Common use of Anti-Money Laundering Provisions Clause in Contracts

Anti-Money Laundering Provisions. The Company acknowledges that it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism ("USA PATRIOT") Act of 2001 and the Bank Secrecy Act (collectively, the "AML Acts") and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the "Applicable AML Laws") in all relevant respects, subject to the delegation of certain responsibilities to Citi, as provided in the next paragraph below. The Company hereby delegates to Citi the performance, on behalf of the Company, of the anti-money laundering services set forth under Item 6 of Schedule D (the "AML Services") with respect to the shareholder accounts maintained by Citi pursuant to this Agreement, and Citi agrees to the foregoing delegation and agrees to perform such services in accordance with the Company's AML Program for the fee set forth on Schedule E to this Agreement. In connection therewith, Citi agrees to maintain policies and procedures, and related internal controls, that are consistent with the Company's AML Program and the requirement that the Company employ procedures reasonably designed to achieve compliance with the Applicable AML Laws. Citi's obligations under this delegation shall be subject to Sections 19 and 21 of this Agreement, which require that the AML Program and any material amendments thereto be submitted to Citi for its review and consent prior to adoption. The Company agrees and acknowledges that, notwithstanding the delegation provided for in the foregoing paragraph, the Company maintains full responsibility for ensuring that its AML Program is, and shall continue to be, reasonably designed to ensure compliance with the Applicable AML Laws, in light of the particular business of the Company, taking into account factors such as its size, location, activities and risks or vulnerabilities to money laundering. In connection with the foregoing delegation, the Company also acknowledges that the performance of the AML Services involves the exercise of discretion which in certain circumstances may result in consequences to the Company and its shareholders (such as in the case of the reporting of suspicious activities and the freezing of shareholder accounts). In this regard, (i) under circumstances in which the AML Program authorizes the taking of certain actions, Citi is granted the discretion to take any such action as may be authorized under the AML Program, and consultation with Company shall not be required in connection therewith unless specifically required under the AML Program, and (ii) the Company instructs Citi that it may avail the Company of any safe harbor from civil liability that may be available under Applicable AML Laws for making a disclosure or filing a report thereunder. As concerns Networked Level III accounts and omnibus accounts, the AML Services performed by Citi are subject to a more limited scope, as discussed in the Release concerning the final rule of the Department of the Treasury, 31 CFR 103 and of the XXX, 00 XXX 000, entitled Customer Identification Programs for Mutual Funds issued on May 9, 2003 and subsequent guidance issued jointly by such agencies entitled Question and Answer Regarding the Mutual Fund Customer Identification Program Rule (31 CFR 103.131) issued on August 11, 2003.

Anti-Money Laundering Provisions. The (a) Company acknowledges represents and certifies that it is a financial institution subject has adopted and implemented, and agrees that it will maintain, policies, procedures, and internal controls reasonably designed to comply with the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism ("USA PATRIOT") Act applicable provisions of 2001 and the Bank Secrecy Act (collectively, the "AML Acts") and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the "Applicable AML Laws") in all relevant respects, subject to the delegation of certain responsibilities to CitiAct, as provided in amended by the next paragraph below. The Company hereby delegates USA PATRIOT Act of 2001, its implementing regulations, Money Laundering Abatement Act, and any other Anti-Money Laundering law, rule or regulation applicable to Citi the performanceit, on behalf of the Companyincluding but not limited to, of the rules requiring it to implement an anti-money laundering services set forth under Item 6 program and a customer identification program (“CIP”). Subject to legal restrictions, Company will, upon GIS’s request, promptly provide to GIS or the respective Fund, evidence of Schedule D those policies and procedures and its compliance therewith and/or evidence establishing the identities and sources of funds for each purchase of shares of the Funds. (b) Further, Company will, upon GIS’s reasonable request, not more than once each year, certify to GIS that it remains in compliance with such rules; specifically, that it or its agents (i) provide notice of its CIP to all new customers, (ii) obtains required identifying data elements for each customer, (iii) reasonably verifies the "AML Services"identity of each new customer (using the data elements), (iv) takes appropriate action with respect to persons the shareholder accounts maintained by Citi pursuant to this Agreementidentities of whom it can not verify, and Citi agrees (v) retains all records for required time periods, each at least to the foregoing delegation and agrees an extent required by relevant USA PATRIOT Act of 2001 regulation. (c) Company also hereby certifies to perform such services GIS that it is in accordance with the Company's AML Program for the fee set forth on Schedule E to this Agreement. In connection therewith, Citi agrees to maintain policies and procedures, and related internal controls, that are consistent with the Company's AML Program and the requirement that the Company employ procedures reasonably designed to achieve compliance with the Applicable AML Lawseconomic