures Procedures, as applicable, on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is t Fund Services and any such amended Procedures will be provided relating to the Trust’s anti-money laundering . Should the Trust desire that Fund Services perform services not provided for in the Procedures, such additional services and identity theft responsibilitiesthe associated cost must be specifically detailed in the attached fee schedule. The Trust acknowledges and agrees that although it is directing USBGFS Fund Services to implement the Procedures on its behalf, USBGFS Fund Services is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003AML Rules, or otherwise, including, without limitationsuch as, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer, as applicable. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFSFund Services, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS Fund Services shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national National Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (b) Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholder; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to the Procedures; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBGFS Fund Services acknowledges, that USBGFS Fund Services shall (i) permit federal regulators access to such information and records maintained by USBGFS Fund Services and relating to USBGFSFund Services’ implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBGFSFund Services’ implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust acknowledges that it has had an opportunity to review review, consider and consider comment upon the written procedures provided by USBGFS USBFS describing various tools used by USBGFS which USBFS that are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity activity, as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has and USBFS have each determined that the Procedures, as part of the Trust’s overall anti-money laundering program and the Red Flag Identity Theft Prevention program, are reasonably designed to to: (i) prevent the Trust Fund from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), Fair and Accurate Credit Transactions Act of 2003 and the USA PATRIOT Patriot Act of 2001, 2001 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBGFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering and identity theft responsibilities. The Trust acknowledges and agrees that although it is directing USBGFS USBFS to implement the Procedures on its behalf, USBGFS USBFS is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS USBFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary.. Based on this determination, the Trust hereby instructs and directs USBFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering and identity theft responsibilities. USBFS agrees to provide to the Trust: (a) A. Prompt written notification of any transaction or combination of transactions that USBGFS USBFS believes, based on the Procedures, evidence money laundering laundering, activity that may warrant a suspicious activity report or identity theft activities in connection with the Trust or any shareholder of the TrustFund; (b) B. Prompt written notification of any shareholder(scustomer(s) that USBGFS USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering laundering, activity that may warrant a suspicious activity report or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholdercustomer; (c) C. Any reports received by USBGFS USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring or the ProceduresRed Flag Identity Theft Prevention Program on behalf of the Trust; (d) D. Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a)subsections 5.A, (b) B or (c); andC above; (e) E. Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust; and F. Prompt written notification of any material changes to the Procedures. The Trust hereby directs, and USBGFS USBFS acknowledges, that USBGFS shall USBFS shall: (i) permit federal regulators access to such information and records maintained by USBGFS USBFS and relating to USBGFS’ USBFS’s implementation of the Procedures, on behalf of the Trust, as they may request, ; and (ii) permit such federal regulators to inspect USBGFS’ USBFS’s implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust Adviser acknowledges that it has had an opportunity to review and consider the written procedures provided by USBGFS describing various tools processes used by USBGFS which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust Adviser has determined that the Procedures, as part of the TrustAdviser’s overall anti-money laundering program and the Red Flag Identity Theft Prevention programidentity theft prevention program responsibilities, are reasonably designed to help: (i) prevent the Trust Adviser from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Bank Secrecy Act, the USA Patriot Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, and the implementing regulations thereunderthereunder (together “AML Rules”). Based on this determination, the Trust Adviser hereby instructs and directs USBGFS to implement the Procedures Procedures, as applicable, on the TrustAdviser’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is and any such amended Procedures will be provided relating to the Trust’s anti-money laundering Adviser. Should the Adviser desire that USBGFS perform services not provided for in the Procedures, such additional services and identity theft responsibilitiesthe associated cost must be specifically detailed in the attached fee schedule. The Trust Adviser acknowledges and agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider to the Trust Adviser and the Trust Adviser is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003AML Rules, or otherwise, including, without limitationsuch as, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer, as applicable. The Trust Adviser further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the TrustAdviser. The Trust Adviser has had the opportunity to discuss the Procedures with USBGFS, and the Trust Adviser understands and agrees which portions of the Procedures may not be implemented on behalf of the TrustAdviser. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national National Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust Adviser and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (b) Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholder; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to the Procedures; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust Adviser hereby directs, and USBGFS acknowledges, that USBGFS shall (i) permit federal regulators access to such information and records maintained by USBGFS and relating to USBGFS’ implementation of the Procedures, on behalf of the TrustAdviser, as they may request, and (ii) permit such federal regulators to inspect USBGFS’ implementation of the Procedures on behalf of the TrustAdviser.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. USBFS acknowledges and represents that (1) it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (“USA Patriot”) Act of 2001 and the Bank Secrecy Act (collectively the “AML Acts”) and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the “Applicable AML Laws”) in all relevant respects; and (2) it is subject to a rule implementing 31 U.S.C. 5318(h) (the anti-money laundering program provision of the USA Patriot Act) and is regulated by a federal functional regulator such as a federal banking regulator or the SEC. The Trust acknowledges that it has had an opportunity to review review, consider and consider comment upon the written procedures provided by USBGFS Fund Services describing various tools used by USBGFS Fund Services which are designed to promote the detection and reporting of identity theft and potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has and Fund Services have each determined that the Procedures, as part of the Trust’s overall antiAnti-money laundering program Money Laundering Program and the Red Flag Identity Theft Prevention programProgram, are reasonably designed to to: (i) prevent the Trust each Fund from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Bank Secrecy Act, Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), 2003 and the USA PATRIOT Patriot Act of 2001, 2001 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBGFS Fund Services to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering and identity theft responsibilities. The Trust acknowledges and Fund Services agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect provide to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary.: (a) Prompt written notification of any transaction or combination of transactions that USBGFS Fund Services believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the TrustFund shareholder; (b) Prompt written notification of any shareholder(scustomer(s) that USBGFS Fund Services reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholdercustomer; (c) Any reports received by USBGFS Fund Services from any government agency or applicable industry self-regulatory organization pertaining to Fund Services’ Anti-Money Laundering Program or the ProceduresRed Flag Identity Theft Prevention Program on behalf of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c)) immediately above; and (e) Certified annual and quarterly reports of its monitoring and customer identification activities pursuant to the Procedures on behalf of the Trust. The Trust hereby directs, and USBGFS Fund Services acknowledges, that USBGFS Fund Services shall (i) permit federal regulators access to such information and records maintained by USBGFS Funder Services and relating to USBGFSFund Services’ implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBGFSFund Services’ implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust Company acknowledges that it has had an opportunity to review review, consider and consider comment upon the written procedures provided by USBGFS USBFS describing various tools used by USBGFS USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust Company has determined that the Procedures, as part of the TrustCompany’s overall anti-money laundering program and the Red Flag Identity Theft Prevention program, are reasonably designed to prevent the Trust Company from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), 2003 and the USA PATRIOT Patriot Act of 2001, 2001 and the implementing regulations thereunder. Based on this determination, the Trust Company hereby instructs and directs USBGFS USBFS to implement the Procedures Procedures, as applicable, on the TrustCompany’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is USBFS and any such amended Procedures will be provided relating to the Trust’s anti-money laundering Company. Should the Company desire that USBFS perform services not provided for in the Procedures, such additional services and identity theft responsibilitiesthe associated cost must be specifically detailed in the attached fee schedule. The Trust Company acknowledges and agrees that although it is directing USBGFS USBFS to implement the Procedures on its behalf, USBGFS USBFS is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003AML Rules, or otherwise, including, without limitationsuch as, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer, as applicable. The Trust Company further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the TrustCompany. The Trust Company has had the opportunity to discuss the Procedures with USBGFSUSBFS, and the Trust Company understands and agrees which portions of the Procedures may not be implemented on behalf of the TrustCompany. Without limitation of the foregoing, USBGFS USBFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national National Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust Company and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (b) Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholder; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to the Procedures; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust Company hereby directs, and USBGFS USBFS acknowledges, that USBGFS USBFS shall (i) permit federal regulators access to such information and records maintained by USBGFS USBFS and relating to USBGFSUSBFS’ implementation of the Procedures, on behalf of the TrustCompany, as they may request, and (ii) permit such federal regulators to inspect USBGFSUSBFS’ implementation of the Procedures on behalf of the TrustCompany.