Common use of Anti-Money Laundering Compliance Programs Clause in Contracts

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents to the Dealer Manager and to the Company that it has established and implemented anti-money laundering compliance programs in accordance with applicable law, including applicable FINRA Conduct Rules, the Exchange Act Rules and Regulations and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, as amended (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Shares. Soliciting Dealer further represents that it currently is in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, and Soliciting Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager or the Company, provide a certification to the Dealer Manager or the Company that, as of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Upon request by the Dealer Manager at any time, Soliciting Dealer will (i) furnish a written copy of its AML Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its most recent independent testing of its AML Program.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents (a) Participating Dealer’s acceptance of this Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Participating Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, rules promulgated by the Exchange Act Rules and Regulations Commission (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Primary Shares. Soliciting Participating Dealer’s acceptance of this Agreement also constitutes a representation to the Company and the Dealer further represents Manager that it currently as of the date hereof, Participating Dealer is in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Participating Dealer covenants that it will perform all activities it is required to perform by applicable AML Rules and its AML Program with respect to all customers on whose behalf Participating Dealer submits orders to the Company. To the extent permitted by applicable law, and Soliciting Participating Dealer hereby covenants to remain in compliance will share information with such requirements and shall, upon request by the Dealer Manager or the Company, provide a certification to the Dealer Manager or and the Company that, as for purposes of ascertaining whether a suspicious activity report is warranted with respect to any suspicious transaction involving the date purchase or intended purchase of such certification (a) its AML Program is consistent with the AML Rules, and Primary Shares. (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Upon request by the Dealer Manager at any time, Soliciting Participating Dealer will hereby agrees to (i) furnish a written copy of its AML Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Participating Dealer’s most recent independent testing of its AML Program. Participating Dealer further represents that it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, and Participating Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager, provide a certification to Dealer Manager that, as of the date of such certification, (i) its AML Program is consistent with the AML Rules, (ii) it has continued to implement its AML Program, and (iii) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents Dealer’s acceptance of this Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, the Exchange Act Rules and Regulations and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, as amended (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Shares. Soliciting Dealer’s acceptance of this Agreement also constitutes a representation to the Company and the Dealer further represents Manager that it is currently is in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, and Soliciting . Dealer Manager hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager or the Company, provide a certification to the Dealer Manager or the Company that, as of the date of such certification (a) its AML Program is consistent with the AML Rules, Rules and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Upon request Further, Dealer agrees, upon receipt of an “information request” issued under Section 314 (a) of the USA Patriot Act to provide the Financial Crimes Enforcement Network with information regarding: (i) the identity of a specified individual or organization; (ii) account number; (iii) all identifying information provided by the account holder; and (iv) the date and type of transaction. The Dealer Manager from time to time will monitor account activity to identify patterns of unusual size or volume, geographic factors, and any other potential signals of suspicious activity, including possible money laundering or terrorist financing. The Company and the Dealer Manager at any time, Soliciting Dealer will (i) furnish a written copy of its AML Program reserve the right to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its most recent independent testing of its AML Programreject account applications from new customers who fail to provide necessary account information or who intentionally provide misleading information.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents (a) Participating Dealer’s acceptance of this Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Participating Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, rules promulgated by the Exchange Act Rules and Regulations Commission (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Primary Shares. Soliciting Participating Dealer’s acceptance of this Agreement also constitutes a representation to the Company and the Dealer further represents Manager that it currently as of the date hereof, Participating Dealer is in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Participating Dealer covenants that it will perform all activities it is required to perform by applicable AML Rules and its AML Program with respect to all customers on whose behalf Participating Dealer submits orders to the Company. To the extent permitted by applicable law, and Soliciting Participating Dealer hereby covenants to remain in compliance will share information with such requirements and shall, upon request by the Dealer Manager or the Company, provide a certification to the Dealer Manager or and the Company that, as for purposes of ascertaining whether a suspicious activity report is warranted with respect to any suspicious transaction involving the date purchase or intended purchase of such certification (a) its AML Program is consistent with the AML Rules, and Primary Shares. (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Upon request by the Dealer Manager at any time, Soliciting Participating Dealer will hereby agrees to (i) furnish a written copy of its AML Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Participating Dealer’s most recent independent testing of its AML Program. Participating Dealer further represents that it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, and Participating Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager, provide a certification to Dealer Manager that, as of the date of such certification, (i) its AML Program is consistent with the AML Rules, (ii) it has continued to implement its AML Program, and (iii) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents Each Dealer’s acceptance of this Agreement constitutes a representation to the Managing Broker-Dealer Manager and to that the Company that it Dealer has established and implemented an anti-money laundering (“AML”) compliance programs program (“AML Program”), in accordance with applicable law, including applicable FINRA Conduct RulesRule 3310 and Section 352 of the Money Laundering Abatement Act, the Exchange Act Rules Bank Secrecy Act, as amended, and Regulations and Section 326 of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Patriot Act of 2001, as amended (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Shares. Soliciting In addition, the Dealer further represents that it has established and implemented a program (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer at any time, the Dealer hereby agrees to (i) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer for review and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Shares through the Dealer are “Customers” of the Dealer and not the Managing Broker-Dealer. Nonetheless, to the extent that the Managing Broker-Dealer deems it prudent, the Dealer shall cooperate with the Managing Broker-Dealer’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently is in compliance with all AML Rulesrules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement USA PATRIOT Act, and Soliciting . The Dealer hereby covenants to remain in compliance with such requirements and shallagrees, upon request by the Managing Broker-Dealer Manager or the Company, to (i) provide a an annual certification to the Managing Broker-Dealer Manager or the Company that, as of the date of such certification (aA) its AML Program is and its OFAC Program are consistent with the AML RulesRules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (bC) it is currently in compliance with all AML RulesRules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Upon request by the Dealer Manager at any time, Soliciting Dealer will (i) furnish a written copy of its AML Program to the Dealer Manager for review, USA PATRIOT Act and (ii) furnish a copy perform and carry out, on behalf of both the Managing Broker-Dealer and the Company, the Customer Identification Program requirements in accordance with Section 326 of the findings USA PATRIOT Act and any remedial actions taken in connection with its most recent independent testing of its AML Programapplicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents Each Selling Group Member’s acceptance of this Agreement constitutes a representation to the Managing Broker-Dealer Manager and to that the Company that it Selling Group Member has established and implemented an anti-money laundering (“AML”) compliance programs program (“AML Program”), in accordance with applicable law, including applicable FINRA Conduct Rules, Rule 3310 and Section 352 of the Exchange Money Laundering Abatement Act Rules and Regulations and Section 326 of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Patriot Act of 2001, as amended (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of Bonds. In addition, the Shares. Soliciting Dealer further Selling Group Member represents that it has established and implemented a program (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer at any time, the Selling Group Member hereby agrees to (i) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer for review and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Selling Group Member’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Bonds through the Selling Group Member are “Customers” of the Selling Group Member and not the Managing Broker-Dealer. Nonetheless, to the extent that the Managing Broker-Dealer deems it prudent, the Selling Group Member shall cooperate with the Managing Broker-Dealer’s auditing and monitoring of the Selling Group Member’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s Investors introduced to, and serviced by, the Selling Group Member (the “Customers”). Such documentation could include, among other things: (i) copies of Selling Group Member’s AML Program and its OFAC Program, (ii) documents maintained pursuant to the Selling Group Member’s AML Program and its OFAC Program related to the Customers, (iii) any suspicious activity reports filed related to the Customers, (iv) audits and any exception reports related to the Selling Group Member’s AML activities and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Selling Group Member will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Selling Group Member’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Selling Group Member shall not be required to provide to the Managing Broker-Dealer any documentation that, in the Selling Group Member’s reasonable judgment, would cause the Selling Group Member to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Selling Group Member hereby represents that it is currently is in compliance with all AML Rulesrules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement USA PATRIOT Act, and Soliciting Dealer . The Selling Group Member hereby covenants to remain in compliance with such requirements and shallagrees, upon request by the Managing Broker-Dealer Manager or the Company, to (i) provide a an annual certification to the Managing Broker-Dealer Manager or the Company that, as of the date of such certification (aA) its AML Program is and its OFAC Program are consistent with the AML RulesRules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (bC) it is currently in compliance with all AML RulesRules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Upon request by the Dealer Manager at any time, Soliciting Dealer will (i) furnish a written copy of its AML Program to the Dealer Manager for review, USA PATRIOT Act and (ii) furnish a copy perform and carry out, on behalf of both the Managing Broker-Dealer and the Company, the Customer Identification Program requirements in accordance with Section 326 of the findings USA PATRIOT Act and any remedial actions taken in connection with its most recent independent testing of its AML Programapplicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents Participating Dealer’s acceptance of this Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Participating Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, Securities and Exchange Commission Rules (the Exchange Act Rules and Regulations “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Primary Shares. Soliciting Participating Dealer further represents covenants that it currently will perform all activities it is in compliance required to perform by applicable AML Rules and its AML Program with respect to all AML Rulescustomers on whose behalf Participating Dealer submits orders to the Company. To the extent permitted by applicable law, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, and Soliciting Participating Dealer hereby covenants to remain in compliance will share information with such requirements and shall, upon request by the Dealer Manager or the Company, provide a certification to the Dealer Manager or and the Company that, as for purposes of ascertaining whether a suspicious activity report (“SAR”) is warranted with respect to any suspicious transaction involving the date purchase or intended purchase of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement ActPrimary Shares. Upon request by the Dealer Manager at any time, Soliciting Participating Dealer will hereby agrees to (i) furnish a written copy of its AML Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Participating Dealer’s most recent independent testing of its AML Program. Participating Dealer further represents that it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, and such Participating Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager, provide a certification to Dealer Manager that, as of the date of such certification (i) its AML Program is consistent with the AML Rules, (ii) it has continued to implement its AML Program, and (iii) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act.