sanctions programs administered by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”), and has an OFAC compliance program that satisfies all applicable laws and regulations. Citi's obligations under this delegation shall Company understands that GIS will be subject relying on the foregoing certifications in administering the Funds’ anti-money laundering compliance program. Company hereby undertakes to Sections 19 notify GIS promptly if any of the foregoing certifications cease to be true and 21 of this Agreement, which require that the AML Program and correct in any material amendments thereto be submitted to Citi for its review and consent prior to adoption. The Company agrees and acknowledges that, notwithstanding the delegation provided for in the foregoing paragraph, the Company maintains full responsibility for ensuring that its AML Program is, and shall continue to be, reasonably designed to ensure compliance with the Applicable AML Laws, in light of the particular business of the Company, taking into account factors such as its size, location, activities and risks or vulnerabilities to money laundering. In connection with the foregoing delegation, the Company also acknowledges that the performance of the AML Services involves the exercise of discretion which in certain circumstances may result in consequences to the Company and its shareholders (such as in the case of the reporting of suspicious activities and the freezing of shareholder accounts). In this regard, (i) under circumstances in which the AML Program authorizes the taking of certain actions, Citi is granted the discretion to take any such action as may be authorized under the AML Program, and consultation with Company shall not be required in connection therewith unless specifically required under the AML Program, and (ii) the Company instructs Citi that it may avail the Company of any safe harbor from civil liability that may be available under Applicable AML Laws for making a disclosure or filing a report thereunder. As concerns Networked Level III accounts and omnibus accounts, the AML Services performed by Citi are subject to a more limited scope, as discussed in the Release concerning the final rule of the Department of the Treasury, 31 CFR 103 and of the XXX, 00 XXX 000, entitled Customer Identification Programs for Mutual Funds issued on May 9, 2003 and subsequent guidance issued jointly by such agencies entitled Question and Answer Regarding the Mutual Fund Customer Identification Program Rule (31 CFR 103.131) issued on August 11, 2003respect.

Anti-Money Laundering Provisions. The Company acknowledges that it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism ("“USA PATRIOT"”) Act of 2001 and the Bank Secrecy Act (collectively, the "“AML Acts"”) and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the "“Applicable AML Laws"”) in all relevant respects, subject to the delegation of certain responsibilities to CitiBISYS, as provided in the next paragraph below. The Company hereby delegates to Citi BISYS the performance, on behalf of the Company, of the anti-money laundering services set forth under Item 6 of Schedule D (the "“AML Services"”) with respect to the shareholder accounts maintained by Citi BISYS pursuant to this Agreement, and Citi BISYS agrees to the foregoing delegation and agrees to perform such services in accordance with the Company's ’s AML Program for the fee set forth on Schedule E to this Agreement. In connection therewith, Citi BISYS agrees to maintain policies and procedures, and related internal controls, that are consistent with the Company's ’s AML Program and the requirement that the Company employ procedures reasonably designed to achieve compliance with the Applicable AML Laws. Citi's BISYS’ obligations under this delegation shall be subject to Sections 19 and 21 of this Agreement, which require that the AML Program and any material amendments thereto be submitted to Citi BISYS for its review and consent prior to adoption. The Company agrees and acknowledges that, notwithstanding the delegation provided for in the foregoing paragraph, the Company maintains full responsibility for ensuring that its AML Program is, and shall continue to be, reasonably designed to ensure compliance with the Applicable AML Laws, in light of the particular business of the Company, taking into account factors such as its size, location, activities and risks or vulnerabilities to money laundering. In connection with the foregoing delegation, the Company also acknowledges that the performance of the AML Services involves the exercise of discretion which in certain circumstances may result in consequences to the Company and its shareholders (such as in the case of the reporting of suspicious activities and the freezing of shareholder accounts). In this regard, (i) under circumstances in which the AML Program authorizes the taking of certain actions, Citi BISYS is granted the discretion to take any such action as may be authorized under the AML Program, and consultation with Company shall not be required in connection therewith unless specifically required under the AML Program, and (ii) the Company instructs Citi BISYS that it may avail the Company of any safe harbor from civil liability that may be available under Applicable AML Laws for making a disclosure or filing a report thereunder. As concerns Networked Level III accounts and omnibus accounts, the AML Services performed by Citi BISYS are subject to a more limited scope, as discussed in the Release concerning the final rule of the Department of the Treasury, 31 CFR 103 and of the XXXCommission, 00 XXX 00017 CFR 270, entitled Customer Identification Programs for Mutual Funds issued on May 9, 2003 and subsequent guidance issued jointly by such agencies entitled Question and Answer Regarding the Mutual Fund Customer Identification Program Rule (31 CFR 103.131) issued on August 11, 2003.