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust Fund acknowledges that it has had an opportunity to review and consider the written procedures provided by USBGFS describing various tools processes used by USBGFS which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust Fund has determined that the Procedures, as part of the TrustFund’s overall anti-anti- money laundering program and the Red Flag Identity Theft Prevention programidentity theft prevention program responsibilities, are reasonably designed to help: (i) prevent the Trust Fund from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Bank Secrecy Act, the USA Patriot Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, and the implementing regulations thereunderthereunder (together “AML Rules”). Based on this determination, the Trust Fund hereby instructs and directs USBGFS to implement the Procedures Procedures, as applicable, on the TrustFund’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is and any such amended Procedures will be provided relating to the Trust’s anti-money laundering Fund. Should the Fund desire that USBGFS perform services not provided for in the Procedures, such additional services and identity theft responsibilitiesthe associated cost must be specifically detailed in the attached fee schedule. The Trust Fund acknowledges and agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider to the Trust Fund and the Trust Fund is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003AML Rules, or otherwise, including, without limitationsuch as, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer, as applicable. The Trust Fund further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the TrustFund. The Trust Fund has had the opportunity to discuss the Procedures with USBGFS, and the Trust Fund understands and agrees which portions of the Procedures may not be implemented on behalf of the TrustFund. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-sub- accounts through the Fund/SERV system operated by the national National Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust Fund and the intermediary.. The Fund hereby directs, and USBGFS acknowledges, that USBGFS shall (i) permit federal regulators access to such information and records maintained by USBGFS and relating to USBGFS’ implementation of the Procedures, on behalf of the Fund, as they may request, and (ii) permit such federal regulators to inspect USBGFS’ implementation of the Procedures on behalf of the Fund. USBFS agrees to provide to the Fund: (a) Prompt written notification of any transaction or combination of transactions that USBGFS USBFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust Fund or any shareholder of the TrustFund; (b) Prompt written notification of any shareholder(scustomer(s) that USBGFS USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust Fund agrees not to communicate this information to the shareholdercustomer; (c) Any reports received by USBGFS USBFS from any government agency or applicable industry self-self- regulatory organization pertaining to USBFS’s anti-money laundering monitoring or the ProceduresRed Flag Identity Theft Prevention Program on behalf of the Fund; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBGFS acknowledges, that USBGFS shall (i) permit federal regulators access to such information and records maintained by USBGFS and relating to USBGFS’ implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBGFS’ implementation of the Procedures on behalf of the TrustFund.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust Fund acknowledges that it has had an opportunity to review and consider the written procedures provided by USBGFS describing various tools processes used by USBGFS which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). FurtherUBGFS shall, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program and the Red Flag Identity Theft Prevention program, are reasonably designed to prevent the Trust from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBGFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering and identity theft responsibilities. The Trust acknowledges and agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider to the Trust Fund, perform checks of the Fund’s shareholders against Office of Foreign Assets Control lists to the extent legally required. The Fund acknowledges and agrees that USBGFS is a service provider to the Fund and the Trust Fund is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the applicable provisions of the Bank Secrecy Act, the USA PATRIOT Patriot Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, and the implementing regulations thereunder, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust Fund further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the TrustFund. The Trust Fund has had the opportunity to discuss the Procedures with USBGFS, and the Trust Fund understands and agrees which portions of the Procedures may not be implemented on behalf of the TrustFund. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national National Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust Fund and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (b) Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholder; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to the Procedures; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust Fund hereby directs, and USBGFS acknowledges, that USBGFS shall (i) permit federal regulators access to such information and records maintained by USBGFS and relating to USBGFS’ implementation of the Procedures, in connection with such services on behalf of the TrustFund, as they may request, and (ii) permit such federal regulators to inspect USBGFS’ implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust Company acknowledges that it has had an opportunity to review and consider the written procedures provided by USBGFS describing various tools processes used by USBGFS which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust Company has determined that the Procedures, as part of the TrustCompany’s overall anti-money laundering program and the Red Flag Identity Theft Prevention programidentity theft prevention program responsibilities, are reasonably designed to help: (i) prevent the Trust Company from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Bank Secrecy Act, the USA Patriot Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, and the implementing regulations thereunderthereunder (together “AML Rules”). Based on this determination, the Trust Company hereby instructs and directs USBGFS to implement the Procedures Procedures, as applicable, on the TrustCompany’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is and any such amended Procedures will be provided relating to the Trust’s anti-money laundering Company. Should the Company desire that USBGFS perform services not provided for in the Procedures, such additional services and identity theft responsibilitiesthe associated cost must be specifically detailed in the attached fee schedule. The Trust Company acknowledges and agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider to the Trust Company and the Trust Company is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003AML Rules, or otherwise, including, without limitationsuch as, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer, as applicable. The Trust Company further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the TrustCompany. The Trust Company has had the opportunity to discuss the Procedures with USBGFS, and the Trust Company understands and agrees which portions of the Procedures may not be implemented on behalf of the TrustCompany. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national National Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust Company and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (b) Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholder; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to the Procedures; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust Company hereby directs, and USBGFS acknowledges, that USBGFS shall (i) permit federal regulators access to such information and records maintained by USBGFS and relating to USBGFS’ implementation of the Procedures, on behalf of the TrustCompany, as they may request, and (ii) permit such federal regulators to inspect USBGFS’ implementation of the Procedures on behalf of the TrustCompany.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust Fund acknowledges that it has had an opportunity to review review, consider and consider comment upon the written procedures provided by USBGFS USBFS describing various tools used by USBGFS USBFS which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has Fund and USBFS have each determined that the Procedures, as part of the TrustFund’s overall antiAnti-money laundering program Money Laundering Program and the Red Flag Identity Theft Prevention programProgram, are reasonably designed to to: (i) prevent the Trust each Fund from being used for money laundering or the financing of terrorist activities and to activities, (ii) achieve compliance with the applicable provisions of the Bank Secrecy Act, Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), 2003 and the USA PATRIOT Patriot Act of 2001, 2001 and the implementing regulations thereunder. Based on this determination, the Trust Fund hereby instructs and directs USBGFS USBFS to implement the Procedures on the TrustFund’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustFund’s anti-money laundering and identity theft responsibilities. The Trust acknowledges and USBFS agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider provide to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary.: (a) A. Prompt written notification of any transaction or combination of transactions that USBGFS USBFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust Fund or any shareholder of the TrustFund shareholder; (b) B. Prompt written notification of any shareholder(scustomer(s) that USBGFS USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust Fund agrees not to communicate this information to the shareholdercustomer; (c) C. Any reports received by USBGFS USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s Anti-Money Laundering Program or the ProceduresRed Flag Identity Theft Prevention Program on behalf of the Fund; (d) D. Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (aA), (bB) or (c)C) immediately above; and (e) E. Certified annual and quarterly reports of its monitoring and customer identification activities pursuant to the Procedures on behalf of the TrustFund. The Trust Fund hereby directs, and USBGFS USBFS acknowledges, that USBGFS USBFS shall (i) permit federal regulators access to such information and records maintained by USBGFS USBFS and relating to USBGFSUSBFS’ implementation of the Procedures, on behalf of the TrustFund, as they may request, and (ii) permit such federal regulators to inspect USBGFSUSBFS’ implementation of the Procedures on behalf of the TrustFund.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. a. The Trust acknowledges that it has had an opportunity to review review, consider and consider approve the written procedures provided by USBGFS describing various tools processes used by USBGFS which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program and the Red Flag Identity Theft Prevention programidentity theft prevention program responsibilities, are reasonably designed to help: (i) prevent the Trust from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, and the implementing regulations thereunder. Based on this determination, the thereunder (together “AML Rules”). b. The Trust hereby instructs and directs USBGFS to implement the Procedures Procedures, as applicable, on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is and any such amended Procedures will be provided relating to the Trust’s anti-money laundering . Should the Trust desire that USBGFS perform services not provided for in the Procedures, such additional services and identity theft responsibilities. the associated cost must be specifically detailed in writing in the attached fee schedule. c. The Trust acknowledges and agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003AML Rules, or otherwise, including, without limitationsuch as, the establishment and adoption by the Trust’s board adoption of its Trustees (the “Board”) of the Trust’s own formal anti-money laundering program and the designation of its own anti-money laundering officer. , as applicable. d. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national National Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (b) Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholder; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to the Procedures; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. e. The Trust hereby directs, and USBGFS acknowledges, that USBGFS shall (i) permit federal regulators access to such information and records maintained by USBGFS and relating to USBGFS’ implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBGFS’ implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust Fund acknowledges that it has had an opportunity to review review, consider and consider comment upon the written procedures provided by USBGFS USBFS describing various tools used by USBGFS USBFS which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has Fund and USBFS have each determined that the Procedures, as part of the TrustFund’s overall antiAnti-money laundering program Money Laundering Program and the Red Flag Identity Theft Prevention programProgram, are reasonably designed to to: (i) prevent the Trust each Fund from being used for money laundering or the financing of terrorist activities and to activities, (ii) achieve compliance with the applicable provisions of the Bank Secrecy Act, Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), 2003 and the USA PATRIOT Patriot Act of 2001, 2001 and the implementing regulations thereunder. Based on this determination, the Trust Fund hereby instructs and directs USBGFS USBFS to implement the Procedures on the TrustFund’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustFund’s anti-money laundering and identity theft responsibilities. The Trust acknowledges and USBFS agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider provide to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary.: (a) A. Prompt written notification of any transaction or combination of transactions that USBGFS USBFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust Fund or any shareholder of the TrustFund shareholder; (b) B. Prompt written notification of any shareholder(scustomer(s) that USBGFS USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust Fund agrees not to communicate this information to the shareholdercustomer; (c) C. Any reports received by USBGFS USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’ Anti-Money Laundering Program or the ProceduresRed Flag Identity Theft Prevention Program on behalf of the Fund; (d) D. Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (aA), (bB) or (c)C) immediately above; and (e) E. Certified annual and quarterly reports of its monitoring and customer identification activities pursuant to the Procedures on behalf of the TrustFund. The Trust Fund hereby directs, and USBGFS USBFS acknowledges, that USBGFS USBFS shall (i) permit federal regulators access to such information and records maintained by USBGFS USBFS and relating to USBGFSUSBFS’ implementation of the Procedures, on behalf of the TrustFund, as they may request, and (ii) permit such federal regulators to inspect USBGFSUSBFS’ implementation of the Procedures on behalf of the TrustFund.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust Fund acknowledges that it has had an opportunity to review and consider the written procedures provided by USBGFS describing various tools used by USBGFS which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has Fund and USBGFS have each determined that the Procedures, as part of the TrustFund’s overall anti-money laundering program and the Red Flag Identity Theft Prevention program, are reasonably designed to to: (i) prevent the Trust Fund from being used for money laundering or the financing of terrorist activities activities; (ii) to prevent identity theft; and to (iii)to achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, and the implementing regulations thereunder. Based on this determination, the Trust Fund hereby instructs and directs USBGFS to implement the Procedures on the TrustFund’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustFund’s anti-money laundering and identity theft responsibilities. The Trust Fund acknowledges and agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider to the Trust Fund and the Trust Fund is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust Fund further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the TrustFund. The Trust Fund has had the opportunity to discuss the Procedures with USBGFS, and the Trust Fund understands and agrees which portions of the Procedures may not be implemented on behalf of the TrustFund. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust Fund and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust Fund or any shareholder of the TrustFund; (b) Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust Fund agrees not to communicate this information to the shareholder; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to USBGFS’ Anti-Money Laundering Program or the ProceduresRed Flag Identity Theft Prevention Program on behalf of the Fund; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities pursuant to the Procedures on behalf of the TrustFund. The Trust Fund hereby directs, and USBGFS acknowledges, that USBGFS shall (i) permit federal regulators access to such information and records maintained by USBGFS and relating to USBGFS’ implementation of the Procedures, on behalf of the TrustFund, as they may request, and (ii) permit such federal regulators to inspect USBGFS’ implementation of the Procedures on behalf of the TrustFund.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust acknowledges that it has had an opportunity to review and consider the written procedures provided by USBGFS describing various tools processes used by USBGFS which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-anti- money laundering program and the Red Flag Identity Theft Prevention programidentity theft prevention program responsibilities, are reasonably designed to help: (i) prevent the Trust from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Bank Secrecy Act, the USA Patriot Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, and the implementing regulations thereunderthereunder (together “AML Rules”). Based on this determination, the Trust hereby instructs and directs USBGFS to implement the Procedures Procedures, as applicable, on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is and any such amended Procedures will be provided relating to the Trust’s anti-money laundering . Should the Trust desire that USBGFS perform services not provided for in the Procedures, such additional services and identity theft responsibilitiesthe associated cost must be specifically detailed in the attached fee schedule. The Trust acknowledges and agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003AML Rules, or otherwise, including, without limitationsuch as, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer, as applicable. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-sub- accounts through the Fund/SERV system operated by the national National Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (b) Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholder; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to the Procedures; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBGFS acknowledges, that USBGFS shall (i) permit federal regulators access to such information and records maintained by USBGFS and relating to USBGFS’ implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBGFS’ implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. Fund Services acknowledges and represents that (1) it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (“USA Patriot”) Act of 2001 and the Bank Secrecy Act (collectively the “AML Acts”) and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the “Applicable AML Laws”) in all relevant respects; and (2) it is subject to a rule implementing 31 U.S.C. 5318(h) (the anti-money laundering program provision of the USA Patriot Act) and is regulated by a federal functional regulator such as a federal banking regulator or the SEC. The Trust acknowledges that it has had an opportunity to review review, consider and consider comment upon the written procedures provided by USBGFS Fund Services describing various tools used by USBGFS Fund Services which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has and Fund Services have each determined that the Procedures, as part of the Trust’s overall antiAnti-money laundering program Money Laundering Program and the Red Flag Identity Theft Prevention programProgram, are reasonably designed to to: (i) prevent the Trust each Fund from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Bank Secrecy Act, Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), 2003 and the USA PATRIOT Patriot Act of 2001, 2001 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBGFS Fund Services to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering and identity theft responsibilities. The Trust acknowledges and agrees that although it is directing USBGFS Fund Services to implement the Procedures on its behalf, USBGFS Fund Services is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust further acknowledges and Fund Services agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect provide to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary.: (a) Prompt written notification of any transaction or combination of transactions that USBGFS Fund Services believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the TrustFund shareholder; (b) Prompt written notification of any shareholder(scustomer(s) that USBGFS Fund Services reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholdercustomer; (c) Any reports received by USBGFS Fund Services from any government agency or applicable industry self-regulatory organization pertaining to Fund Services’ Anti-Money Laundering Program or the ProceduresRed Flag Identity Theft Prevention Program on behalf of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c)) immediately above; and (e) Certified annual and quarterly reports of its monitoring and customer identification activities pursuant to the Procedures on behalf of the Trust. The Trust hereby directs, and USBGFS Fund Services acknowledges, that USBGFS Fund Services shall (i) permit federal regulators access to such information and records maintained by USBGFS Fund Services and relating to USBGFSFund Services’ implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBGFSFund Services’ implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust acknowledges that it has had an opportunity to review review, consider and consider comment upon the written procedures provided by USBGFS USBFS describing various tools used by USBGFS which USBFS that are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity activity, as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has and USBFS have each determined that the Procedures, as part of the Trust’s overall anti-money laundering program and the Red Flag Identity Theft Prevention program, are reasonably designed to to: (i) prevent the Trust Fund from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), Fair and Accurate Credit Transactions Act of 2003 and the USA PATRIOT Patriot Act of 2001, 2001 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBGFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering and identity theft responsibilities. The Trust acknowledges and agrees that although it is directing USBGFS USBFS to implement the Procedures on its behalf, USBGFS USBFS is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFSUSBFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS USBFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary.. Based on this determination, the Trust hereby instructs and directs USBFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering and identity theft responsibilities. XXXXX agrees to provide to the Trust: (a) A. Prompt written notification of any transaction or combination of transactions that USBGFS USBFS believes, based on the Procedures, evidence money laundering laundering, activity that may warrant a suspicious activity report or identity theft activities in connection with the Trust or any shareholder of the TrustFund; (b) B. Prompt written notification of any shareholder(scustomer(s) that USBGFS USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering laundering, activity that may warrant a suspicious activity report or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholdercustomer; (c) C. Any reports received by USBGFS USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring or the ProceduresRed Flag Identity Theft Prevention Program on behalf of the Trust; (d) D. Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a)subsections 5.A, (b) B or (c); andC above; (e) E. Certified annual and quarterly reports of its monitoring monitoring, reporting, and customer identification activities on behalf of the Trust, including an annual certification that USBFS has applied and followed the Procedures during the relevant period; F. Prompt written notification of any material changes to the Procedures. The Trust hereby directs, and USBGFS USBFS acknowledges, that USBGFS shall USBFS shall: (i) permit federal regulators access to such information and records maintained by USBGFS USBFS and relating to USBGFS’ USBFS’s implementation of the Procedures, on behalf of the Trust, as they may request, ; and (ii) permit such federal regulators to inspect USBGFS’ USBFS’s implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust acknowledges Company delegates to USBFS the performance of the services set forth below (the “AML and Red Flag Identity Theft Prevention Services”) with respect to shareholder accounts maintained by USBFS pursuant to this Agreement; and subject to the terms and conditions of this Agreement, USBFS accepts this delegation and agrees to perform the AML and Red Flag Identity Theft Prevention Services in accordance with the Company’s and USBFS’ AML and Red Flag Identity Theft Prevention Programs. Notwithstanding this delegation, the Company shall maintain full responsibility for ensuring that it has had its AML and Red Flag Identity Theft Prevention Programs are and continue to be reasonable designed ensure compliance with applicable AML Laws and the Fair and Accurate Credit Transaction Act of 2003. a. Verify shareholder identity upon opening new accounts in accordance with Section 326 of the USA PATRIOT Act (the “Patriot Act”) and any regulations thereunder, as required under applicable law and maintain records of the information used to verify the shareholder’s identity; b. Monitor shareholder transactions and identify and report suspicious activities that are required to be so identified and reported, in each case consistent with the AML and Red Flag Identity Theft Prevention programs of the Company and USBFS; c. Office of Foreign Asset Control (“OFAC”) ; (i) Submit all account registrations, outgoing wires and withdrawal files through OFAC databases and such other lists or databases as may be required from time to time by applicable regulatory authorities; (ii) Freeze an opportunity account subject to a positive OFAC match; (iii) Determine when an initial or periodic OFAC report should be filed as required by regulations; (iv) Prepare and file such initial or periodic OFAC report on behalf of the Fund; (v) Provide the Fund with a copy of the OFAC report within a reasonable time after filing; (vi) Notify the Fund if any further communication is received from the U.S. Department of the Treasury or other law enforcement agencies regarding such filing; and d. Suspicious Activity Report – Securities and Futures Industry (“SAR-SF”); (i) Determine when a SAR-SF should be filed as required by regulations applicable to mutual funds; (ii) Prepare and file the SAR-SF; (iii) Provide the Fund with a copy of the SAR-SF to review and consider send the Fund a copy of the SAR-SF within a reasonable time after filing; (iv) Notify the Fund if any further communication is received from the U.S. Department of the Treasury or other law enforcement agencies regarding such filing; and e. FinCEN; (i) Compare account information to any FinCEN request pursuant to the Patriot Act Sec. 314(a); (ii) Provide the Fund with the necessary information for it to respond to such request within the required time frame: (iii) Determine whether any account registrations appear on any lists of known or suspected terrorists or terrorists organizations provided to the Fund by any government agency; and f. New and existing correspondent accounts for foreign financial institutions (as defined in 31 C.F.R. 103.175); (i) Conduct due diligence and if required, enhanced due diligence in accordance with 31 C.F.R. 103.176 (b); (ii) USBFS will perform an assessment of the money laundering risk presented by the account based on a consideration of relevant factors in accordance with applicable law and information provided by the foreign financial institution in a financial institution questionnaire; (iii) USBFS will inform the Fund and will either monitor the account on a monthly basis for unusual activity or restrict said account per instruction from the Fund; (iv) If due diligence cannot be completed with respect to an account, USBFS will contact the Fund’s AML officer for further instruction; and g. Monitoring and tracking of certain cash equivalents (i) Monitor and track cash equivalents under $10,000 for a rolling twelve-month period and if the threshold is exceeded, file IRS Form 8300; (ii) Provide the Fund with a copy of the IRS Form 8300 within a reasonable time after filing; (iii) Notify the Fund if any further communication is received from the IRS or other law enforcement agencies regarding such filing; and h. Follow the Company’s third party check policies; provided, however, that under no circumstance will USBFS accept a corporate third party check; i. Place holds on transactions in shareholder accounts or freeze assets in shareholder accounts, as provided in the AML and Red Flag Identity Theft Prevention programs of the Company and USBFS and in accordance with the Patriot Act and OFAC; and j. Maintain policies, procedures and internal controls that are consistent with the Company’s AML and Red Flag Identity Theft Prevention programs USBFS agrees to provide to the Company: A. Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the written procedures provided by USBGFS describing various tools used by USBGFS USBFS which are designed to promote the detection and reporting of potential money laundering activity or identity theft activities by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program and the Red Flag Identity Theft Prevention program, are reasonably designed to prevent the Trust from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBGFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering and identity theft responsibilities. The Trust acknowledges and agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust Company or any shareholder of the TrustFund; (b) B. Prompt written notification of any shareholder(scustomer(s) that USBGFS USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust Company agrees not to communicate this information to the shareholdercustomer; (c) C. Any reports received by USBGFS USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring or the ProceduresRed Flag Identity Theft Prevention Program on behalf of the Company; (d) D. Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (aA), (bB) or (c)C) above; and (e) E. Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the TrustCompany. The Trust Company hereby directs, and USBGFS USBFS acknowledges, that USBGFS USBFS shall (i) permit federal regulators access to such information and records maintained by USBGFS USBFS and relating to USBGFS’ USBFS’s implementation of the Procedures, on behalf of the TrustCompany, as they may request, and (ii) permit such federal regulators to inspect USBGFS’ USBFS’s implementation of the Procedures on behalf of the TrustCompany. USBFS agrees that at least annually the Company’s Identity Theft Program Officer will evaluate the design of the Procedures and the effectiveness of the implementation USBFS agrees to cooperate with the Company to make revisions to the Procedures and their implementation from time to time to reflect regulatory changes impacting the Procedures or the Red Flag Identity Theft Program in general, as well as reasonable revisions to reflect the results of any such evaluation, or for any other reason.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust acknowledges that it has had an opportunity to review and consider the written procedures provided by USBGFS describing various tools processes used by USBGFS which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s 's identity (collectively, the “"Procedures”"). Further, the Trust has determined that the Procedures, as part of the Trust’s 's overall anti-anti money laundering program and the Red Flag Identity Theft Prevention programidentity theft prevention program responsibilities, are reasonably designed to help: (i) prevent the Trust from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Bank Secrecy Act, the USA Patriot Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, and the implementing regulations thereunderthereunder (together "AML Rules"). Based on this determination, the Trust hereby instructs and directs USBGFS to implement the Procedures Procedures, as applicable, on the Trust’s 's behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is and any such amended Procedures will be provided relating to the Trust’s anti-money laundering . Should the Trust desire that USBGFS perform services not provided for in the Procedures, such additional services and identity theft responsibilitiesthe associated cost must be specifically detailed in the attached fee schedule. The Trust acknowledges and agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003AML Rules, or otherwise, including, without limitationsuch as, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer, as applicable. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-sub accounts through the Fund/SERV system operated by the national National Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (b) Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholder; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to the Procedures; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBGFS acknowledges, that USBGFS shall (i) permit federal regulators access to such information and records maintained by USBGFS and relating to USBGFS’ ' implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBGFS’ ' implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust Fund acknowledges that it has had an opportunity to review and consider the written procedures provided by USBGFS Fund Services describing various tools processes used by USBGFS Fund Services which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust Fund has determined that the Procedures, as part of the TrustFund’s overall anti-money laundering program and the Red Flag Identity Theft Prevention programidentity theft prevention program responsibilities, are reasonably designed to help: (i) prevent the Trust Fund from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Bank Secrecy Act, the USA Patriot Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, and the implementing regulations thereunderthereunder (together “AML Rules”). Based on this determination, the Trust Fund hereby instructs and directs USBGFS Fund Services to implement the Procedures Procedures, as applicable, on the TrustFund’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is Fund Services and any such amended Procedures will be provided relating to the Trust’s anti-money laundering Fund prior to their implementation. Should the Fund desire that Fund Services perform services not provided for in the Procedures, such additional services and identity theft responsibilitiesthe associated cost must be specifically detailed in the attached fee schedule. The Trust Fund acknowledges and agrees that although it is directing USBGFS Fund Services to implement the Procedures on its behalf, USBGFS Fund Services is implementing the Procedures as a service provider to the Trust Fund and the Trust Fund is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003AML Rules, or otherwise, including, without limitationsuch as, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer, as applicable. The Trust Fund further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the TrustFund. The Trust Fund has had the opportunity to discuss the Procedures with USBGFSFund Services, and the Trust Fund understands and agrees which portions of the Procedures may not be implemented on behalf of the TrustFund. Without limitation of the foregoing, USBGFS Fund Services shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national National Securities Clearing CorporationFund) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust Fund and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (b) Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholder; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to the Procedures; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust Fund hereby directs, and USBGFS Fund Services acknowledges, that USBGFS Fund Services shall (i) permit federal regulators access to such information and records maintained by USBGFS Fund Services and relating to USBGFSFund Services’ implementation of the Procedures, on behalf of the TrustFund, as they may request, and (ii) permit such federal regulators to inspect USBGFSFund Services’ implementation of the Procedures on behalf of the TrustFund.