Anti-Money Laundering Compliance Programs. Soliciting Selected Dealer’s acceptance of this Dealer represents Agreement constitutes a representation to the Corporation and the Dealer Manager and to the Company that it Selected Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, Securities and Exchange Commission Rules (the Exchange Act Rules and Regulations “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Offered Shares. Soliciting In addition, Selected Dealer further represents that it currently is in has established and implemented a program for compliance with Executive Order 13224 and all AML Rules, specifically including, but not limited to, regulations and programs administered by the Customer Identification Program requirements under Section 326 U.S. Department of the Money Laundering Abatement Act, Treasury’s Office of Foreign Assets Control (“OFAC Program”) and Soliciting Dealer hereby covenants will continue to remain in compliance with such requirements and shall, upon request by maintain its OFAC Program during the Dealer Manager or the Company, provide a certification to the Dealer Manager or the Company that, as term of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Actthis Agreement. Upon request by the Dealer Manager at any time, Soliciting Selected Dealer will hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Selected Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the investors who purchase Offered Shares through Selected Dealer are “customers” of Selected Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Selected Dealer shall cooperate with the Dealer Manager’s reasonable requests for information, records and data related to the Corporation’s stockholders introduced to, and serviced by, Selected Dealer (the “Customers”). Notwithstanding the foregoing, Selected Dealer shall not be required to provide to the Dealer Manager any documentation that, in Selected Dealer’s reasonable judgment, would cause Selected Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Selected Dealer hereby represents that it is currently in compliance with all AML Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. Selected Dealer hereby agrees, upon request by the Dealer Manager to (A) provide an annual certification to Dealer Manager that, as of the date of such certification (i) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements; (ii) it has continued to implement its AML Program and its OFAC Program, and (iii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act; and (B) perform and carry out, on behalf of both the Dealer Manager and the Corporation, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents Selected Dealer’s acceptance of this Agreement constitutes a representation to the Fund and the Dealer Manager and to the Company that it Selected Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, the Exchange Act SEC Rules and Regulations and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, as amended (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) , reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Offered Shares. Soliciting In addition, Selected Dealer further represents that it currently is in has established and implemented a program for compliance with Executive Order 13224 and all AML Rules, specifically including, but not limited to, regulations and programs administered by OFAC (“OFAC Program”) and will continue to maintain its OFAC Program during the Customer Identification Program requirements under Section 326 term of the Money Laundering Abatement Act, and Soliciting Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager or the Company, provide a certification to the Dealer Manager or the Company that, as of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Actthis Agreement. Upon request by the Dealer Manager at any time, Soliciting Selected Dealer will hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Dealer Manager for review, review and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Selected Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the investors who purchase Offered Shares through Selected Dealer are “customers” of Selected Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Selected Dealer shall cooperate with the Dealer Manager’s reasonable requests for information, records and data related to the Fund’s shareholders introduced to, and serviced by, Selected Dealer (the “Customers”). Notwithstanding the foregoing, Selected Dealer shall not be required to provide to the Dealer Manager any documentation that, in Selected Dealer’s reasonable judgment, would cause Selected Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Selected Dealer hereby represents that it is currently in compliance with all AML Rules and all OFAC requirements, including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. Selected Dealer hereby agrees, upon request by the Dealer Manager to (A) provide an annual certification to Dealer Manager that, as of the date of such certification, (i) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (ii) it has continued to implement its AML Program and its OFAC Program and (iii) it is currently in compliance with all AML Rules and OFAC requirements, including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act; and (B) perform and carry out, on behalf of both the Dealer Manager and the Fund, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and U.S. Department of Treasury rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents (a) Participating Dealer’s acceptance of this Agreement constitutes a representation to the Fund and the Dealer Manager and to the Company that it Participating Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, rules promulgated by the Exchange Act Rules and Regulations Commission (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Offered Shares. Soliciting Participating Dealer’s acceptance of this Agreement also constitutes a representation to the Fund and the Dealer further represents Manager that as of the date hereof, Participating Dealer is in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Participating Dealer covenants that it currently will perform all activities it is required to perform by applicable AML Rules and its AML Program with respect to all customers on whose behalf Participating Dealer submits orders to the Fund. To the extent permitted by applicable law, Participating Dealer will share information with the Dealer Manager and the Fund for purposes of ascertaining whether a suspicious activity report is warranted with respect to any suspicious transaction involving the purchase or intended purchase of Offered Shares. (b) Upon request by the Dealer Manager at any time, Participating Dealer hereby agrees to (i) furnish a written copy of its AML Program to the Dealer Manager for review and (ii) furnish a copy of the findings and any remedial actions taken in connection with Participating Dealer’s most recent independent testing of its AML Program. Participating Dealer hereby covenants to remain in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, and Soliciting Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager or the CompanyManager, provide a certification to the Dealer Manager or the Company that, as of the date of such certification certification, (ai) its AML Program is consistent with the AML Rules, (ii) it has continued to implement its AML Program, and (biii) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. (c) In addition, Participating Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by OFAC (“OFAC Program”) and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Dealer Manager at any time, Soliciting Participating Dealer will hereby agrees to (i) furnish a written copy of its AML OFAC Program to the Dealer Manager for review, review and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Participating Dealer’s most recent independent testing of its AML OFAC Program. Participating Dealer hereby represents that it is currently in compliance with all OFAC requirements. Participating Dealer hereby agrees, upon request by the Dealer Manager to provide an annual certification to Dealer Manager that, as of the date of such certification, (i) its OFAC Program is consistent with the OFAC requirements, (ii) it has continued to implement its OFAC Program and (iii) it is currently in compliance with all OFAC requirements. (d) The parties acknowledge that for the purposes of FINRA Rules, the investors who purchase Offered Shares through Participating Dealer are “customers” of Participating Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Participating Dealer shall cooperate with the Dealer Manager’s reasonable requests for information, records and data related to the Fund’s shareholders introduced to, and serviced by, Participating Dealer. Notwithstanding the foregoing, Participating Dealer shall not be required to provide to the Dealer Manager any documentation that, in Participating Dealer’s reasonable judgment, would cause Participating Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings.

Anti-Money Laundering Compliance Programs. Soliciting Participating Broker-Dealer’s acceptance of this Dealer represents Agreement constitutes a representation to the Corporation and the Dealer Manager and to the Company that it Participating Broker-Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, U.S. Securities and Exchange Commission (the Exchange Act “SEC”) Rules and Regulations (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Offered Shares. Soliciting In addition, Participating Broker-Dealer further represents that it currently is in has established and implemented a program for compliance with Executive Order 13224 and all AML Rules, specifically including, but not limited to, regulations and programs administered by the Customer Identification Program requirements under Section 326 U.S. Department of the Money Laundering Abatement ActTreasury’s Office of Foreign Assets Control Department of Commerce, Bureau of Industry and Soliciting Dealer hereby covenants to remain in compliance with Security, or the Department of State (such requirements regulations and shallprogram, upon request “Sanctions,” and such program as established by the Dealer Manager or Participating Broker-Dealer, “OFAC Program”) and will continue to maintain its OFAC Program during the Company, provide a certification to the Dealer Manager or the Company that, as term of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Actthis Agreement. Upon request by the Dealer Manager at any time, Soliciting Participating Broker-Dealer will hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Participating Broker-Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the investors who purchase Offered Shares through Participating Broker-Dealer are “customers” of Participating Broker-Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Participating Broker-Dealer shall cooperate with the Dealer Manager’s reasonable requests for information, records and data related to the Corporation’s stockholders introduced to, and serviced by, Participating Broker-Dealer (the “Customers”). Notwithstanding the foregoing, Participating Broker-Dealer shall not be required to provide to the Dealer Manager any documentation that, in Participating Broker-Dealer’s reasonable judgment, would cause Participating Broker-Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Participating Broker-Dealer hereby represents that it is currently in compliance with all AML Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. Participating Broker-Dealer hereby agrees, upon request by the Dealer Manager to (A) provide an annual certification to Dealer Manager that, as of the date of such certification (i) its AML Program and its OFAC Program are consistent with the AML Rules and Sanctions requirements; (ii) it has continued to implement its AML Program and its OFAC Program, and (iii) it is currently in compliance with all AML Rules and Sanctions requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act; and (B) perform and carry out, on behalf of both the Dealer Manager and the Corporation, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents 2.18.1 You will conduct reasonable investigation to ensure that all prospective Investors are not (i) listed on the Specially Designated Nationals and Blocked Persons List maintained by the Office of Foreign Asset Control, Department of the Treasury (“OFAC”) and/or on any other list of terrorists or terrorist organizations maintained pursuant to any of the rules and regulations of OFAC or pursuant to any other applicable enabling legislation or other Executive Orders in respect thereof (such lists are collectively referred to as “Lists”) or (ii) owned or controlled by, nor act for or on behalf of, any person or entity on the Lists. 2.18.2 Each Selling Group Member’s acceptance of this Agreement constitutes a representation to the Managing Broker Dealer Manager and to that the Company that it Selling Group Member has established and implemented an anti-money laundering (“AML”) compliance programs program (“AML Program”), in accordance with applicable law, including applicable FINRA Conduct Rules, Rule 3310 and Section 352 of the Exchange Money Laundering Abatement Act Rules and Regulations and Section 326 of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Patriot Act of 2001, as amended (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of Securities. In addition, the Shares. Soliciting Dealer further Selling Group Member represents that it has established and implemented a program (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker Dealer at any time, the Selling Group Member hereby agrees to (i) furnish a copy of its AML Program and OFAC Program to the Managing Broker Dealer for review and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Selling Group Member’s most recent independent testing of its AML Program and/or its OFAC Program. 2.18.3 The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Securities through the Selling Group Member are “Customers” of the Selling Group Member and not the Managing Broker Dealer. Nonetheless, to the extent that the Managing Broker Dealer deems it prudent, the Selling Group Member shall cooperate with the Managing Broker Dealer’s auditing and monitoring of the Selling Group Member’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to Investors introduced to, and serviced by, the Selling Group Member (the “Customers”). Such documentation could include, among other things: (i) copies of Selling Group Member’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Selling Group Member’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Selling Group Member’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker Dealer, a potential violation of the Managing Broker Dealer’s obligations in respect of its AML or OFAC requirements, the Selling Group Member will permit the Managing Broker Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Selling Group Member’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Selling Group Member shall not be required to provide to the Managing Broker Dealer any documentation that, in the Selling Group Member’s reasonable judgment, would cause the Selling Group Member to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Selling Group Member hereby represents that it is currently is in compliance with all AML Rulesrules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement USA PATRIOT Act, and Soliciting Dealer . The Selling Group Member hereby covenants to remain in compliance with such requirements and shallagrees, upon request by the Managing Broker Dealer Manager or the Company, to (i) provide a an annual certification to the Managing Broker Dealer Manager or the Company that, as of the date of such certification (aA) its AML Program is and its OFAC Program are consistent with the AML RulesRules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (bC) it is currently in compliance with all AML RulesRules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Upon request by the Dealer Manager at any time, Soliciting Dealer will (i) furnish a written copy of its AML Program to the Dealer Manager for review, USA PATRIOT Act and (ii) furnish a copy perform and carry out, on behalf of both the Managing Broker Dealer and the Issuer, the Customer Identification Program requirements in accordance with Section 326 of the findings USA PATRIOT Act and any remedial actions taken in connection with its most recent independent testing of its AML Programapplicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Selected Dealer’s acceptance of this Dealer represents Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Selected Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, Securities and Exchange Commission Rules (the Exchange Act Rules and Regulations “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Offered Shares. Soliciting In addition, Selected Dealer further represents that it currently is in has established and implemented a program for compliance with Executive Order 13224 and all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, regulations and Soliciting Dealer hereby covenants to remain in compliance with such requirements and shall, upon request programs administered by the Dealer Manager or Treasury Department’s Office of foreign Assets Control regulations and programs administered by the Company, provide a certification Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) and will continue to maintain its OFAC Program during the Dealer Manager or the Company that, as term of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Actthis Agreement. Upon request by the Dealer Manager at any time, Soliciting Selected Dealer will hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Selected Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the investors who purchase Offered Shares through Selected Dealer are “customers” of Selected Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Selected Dealer shall cooperate with the Dealer Manager’s reasonable requests for information, records and data related to the Company’s stockholders introduced to, and serviced by, Selected Dealer (the “Customers”). Notwithstanding the foregoing, Selected Dealer shall not be required to provide to the Dealer Manager any documentation that, in Selected Dealer’s reasonable judgment, would cause Selected Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Selected Dealer hereby represents that it is currently in compliance with all AML Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. Selected Dealer hereby agrees, upon request by the Dealer Manager to (A) provide an annual certification to Dealer Manager that, as of the date of such certification (i) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements; (ii) it has continued to implement its AML Program and its OFAC Program, and (iii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act; and (B) perform and carry out, on behalf of both the Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents Participating Broker-Dealer’s acceptance of this Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Participating Broker-Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, rules promulgated by the Exchange Act Rules and Regulations Commission (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Primary Shares. Soliciting Participating Broker-Dealer covenants that it will perform all activities it is required to perform by applicable AML Rules and its AML Program with respect to all customers on whose behalf Participating Broker-Dealer submits orders to the Company. To the extent permitted by applicable law, Participating Broker-Dealer will share information with the Dealer Manager and the Company for purposes of ascertaining whether a suspicious activity report is warranted with respect to any suspicious transaction involving the purchase or intended purchase of Primary Shares. Upon request by the Dealer Manager at any time, Participating Broker-Dealer hereby agrees to provide annual certification to the Dealer Manager that Participating Broker-Dealer has complied with the provisions of its AML Program and relevant legal requirements. Participating Broker-Dealer further represents that it is currently is in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, and Soliciting Participating Broker-Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager or the CompanyManager, provide a an annual certification to the Dealer Manager or the Company that, as of the date of such certification (a) its AML Program is consistent with the AML Rules, (b) it has continued to implement its AML Program, and (bc) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Upon request by the Dealer Manager at any time, Soliciting Dealer will (i) furnish a written copy of its AML Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its most recent independent testing of its AML Program.