Anti-Money Laundering Provisions. The Company acknowledges that it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism ("USA PATRIOT") Act of 2001 and the Bank Secrecy Act (collectively, the "AML Acts") and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the "Applicable AML Laws") in all relevant respects, subject to the delegation of certain responsibilities to CitiBISYS, as provided in the next paragraph below. The Company hereby delegates to Citi BISYS the performance, on behalf of the Company, of the anti-money laundering services set forth under Item 6 of Schedule D (the "AML Services") with respect to the shareholder accounts maintained by Citi BISYS pursuant to this Agreement, and Citi BISYS agrees to the foregoing delegation and agrees to perform such services in accordance with the Company's AML Program for the fee set forth on Schedule E to this Agreement. In connection therewith, Citi BISYS agrees to maintain policies and procedures, and related internal controls, that are consistent with the Company's AML Program and the requirement that the Company employ procedures reasonably designed to achieve compliance with the Applicable AML Laws. Citi's BISYS' obligations under this delegation shall be subject to Sections 19 and 21 of this Agreement, which require that the AML Program and any material amendments thereto be submitted to Citi BISYS for its review and consent prior to adoption. The Company agrees and acknowledges that, notwithstanding the delegation provided for in the foregoing paragraph, the Company maintains full responsibility for ensuring that its AML Program is, and shall continue to be, reasonably designed to ensure compliance with the Applicable AML Laws, in light of the particular business of the Company, taking into account factors such as its size, location, activities and risks or vulnerabilities to money laundering. In connection with the foregoing delegation, the Company also acknowledges that the performance of the AML Services involves the exercise of discretion which in certain circumstances may result in consequences to the Company and its shareholders (such as in the case of the reporting of suspicious activities and the freezing of shareholder accounts). In this regard, (i) under circumstances in which the AML Program authorizes the taking of certain actions, Citi BISYS is granted the discretion to take any such action as may be authorized under the AML Program, and consultation with Company shall not be required in connection therewith unless specifically required under the AML Program, and (ii) the Company instructs Citi BISYS that it may avail the Company of any safe harbor from civil liability that may be available under Applicable AML Laws for making a disclosure or filing a report thereunder. As concerns Networked Level III accounts and omnibus accounts, the AML Services performed by Citi BISYS are subject to a more limited scope, as discussed in the Release concerning the final rule of the Department of the Treasury, 31 CFR 103 and of the XXXCommission, 00 XXX 00017 CFR 270, entitled Customer Identification Programs for Mutual Funds issued on May 9, 2003 and subsequent guidance issued jointly by such agencies entitled Question and Answer Regarding the Mutual Fund Customer Identification Program Rule (31 CFR 103.131) issued on August 11, 2003.