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust Company acknowledges that it has had an opportunity to review review, consider and consider comment upon the written procedures provided by USBGFS Fund Services describing various tools used by USBGFS Fund Services which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust Fund has determined that the Procedures, as part of the TrustFund’s overall anti-money laundering program and the Red Flag Identity Theft Prevention program, are reasonably designed to prevent the Trust Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), 2003 and the USA PATRIOT Patriot Act of 2001, 2001 and the implementing regulations thereunder. Based on this determination, the Trust Company hereby instructs and directs USBGFS Fund Services to implement the Procedures on the TrustFund’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustFund’s anti-money laundering and identity theft responsibilities. The Trust acknowledges and Fund Services agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider provide to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary.: (a) Prompt written notification of any transaction or combination of transactions that USBGFS Fund Services believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust Fund or any shareholder of the TrustFund; (b) Prompt written notification of any shareholder(scustomer(s) that USBGFS Fund Services reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust Fund agrees not to communicate this information to the shareholdercustomer; (c) Any reports received by USBGFS Fund Services from any government agency or applicable industry self-regulatory organization pertaining to Fund Services’ anti-money laundering monitoring or the ProceduresRed Flag Identity Theft Prevention Program on behalf of the Fund; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the TrustFund. The Trust Company hereby directs, and USBGFS Fund Services acknowledges, that USBGFS Fund Services shall (i) permit federal regulators access to such information and records maintained by USBGFS Fund Services and relating to USBGFSFund Services’ implementation of the Procedures, on behalf of the TrustFund, as they may request, and (ii) permit such federal regulators to inspect USBGFSFund Services’ implementation of the Procedures on behalf of the TrustFund.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust acknowledges that it has had an opportunity to review and consider the written procedures provided by USBGFS Fund Services describing various tools processes used by USBGFS Fund Services which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program and the Red Flag Identity Theft Prevention programidentity theft prevention program responsibilities, are reasonably designed to help: (i) prevent the Trust from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Bank Secrecy Act, the USA Patriot Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, and the implementing regulations thereunderthereunder (together “AML Rules”). Based on this determination, the Trust hereby instructs and directs USBGFS Fund Services to implement the Procedures Procedures, as applicable, on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is Fund Services and any such amended Procedures will be provided relating to the Trust’s anti-money laundering . Should the Trust desire that Fund Services perform services not provided for in the Procedures, such additional services and identity theft responsibilitiesthe associated cost must be specifically detailed in the attached fee schedule. The Trust acknowledges and agrees that although it is directing USBGFS Fund Services to implement the Procedures on its behalf, USBGFS Fund Services is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003AML Rules, or otherwise, including, without limitationsuch as, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer, as applicable. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFSFund Services, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS Fund Services shall not be responsible for providing anti-anti- money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national National Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (b) Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholder; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to the Procedures; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBGFS Fund Services acknowledges, that USBGFS Fund Services shall (i) permit federal regulators access to such information and records maintained by USBGFS Fund Services and relating to USBGFSFund Services’ implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBGFSFund Services’ implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust Corporation acknowledges that it has had an opportunity to review and consider the written procedures provided by USBGFS describing various tools processes used by USBGFS which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust Corporation has determined that the Procedures, as part of the TrustCorporation’s overall anti-money laundering program and the Red Flag Identity Theft Prevention programidentity theft prevention program responsibilities, are reasonably designed to help: (i) prevent the Trust Corporation from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Bank Secrecy Act, the USA Patriot Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, and the implementing regulations thereunderthereunder (together “AML Rules”). Based on this determination, the Trust Corporation hereby instructs and directs USBGFS to implement the Procedures Procedures, as applicable, on the TrustCorporation’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is and any such amended Procedures will be provided relating to the Trust’s anti-money laundering Corporation prior to their implementation. Should the Corporation desire that USBGFS perform services not provided for in the Procedures, such additional services and identity theft responsibilitiesthe associated cost must be specifically detailed in the attached fee schedule. The Trust Corporation acknowledges and agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider to the Trust Corporation and the Trust Corporation is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003AML Rules, or otherwise, including, without limitationsuch as, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer, as applicable. The Trust Corporation further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the TrustCorporation. The Trust Corporation has had the opportunity to discuss the Procedures with USBGFS, and the Trust Corporation understands and agrees which portions of the Procedures may not be implemented on behalf of the TrustCorporation. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national National Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust Corporation and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (b) Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholder; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to the Procedures; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust Corporation hereby directs, and USBGFS acknowledges, that USBGFS shall (i) permit federal regulators access to such information and records maintained by USBGFS and relating to USBGFS’ implementation of the Procedures, on behalf of the TrustCorporation, as they may request, and (ii) permit such federal regulators to inspect USBGFS’ implementation of the Procedures on behalf of the TrustCorporation.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. Fund Services acknowledges and represents that (1) it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (“USA Patriot”) Act of 2001 and the Bank Secrecy Act (collectively the “AML Acts”) and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the “Applicable AML Laws”) in all relevant respects; and (2) it is subject to a rule implementing 31 U.S.C. 5318(h) (the anti-money laundering program provision of the USA Patriot Act) and is regulated by a federal functional regulator such as a federal banking regulator or the SEC. The Trust acknowledges that it has had an opportunity to review review, consider and consider comment upon the written procedures provided by USBGFS Fund Services describing various tools used by USBGFS Fund Services which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has and Fund Services have each determined that the Procedures, as part of the Trust’s overall antiAnti-money laundering program Money Laundering Program and the Red Flag Identity Theft Prevention programProgram, are reasonably designed to to: (i) prevent the Trust each Fund from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Bank Secrecy Act, Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), 2003 and the USA PATRIOT Patriot Act of 2001, 2001 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBGFS Fund Services to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering and identity theft responsibilities. The Trust acknowledges and Fund Services agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect provide to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary. : 4 (a) Prompt written notification of any transaction or combination of transactions that USBGFS Fund Services believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; Fund shareholder; (b) Prompt written notification of any shareholder(scustomer(s) that USBGFS Fund Services reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholder; customer; (c) Any reports received by USBGFS Fund Services from any government agency or applicable industry self-regulatory organization pertaining to Fund Services’ Anti-Money Laundering Program or the Procedures; Red Flag Identity Theft Prevention Program on behalf of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c)) immediately above; and and (e) Certified annual and quarterly reports of its monitoring and customer identification activities pursuant to the Procedures on behalf of the Trust. The Trust hereby directs, and USBGFS Fund Services acknowledges, that USBGFS Fund Services shall (i) permit federal regulators access to such information and records maintained by USBGFS Fund Services and relating to USBGFSFund Services’ implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBGFSFund Services’ implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust acknowledges that it has had an opportunity to review and consider the written procedures provided by USBGFS Fund Services describing various tools processes used by USBGFS Fund Services which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program and the Red Flag Identity Theft Prevention programidentity theft prevention program responsibilities, are reasonably designed to help: (i) prevent the Trust each Fund from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Bank Secrecy Act, the USA Patriot Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, and the implementing regulations thereunderthereunder (together “AML Rules”). Based on this determination, the Trust hereby instructs and directs USBGFS Fund Services to implement the Procedures Procedures, as applicable, on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is Fund Services and any such amended Procedures will be provided relating to the Trust’s anti-money laundering . Should the Trust desire that Fund Services perform services not provided for in the Procedures, such additional services and identity theft responsibilitiesthe associated cost must be specifically detailed in the attached fee schedule. The Trust acknowledges and agrees that although it is directing USBGFS Fund Services to implement the Procedures on its behalf, USBGFS Fund Services is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003AML Rules, or otherwise, including, without limitationsuch as, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer, as applicable. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFSFund Services, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS Fund Services shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national National Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (b) Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholder; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to the Procedures; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBGFS Fund Services acknowledges, that USBGFS Fund Services shall (i) permit federal regulators access to such information and records maintained by USBGFS Fund Services and relating to USBGFSFund Services’ implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBGFSFund Services’ implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust Fund acknowledges that it has had an opportunity to review review, consider and consider comment upon the written procedures provided by USBGFS describing various tools used by USBGFS which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has Fund and USBGFS have each determined that the Procedures, as part of the TrustFund’s overall antiAnti-money laundering program Money Laundering Program and the Red Flag Identity Theft Prevention programProgram, are reasonably designed to to: (i) prevent the Trust Fund from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Bank Secrecy Act, Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), ) and the USA PATRIOT Patriot Act of 2001, 2001 and the implementing regulations thereunderthereunder and any other applicable laws and regulations. Based on this determinationUSBGFS has undertaken appropriate due diligence efforts with respect to each of the respective investors in the Fund that have come to USBGFS and the Fund directly (not through a selling agent), including the Trust hereby instructs and directs USBGFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering and identity theft responsibilitiesscreening of each investor against relevant sanctions programs. The Trust Fund acknowledges and agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider to the Trust Fund and the Trust Fund is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust further acknowledges Based on this determination, the Fund hereby instructs and agrees that certain portions of directs USBGFS to implement the Procedures on the Fund’s behalf to the extent that Anti-Money Laundering and Red Flag Identity Theft regulations are applicable to certain productsthe Fund’s activities, entities, structures, as such may be amended or geographies and, accordingly, certain portions of revised from time to time. It is contemplated that these Procedures will be amended from time to time by the Procedures may not be implemented with respect parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS shall not be responsible for providing Fund’s anti-money laundering or customer identification services with respect and identity theft responsibilities. USBGFS agrees to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through provide to the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary.: (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust Fund or any shareholder of the TrustFund shareholder; (b) Prompt written notification of any shareholder(scustomer(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust Fund agrees not to communicate this information to the shareholdercustomer; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to USBGFS’ Anti-Money Laundering Program or the ProceduresRed Flag Identity Theft Prevention Program on behalf of the Fund; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c)) immediately above; and (e) Certified annual and quarterly reports of its monitoring and customer identification activities pursuant to the Procedures on behalf of the TrustFund. USBGF hereby represents that it has not been convicted of any felony under the Bank Secrecy Act or any other money-laundering offenses or related financial crimes, has not been subject to any enforcement actions brought by the Financial Crimes Enforcement Network or any other federal functional regulator for violations of the Bank Secrecy Act and regulations thereunder and is currently not under open investigation related to any such violations. The Trust Fund hereby directs, and USBGFS acknowledges, that USBGFS shall (i) permit federal regulators access to such information and records maintained by USBGFS and relating to USBGFS’ implementation of the Procedures, on behalf of the TrustFund, as they may request, and (ii) permit such federal regulators to inspect USBGFS’ implementation of the Procedures on behalf of the TrustFund.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust Company acknowledges that it has had an opportunity to review and consider the written procedures provided by USBGFS describing various tools used by USBGFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust Company has determined that the Procedures, as part of the TrustCompany’s overall anti-money laundering program and the Red Flag Identity Theft Prevention program, are reasonably designed to prevent the Trust Company from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, and the implementing regulations thereunder. Based on this determination, the Trust Company hereby instructs and directs USBGFS to implement the Procedures on the TrustCompany’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustCompany’s anti-money laundering and identity theft responsibilities. The Trust Company acknowledges and agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider to the Trust Company and the Trust Company is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust Company further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the TrustCompany. The Trust Company has had the opportunity to discuss the Procedures with USBGFS, and the Trust Company understands and agrees which portions of the Procedures may not be implemented on behalf of the TrustCompany. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust Company and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust Company or any shareholder of the TrustCompany; (b) Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust Company agrees not to communicate this information to the shareholder; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to the Procedures; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the TrustCompany. The Trust Company hereby directs, and USBGFS acknowledges, that USBGFS shall (i) permit federal regulators access to such information and records maintained by USBGFS and relating to USBGFS’ implementation of the Procedures, on behalf of the TrustCompany, as they may request, and (ii) permit such federal regulators to inspect USBGFS’ implementation of the Procedures on behalf of the TrustCompany.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust acknowledges that it has had an opportunity to review and consider the written procedures provided by USBGFS describing various tools used by USBGFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program and the Red Flag Identity Theft Prevention program, are reasonably designed to prevent the Trust from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBGFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering and identity theft responsibilities. The Trust acknowledges and agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-sub- accounts through the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary. . USBGFS agrees to provide to the Trust: (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; ; (b) Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholder; ; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to the Procedures; ; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBGFS acknowledges, that USBGFS shall (i) permit federal regulators access to such information and records maintained by USBGFS and relating to USBGFS’ implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBGFS’ implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust Fund acknowledges that it has had an opportunity to review review, consider and consider comment upon the written procedures provided by USBGFS Fund Services describing various tools used by USBGFS Fund Services which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has Fund and Fund Services have determined that the Procedures, as part of the TrustFund’s overall anti-money laundering program and the Red Flag Identity Theft Prevention program, are reasonably designed to to: (i) prevent the Trust Fund from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and (iii) to achieve compliance with the applicable provisions of the Fair Bank Secrecy Act and Accurate Credit Transactions the USA Patriot Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, 2001 and the implementing regulations thereunder. Based on this determination, the Trust Fund hereby instructs and directs USBGFS Fund Services to implement the Procedures on the TrustFund’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS the parties (and any such amended procedures will be provided to the Fund) as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustFund’s anti-money laundering and identity theft responsibilities. The Trust acknowledges and Fund Services agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider provide to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary.: (a) Prompt written notification of any transaction or combination of transactions that USBGFS Fund Services believes, based on the Procedures, evidence money laundering laundering, activity that may warrant a suspicious activity report or identity theft activities in connection with the Trust Fund or any shareholder of the TrustFund; (b) Prompt written notification of any shareholder(scustomer(s) that USBGFS Fund Services reasonably believes, based upon the Procedures, to be engaged in money laundering laundering, activity that may warrant a suspicious activity report or identity theft activities, provided that the Trust Fund agrees not to communicate this information to the shareholdersuch customer; (c) Any reports received by USBGFS Fund Services from any government agency or applicable industry self-regulatory organization pertaining to Fund Services’ anti-money laundering monitoring or the ProceduresRed Flag Identity Theft Prevention Program on behalf of the Fund; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust Fund, including an annual certification that Fund Services has applied and followed the Procedures during the relevant reporting period; Subject in all cases to Section 9 below, Fund Services hereby directs, and USBGFS acknowledges, that USBGFS shall Fund Services may be required to, and upon request of the Fund shall, (i) permit federal regulators access to such information and records maintained by USBGFS Fund Services and relating to USBGFSFund Services’ implementation of the Procedures, Procedures on behalf of the TrustFund, as they it may request, and (ii) permit such federal regulators to inspect USBGFSFund Services’ implementation of the Procedures on behalf of the TrustFund.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust acknowledges that it has had an opportunity to review and consider the written procedures provided by USBGFS Fund Services describing various tools processes used by USBGFS Fund Services which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program and the Red Flag Identity Theft Prevention programidentity theft prevention program responsibilities, are reasonably designed to help: (i) prevent the Trust from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Bank Secrecy Act, the USA Patriot Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, and the implementing regulations thereunderthereunder (together “AML Rules”). Based on this determination, the Trust hereby instructs and directs USBGFS Fund Services to implement the Procedures Procedures, as applicable, on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is Fund Services and any such amended Procedures will be provided relating to the Trust’s anti-money laundering . Should the Trust desire that Fund Services perform services not provided for in the Procedures, such additional services and identity theft responsibilitiesthe associated cost must be specifically detailed in the attached fee schedule. The Trust acknowledges and agrees that although it is directing USBGFS Fund Services to implement the Procedures on its behalf, USBGFS Fund Services is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003AML Rules, or otherwise, including, without limitationsuch as, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer, as applicable. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFSFund Services, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS USB Fund Services GFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national National Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (b) Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholder; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to the Procedures; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBGFS Fund Services acknowledges, that USBGFS Fund Services shall (i) permit federal regulators access to such information and records maintained by USBGFS Fund Services and relating to USBGFSFund Services’ implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBGFSFund Services’ implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. USBFS acknowledges and represents that (1) it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (“USA Patriot”) Act of 2001 and the Bank Secrecy Act (collectively the “AML Acts”) and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the “Applicable AML Laws”) in all relevant respects; and (2) it is subject to a rule implementing 31 U.S.C. 5318(h) (the anti-money laundering program provision of the USA Patriot Act) and is regulated by a federal functional regulator such as a federal banking regulator or the SEC. The Trust acknowledges that it has had an opportunity to review review, consider and consider comment upon the written procedures provided by USBGFS USBFS describing various tools used by USBGFS USBFS which are designed to promote the detection and reporting of identity theft and potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program and the Red Flag Identity Theft Prevention program, are reasonably designed to prevent identity theft and to prevent the Trust Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the Bank Secrecy Act, Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), 2003 and the USA PATRIOT Patriot Act of 2001, 2001 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBGFS USBFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering and identity theft responsibilities. The Trust acknowledges and USBFS agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect provide to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary.: (a) A. Prompt written notification of any transaction or combination of transactions that USBGFS USBFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the TrustFund; (b) B. Prompt written notification of any shareholder(scustomer(s) that USBGFS USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholdercustomer; (c) C. Any reports received by USBGFS USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’ anti-money laundering monitoring or the ProceduresRed Flag Identity Theft Prevention Program on behalf of the Trust; (d) D. Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) E. Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBGFS USBFS acknowledges, that USBGFS USBFS shall (i) permit federal regulators access to such information and records maintained by USBGFS USBFS and relating to USBGFSUSBFS’ implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBGFSUSBFS’ implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust acknowledges that it has had an opportunity to review and consider the written procedures provided by USBGFS describing various tools used by USBGFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program and the Red Flag Identity Theft Prevention program, are reasonably designed to prevent the Trust from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBGFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering and identity theft responsibilities. The Trust acknowledges and agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-sub- accounts through the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary. (a) i. Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (b) ii. Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholder; (c) iii. Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to the Procedures; (d) iv. Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) v. Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBGFS acknowledges, that USBGFS shall (i) permit federal regulators access to such information and records maintained by USBGFS and relating to USBGFS’ implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBGFS’ implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust acknowledges that it has had an opportunity to review review, consider and consider comment upon the written procedures provided by USBGFS Fund Services describing various tools used by USBGFS Fund Services which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust Fund has determined that the Procedures, as part of the TrustFund’s overall anti-money laundering program and the Red Flag Identity Theft Prevention program, are reasonably designed to prevent the Trust Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), 2003 and the USA PATRIOT Patriot Act of 2001, 2001 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBGFS Fund Services to implement the Procedures on the TrustFund’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustFund’s anti-money laundering and identity theft responsibilities. The Trust acknowledges and agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS Fund Services believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust Fund or any shareholder of the TrustFund; (b) Prompt written notification of any shareholder(scustomer(s) that USBGFS Fund Services reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust Fund agrees not to communicate this information to the shareholdercustomer; (c) Any reports received by USBGFS Fund Services from any government agency or applicable industry self-regulatory organization pertaining to Fund Services anti-money laundering monitoring or the ProceduresRed Flag Identity Theft Prevention Program on behalf of the Fund; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the TrustFund. The Trust hereby directs, and USBGFS Fund Services acknowledges, that USBGFS Fund Services shall (i) permit federal regulators access to such information and records maintained by USBGFS Fund Services and relating to USBGFSFund Services’ implementation of the Procedures, on behalf of the TrustFund, as they may request, and (ii) permit such federal regulators to inspect USBGFSFund Services’ implementation of the Procedures on behalf of the TrustFund.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust Fund acknowledges that it has had an opportunity to review review, consider and consider comment upon the written procedures provided by USBGFS Fund Services describing various tools used by USBGFS Fund Services which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has Fund and Fund Services have determined that the Procedures, as part of the TrustFund’s overall anti-money laundering program and the Red Flag Identity Theft Prevention program, are reasonably designed to to: (i) prevent the Trust Fund from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and (iii) to achieve compliance with the applicable provisions of the Bank Secrecy Act, Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), 2003 and the USA PATRIOT Patriot Act of 2001, 2001 and the implementing regulations thereunder. Based on this determination, the Trust Fund hereby instructs and directs USBGFS Fund Services to implement the Procedures Procedures, as applicable, on the TrustFund’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is Fund Services and any such amended Procedures will be provided relating to the Trust’s anti-money laundering Fund. Should the Fund desire that Fund Services perform services not provided for in the Procedures, such additional services and identity theft responsibilitiesthe associated cost must be specifically detailed in the attached fee schedule. The Trust Fund acknowledges and agrees that although it is directing USBGFS Fund Services to implement the Procedures on its behalf, USBGFS Fund Services is implementing the Procedures as a service provider to the Trust Fund and the Trust Fund is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003AML Rules, or otherwise, including, without limitationsuch as, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer, as applicable. The Trust Fund further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the TrustFund. The Trust Fund has had the opportunity to discuss the Procedures with USBGFSFund Services, and the Trust Fund understands and agrees which portions of the Procedures may not be implemented on behalf of the TrustFund. Without limitation of the foregoing, USBGFS Fund Services shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national National Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust Fund and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (b) Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholder; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to the Procedures; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust Fund hereby directs, and USBGFS Fund Services acknowledges, that USBGFS Fund Services shall (i) permit federal regulators access to such information and records maintained by USBGFS Fund Services and relating to USBGFSFund Services’ implementation of the Procedures, on behalf of the TrustFund, as they may request, and (ii) permit such federal regulators to inspect USBGFSFund Services’ implementation of the Procedures on behalf of the TrustFund.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust Company acknowledges that it has had an opportunity to review review, consider and consider comment upon the written procedures provided by USBGFS USBFS describing various tools used by USBGFS USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust Company has determined that the Procedures, as part of the TrustCompany’s overall anti-money laundering program and the Red Flag Identity Theft Prevention program, are reasonably designed to prevent the Trust Company from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), 2003 and the USA PATRIOT Patriot Act of 2001, 2001 and the implementing regulations thereunder. Based on this determination, the Trust Company hereby instructs and directs USBGFS USBFS to implement the Procedures Procedures, as applicable, on the TrustCompany’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is USBFS and any such amended Procedures will be provided relating to the Trust’s anti-money laundering Company. Should the Company desire that USBFS perform services not provided for in the Procedures, such additional services and identity theft responsibilitiesthe associated cost must be specifically detailed in the attached fee schedule. The Trust Company acknowledges and agrees that although it is directing USBGFS USBFS to implement the Procedures on its behalf, USBGFS USBFS is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003AML Rules, or otherwise, including, without limitationsuch as, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer, as applicable. The Trust Company further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the TrustCompany. The Trust Company has had the opportunity to discuss the Procedures with USBGFSUSBFS, and the Trust Company understands and agrees which portions of the Procedures may not be implemented on behalf of the TrustCompany. Without limitation of the foregoing, USBGFS USBFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national National Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust Company and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (b) Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholder; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to the Procedures; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust Company hereby directs, and USBGFS USBFS acknowledges, that USBGFS USBFS shall (i) permit federal regulators access to such information and records maintained by USBGFS USBFS and relating to USBGFSUSBFS’ implementation of the Procedures, on behalf of the TrustCompany, as they may request, and (ii) permit such federal regulators to inspect USBGFSUSBFS’ implementation of the Procedures on behalf of the Company. USBFS will reimburse each Company and/or Fund for any Net Material Loss that may exist on the Company’s or Fund’s books and for which USBFS is responsible, at the end of each calendar month. “Net Material Loss” shall be defined as any remaining loss, after netting losses against any gains, which impacts a Company’s or Fund’s net asset value per share by at least ½ cent. Gains and losses will be reflected on the Company’s or Fund’s daily share sheet, and the Company or Fund will be reimbursed for any net material loss on a monthly basis. USBFS will reset the “as of” ledger each calendar month so that any losses which do not exceed the materiality threshold of ½ cent will not be carried forward to the next succeeding month. USBFS will notify the adviser to the Fund on the daily share sheet of any losses for which the adviser may be held accountable. Angel Oak Funds Trust, with the following series: • Angel Oak Financials Income Fund • Angel Oak Multi-Strategy Income Fund • Angel Oak High Yield Opportunities Fund • Angel Oak UltraShort Income Fund • Angel Oak Core Impact Fund Angel Oak Strategic Credit Fund Angel Oak Dynamic Financial Strategies Income Term Trust Angel Oak Financial Strategies Income Term Trust Service Line Agreements, dated October 16, 2014 by and between Angel Oak Funds Trust and U.S. Bancorp Fund Services, LLC Service Line Agreements, dated November 9, 2017 by and between Angel Oak Strategic Credit Fund and U.S. Bancorp Fund Services, LLC Service Line Agreements, dated April 29, 2020 by and between Angel Oak Dynamic Financial Strategies Income Term Trust and U.S. Bancorp Fund Services, LLC Service Line Agreements, dated August 1, 2018 by and between Angel Oak Financial Strategies Income Term Trust and U.S. Bancorp Fund Services, LLC [ ] basis points on the first $2 billion [ ] basis points >$2 billion – $6 billion [ ] basis point on the balance Minimum Annual Fee: $[ ] million for fund complex • $[ ] – Domestic Equities, Options, ADRs, Foreign Equities, Futures, Forwards, Currency Rates, Mutual Funds, ETFs, Total Return Swaps, Total Return Bullet Swaps • $[ ] – Domestic Corporates, Domestic Convertibles, Domestic Governments, Domestic Agencies, Mortgage Backed Securities, Municipal Bonds • $[ ] – CMOs, Money Market Instruments, Foreign Corporates, Foreign Convertibles, Foreign Governments, Foreign Agencies, Asset Backed, High Yield Bonds • $[ ] – Interest Rate Swaps, Foreign Currency Swaps • $[ ] – Bank Loans • $[ ] – Credit Default Swaps • $[ ] – Swaptions • $[ ] – Intraday money market funds pricing, up to 3 times per day • $[ ] per month – Manual Security Pricing (>25 per day) • $[ ] per Foreign Equity Security Corporate Action Service per month • $[ ] per Domestic Equity Security Corporate Action Service per month • $[ ] per CMO, Asset Backed, Mortgage Backed Securities Factor Services per month • $[ ] per security per month for fund administrative data Tier 1: $[ ] Tier 2: $[ ] Tier 3: $[ ] Tier 4: $[ ] Tier 5: $[ ] Each security’s Tier to be charged is determined by the pricing vendor. Rates subject to change based on changes in costs from the underlying pricing service.