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents 21.18.1 You will conduct reasonable investigation to ensure that all prospective Investors are not (i) listed on the Specially Designated Nationals and Blocked Persons List maintained by the Office of Foreign Asset Control, Department of the Treasury (“OFAC”) and/or on any other list of terrorists or terrorist organizations maintained pursuant to any of the rules and regulations of OFAC or pursuant to any other applicable enabling legislation or other Executive Orders in respect thereof (such lists are collectively referred to as “Lists”) or (ii) owned or controlled by, nor act for or on behalf of, any person or entity on the Lists. 21.18.2 Each Introducing RIA’s acceptance of this Agreement constitutes a representation to the Managing Broker Dealer Manager and to that the Company that it Introducing RIA has established and implemented an anti-money laundering (“AML”) compliance programs program (“AML Program”), in accordance with applicable law, including applicable FINRA Conduct Rules, 31 U.S.C. 5318(h) and Section 352 of the Exchange Money Laundering Abatement Act Rules and Regulations and Section 326 of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Patriot Act of 2001, as amended (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of Securities. In addition, the Shares. Soliciting Dealer further Introducing RIA represents that it has established and implemented a program (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker Dealer at any time, the Introducing RIA hereby agrees to (i) furnish a copy of its AML Program and OFAC Program to the Managing Broker Dealer for review and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Introducing RIA’s most recent independent testing of its AML Program and/or its OFAC Program. 21.18.3 The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Securities through the Introducing RIA are “Customers” of the Introducing RIA and not the Managing Broker Dealer. Nonetheless, to the extent that the Managing Broker Dealer deems it prudent, the Introducing RIA shall cooperate with the Managing Broker Dealer’s auditing and monitoring of the Introducing RIA’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to Investors introduced to, and serviced by, the Introducing RIA (the “Customers”). Such documentation could include, among other things: (i) copies of Introducing RIA’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Introducing RIA’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Introducing RIA’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker Dealer, a potential violation of the Managing Broker Dealer’s obligations in respect of its AML or OFAC requirements, the Introducing RIA will permit the Managing Broker Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Introducing RIA’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Introducing RIA shall not be required to provide to the Managing Broker Dealer any documentation that, in the Introducing RIA’s reasonable judgment, would cause the Introducing RIA to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Introducing RIA hereby represents that it is currently is in compliance with all AML Rulesrules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement USA PATRIOT Act, and Soliciting Dealer . The Introducing RIA hereby covenants to remain in compliance with such requirements and shallagrees, upon request by the Managing Broker Dealer Manager or the Company, to (i) provide a an annual certification to the Managing Broker Dealer Manager or the Company that, as of the date of such certification (aA) its AML Program is and its OFAC Program are consistent with the AML RulesRules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (bC) it is currently in compliance with all AML RulesRules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Upon request by the Dealer Manager at any time, Soliciting Dealer will (i) furnish a written copy of its AML Program to the Dealer Manager for review, USA PATRIOT Act and (ii) furnish a copy perform and carry out, on behalf of both the Managing Broker Dealer and the Issuer, the Customer Identification Program requirements in accordance with Section 326 of the findings USA PATRIOT Act and any remedial actions taken in connection with its most recent independent testing of its AML Programapplicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Selected Dealer’s acceptance of this Dealer represents Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Selected Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, Securities and Exchange Commission Rules (the Exchange Act Rules and Regulations “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Offered Shares. Soliciting In addition, Selected Dealer further represents that it currently is in has established and implemented a program for compliance with Executive Order 13224 and all AML Rules, specifically including, but not limited to, regulations and programs administered by the Customer Identification Program requirements under Section 326 U.S. Department of the Money Laundering Abatement Act, Treasury’s Office of Foreign Assets Control (“OFAC Program”) and Soliciting Dealer hereby covenants will continue to remain in compliance with such requirements and shall, upon request by maintain its OFAC Program during the Dealer Manager or the Company, provide a certification to the Dealer Manager or the Company that, as term of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Actthis Agreement. Upon request by the Dealer Manager at any time, Soliciting Selected Dealer will hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Selected Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the investors who purchase Offered Shares through Selected Dealer are “customers” of Selected Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Selected Dealer shall cooperate with the Dealer Manager’s reasonable requests for information, records and data related to the Company’s shareholders introduced to, and serviced by, Selected Dealer (the “Customers”). Notwithstanding the foregoing, Selected Dealer shall not be required to provide to the Dealer Manager any documentation that, in Selected Dealer’s reasonable judgment, would cause Selected Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Selected Dealer hereby represents that it is currently in compliance with all AML Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. Selected Dealer hereby agrees, upon request by the Dealer Manager to (A) provide an annual certification to Dealer Manager that, as of the date of such certification (i) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements; (ii) it has continued to implement its AML Program and its OFAC Program, and (iii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act; and (B) perform and carry out, on behalf of both the Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Selected Dealer’s acceptance of this Dealer represents Agreement constitutes a representation to the Corporation and the Dealer Manager and to the Company that it Selected Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, U.S. Securities and Exchange Commission (the Exchange Act “SEC”) Rules and Regulations (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Offered Shares. Soliciting In addition, Selected Dealer further represents that it currently is in has established and implemented a program for compliance with Executive Order 13224 and all AML Rules, specifically including, but not limited to, regulations and programs administered by the Customer Identification Program requirements under Section 326 U.S. Department of the Money Laundering Abatement Act, Treasury’s Office of Foreign Assets Control (“OFAC Program”) and Soliciting Dealer hereby covenants will continue to remain in compliance with such requirements and shall, upon request by maintain its OFAC Program during the Dealer Manager or the Company, provide a certification to the Dealer Manager or the Company that, as term of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Actthis Agreement. Upon request by the Dealer Manager at any time, Soliciting Selected Dealer will hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Selected Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the investors who purchase Offered Shares through Selected Dealer are “customers” of Selected Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Selected Dealer shall cooperate with the Dealer Manager’s reasonable requests for information, records and data related to the Corporation’s stockholders introduced to, and serviced by, Selected Dealer (the “Customers”). Notwithstanding the foregoing, Selected Dealer shall not be required to provide to the Dealer Manager any documentation that, in Selected Dealer’s reasonable judgment, would cause Selected Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Selected Dealer hereby represents that it is currently in compliance with all AML Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. Selected Dealer hereby agrees, upon request by the Dealer Manager to (A) provide an annual certification to Dealer Manager that, as of the date of such certification (i) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements; (ii) it has continued to implement its AML Program and its OFAC Program, and (iii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act; and (B) perform and carry out, on behalf of both the Dealer Manager and the Corporation, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Participating Dealer’s acceptance of this Participating Dealer represents Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Participating Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, Securities and Exchange Commission Rules (the Exchange Act Rules and Regulations “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Offered Shares. Soliciting In addition, Participating Dealer further represents that it currently is in has established and implemented a program for compliance with Executive Order 13224 and all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, regulations and Soliciting Dealer hereby covenants to remain in compliance with such requirements and shall, upon request programs administered by the Dealer Manager or Treasury Department’s Office of foreign Assets Control regulations and programs administered by the Company, provide a certification Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) and will continue to maintain its OFAC Program during the Dealer Manager or the Company that, as term of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Actthis Agreement. Upon request by the Dealer Manager at any time, Soliciting Participating Dealer will hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Participating Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the investors who purchase Offered Shares through Participating Dealer are “customers” of Participating Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Participating Dealer shall cooperate with the Dealer Manager’s reasonable requests for information, records and data related to the Company’s stockholders introduced to, and serviced by, Participating Dealer (the “Customers”). Notwithstanding the foregoing, Participating Dealer shall not be required to provide to the Dealer Manager any documentation that, in Participating Dealer’s reasonable judgment, would cause Participating Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Participating Dealer hereby represents that it is currently in compliance with all AML Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. Participating Dealer hereby agrees, upon request by the Dealer Manager to (A) provide an annual certification to Dealer Manager that, as of the date of such certification (i) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements; (ii) it has continued to implement its AML Program and its OFAC Program, and (iii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act; and (B) perform and carry out, on behalf of both the Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable Commission and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Selected Dealer’s acceptance of this Dealer represents Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Selected Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, U.S. Securities and Exchange Commission (the Exchange Act “SEC”) Rules and Regulations (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Offered Shares. Soliciting In addition, Selected Dealer further represents that it currently is in has established and implemented a program for compliance with Executive Order 13224 and all AML Rules, specifically including, but not limited to, regulations and programs administered by the Customer Identification Program requirements under Section 326 U.S. Department of the Money Laundering Abatement Act, Treasury’s Office of Foreign Assets Control (“OFAC Program”) and Soliciting Dealer hereby covenants will continue to remain in compliance with such requirements and shall, upon request by maintain its OFAC Program during the Dealer Manager or the Company, provide a certification to the Dealer Manager or the Company that, as term of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Actthis Agreement. Upon request by the Dealer Manager at any time, Soliciting Selected Dealer will hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Selected Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the investors who purchase Offered Shares through Selected Dealer are “customers” of Selected Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Selected Dealer shall cooperate with the Dealer Manager’s reasonable requests for information, records and data related to the Company’s stockholders introduced to, and serviced by, Selected Dealer (the “Customers”). Notwithstanding the foregoing, Selected Dealer shall not be required to provide to the Dealer Manager any documentation that, in Selected Dealer’s reasonable judgment, would cause Selected Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Selected Dealer hereby represents that it is currently in compliance with all AML Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. Selected Dealer hereby agrees, upon request by the Dealer Manager to (A) provide an annual certification to Dealer Manager that, as of the date of such certification (i) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements; (ii) it has continued to implement its AML Program and its OFAC Program, and (iii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act; and (B) perform and carry out, on behalf of both the Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents Participating Dealer’s acceptance of this Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Participating Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, rules promulgated by the Exchange Act Rules and Regulations Commission (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Primary Shares. Soliciting Participating Dealer’s acceptance of this Agreement also constitutes a representation to the Company and the Dealer further represents Manager that it currently as of the date hereof, Participating Dealer is in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Participating Dealer covenants that it will perform all activities it is required to perform by applicable AML Rules and its AML Program with respect to all customers on whose behalf Participating Dealer submits orders to the Company. To the extent permitted by applicable law, and Soliciting Participating Dealer hereby covenants to remain in compliance will share information with such requirements and shall, upon request by the Dealer Manager or the Company, provide a certification to the Dealer Manager or and the Company that, as for purposes of ascertaining whether a suspicious activity report is warranted with respect to any suspicious transaction involving the date purchase or intended purchase of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement ActPrimary Shares. Upon request by the Dealer Manager at any time, Soliciting Participating Dealer will hereby agrees to (i) furnish a written copy of its AML Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Participating Dealer’s most recent independent testing of its AML Program. Participating Dealer further represents that it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, and Participating Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager, provide a certification to Dealer Manager that, as of the date of such certification (i) its AML Program is consistent with the AML Rules, (ii) it has continued to implement its AML Program, and (iii) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act.