Anti-Money Laundering Provisions. The Company acknowledges that it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism ("“USA PATRIOT"”) Act of 2001 and the Bank Secrecy Act (collectively, the "“AML Acts"”) and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the "“Applicable AML Laws"”) in all relevant respects, subject to the delegation of certain responsibilities to CitiBISYS, as provided in the next paragraph below. The Company hereby delegates to Citi BISYS the performance, on behalf of the Company, of the anti-money laundering services set forth under Item 6 of Schedule D (the "“AML Services"”) with respect to the shareholder accounts maintained by Citi BISYS pursuant to this Agreement, and Citi BISYS agrees to the foregoing delegation and agrees to perform such services in accordance with the Company's ’s AML Program for the fee set forth on Schedule E to this Agreement. In connection therewith, Citi BISYS agrees to maintain policies and procedures, and related internal controls, that are consistent with the Company's ’s AML Program and the requirement that the Company employ procedures reasonably designed to achieve compliance with the Applicable AML Laws. Citi's BISYS’ obligations under this delegation shall be subject to Sections 19 and 21 of this Agreement21, which require that the AML Program and any material amendments thereto be submitted to Citi BISYS for its review and consent prior to adoption. The Company agrees and acknowledges that, notwithstanding the delegation provided for in the foregoing paragraph, the Company maintains full responsibility for ensuring that its AML Program is, and shall continue to be, reasonably designed to ensure compliance with the Applicable AML Laws, in light of the particular business of the Company, taking into account factors such as its size, location, activities and risks or vulnerabilities to money laundering. In connection with the foregoing delegation, the Company also acknowledges that the performance of the AML Services involves the exercise of discretion which in certain circumstances may result in consequences to the Company and its shareholders (such as in the case of the reporting of suspicious activities and the freezing of shareholder accounts). In this regard, (i) under circumstances in which the AML Program authorizes the taking of certain actions, Citi BISYS is granted the discretion to take any such action as may be authorized under the AML Program, and consultation with Company shall not be required in connection therewith unless specifically required under the AML Program, and (ii) the Company instructs Citi BISYS that it may avail the Company of any safe harbor from civil liability that may be available under Applicable AML Laws for making a disclosure or filing a report thereunder. As concerns Networked Networking Level III accounts and omnibus accounts, the AML Services performed by Citi BISYS are subject to a more limited scope, as discussed in the Release concerning the final rule of the Department of the Treasury, 31 CFR 103 and of the XXXCommission, 00 XXX 00017 CFR 270, entitled Customer Identification Programs for Mutual Funds issued on May 9, 2003 and subsequent guidance issued jointly by such agencies entitled Question and Answer Regarding the Mutual Fund Customer Identification Program Rule (31 CFR 103.131) issued on August 11, 2003.

Anti-Money Laundering Provisions. The (a) Company acknowledges represents and certifies that it is a financial institution subject has adopted and implemented, and agrees that it will maintain, policies, procedures, and internal controls reasonably designed to comply with the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism ("USA PATRIOT") Act applicable provisions of 2001 and the Bank Secrecy Act (collectively, the "AML Acts") and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the "Applicable AML Laws") in all relevant respects, subject to the delegation of certain responsibilities to CitiAct, as provided in amended by the next paragraph below. The Company hereby delegates USA PATRIOT Act of 2001, its implementing regulations, Money Laundering Abatement Act, and any other Anti-Money Laundering law, rule or regulation applicable to Citi the performanceit, on behalf of the Companyincluding but not limited to, of the rules requiring it to implement an anti-money laundering services set forth under Item 6 program and a customer identification program ("CIP"). Subject to legal restrictions, Company will, upon GIS's request, promptly provide to GIS or the respective Fund, evidence of Schedule D those policies and procedures and its compliance therewith and/or evidence establishing the identities and sources of funds for each purchase of shares of the Funds. (b) Further, Company will, upon GIS's reasonable request, not more than once each year, certify to GIS that it remains in compliance with such rules; specifically, that it or its agents (i) provide notice of its CIP to all new customers, (ii) obtains required identifying data elements for each customer, (iii) reasonably verifies the "AML Services"identity of each new customer (using the data elements), (iv) takes appropriate action with respect to persons the shareholder accounts maintained by Citi pursuant to this Agreementidentities of whom it can not verify, and Citi agrees (v) retains all records for required time periods, each at least to the foregoing delegation and agrees an extent required by relevant USA PATRIOT Act of 2001 regulation. (c) Company also hereby certifies to perform such services GIS that it is in accordance with the Company's AML Program for the fee set forth on Schedule E to this Agreement. In connection therewith, Citi agrees to maintain policies and procedures, and related internal controls, that are consistent with the Company's AML Program and the requirement that the Company employ procedures reasonably designed to achieve compliance with the Applicable AML Lawseconomic sanctions programs administered by the U.S. Treasury Department's Office of Foreign Assets Control ("OFAC"), and has an OFAC compliance program that satisfies all applicable laws and regulations. Citi's obligations under this delegation shall Company understands that GIS will be subject relying on the foregoing certifications in administering the Funds' anti-money laundering compliance program. Company hereby undertakes to Sections 19 notify GIS promptly if any of the foregoing certifications cease to be true and 21 of this Agreement, which require that the AML Program and correct in any material amendments thereto be submitted to Citi for its review and consent prior to adoption. The Company agrees and acknowledges that, notwithstanding the delegation provided for in the foregoing paragraph, the Company maintains full responsibility for ensuring that its AML Program is, and shall continue to be, reasonably designed to ensure compliance with the Applicable AML Laws, in light of the particular business of the Company, taking into account factors such as its size, location, activities and risks or vulnerabilities to money laundering. In connection with the foregoing delegation, the Company also acknowledges that the performance of the AML Services involves the exercise of discretion which in certain circumstances may result in consequences to the Company and its shareholders (such as in the case of the reporting of suspicious activities and the freezing of shareholder accounts). In this regard, (i) under circumstances in which the AML Program authorizes the taking of certain actions, Citi is granted the discretion to take any such action as may be authorized under the AML Program, and consultation with Company shall not be required in connection therewith unless specifically required under the AML Program, and (ii) the Company instructs Citi that it may avail the Company of any safe harbor from civil liability that may be available under Applicable AML Laws for making a disclosure or filing a report thereunder. As concerns Networked Level III accounts and omnibus accounts, the AML Services performed by Citi are subject to a more limited scope, as discussed in the Release concerning the final rule of the Department of the Treasury, 31 CFR 103 and of the XXX, 00 XXX 000, entitled Customer Identification Programs for Mutual Funds issued on May 9, 2003 and subsequent guidance issued jointly by such agencies entitled Question and Answer Regarding the Mutual Fund Customer Identification Program Rule (31 CFR 103.131) issued on August 11, 2003respect.