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust acknowledges that it has had an opportunity to review review, consider and consider comment upon the written procedures provided by USBGFS USBFS describing various tools used by USBGFS which USBFS that are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity activity, as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has and USBFS have each determined that the Procedures, as part of the Trust’s overall anti-money laundering program and the Red Flag Identity Theft Prevention program, are reasonably designed to to: (i) prevent the Trust Fund from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), Fair and Accurate Credit Transactions Act of 2003 and the USA PATRIOT Patriot Act of 2001, 2001 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBGFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering and identity theft responsibilities. The Trust acknowledges and agrees that although it is directing USBGFS USBFS to implement the Procedures on its behalf, USBGFS USBFS is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the TrustFund. The Trust Fund has had the opportunity to discuss the Procedures with USBGFSUSBFS, and the Trust Fund understands and agrees which portions of the Procedures may not be implemented on behalf of the TrustFund. Without limitation of the foregoing, USBGFS USBFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary.. Based on this determination, the Trust hereby instructs and directs USBFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering and identity theft responsibilities. XXXXX agrees to provide to the Trust: (a) A. Prompt written notification of any transaction or combination of transactions that USBGFS USBFS believes, based on the Procedures, evidence money laundering laundering, activity that may warrant a suspicious activity report or identity theft activities in connection with the Trust or any shareholder of the TrustFund; (b) B. Prompt written notification of any shareholder(scustomer(s) that USBGFS USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering laundering, activity that may warrant a suspicious activity report or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholdercustomer; (c) C. Any reports received by USBGFS USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring or the ProceduresRed Flag Identity Theft Prevention Program on behalf of the Trust; (d) D. Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a)subsections 5.A, (b) B or (c); andC above; (e) E. Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust; and F. Prompt written notification of any material changes to the Procedures. The Trust hereby directs, and USBGFS USBFS acknowledges, that USBGFS shall USBFS shall: (i) permit federal regulators access to such information and records maintained by USBGFS USBFS and relating to USBGFS’ USBFS’s implementation of the Procedures, on behalf of the Trust, as they may request, ; and (ii) permit such federal regulators to inspect USBGFS’ USBFS’s implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust acknowledges that it has had an opportunity to review and consider the written procedures provided by USBGFS describing various tools processes used by USBGFS which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Procedures”).2 Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program and the Red Flag Identity Theft Prevention programidentity theft prevention program responsibilities, are reasonably designed to help: (i) prevent the Trust from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, and the implementing regulations thereunderthereunder (together “AML Rules”). Based on this determination, the Trust hereby instructs and directs USBGFS to implement the Procedures Procedures, as applicable, on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is and any such amended Procedures will be provided relating to the Trust’s anti-money laundering . Should the Trust desire that USBGFS perform services not provided for in the Procedures, such additional services and identity theft responsibilitiesthe associated cost must be specifically detailed in the attached fee schedule. The Trust acknowledges and agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003AML Rules, or otherwise, including, without limitationsuch as, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer, as applicable. 2 NTD: Please provide. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national Securities Clearing CorporationNSCC) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (b) Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholder; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to the Procedures; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBGFS acknowledges, that USBGFS shall (i) permit federal regulators access to such information and records maintained by USBGFS and relating to USBGFS’ implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBGFS’ implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust acknowledges that it has had an opportunity to review and consider the written procedures provided by USBGFS describing various tools processes used by USBGFS which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program and the Red Flag Identity Theft Prevention programidentity theft prevention program responsibilities, are reasonably designed to help: (i) prevent the Trust from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Bank Secrecy Act, the USA Patriot Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, and the implementing regulations thereunderthereunder (together “AML Rules”). Based on this determination, the Trust hereby instructs and directs USBGFS to implement the Procedures Procedures, as applicable, on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is and any such amended Procedures will be provided relating to the Trust’s anti-money laundering . Should the Trust desire that USBGFS perform services not provided for in the Procedures, such additional services and identity theft responsibilitiesthe associated cost must be specifically detailed in the attached fee schedule. The Trust acknowledges and agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures solely as a service provider to the Trust and Trust. Notwithstanding the foregoing, USBGFS represents to the Trust is and remains ultimately responsible for complying that the Procedures will at all times throughout the term of this Agreement comply with all applicable lawslaw and regulation, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under including the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the TrustAML Rules. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national National Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary. (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering or identity theft activities in connection with the Trust or any shareholder of the Trust; (b) Prompt written notification of any shareholder(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering or identity theft activities, provided that the Trust agrees not to communicate this information to the shareholder; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to the Procedures; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBGFS acknowledges, that USBGFS shall (i) permit federal regulators access to such information and records maintained by USBGFS and relating to USBGFS’ implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBGFS’ implementation of the Procedures on behalf of the Trust. USBGFS agrees to certify to the Trust, on a quarterly basis, that it has implemented its anti-money laundering program, including the Procedures, in accordance with Section 4 of this Agreement, and to provide related reports and permit inspection of its Procedures (and its compliance therewith) by the Trust, including its AML Chief Compliance Officer, as may be requested by the Trust. Furthermore, USBGFS agrees to promptly notify the Trust’s designated anti-money laundering officer of any Fund account, shareholder or beneficial owner that is a subject of a suspicious activity report filing or an OFAC, United Nations, or other applicable sanction.

Anti-Money Laundering and Red Flag Identity Theft Prevention Programs. The Trust Fund acknowledges that it has had an opportunity to review and consider and comment upon the written procedures provided by USBGFS describing various tools processes used by USBGFS which are designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust Fund has determined that the Procedures, as part of the TrustFund’s overall anti-money laundering program and the Red Flag Identity Theft Prevention programidentity theft prevention program responsibilities, are reasonably designed to help: (i) prevent the Trust Fund from being used for money laundering or the financing of terrorist activities activities; (ii) prevent identity theft; and to (iii) achieve compliance with the applicable provisions of the Bank Secrecy Act, the USA Patriot Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, the Bank Secrecy Act, the Office of Foreign Assets Control Sanctions Programs (“economic sanctions”), the USA PATRIOT Act of 2001, and the implementing regulations thereunderthereunder (together “AML Rules”). Based on this determination, the Trust Fund hereby instructs and directs USBGFS to implement the Procedures Procedures, as applicable, on the TrustFund’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by USBGFS as additional regulations are adopted and/or regulatory guidance is and any such amended Procedures will be provided relating to the Trust’s anti-money laundering Fund. Should the Fund desire that USBGFS perform services not provided for in the Procedures, such additional services and identity theft responsibilitiesthe associated cost must be specifically detailed in the attached fee schedule. The Trust acknowledges and USBGFS agrees that although it is directing USBGFS to implement the Procedures on its behalf, USBGFS is implementing the Procedures as a service provider provide to the Trust and the Trust is and remains ultimately responsible for complying with all applicable laws, rules, and regulations with respect to anti-money laundering, customer identification, identity theft prevention, economic sanctions, and terrorist financing, whether under the Bank Secrecy Act, the USA PATRIOT Act of 2001, the Fair and Accurate Credit Transactions Act of 2003, or otherwise, including, without limitation, the establishment and board adoption of its own formal anti-money laundering program and the designation of its own anti-money laundering officer. The Trust further acknowledges and agrees that certain portions of the Procedures are applicable to certain products, entities, structures, or geographies and, accordingly, certain portions of the Procedures may not be implemented with respect to the Trust. The Trust has had the opportunity to discuss the Procedures with USBGFS, and the Trust understands and agrees which portions of the Procedures may not be implemented on behalf of the Trust. Without limitation of the foregoing, USBGFS shall not be responsible for providing anti-money laundering or customer identification services with respect to certain intermediary or dealer-controlled customer accounts (i.e., level 0 sub-accounts through the Fund/SERV system operated by the national Securities Clearing Corporation) and other fund client relationships where there is a sub-transfer agency or similar arrangement between the Trust and the intermediary.: (a) Prompt written notification of any transaction or combination of transactions that USBGFS believes, based on the Procedures, evidence money laundering laundering, activity that may warrant a suspicious activity report or identity theft activities in connection with the Trust Fund or any shareholder of the TrustFund; (b) Prompt written notification of any shareholder(scustomer(s) that USBGFS reasonably believes, based upon the Procedures, to be engaged in money laundering laundering, activity that may warrant a suspicious activity report or identity theft activities, provided that the Trust Fund agrees not to communicate this information to the shareholdersuch customer; (c) Any reports received by USBGFS from any government agency or applicable industry self-regulatory organization pertaining to USBGFS anti-money laundering monitoring or the ProceduresRed Flag Identity Theft Prevention Program on behalf of the Fund; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. Fund, including an annual certification that USBGFS has applied and followed the Procedures during the relevant reporting period; The Trust Fund hereby directs, and USBGFS acknowledges, that USBGFS shall (i) permit federal regulators access to such information and records maintained by USBGFS and relating to USBGFS’ implementation of the Procedures, on behalf of the TrustFund, as they may request, and (ii) permit such federal regulators to inspect USBGFS’ implementation of the Procedures on behalf of the TrustFund.