Anti-Money Laundering Compliance Programs. Soliciting Participating Broker-Dealer’s acceptance of this Dealer represents Agreement constitutes a representation to the Fund and the Dealer Manager and to the Company that it Participating Broker-Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rulesthe Bank Secrecy Act, the Exchange Act Rules and Regulations and as amended by the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, as amended (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” ”) and together with the USA PATRIOT ActAnti-Money Laundering Act of 2020 (each as may be amended from time to time , and implementing regulations thereunder promulgated by the U.S. Department of the Treasury, the Financial Crimes Enforcement Network, FINRA, and the U.S. Securities and Exchange Commission (the “SEC”) Rules (the “Commission Rules”) (collectively, the “AML Rules”) reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Offered Shares. Soliciting In addition, Participating Broker-Dealer further represents that it currently is in has established and implemented a program for compliance with Executive Order 13224 and all AML Rules, specifically including, but not limited to, regulations and programs administered by the Customer Identification Program requirements under Section 326 U.S. Department of the Money Laundering Abatement ActTreasury’s Office of Foreign Assets Control Department of Commerce, Bureau of Industry and Soliciting Dealer hereby covenants to remain in compliance with Security, or the Department of State (such requirements regulations and shallprogram, upon request “Sanctions,” and such program as established by the Dealer Manager or Participating Broker-Dealer, “OFAC Program”) and will continue to maintain its OFAC Program during the Company, provide a certification to the Dealer Manager or the Company that, as term of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Actthis Agreement. Upon request by the Dealer Manager at any time, Soliciting Participating Broker-Dealer will hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Participating Broker-Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of AML Rules, the investors who purchase Offered Shares through Participating Broker-Dealer are “customers” of Participating Broker-Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Participating Broker-Dealer shall cooperate with the Dealer Manager’s reasonable requests for information, records and data related to the Fund’s stockholders introduced to, and serviced by, Participating Broker-Dealer (the “Customers”). Notwithstanding the foregoing, Participating Broker-Dealer shall not be required to provide to the Dealer Manager any documentation that, in Participating Broker-Dealer’s reasonable judgment, would cause Participating Broker-Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Participating Broker-Dealer hereby represents that it is currently in compliance with all AML Rules and all OFAC requirements, specifically including, but not limited to, the Customer Due Diligence requirements under 31 C.F.R. § 1023.210(b)(5) and the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. Participating Broker-Dealer hereby agrees, upon request by the Dealer Manager to (A) provide an annual certification to Dealer Manager that, as of the date of such certification (i) its AML Program and its OFAC Program are consistent with the AML Rules and Sanctions requirements; (ii) it has continued to implement its AML Program and its OFAC Program, and (iii) it is currently in compliance with all AML Rules and Sanctions requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and beneficial ownership requirements under 31 C.F.R. § 1010.220; and (B) perform and carry out, on behalf of both the Dealer Manager and the Fund, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Dealer’s acceptance of this Selected Dealer represents Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Dealer has established and implemented an anti-money laundering compliance programs program and customer identification program (“AML Program”) in accordance with applicable lawFINRA rules, including applicable FINRA NASD Conduct Rules, the Exchange Act SEC Rules and Regulations and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001Bank Secrecy Act, Title 31 U.S.C. Sections 5311-5355, as amended (by the “USA PATRIOT Act”, and related regulations (31 C.F.R. Part 103), specifically including, but not limited to, Section 352 of the International 31 U.S.C. 5318(h) (Anti-Money Laundering Abatement and AntiPrograms) requiring financial institutions, including securities broker-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Actdealers, the “AML Rules”) to establish anti-money laundering programs reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of Shares of the SharesCompany and 31 C.F.R. 103.122 (Customer Identification Programs for broker-dealers) (the “AML Rules”). Soliciting In addition, Dealer further represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC Program”), and will continue to maintain its AML and OFAC Programs consistent with AML Rules and OFAC requirements during the term of this Selected Dealer Agreement. Upon request by the Dealer Manager at any time, Dealer hereby agrees to (A) furnish a copy of its AML Program and OFAC Program to the Dealer Manager for review, and (B) furnish a copy of the findings and any remedial actions taken in connection with Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The Dealer Manager shall have the right, upon reasonable notice to Dealer, but not the obligation, to audit and/or monitor Dealer’s AML Program and OFAC Program. In any such event, Dealer agrees to cooperate with the Dealer Manager’s auditing and monitoring of Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports related to any customers of Dealer purchasing Shares in the Company (“Dealer’s Customers”). Such documentation could include, among other things, copies of: Dealer’s AML Program and its OFAC Program; documents maintained pursuant to Dealer’s AML Program and its OFAC Program related to Dealer’s Customers; any suspicious activity reports filed related to Dealer’s Customers; audits and any exception reports related to Dealer’s AML activities; and any other files maintained related to Dealer’s Customers. In the event that such documents reflect, in the opinion of the Dealer Manager, a potential violation of Dealer Manager’s AML or OFAC requirements, Dealer will permit the Dealer Manager to further inspect relevant books and records related to Dealer’s Customers and/or Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, Dealer shall not be required to provide to Dealer Manager any documentation that, in Dealer’s reasonable judgment, would cause Dealer to lose the benefit of attorney-client privilege or other privilege which Dealer would be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Dealer hereby represents that it is currently is in compliance with all AML RulesRules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, and Soliciting 31 C.F.R. 103.122. Dealer hereby covenants agrees: (A) to remain in compliance with such requirements perform and shallcarry out, upon request by on behalf of both the Dealer Manager or and the Company, the Customer Identification Program requirements in accordance with 31 C.F.R. 103.122 and applicable Securities and Exchange Commission (“SEC”), FINRA, including NASD, and Treasury Department Rules thereunder, and (B) to provide a an annual certification to the Dealer Manager or the Company that, as of the date of such certification certification, (a1) it has implemented and is continuing to implement its AML Program and its OFAC Program, (2) its AML Program is and its OFAC Program are consistent with the AML RulesRules and OFAC requirements, and (b3) it is currently in compliance with all AML RulesRules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Upon request by the Dealer Manager at any time, Soliciting Dealer will (i) furnish a written copy of its AML Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its most recent independent testing of its AML Program31 C.F.R. 103.122.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents (a) Participating Dealer’s acceptance of this Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Participating Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct rules, rules promulgated by the Commission (the “Commission Rules, the Exchange Act Rules and Regulations ”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Primary Shares. Soliciting Participating Dealer’s acceptance of this Agreement also constitutes a representation to the Company and the Dealer further represents Manager that it currently as of the date hereof, Participating Dealer is in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Participating Dealer covenants that it will perform all activities it is required to perform by applicable AML Rules and its AML Program with respect to all customers on whose behalf Participating Dealer submits orders to the Company. To the extent permitted by applicable law, and Soliciting Participating Dealer hereby covenants to remain in compliance will share information with such requirements and shall, upon request by the Dealer Manager or the Company, provide a certification to the Dealer Manager or and the Company that, as for purposes of ascertaining whether a suspicious activity report is warranted with respect to any suspicious transaction involving the date purchase or intended purchase of such certification (a) its AML Program is consistent with the AML Rules, and Primary Shares. (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Upon request by the Dealer Manager at any time, Soliciting Participating Dealer will hereby agrees to (i) furnish a written copy of its AML Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Participating Dealer’s most recent independent testing of its AML Program. Participating Dealer further represents that it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, and Participating Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager, provide a certification to Dealer Manager that, as of the date of such certification, (i) its AML Program is consistent with the AML Rules, (ii) it has continued to implement its AML Program, and (iii) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act.

Anti-Money Laundering Compliance Programs. Soliciting Participating Dealer’s acceptance of this Dealer represents Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Participating Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, Securities and Exchange Commission Rules (the Exchange Act Rules and Regulations “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Primary Shares. Soliciting Dealer further represents that it currently is in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, and Soliciting Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager or the Company, provide a certification to the Dealer Manager or the Company that, as of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Upon request by the Dealer Manager at any time, Soliciting Participating Dealer will hereby agrees to (i) furnish a written copy of its AML Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Participating Dealer’s most recent independent testing of its AML Program. Participating Dealer further represents that it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, and such Participating Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager, provide a certification to Dealer Manager that, as of the date of such certification (i) its AML Program is consistent with the AML Rules, (ii) it has continued to implement its AML Program, and (iii) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act.

Anti-Money Laundering Compliance Programs. Soliciting Participating Dealer’s acceptance of this Participating Dealer represents Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Participating Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, Securities and Exchange Commission Rules (the Exchange Act Rules and Regulations “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Offered Shares. Soliciting In addition, Participating Dealer further represents that it currently is in has established and implemented a program for compliance with Executive Order 13224 and all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, regulations and Soliciting Dealer hereby covenants to remain in compliance with such requirements and shall, upon request programs administered by the Dealer Manager or Treasury Department’s Office of foreign Assets Control regulations and programs administered by the Company, provide a certification Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) and will continue to maintain its OFAC Program during the Dealer Manager or the Company that, as term of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Actthis Agreement. Upon request by the Dealer Manager at any time, Soliciting Participating Dealer will hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Participating Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the investors who purchase Offered Shares through Participating Dealer are “customers” of Participating Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Participating Dealer shall cooperate with the Dealer Manager’s reasonable requests for information, records and data related to the Company’s stockholders introduced to, and serviced by, Participating Dealer (the “Customers”). Notwithstanding the foregoing, Participating Dealer shall not be required to provide to the Dealer Manager any documentation that, in Participating Dealer’s reasonable judgment, would cause Participating Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Participating Dealer hereby represents that it is currently in compliance with all AML Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. Participating Dealer hereby agrees, upon request by the Dealer Manager to (A) provide an annual certification to Dealer Manager that, as of the date of such certification (i) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements; (ii) it has continued to implement its AML Program and its OFAC Program, and (iii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act; and (B) perform and carry out, on behalf of both the Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents Participating Broker-Dealer’s acceptance of this Agreement constitutes a representation and warranty to the Company and the Dealer Manager and to the Company that it Participating Broker-Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, rules promulgated by the Exchange Act Rules and Regulations SEC and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Primary Shares. Soliciting Participating Broker-Dealer covenants that it will perform all activities it is required to perform by applicable AML Rules and its AML Program with respect to all customers on whose behalf Participating Broker-Dealer submits orders to the Company. To the extent permitted by applicable law, Participating Broker-Dealer will share information with the Dealer Manager and the Company for purposes of ascertaining whether a suspicious activity report is warranted with respect to any suspicious transaction involving the purchase or intended purchase of Primary Shares. Upon request by the Dealer Manager at any time, Participating Broker-Dealer hereby agrees to (i) furnish a written copy of its AML Program and relevant legal requirements to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with Participating Broker-Dealer’s most recent independent testing of its AML Program. Participating Broker-Dealer further represents and warrants that (i) it is currently is in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, Act and Soliciting Participating Broker-Dealer hereby covenants to will remain in compliance with such requirements requirements, (ii) it has Know Your Customer (KYC) policies and procedures in place, (iii) the Participating Broker-Dealer’s AML Program has been adopted by a person with sufficient authority to oversee the AML policies and procedures, and (iv) the Participating Broker-Dealer’s AML Program has education and/or training programs for officers and employees regarding AML policies and procedures. Participating Dealer shall, upon request by the Dealer Manager or the CompanyManager, provide a certification to the Dealer Manager or the Company that, as of the date of such certification (ai) its AML Program is consistent with the AML Rules, (ii) it has continued to implement its AML Program and has complied with the provisions of its AML Program, and (biii) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Upon request by the Dealer Manager at any time, Soliciting Dealer will (i) furnish a written copy of its AML Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its most recent independent testing of its AML Program.