Anti-Money Laundering Provisions. The Company acknowledges that it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism ("“USA PATRIOT"”) Act of 2001 and the Bank Secrecy Act (collectively, the "“AML Acts"”) and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the "“Applicable AML Laws"”) in all relevant respects, subject to the delegation of certain responsibilities to CitiBISYS, as provided in the next paragraph below. The Company hereby delegates to Citi BISYS the performance, on behalf of the Company, of the anti-money laundering services set forth under Item 6 of Schedule D (the "“AML Services"”) with respect to the shareholder accounts maintained by Citi BISYS pursuant to this Agreement, and Citi BISYS agrees to the foregoing delegation and agrees to perform such services in accordance with the Company's ’s AML Program for the fee set forth on Schedule E to this Agreement. In connection therewith, Citi BISYS agrees to maintain policies and procedures, and related internal controls, that are consistent with the Company's ’s AML Program and the requirement that the Company employ procedures reasonably designed to achieve compliance with the Applicable AML Laws. Citi's BISYS’ obligations under this delegation shall be subject to Sections 19 and 21 of this Agreement, which require that the AML Program and any material amendments thereto be submitted to Citi BISYS for its review and consent prior to adoption. The Company agrees and acknowledges that, notwithstanding the delegation provided for in the foregoing paragraph, the Company maintains full responsibility for ensuring that its AML Program is, and shall continue to be, reasonably designed to ensure compliance with the Applicable AML Laws, in light of the particular business of the Company, taking into account factors such as its size, location, activities and risks or vulnerabilities to money laundering. In connection with the foregoing delegation, the Company also acknowledges that the performance of the AML Services involves the exercise of discretion which in certain circumstances may result in consequences to the Company and its shareholders (such as in the case of the reporting of suspicious activities and the freezing of shareholder accounts). In this regard, (i) under circumstances in which the AML Program authorizes the taking of certain actions, Citi BISYS is granted the discretion to take any such action as may be authorized under the AML Program, and consultation with Company shall not be required in connection therewith unless specifically required under the AML Program, and (ii) the Company instructs Citi BISYS that it may avail the Company of any safe harbor from civil liability that may be available under Applicable AML Laws for making a disclosure or filing a report thereunder. As concerns Networked Level III accounts and omnibus accounts, the AML Services performed by Citi BISYS are subject to a more limited scope, as discussed in the Release concerning the final rule of the Department of the Treasury, 31 CFR 103 and of the XXXCommission, 00 XXX 00017 CFR 270, entitled Customer Identification Programs for Mutual Funds issued on May 9, 2003 and subsequent guidance issued jointly by such agencies entitled Question and Answer Regarding the Mutual Fund Customer Identification Program Rule (31 CFR 103.131) issued on August 11, 2003.