Anti-Money Laundering Compliance Programs. Soliciting Participating Broker-Dealer’s acceptance of this Dealer represents Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Participating Broker-Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, U.S. Securities and Exchange Commission (the Exchange Act “SEC”) Rules and Regulations (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Shares. Soliciting In addition, Participating Broker-Dealer further represents that it currently is in has established and implemented a program for compliance with Executive Order 13224 and all AML Rules, specifically including, but not limited to, regulations and programs administered by the Customer Identification Program requirements under Section 326 U.S. Department of the Money Laundering Abatement Act, Treasury's Office of Foreign Assets Control (“OFAC Program”) and Soliciting Dealer hereby covenants will continue to remain in compliance with such requirements and shall, upon request by maintain its OFAC Program during the Dealer Manager or the Company, provide a certification to the Dealer Manager or the Company that, as term of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Actthis Agreement. Upon request by the Dealer Manager at any time, Soliciting Participating Broker-Dealer will hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Participating Broker-Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the investors who purchase Offered Shares through Participating Broker-Dealer are “customers” of Participating Broker-Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Participating Broker-Dealer shall cooperate with the Dealer Manager’s reasonable requests for information, records and data related to the Company’s stockholders introduced to, and serviced by, Participating Broker-Dealer (the “Customers”). Notwithstanding the foregoing, Participating Broker-Dealer shall not be required to provide to the Dealer Manager any documentation that, in Participating Broker-Dealer’s reasonable judgment, would cause Participating Broker-Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Participating Broker-Dealer hereby represents that it is currently in compliance with all AML Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. Selected Dealer hereby agrees, upon request by the Participating Broker-Dealer to: (a) provide an annual certification to Dealer Manager that, as of the date of such certification: (i) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements; (ii) it has continued to implement its AML Program and its OFAC Program, and (iii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act; and (b) perform and carry out, on behalf of both the Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Dealer’s acceptance of this Selected Dealer represents Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Dealer has established and implemented an anti-money laundering compliance programs program and customer identification program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct NASD Rules, the Exchange Act SEC Rules and Regulations and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, as amended (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Actcollectively, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of Shares of the SharesCompany. Soliciting In addition, Dealer further represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) and will continue to maintain its OFAC Program during the term of the Selected Dealer Agreement. Upon request by the Dealer Manager at any time, Dealer hereby agrees to (1) furnish a copy of its AML Program and OFAC Program to the Dealer Manager for review, and (2) furnish a copy of the findings and any remedial actions taken in connection with Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. Dealer Manager shall have the right, upon reasonable notice to Dealer, but not the obligation, to audit and/or monitor Dealer’s AML Program and OFAC Program. In any such event, Dealer agrees to cooperate with Dealer Manager’s auditing and monitoring of Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s shareholders serviced by Dealer (“Dealer’s Customers”). Such documentation could include, among other things, copies of: Dealer’s AML Program and its OFAC Program; documents maintained pursuant to Dealer’s AML Program and its OFAC Program related to Dealer’s Customers; any suspicious activity reports filed related to Dealer’s Customers; audits and any exception reports related to Dealer’s AML activities; and any other files maintained related to Dealer’s Customers. In the event that such documents reflect, in the opinion of Dealer Manager, a potential violation of Dealer Manager’s AML or OFAC requirements, Dealer will permit Dealer Manager to further inspect relevant books and records related to Dealer’s Customers and/or Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, Dealer shall not be required to provide to Dealer Manager any documentation that, in Dealer’s reasonable judgment, would cause Dealer to lose the benefit of attorney-client privilege or other privilege which Dealer would be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Dealer hereby represents that it is currently is in compliance with all AML RulesRules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement USA PATRIOT Act, and Soliciting . Dealer hereby covenants agrees: (A) to remain in compliance with such requirements and shall, upon request by the provide an annual certification to Dealer Manager or the Company, provide a certification to the Dealer Manager or the Company that, as of the date of such certification (ai) its AML Program is and its OFAC Program are consistent with the AML RulesRules and OFAC requirements, (ii) it has continued to implement its AML Program and its OFAC Program, and (biii) it is currently in compliance with all AML RulesRules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement USA PATRIOT Act. Upon request by ; and (B) to perform and carry out, on behalf of both the Dealer Manager at any timeand the Company, Soliciting Dealer will (i) furnish a written copy of its AML the Customer Identification Program to the Dealer Manager for review, and (ii) furnish a copy requirements in accordance with Section 326 of the findings USA PATRIOT Act and any remedial actions taken in connection with its most recent independent testing of its AML Programapplicable Securities and Exchange Commission (“SEC”), NASD and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents (a) Participating Dealer’s acceptance of this Agreement constitutes a representation to the Trust and the Dealer Manager and to the Company that it Participating Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, rules and regulations promulgated by the Securities and Exchange Act Rules and Regulations Commission (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Shares. Soliciting In addition, Participating Dealer further represents that it currently has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by OFAC (“OFAC Program”) and will continue to maintain its OFAC Program during the term of this Agreement. Participating Dealer’s acceptance of this Agreement also constitutes a representation to the Trust and the Dealer Manager that as of the date hereof, Participating Dealer is in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, Rules and Soliciting Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager or the Company, provide a certification to the Dealer Manager or the Company that, as of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML RulesOFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Participating Dealer covenants that it will perform all activities it is required to perform by applicable AML Rules and its AML Program with respect to all customers on whose behalf Participating Dealer submits orders to the Trust. To the extent permitted by applicable law, Participating Dealer will share information with the Dealer Manager and the Trust for purposes of ascertaining whether a suspicious activity report is warranted with respect to any suspicious transaction involving the purchase or intended purchase of Shares. (b) Upon request by the Dealer Manager at any time, Soliciting Participating Dealer will hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Participating Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. Participating Dealer further represents that it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, and Participating Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager, provide a certification to Dealer Manager that, as of the date of such certification, (i) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (ii) it has continued to implement its AML Program and its OFAC Program, and (iii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act and applicable SEC and U.S. Department of Treasury rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents to the Dealer Manager and Selected Dealer’s acceptance of this Agreement constitutes a representation to the Company and the Placement Agent that it Selected Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, the Exchange Act Rules and Regulations and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, as amended (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Shares. Soliciting Dealer further represents Selected Dealer’s acceptance of this Agreement also constitutes a representation to the Company and the Placement Agent that it is currently is in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, and Soliciting . Selected Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager Company or the CompanyPlacement Agent, provide a certification to the Dealer Manager or the Company that, as of the date of such certification (a) its AML Program program is consistent with the AML Rules, Rules and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Upon request by Further, Selected Dealer agrees, upon receipt of an “information request” issued under Section 314 (a) of the Dealer Manager at any time, Soliciting Dealer will USA Patriot Act to provide the Financial Crimes Enforcement Network with information regarding: (i) furnish the identity of a written copy of its AML Program to the Dealer Manager for review, and specified individual or organization; (ii) furnish a copy account number; (iii) all identifying information provided by the account holder; and (iv) the date and type of the findings transaction. The Placement Agent from time to time will monitor account activity to identify patterns of unusual size or volume, geographic factors, and any remedial actions taken in connection with its most recent independent testing other potential signals of its AML Programsuspicious activity, including possible money laundering or terrorist financing. The Company and the Placement Agent reserve the right to reject account applications from new customers who fail to provide necessary account information or who intentionally provide misleading information.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents Each Dealer’s acceptance of this Agreement constitutes a representation to the Managing Broker Dealer Manager and to that the Company that it Dealer has established and implemented an anti-money laundering (“AML”) compliance programs program (“AML Program”), in accordance with applicable law, including applicable FINRA Conduct Rules, Rule 3310 and Section 352 of the Exchange Money Laundering Abatement Act Rules and Regulations and Section 326 of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Patriot Act of 2001, as amended (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of Securities. In addition, the Shares. Soliciting Dealer further represents that it has established and implemented a program (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker Dealer at any time, the Dealer hereby agrees to (i) furnish a copy of its AML Program and OFAC Program to the Managing Broker Dealer for review and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Securities through the Dealer are “Customers” of the Dealer and not the Managing Broker Dealer. Nonetheless, to the extent that the Managing Broker Dealer deems it prudent, the Dealer shall cooperate with the Managing Broker Dealer’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s bond holders introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker Dealer, a potential violation of the Managing Broker Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, when so directed by his or her legal counsel, the Dealer shall not be required to provide to the Managing Broker Dealer any documentation that could potentially cause the Dealer to lose the benefit of an attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently is in compliance with all AML Rulesrules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement USA PATRIOT Act, and Soliciting . The Dealer hereby covenants to remain in compliance with such requirements and shallagrees, upon request by the Managing Broker Dealer Manager or the Company, to (i) provide a an annual certification to the Managing Broker Dealer Manager or the Company that, as of the date of such certification (aA) its AML Program is and its OFAC Program are consistent with the AML RulesRules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (bC) it is currently in compliance with all AML RulesRules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Upon request by the Dealer Manager at any time, Soliciting Dealer will (i) furnish a written copy of its AML Program to the Dealer Manager for review, USA PATRIOT Act and (ii) furnish a copy perform and carry out, on behalf of both the Managing Broker Dealer and the Company, the Customer Identification Program requirements in accordance with Section 326 of the findings USA PATRIOT Act and any remedial actions taken in connection with its most recent independent testing of its AML Programapplicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Dealer’s acceptance of this Participating Dealer represents Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable NASD Conduct Rules under FINRA Conduct and other applicable FINRA Rules, Securities and Exchange Commission Rules (the Exchange Act Rules and Regulations “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Shares. Soliciting In addition, Dealer further represents that it currently is in has established and implemented a program for compliance with Executive Order 13224 and all AML Rules, specifically including, but not limited to, regulations and programs administered by the Customer Identification Program requirements under Section 326 U.S. Department of the Money Laundering Abatement Act, Treasury’s Office of Foreign Assets Control (“OFAC Program”) and Soliciting will continue to maintain its OFAC Program during the term of this Participating Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager or the Company, provide a certification to the Dealer Manager or the Company that, as of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement ActAgreement. Upon request by the Dealer Manager at any time, Soliciting Dealer will hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. Dealer undertakes to promptly notify the Dealer Manager of any material changes to such Dealer’s AML program. The parties acknowledge that for the purposes of FINRA Rules, the investors who purchase Shares through Dealer are “customers” of Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Dealer shall cooperate with the Dealer Manager’s reasonable requests for information, records and data related to the Company’s stockholders introduced to, and serviced by, Dealer (the “Customers”). Notwithstanding the foregoing, Dealer shall not be required to provide to the Dealer Manager any documentation that, in Dealer’s reasonable judgment, would cause Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Dealer hereby represents that it is currently in compliance with all AML Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. Dealer hereby agrees, upon request by the Dealer Manager to (A) provide an annual certification to Dealer Manager that, as of the date of such certification (i) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements; (ii) it has continued to implement its AML Program and its OFAC Program, and (iii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act; and (B) perform and carry out, on behalf of both the Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents Dealer’s acceptance of this Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Dealer has established and implemented an anti-money laundering (“AML”) compliance programs program and customer identification program (“AML Program”) in accordance with applicable law, including applicable rules of the SEC, FINRA Conduct Rules, the Exchange Act Rules and Regulations rules and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, as amended (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Actcollectively, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Shares. Soliciting In addition, Dealer further represents that it has established and implemented a program (“OFAC Program”) for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC”) and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Dealer Manager at any time, Dealer hereby agrees to (a) furnish a copy of its AML Program and OFAC Program to the Dealer Manager for review, and (b) furnish a copy of the findings and any remedial actions taken in connection with Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA rules the investors who purchase Shares through Dealer are “customers” of Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Dealer shall cooperate with the Dealer Manager’s auditing and monitoring of Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s stockholders introduced to, and serviced by, Dealer (the “Customers”). The documentation could include, among other things, copies of Dealer’s AML Program and its OFAC Program; documents maintained pursuant to Dealer’s AML Program and its OFAC Program related to the Customers; any suspicious activity reports filed related to the Customers; audits and any exception reports related to Dealer’s AML activities; and any other files maintained related to the Customers. In the event that these documents reflect, in the opinion of the Dealer Manager, a potential violation of the Dealer Manager’s obligations in respect of its AML or OFAC requirements, Dealer will permit the Dealer Manager to further inspect relevant books and records related to the Customers and/or Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, Dealer shall not be required to provide to the Dealer Manager any documentation that, in Dealer’s reasonable judgment, would cause Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Dealer hereby represents that it is currently is in compliance with all AML RulesRules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement USA PATRIOT Act, and Soliciting . Dealer hereby covenants to remain in compliance with such requirements and shallagrees, upon request by the Dealer Manager or the Company, to (A) provide a an annual certification to the Dealer Manager or the Company that, as of the date of such certification (ai) its AML Program is and its OFAC Program are consistent with the AML RulesRules and OFAC requirements, (ii) it has continued to implement its AML Program and its OFAC Program, and (biii) it is currently in compliance with all AML RulesRules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement USA PATRIOT Act. Upon request by ; and (B) perform and carry out, on behalf of both the Dealer Manager at any timeand the Company, Soliciting Dealer will (i) furnish a written copy of its AML the Customer Identification Program to the Dealer Manager for review, and (ii) furnish a copy requirements in accordance with Section 326 of the findings USA PATRIOT Act and any remedial actions taken in connection with its most recent independent testing of its AML Programapplicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Selected Dealer’s acceptance of this Dealer represents Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Selected Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, Securities and Exchange Commission Rules (the Exchange Act Rules and Regulations “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Offered Shares. Soliciting In addition, Selected Dealer further represents that it currently is in has established and implemented a program for compliance with Executive Order 13224 and all AML Rules, specifically including, but not limited to, regulations and programs administered by the Customer Identification Program requirements under Section 326 U.S. Department of the Money Laundering Abatement Act, Treasury’s Office of Foreign Assets Control (“OFAC Program”) and Soliciting Dealer hereby covenants will continue to remain in compliance with such requirements and shall, upon request by maintain its OFAC Program during the Dealer Manager or the Company, provide a certification to the Dealer Manager or the Company that, as term of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Actthis Agreement. Upon request by the Dealer Manager at any time, Soliciting Selected Dealer will hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Selected Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the investors who purchase Offered Shares through Selected Dealer are “customers” of Selected Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Selected Dealer shall cooperate with the Dealer Manager’s reasonable requests for information, records and data related to the Company’s shareholders introduced to, and serviced by, Selected Dealer (the “Customers”). Notwithstanding the foregoing, Selected Dealer shall not be required to provide to the Dealer Manager any documentation that, in Selected Dealer’s reasonable judgment, would cause Selected Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Selected Dealer hereby represents that it is currently in compliance with all AML Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. Selected Dealer hereby agrees, upon request by the Dealer Manager to (A) provide an annual certification to Dealer Manager that, as of the date of such certification (i) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (ii) it has continued to implement its AML Program and its OFAC Program, and (iii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act; and (B) perform and carry out, on behalf of both the Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents Participating Dealer’s acceptance of this Agreement constitutes a representation to the Fund and the Dealer Manager and to the Company that it Participating Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, the Exchange Act SEC Rules and Regulations and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, as amended (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) , reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Offered Shares. Soliciting In addition, Participating Dealer further represents that it currently is in has established and implemented a program for compliance with Executive Order 13224 and all AML Rules, specifically including, but not limited to, regulations and programs administered by OFAC (“OFAC Program”) and will continue to maintain its OFAC Program during the Customer Identification Program requirements under Section 326 term of the Money Laundering Abatement Act, and Soliciting Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager or the Company, provide a certification to the Dealer Manager or the Company that, as of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Actthis Agreement. Upon request by the Dealer Manager at any time, Soliciting Participating Dealer will hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Dealer Manager for review, review and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Participating Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. 9.1 The parties acknowledge that for the purposes of FINRA Rules, the investors who purchase Offered Shares through Participating Dealer are “customers” of Participating Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Participating Dealer shall cooperate with the Dealer Manager’s reasonable requests for information, records and data related to the Fund’s shareholders introduced to, and serviced by, Participating Dealer (the “Customers”). Notwithstanding the foregoing, Participating Dealer shall not be required to provide to the Dealer Manager any documentation that, in Participating Dealer’s reasonable judgment, would cause Participating Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Participating Dealer hereby represents that it is currently in compliance with all AML Rules and all OFAC requirements, including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. Participating Dealer hereby agrees, upon request by the Dealer Manager to (A) provide an annual certification to Dealer Manager that, as of the date of such certification, (i) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (ii) it has continued to implement its AML Program and its OFAC Program and (iii) it is currently in compliance with all AML Rules and OFAC requirements, including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act; and (B) perform and carry out, on behalf of both the Dealer Manager and the Fund, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and U.S. Department of Treasury rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents Dealer’s acceptance of this Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Dealer has established and implemented an anti-money laundering compliance programs program and customer identification program (“AML Program”) in accordance with applicable law, including applicable rules of the SEC, FINRA Conduct Rules, the Exchange Act Rules and Regulations rules and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, as amended (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Actcollectively, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Shares. Soliciting In addition, Dealer further represents that it has established and implemented a program for compliance with all regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Dealer Manager at any time, Dealer hereby agrees to (a) furnish a copy of its AML Program and OFAC Program to the Dealer Manager for review, and (b) furnish a copy of the findings and any remedial actions taken in connection with Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA rules the investors who purchase Shares through Dealer are “customers” of Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Dealer shall cooperate with the Dealer Manager’s auditing and monitoring of Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s shareholders introduced to, and serviced by, Dealer (the “Customers”). Such documentation could include, among other things, copies of Dealer’s AML Program and its OFAC Program; documents maintained pursuant to Dealer’s AML Program and its OFAC Program related to the Customers; any suspicious activity reports filed related to the Customers; audits and any exception reports related to Dealer’s AML activities; and any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Dealer Manager, a potential violation of the Dealer Manager’s obligations in respect of its AML or OFAC requirements, Dealer will permit the Dealer Manager to further inspect relevant books and records related to the Customers and/or Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, Dealer shall not be required to provide to the Dealer Manager any documentation that, in Dealer’s reasonable judgment, would cause Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Dealer hereby represents that it is currently is in compliance with all AML RulesRules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement USA PATRIOT Act, and Soliciting . Dealer hereby covenants to remain in compliance with such requirements and shallagrees, upon request by the Dealer Manager or the Company, to (A) provide a an annual certification to the Dealer Manager or the Company that, as of the date of such certification (ai) its AML Program is and its OFAC Program are consistent with the AML RulesRules and OFAC requirements, (ii) it has continued to implement its AML Program and its OFAC Program, and (biii) it is currently in compliance with all AML RulesRules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement USA PATRIOT Act. Upon request by ; and (B) perform and carry out, on behalf of both the Dealer Manager at any timeand the Company, Soliciting Dealer will (i) furnish a written copy of its AML the Customer Identification Program to the Dealer Manager for review, and (ii) furnish a copy requirements in accordance with Section 326 of the findings USA PATRIOT Act and any remedial actions taken in connection with its most recent independent testing of its AML Programapplicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents to the Dealer Manager and Participating Dealer’s acceptance of this Agreement constitutes a representation to the Company and the Distributor that it Participating Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, rules promulgated by the Exchange Act Rules and Regulations Commission (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Primary Shares. Soliciting Participating Dealer covenants that it will perform all activities it is required to perform by applicable AML Rules and its AML Program with respect to all customers on whose behalf Participating Dealer submits orders to the Company. To the extent permitted by applicable law, Participating Dealer will share information with the Distributor and the Company for purposes of ascertaining whether a suspicious activity report is warranted with respect to any suspicious transaction involving the purchase or intended purchase of Primary Shares. Upon request by the Distributor at any time, Participating Dealer hereby agrees to (i) furnish a written copy of its AML Program to the Distributor for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with Participating Dealer’s most recent independent testing of its AML Program. Participating Dealer further represents that it is currently is in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, and Soliciting Participating Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager or the CompanyDistributor, provide a certification to the Dealer Manager or the Company Distributor that, as of the date of such certification (ai) its AML Program is consistent with the AML Rules, (ii) it has continued to implement its AML Program, and (biii) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Upon request by the Dealer Manager at any time, Soliciting Dealer will (i) furnish a written copy of its AML Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its most recent independent testing of its AML Program.

Anti-Money Laundering Compliance Programs. Soliciting Dealer’s acceptance of this Dealer represents Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Dealer has established and implemented an anti-money laundering and customer identification compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rulesrules, the Exchange Act Rules and Regulations and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, as amended (the “USA PATRIOT Act”), specifically including, but not limited toSEC rules, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” , and together with the Bank Secrecy Act, Title 31 U.S.C. Sections 5311-5355, as amended by the USA PATRIOT ActPatriot Act of 2001, the “AML Rules”) and related regulations (31 C.F.R. Part 103), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Shares. Soliciting Dealer further represents that it currently is in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 Shares of the Money Laundering Abatement Act, and Soliciting Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager or the Company, provide and will continue to maintain its AML Program consistent with applicable laws and regulations during the term of this Dealer Agreement. Dealer hereby agrees to furnish, upon request, a certification copy of its AML Program to the Dealer Manager or for review and to promptly notify the Company that, as Dealer Manager of the date of such certification (a) any material changes to its AML Program is consistent Program. In accordance with these applicable laws and regulations and its AML Program, Dealer agrees to verify the AML Rulesidentity of its new customers; to maintain customer records; to check the names of new customers against government watch lists, including the Office of Foreign Asset Control’s (OFAC) list of Specially Designated Nationals and (b) it is currently Blocked Persons. Additionally, Dealer will monitor account activity to identify patterns of unusual size or volume, geographic factors and any other “red flags” described in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 USA Patriot Act as potential signals of money laundering or terrorist financing. Dealer will submit to the Money Laundering Abatement ActFinancial Crimes Enforcement Network any required suspicious activity reports about such activity and further will disclose such activity to applicable federal and state law enforcement when required by law. Upon request by the Dealer Manager at any time, Soliciting the Dealer will hereby agrees to furnish (ia) furnish a written copy of its AML Program to the Dealer Manager for review, and (iib) furnish a copy of the findings and any remedial actions taken in connection with its Dealer’s most recent independent testing of its AML Program.

Anti-Money Laundering Compliance Programs. Soliciting Selected Dealer’s acceptance of this Dealer represents Agreement constitutes a representation to the Fund and the Dealer Manager and to the Company that it Selected Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, Securities and Exchange Commission Rules (the Exchange Act Rules and Regulations “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Offered Shares. Soliciting In addition, Selected Dealer further represents that it currently is in has established and implemented a program for compliance with Executive Order 13224 and all AML Rules, specifically including, but not limited to, regulations and programs administered by the Customer Identification Program requirements under Section 326 U.S. Department of the Money Laundering Abatement Act, Treasury’s Office of Foreign Assets Control (“OFAC Program”) and Soliciting Dealer hereby covenants will continue to remain in compliance with such requirements and shall, upon request by maintain its OFAC Program during the Dealer Manager or the Company, provide a certification to the Dealer Manager or the Company that, as term of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Actthis Agreement. Upon request by the Dealer Manager at any time, Soliciting Selected Dealer will hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Selected Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the investors who purchase Offered Shares through Selected Dealer are “customers” of Selected Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Selected Dealer shall cooperate with the Dealer Manager’s reasonable requests for information, records and data related to the Fund’s shareholders introduced to, and serviced by, Selected Dealer (the “Customers”). Notwithstanding the foregoing, Selected Dealer shall not be required to provide to the Dealer Manager any documentation that, in Selected Dealer’s reasonable judgment, would cause Selected Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Selected Dealer hereby represents that it is currently in compliance with all AML Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. Selected Dealer hereby agrees, upon request by the Dealer Manager to (A) provide an annual certification to Dealer Manager that, as of the date of such certification (i) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements; (ii) it has continued to implement its AML Program and its OFAC Program, and (iii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act; and (B) perform and carry out, on behalf of both the Dealer Manager and the Fund, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents Dealer’s acceptance of this Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Dealer has established and implemented an anti-money laundering compliance programs program and customer identification program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rulesrules of the Securities and Exchange Commission (“SEC”), the Exchange Act Rules and Regulations NASD rules and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, as amended (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Actcollectively, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Shares. Soliciting In addition, Dealer further represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department's Office of Foreign Assets Control (“OFAC Program”) and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Dealer Manager at any time, Dealer hereby agrees to (a) furnish a copy of its AML Program and OFAC Program to the Dealer Manager for review, and (b) furnish a copy of the findings and any remedial actions taken in connection with Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the NASD rules the investors who purchase Shares through Dealer are “customers” of Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Dealer shall cooperate with the Dealer Manager’s auditing and monitoring of Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s shareholders introduced to, and serviced by, Dealer (the “Customers”). Such documentation could include, among other things, copies of Dealer’s AML Program and its OFAC Program; documents maintained pursuant to Dealer’s AML Program and its OFAC Program related to the Customers; any suspicious activity reports filed related to the Customers; audits and any exception reports related to Dealer’s AML activities; and any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Dealer Manager, a potential violation of the Dealer Manager’s obligations in respect of its AML or OFAC requirements, Dealer will permit the Dealer Manager to further inspect relevant books and records related to the Customers and/or Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, Dealer shall not be required to provide to the Dealer Manager any documentation that, in Dealer’s reasonable judgment, would cause Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Dealer hereby represents that it is currently is in compliance with all AML RulesRules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement USA PATRIOT Act, and Soliciting . Dealer hereby covenants to remain in compliance with such requirements and shallagrees, upon request by the Dealer Manager or the Company, to (A) provide a an annual certification to the Dealer Manager or the Company that, as of the date of such certification (ai) its AML Program is and its OFAC Program are consistent with the AML RulesRules and OFAC requirements, (ii) it has continued to implement its AML Program and its OFAC Program, and (biii) it is currently in compliance with all AML RulesRules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement USA PATRIOT Act. Upon request by ; and (B) perform and carry out, on behalf of both the Dealer Manager at any timeand the Company, Soliciting Dealer will (i) furnish a written copy of its AML the Customer Identification Program to the Dealer Manager for review, and (ii) furnish a copy requirements in accordance with Section 326 of the findings USA PATRIOT Act and any remedial actions taken in connection with its most recent independent testing of its AML Programapplicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Participating Dealer represents to the Dealer Co-Manager and to the Company that (a) it has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, the Exchange Act of 1934 Rules and Regulations and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, as amended (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” ”), and together with the USA PATRIOT Act, the “AML Rules”) ,” reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the REG A Shares. Soliciting Participating Dealer further represents that it currently is in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, and Soliciting Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager or the Company, provide a certification to the Dealer Manager or the Company that, as of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Upon , and it hereby covenants to remain in compliance with those requirements and shall, on request by the Dealer Manager at any timeCompany, Soliciting Dealer will provide a certification that, as of the date of the certification; (i) furnish a written copy of its Participating Dealer’s AML Program to is consistent with the Dealer Manager for review, AML Rules; and (ii) furnish a copy Participating Dealer is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the findings Money Laundering Abatement Act; (b) further, in accordance with the USA PATRIOT Act, Participating Dealer agrees that the REG A Shares may not be offered, sold, transferred or delivered, directly or indirectly, to anyone who is (i) a “designated national,” “specially designated national,” “specially designated terrorist,” “specially designated global terrorist,” “foreign terrorist organization,” or “blocked person” within the definitions set forth in the Foreign Assets Control Regulations of the U.S. Treasury Department; (ii) acting on behalf of, or an entity owned or controlled by, any government against whom the U.S. maintains economic sanctions or embargoes under the Regulations of the U.S. Treasury Department; (iii) within the scope of Executive Order 13224 — Blocking Property and Prohibiting Transactions with Persons who Commit, Threaten to Commit, or Support Terrorism, effective September 24, 2001; (iv) subject to additional restrictions imposed by the following statutes or regulations, and executive orders issued thereunder; the Trading with the Enemy Act, the Iraq Sanctions Act, the National Emergencies Act, the Antiterrorism and Effective Death Penalty Act of 1996, the International Emergency Economic Powers Act, the United Nations Participation Act, the International Security and Development Cooperation Act, the Nuclear Proliferation Prevention Act of 1994, the Foreign Narcotics Kingpin Designation Act, the Iran and Libya Sanctions Act of 1996, the Cuban Democracy Act, the Cuban Liberty and Democratic Solidarity Act and the Foreign Operations, Export Financing and Related Programs Appropriation Act or any remedial actions taken other law of similar import as to any non-U.S. country, as each such act or law has been or may be amended, adjusted, modified or reviewed from time to time; or (v) designated or blocked, associated or involved in connection with its most recent independent testing of its AML Programterrorism, or subject to restrictions under laws, regulations, or executive orders as may apply in the future similar to those set forth above.

Anti-Money Laundering Compliance Programs. Soliciting Selling Agent’s acceptance of this Dealer represents Agreement constitutes a representation to the Fund and the Dealer Manager and to the Company that it Selling Agent has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rulesthe Bank Secrecy Act, the Exchange Act Rules and Regulations and as amended by the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, as amended (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” ”) and together with the USA PATRIOT ActAnti-Money Laundering Act of 2020 (each as may be amended from time to time , and implementing regulations thereunder promulgated by the U.S. Department of the Treasury, the Financial Crimes Enforcement Network, FINRA, and the U.S. Securities and Exchange Commission (the “SEC”) Rules (the “Commission Rules”) (collectively, the “AML Rules”) reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the SharesPreferred Stock. Soliciting Dealer further In addition, Selling Agent represents that it currently is in has established and implemented a program for compliance with Executive Order 13224 and all AML Rules, specifically including, but not limited to, regulations and programs administered by the Customer Identification Program requirements under Section 326 U.S. Department of the Money Laundering Abatement ActTreasury’s Office of Foreign Assets Control Department of Commerce, Bureau of Industry and Soliciting Dealer hereby covenants to remain in compliance with Security, or the Department of State (such requirements regulations and shallprogram, upon request “Sanctions,” and such program as established by the Dealer Manager or Selling Agent, “OFAC Program”) and will continue to maintain its OFAC Program during the Company, provide a certification to the Dealer Manager or the Company that, as term of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Actthis Agreement. Upon request by the Dealer Manager at any time, Soliciting Dealer will Selling Agent hxxxxx agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Selling Agent’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of AML Rules, the investors who purchase Preferred Stock through Selling Agent are “customers” of Selling Agent and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Selling Agent shall cooperate with the Dealer Manager’s reasonable requests for information, records and data related to the Fund’s stockholders introduced to, and serviced by, Selling Agent (the “Customers”). Notwithstanding the foregoing, Selling Agent shall not be required to provide to the Dealer Manager any documentation that, in Selling Agent’s reasonable judgment, would cause Selling Agent to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Selling Agent hereby represents that it is currently in compliance with all AML Rules and all OFAC requirements, specifically including, but not limited to, the Customer Due Diligence requirements under 31 C.F.R. § 1023.210(b)(5) and the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. Selling Agent hereby agrees, upon request by the Dealer Manager to (A) provide an annual certification to Dealer Manager that, as of the date of such certification (i) its AML Program and its OFAC Program are consistent with the AML Rules and Sanctions requirements; (ii) it has continued to implement its AML Program and its OFAC Program, and (iii) it is currently in compliance with all AML Rules and Sanctions requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and beneficial ownership requirements under 31 C.F.R. § 1010.230; and (B) perform and carry out, on behalf of both the Dealer Manager and the Fund, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Participating Dealer’s acceptance of this Participating Dealer represents Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Participating Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, Securities and Exchange Commission Rules (the Exchange Act Rules and Regulations “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Offered Shares. Soliciting In addition, Participating Dealer further represents that it currently is in has established and implemented a program for compliance with Executive Order 13224 and all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, regulations and Soliciting Dealer hereby covenants to remain in compliance with such requirements and shall, upon request programs administered by the Dealer Manager or Treasury Department’s Office of foreign Assets Control regulations and programs administered by the Company, provide a certification Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) and will continue to maintain its OFAC Program during the Dealer Manager or the Company that, as term of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Actthis Agreement. Upon request by the Dealer Manager at any time, Soliciting Participating Dealer will hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Participating Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the investors who purchase Offered Shares through Participating Dealer are “customers” of Participating Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Participating Dealer shall cooperate with the Dealer Manager’s reasonable requests for information, records and data related to the Company’s stockholders introduced to, and serviced by, Participating Dealer (the “Customers”). Notwithstanding the foregoing, Participating Dealer shall not be required to provide to the Dealer Manager any documentation that, in Participating Dealer’s reasonable judgment, would Triton Pacific Investment Corporation, Inc. Dealer Manager Agreement cause Participating Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Participating Dealer hereby represents that it is currently in compliance with all AML Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. Participating Dealer hereby agrees, upon request by the Dealer Manager to (A) provide an annual certification to Dealer Manager that, as of the date of such certification (i) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements; (ii) it has continued to implement its AML Program and its OFAC Program, and (iii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act; and (B) perform and carry out, on behalf of both the Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Participating Broker-Dealer’s acceptance of this Dealer represents Agreement constitutes a representation to the Trust and the Dealer Manager and to the Company that it Participating Broker-Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, U.S. Securities and Exchange Commission (the Exchange Act “SEC”) Rules and Regulations (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Shares. Soliciting In addition, Participating Broker-Dealer further represents that it currently is in has established and implemented a program for compliance with Executive Order 13224 and all AML Rules, specifically including, but not limited to, regulations and programs administered by the Customer Identification Program requirements under Section 326 U.S. Department of the Money Laundering Abatement ActTreasury’s Office of Foreign Assets Control Department of Commerce, Bureau of Industry and Soliciting Dealer hereby covenants to remain in compliance with Security, or the Department of State (such requirements regulations and shallprogram, upon request “Sanctions,” and such program as established by the Dealer Manager or Participating Broker-Dealer, “OFAC Program”) and will continue to maintain its OFAC Program during the Company, provide a certification to the Dealer Manager or the Company that, as term of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Actthis Agreement. Upon request by the Dealer Manager at any time, Soliciting Participating Broker-Dealer will hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Participating Broker-Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the investors who purchase Shares through Participating Broker-Dealer are “customers” of Participating Broker-Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Participating Broker-Dealer shall cooperate with the Dealer Manager’s reasonable requests for information, records and data related to the Trust’s stockholders introduced to, and serviced by, Participating Broker-Dealer (the “Customers”). Notwithstanding the foregoing, Participating Broker-Dealer shall not be required to provide to the Dealer Manager any documentation that, in Participating Broker-Dealer’s reasonable judgment, would cause Participating Broker-Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Participating Broker-Dealer hereby represents that it is currently in compliance with all AML Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. Participating Broker-Dealer hereby agrees, upon request by the Dealer Manager to (A) provide an annual certification to Dealer Manager that, as of the date of such certification (i) its AML Program and its OFAC Program are consistent with the AML Rules and Sanctions requirements; (ii) it has continued to implement its AML Program and its OFAC Program, and (iii) it is currently in compliance with all AML Rules and Sanctions requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act; and (B) perform and carry out, on behalf of both the Dealer Manager and the Trust, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents Dealer’s acceptance of this Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Dealer has established and implemented an anti-money laundering compliance programs program and customer identification program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rulesrules of the Securities and Exchange Commission (“SEC”), the Exchange Act Rules and Regulations NASD rules and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, as amended (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Actcollectively, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Shares. Soliciting In addition, Dealer further represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Dealer Manager at any time, Dealer hereby agrees to (a) furnish a copy of its AML Program and OFAC Program to the Dealer Manager for review, and (b) furnish a copy of the findings and any remedial actions taken in connection with Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the NASD rules the investors who purchase Shares through Dealer are “customers” of Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Dealer shall cooperate with the Dealer Manager’s auditing and monitoring of Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s shareholders introduced to, and serviced by, Dealer (the “Customers”). Such documentation could include, among other things, copies of Dealer’s AML Program and its OFAC Program; documents maintained pursuant to Dealer’s AML Program and its OFAC Program related to the Customers; any suspicious activity reports filed related to the Customers; audits and any exception reports related to Dealer’s AML activities; and any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Dealer Manager, a potential violation of the Dealer Manager’s obligations in respect of its AML or OFAC requirements, Dealer will permit the Dealer Manager to further inspect relevant books and records related to the Customers and/or Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, Dealer shall not be required to provide to the Dealer Manager any documentation that, in Dealer’s reasonable judgment, would cause Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Dealer hereby represents that it is currently is in compliance with all AML RulesRules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement USA PATRIOT Act, and Soliciting . Dealer hereby covenants to remain in compliance with such requirements and shallagrees, upon request by the Dealer Manager or the Company, to (A) provide a an annual certification to the Dealer Manager or the Company that, as of the date of such certification (ai) its AML Program is and its OFAC Program are consistent with the AML RulesRules and OFAC requirements, (ii) it has continued to implement its AML Program and its OFAC Program, and (biii) it is currently in compliance with all AML RulesRules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement USA PATRIOT Act. Upon request by ; and (B) perform and carry out, on behalf of both the Dealer Manager at any timeand the Company, Soliciting Dealer will (i) furnish a written copy of its AML the Customer Identification Program to the Dealer Manager for review, and (ii) furnish a copy requirements in accordance with Section 326 of the findings USA PATRIOT Act and any remedial actions taken in connection with its most recent independent testing of its AML Programapplicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents (a) Participating Dealer’s acceptance of this Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Participating Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, rules promulgated by the Exchange Act Rules and Regulations Commission (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Shares. Soliciting Participating Dealer’s acceptance of this Agreement also constitutes a representation to the Company and the Dealer further represents Manager that it currently as of the date hereof, Participating Dealer is in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Participating Dealer covenants that it will perform all activities it is required to perform by applicable AML Rules and its AML Program with respect to all customers on whose behalf Participating Dealer submits orders to the Company. To the extent permitted by applicable law, and Soliciting Participating Dealer hereby covenants to remain in compliance will share information with such requirements and shall, upon request by the Dealer Manager or the Company, provide a certification to the Dealer Manager or and the Company that, as for purposes of ascertaining whether a suspicious activity report is warranted with respect to any suspicious transaction involving the date purchase or intended purchase of such certification (a) its AML Program is consistent with the AML Rules, and Shares. (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Upon request by the Dealer Manager at any time, Soliciting Participating Dealer will hereby agrees to (i) furnish a written copy of its AML Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Participating Dealer’s most recent independent testing of its AML Program. Participating Dealer further represents that it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, and Participating Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager, provide a certification to Dealer Manager that, as of the date of such certification, (i) its AML Program is consistent with the AML Rules, (ii) it has continued to implement its AML Program, and (iii) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents Dealer’s acceptance of this Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Dealer has established and implemented an anti-money laundering compliance programs program and customer identification program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rulesrules of the SEC, the Exchange Act Rules and Regulations NASD rules and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, as amended (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Actcollectively, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Shares. Soliciting In addition, Dealer further represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Dealer Manager at any time, Dealer hereby agrees to (a) furnish a copy of its AML Program and OFAC Program to the Dealer Manager for review, and (b) furnish a copy of the findings and any remedial actions taken in connection with Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the NASD rules the investors who purchase Shares through Dealer are “customers” of Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Dealer shall cooperate with the Dealer Manager’s auditing and monitoring of Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s shareholders introduced to, and serviced by, Dealer (the “Customers”). Such documentation could include, among other things, copies of Dealer’s AML Program and its OFAC Program; documents maintained pursuant to Dealer’s AML Program and its OFAC Program related to the Customers; any suspicious activity reports filed related to the Customers; audits and any exception reports related to Dealer’s AML activities; and any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Dealer Manager, a potential violation of the Dealer Manager’s obligations in respect of its AML or OFAC requirements, Dealer will permit the Dealer Manager to further inspect relevant books and records related to the Customers and/or Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, Dealer shall not be required to provide to the Dealer Manager any documentation that, in Dealer’s reasonable judgment, would cause Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Dealer hereby represents that it is currently is in compliance with all AML RulesRules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement USA PATRIOT Act, and Soliciting . Dealer hereby covenants to remain in compliance with such requirements and shallagrees, upon request by the Dealer Manager or the Company, to (A) provide a an annual certification to the Dealer Manager or the Company that, as of the date of such certification (ai) its AML Program is and its OFAC Program are consistent with the AML RulesRules and OFAC requirements, (ii) it has continued to implement its AML Program and its OFAC Program, and (biii) it is currently in compliance with all AML RulesRules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement USA PATRIOT Act. Upon request by ; and (B) perform and carry out, on behalf of both the Dealer Manager at any timeand the Company, Soliciting Dealer will (i) furnish a written copy of its AML the Customer Identification Program to the Dealer Manager for review, and (ii) furnish a copy requirements in accordance with Section 326 of the findings USA PATRIOT Act and any remedial actions taken in connection with its most recent independent testing of its AML Programapplicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents Dealer’s acceptance of this Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Dealer has established and implemented an anti-money laundering compliance programs program and customer identification program (“AML Program”) in accordance with applicable law, including applicable rules of the SEC, FINRA Conduct Rules, the Exchange Act Rules and Regulations rules and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, as amended (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Actcollectively, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Shares. Soliciting In addition, Dealer further represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Dealer Manager at any time, Dealer hereby agrees to (a) furnish a copy of its AML Program and OFAC Program to the Dealer Manager for review, and (b) furnish a copy of the findings and any remedial actions taken in connection with Dealer’s most recent independent testing of its AML Program and its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the investors who purchase Shares through Dealer are “customers” of Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Dealer shall cooperate with the Dealer Manager’s auditing and monitoring of Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s stockholders introduced to, and serviced by, Dealer (the “Customers”). The documentation could include, among other things, copies of Dealer’s AML Program and its OFAC Program; documents maintained pursuant to Dealer’s AML Program and its OFAC Program related to the Customers; any suspicious activity reports filed related to the Customers; audits and any exception reports related to Dealer’s AML activities; and any other files maintained related to the Customers. In the event that these documents reflect, in the opinion of the Dealer Manager, a potential violation of the Dealer Manager’s obligations in respect of its AML or OFAC requirements, Dealer will permit the Dealer Manager to further inspect relevant books and records related to the Customers or Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, Dealer shall not be required to provide to the Dealer Manager any documentation that, in Dealer’s reasonable judgment, would cause Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Dealer hereby represents that it is currently is in compliance with all AML RulesRules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement USA PATRIOT Act, and Soliciting . Dealer hereby covenants to remain in compliance with such requirements and shallagrees, upon request by the Dealer Manager or the Company, to (A) provide a an annual certification to the Dealer Manager or the Company that, as of the date of such certification (ai) its AML Program is and its OFAC Program are consistent with the AML RulesRules and OFAC requirements, (ii) it has continued to implement its AML Program and its OFAC Program and (biii) it is currently in compliance with all AML RulesRules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement USA PATRIOT Act. Upon request by ; and (B) perform and carry out, on behalf of both the Dealer Manager at any timeand the Company, Soliciting Dealer will (i) furnish a written copy of its AML the Customer Identification Program to the Dealer Manager for review, and (ii) furnish a copy requirements in accordance with Section 326 of the findings USA PATRIOT Act and any remedial actions taken in connection with its most recent independent testing of its AML Programapplicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Participating Dealer’s acceptance of this Dealer represents Agreement constitutes a representation to the Company and the Dealer Manager and to the Company that it Participating Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, Securities and Exchange Commission Rules (the Exchange Act Rules and Regulations “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2006 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Primary Shares. Soliciting Dealer further represents that it currently is in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, and Soliciting Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager or the Company, provide a certification to the Dealer Manager or the Company that, as of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Upon request by the Dealer Manager at any time, Soliciting Participating Dealer will hereby agrees to (i) furnish a written copy of its AML Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Participating Dealer’s most recent independent testing of its AML Program. Participating Dealer further represents that it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, and such Participating Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager, provide a certification to Dealer Manager that, as of the date of such certification (i) its AML Program is consistent with the AML Rules, (ii) it has continued to implement its AML Program, and (iii) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents 2.18.1 You will conduct reasonable investigation to ensure that all prospective Investors are not (i) listed on the Specially Designated Nationals and Blocked Persons List maintained by the Office of Foreign Asset Control, Department of the Treasury (“OFAC”) and/or on any other list of terrorists or terrorist organizations maintained pursuant to any of the rules and regulations of OFAC or pursuant to any other applicable enabling legislation or other Executive Orders in respect thereof (such lists are collectively referred to as “Lists”) or (ii) owned or controlled by, nor act for or on behalf of, any person or entity on the Lists. 2.18.2 Each Introducing RIA’s acceptance of this Agreement constitutes a representation to the Managing Broker Dealer Manager and to that the Company that it Introducing RIA has established and implemented an anti-money laundering (“AML”) compliance programs program (“AML Program”), in accordance with applicable law, including applicable FINRA Conduct Rules, 31 U.S.C. 5318(h) and Section 352 of the Exchange Money Laundering Abatement Act Rules and Regulations and Section 326 of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Patriot Act of 2001, as amended (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of Securities. In addition, the Shares. Soliciting Dealer further Introducing RIA represents that it has established and implemented a program (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker Dealer at any time, the Introducing RIA hereby agrees to (i) furnish a copy of its AML Program and OFAC Program to the Managing Broker Dealer for review and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Introducing RIA’s most recent independent testing of its AML Program and/or its OFAC Program. 2.18.3 The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Securities through the Introducing RIA are “Customers” of the Introducing RIA and not the Managing Broker Dealer. Nonetheless, to the extent that the Managing Broker Dealer deems it prudent, the Introducing RIA shall cooperate with the Managing Broker Dealer’s auditing and monitoring of the Introducing RIA’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to Investors introduced to, and serviced by, the Introducing RIA (the “Customers”). Such documentation could include, among other things: (i) copies of Introducing RIA’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Introducing RIA’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Introducing RIA’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker Dealer, a potential violation of the Managing Broker Dealer’s obligations in respect of its AML or OFAC requirements, the Introducing RIA will permit the Managing Broker Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Introducing RIA’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Introducing RIA shall not be required to provide to the Managing Broker Dealer any documentation that, in the Introducing RIA’s reasonable judgment, would cause the Introducing RIA to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Introducing RIA hereby represents that it is currently is in compliance with all AML Rulesrules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement USA PATRIOT Act, and Soliciting Dealer . The Introducing RIA hereby covenants to remain in compliance with such requirements and shallagrees, upon request by the Managing Broker Dealer Manager or the Company, to (i) provide a an annual certification to the Managing Broker Dealer Manager or the Company that, as of the date of such certification (aA) its AML Program is and its OFAC Program are consistent with the AML RulesRules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (bC) it is currently in compliance with all AML RulesRules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Upon request by the Dealer Manager at any time, Soliciting Dealer will (i) furnish a written copy of its AML Program to the Dealer Manager for review, USA PATRIOT Act and (ii) furnish a copy perform and carry out, on behalf of both the Managing Broker Dealer and the Issuer, the Customer Identification Program requirements in accordance with Section 326 of the findings USA PATRIOT Act and any remedial actions taken in connection with its most recent independent testing of its AML Programapplicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Participating Broker-Dealer’s acceptance of this Dealer represents Agreement constitutes a representation to the Trust and the Dealer Manager and to the Company that it Participating Broker-Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, U.S. Securities and Exchange Commission (the Exchange Act “SEC”) Rules and Regulations (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Shares. Soliciting In addition, Participating Broker-Dealer further represents that it currently is in has established and implemented a program for compliance with Executive Order 13224 and all AML Rules, specifically including, but not limited to, regulations and programs administered by the Customer Identification Program requirements under Section 326 U.S. Department of the Money Laundering Abatement ActTreasury’s Office of Foreign Assets Control Department of Commerce, Bureau of Industry and Soliciting Dealer hereby covenants to remain in compliance with Security, or the Department of State (such requirements regulations and shallprogram, upon request “Sanctions,” and such program as established by the Dealer Manager or Participating Broker-Dealer, “OFAC Program”) and will continue to maintain its OFAC Program during the Company, provide a certification to the Dealer Manager or the Company that, as term of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Actthis Agreement. Upon request by the Dealer Manager at any time, Soliciting Participating Broker-Dealer will hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Participating Broker-Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the investors who purchase Shares through Participating Broker-Dealer are “customers” of Participating Broker-Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Participating Broker-Dealer shall cooperate with the Dealer Manager’s reasonable requests for information, records and data related to the Trust’s shareholders introduced to, and serviced by, Participating Broker-Dealer (the “Customers”). Notwithstanding the foregoing, Participating Broker-Dealer shall not be required to provide to the Dealer Manager any documentation that, in Participating Broker-Dealer’s reasonable judgment, would cause Participating Broker-Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Participating Broker-Dealer hereby represents that it is currently in compliance with all AML Rules and all OFAC requirements, specifically including, but not limited to, the Customer LEGAL02/43103834v6 Identification Program requirements under Section 326 of the USA PATRIOT Act. Participating Broker-Dealer hereby agrees, upon request by the Dealer Manager to (A) provide an annual certification to Dealer Manager that, as of the date of such certification (i) its AML Program and its OFAC Program are consistent with the AML Rules and Sanctions requirements; (ii) it has continued to implement its AML Program and its OFAC Program, and (iii) it is currently in compliance with all AML Rules and Sanctions requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act; and (B) perform and carry out, on behalf of both the Dealer Manager and the Trust, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Dealer represents (a) Participating Dealer’s acceptance of this Agreement constitutes a representation to the Fund and the Dealer Manager and to the Company that it Participating Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, rules and regulations promulgated by the Securities and Exchange Act Rules and Regulations Commission (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Shares. Soliciting In addition, Participating Dealer further represents that it currently has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by OFAC (“OFAC Program”) and will continue to maintain its OFAC Program during the term of this Agreement. Participating Dealer’s acceptance of this Agreement also constitutes a representation to the Fund and the Dealer Manager that as of the date hereof, Participating Dealer is in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, Rules and Soliciting Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager or the Company, provide a certification to the Dealer Manager or the Company that, as of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML RulesOFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act. Participating Dealer covenants that it will perform all activities it is required to perform by applicable AML Rules and its AML Program with respect to all customers on whose behalf Participating Dealer submits orders to the Fund. To the extent permitted by applicable law, Participating Dealer will share information with the Dealer Manager and the Fund for purposes of ascertaining whether a suspicious activity report is warranted with respect to any suspicious transaction involving the purchase or intended purchase of Shares. (b) Upon request by the Dealer Manager at any time, Soliciting Participating Dealer will hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Participating Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. Participating Dealer further represents that it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act, and Participating Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager, provide a certification to Dealer Manager that, as of the date of such certification, (i) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (ii) it has continued to implement its AML Program and its OFAC Program, and (iii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Act and applicable SEC and U.S. Department of Treasury rules thereunder.

Anti-Money Laundering Compliance Programs. Soliciting Participating Broker-Dealer’s acceptance of this Dealer represents Agreement constitutes a representation to the Corporation and the Dealer Manager and to the Company that it Participating Broker-Dealer has established and implemented an anti-money laundering compliance programs program (“AML Program”) in accordance with applicable law, including applicable FINRA Conduct Rules, U.S. Securities and Exchange Commission (the Exchange Act “SEC”) Rules and Regulations (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the “AML Rules”) ), reasonably expected to detect and cause the reporting of suspicious transactions in connection with the offering and sale of the Offered Shares. Soliciting In addition, Participating Broker-Dealer further represents that it currently is in has established and implemented a program for compliance with Executive Order 13224 and all AML Rules, specifically including, but not limited to, regulations and programs administered by the Customer Identification Program requirements under Section 326 U.S. Department of the Money Laundering Abatement Act, Treasury’s Office of Foreign Assets Control (“OFAC Program”) and Soliciting Dealer hereby covenants will continue to remain in compliance with such requirements and shall, upon request by maintain its OFAC Program during the Dealer Manager or the Company, provide a certification to the Dealer Manager or the Company that, as term of the date of such certification (a) its AML Program is consistent with the AML Rules, and (b) it is currently in compliance with all AML Rules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the Money Laundering Abatement Actthis Agreement. Upon request by the Dealer Manager at any time, Soliciting Participating Broker-Dealer will hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Dealer Manager for review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with its Participating Broker-Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the investors who purchase Offered Shares through Participating Broker-Dealer are “customers” of Participating Broker-Dealer and not the Dealer Manager. Nonetheless, to the extent that the Dealer Manager deems it prudent, Participating Broker-Dealer shall cooperate with the Dealer Manager’s reasonable requests for information, records and data related to the Corporation’s stockholders introduced to, and serviced by, Participating Broker-Dealer (the “Customers”). Notwithstanding the foregoing, Participating Broker-Dealer shall not be required to provide to the Dealer Manager any documentation that, in Participating Broker-Dealer’s reasonable judgment, would cause Participating Broker-Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. Participating Broker-Dealer hereby represents that it is currently in compliance with all AML Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. Participating Broker-Dealer hereby agrees, upon request by the Dealer Manager to (A) provide an annual certification to Dealer Manager that, as of the date of such certification (i) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements; (ii) it has continued to implement its AML Program and its OFAC Program, and (iii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act; and (B) perform and carry out, on behalf of both the Dealer Manager and the Corporation, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.