Anti-Money Laundering Provisions. The Company acknowledges that it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism ("USA PATRIOT") Act of 2001 and the Bank Secrecy Act (collectively, the "AML Acts") and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the "Applicable AML Laws") in all relevant respects, subject to the delegation of certain responsibilities to Citi, as provided in the next paragraph below. The Company hereby delegates to Citi the performance, on behalf of the Company, of the anti-money laundering services set forth under Item 6 of Schedule D C (the "AML Services") with respect to the shareholder accounts maintained by Citi pursuant to this Agreement, and Citi agrees to the foregoing delegation and agrees to perform such services in accordance with the Company's AML Program for the fee set forth on Schedule E D to this Agreement. In connection therewith, Citi agrees to maintain policies and procedures, and related internal controls, that are consistent with the Company's AML Program and the requirement that the Company employ procedures reasonably designed to achieve compliance with the Applicable AML Laws. Citi's obligations under this delegation shall be subject to Sections 19 and 21 of this Agreement, which require that the AML Program and any material amendments thereto be submitted to Citi for its review and consent prior to adoption. The Company agrees and acknowledges that, notwithstanding the delegation provided for in the foregoing paragraph, the Company maintains full responsibility for ensuring that its AML Program is, and shall continue to be, reasonably designed to ensure compliance with the Applicable AML Laws, in light of the particular business of the Company, taking into account factors such as its size, location, activities and risks or vulnerabilities to money laundering. In connection with the foregoing delegation, the Company also acknowledges that the performance of the AML Services involves the exercise of discretion which in certain circumstances may result in consequences to the Company and its shareholders (such as in the case of the reporting of suspicious activities and the freezing of shareholder accounts). In this regard, (i) under circumstances in which the AML Program authorizes the taking of certain actions, Citi is granted the discretion to take any such action as may be authorized under the AML Program, and consultation with Company shall not be required in connection therewith unless specifically required under the AML Program, and (ii) the Company instructs Citi that it may avail the Company of any safe harbor from civil liability that may be available under Applicable AML Laws for making a disclosure or filing a report thereunder. As concerns Networked Level III accounts and omnibus accounts, the AML Services performed by Citi are subject to a more limited scope, as discussed in the Release concerning the final rule of the Department of the Treasury, 31 CFR 103 and of the XXXCommission, 00 XXX 00017 CFR 270, entitled Customer Identification Programs for Mutual Funds issued on May 9, 2003 and subsequent guidance issued jointly by such agencies entitled Question and Answer Regarding the Mutual Fund Customer Identification Program Rule (31 CFR 103.131) issued on August 11, 2003.

Anti-Money Laundering Provisions. The Company acknowledges that it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism ("USA PATRIOT") Act of 2001 and the Bank Secrecy Act (collectively, the "AML Acts") and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the "Applicable AML Laws") in all relevant respects, subject to the delegation of certain responsibilities to CitiBISYS, as provided in the next paragraph below. The Company hereby delegates to Citi BISYS the performance, on behalf of the Company, of the anti-money laundering services set forth under Item 6 of Schedule D (the "AML Services") with respect to the shareholder accounts maintained by Citi BISYS pursuant to this Agreement, and Citi BISYS agrees to the foregoing delegation and agrees to perform such services in accordance with the Company's AML Program for the fee set forth on Schedule E to this Agreement. In connection therewith, Citi BISYS agrees to maintain policies and procedures, and related internal controls, that are consistent with the Company's AML Program and the requirement that the Company employ procedures reasonably designed to achieve compliance with the Applicable AML Laws. Citi's BISYS' obligations under this delegation shall be subject to Sections 19 and 21 of this Agreement21, which require that the AML Program and any material amendments thereto be submitted to Citi BISYS for its review and consent prior to adoption. The Company agrees and acknowledges that, notwithstanding the delegation provided for in the foregoing paragraph, the Company maintains full responsibility for ensuring that its AML Program is, and shall continue to be, reasonably designed to ensure compliance with the Applicable AML Laws, in light of the particular business of the Company, taking into account factors such as its size, location, activities and risks or vulnerabilities to money laundering. In connection with the foregoing delegation, the Company also acknowledges that the performance of the AML Services involves the exercise of discretion which in certain circumstances may result in consequences to the Company and its shareholders (such as in the case of the reporting of suspicious activities and the freezing of shareholder accounts). In this regard, (i) under circumstances in which the AML Program authorizes the taking of certain actions, Citi BISYS is granted the discretion to take any such action as may be authorized under the AML Program, and consultation with Company shall not be required in connection therewith unless specifically required under the AML Program, and (ii) the Company instructs Citi BISYS that it may avail the Company of any safe harbor from civil liability that may be available under Applicable AML Laws for making a disclosure or filing a report thereunder. As concerns Networked Level III accounts and omnibus accounts, the AML Services performed by Citi BISYS are subject to a more limited scope, as discussed in the Release concerning the final rule of the Department of the Treasury, 31 CFR 103 and of the XXXCommission, 00 XXX 00017 CFR 270, entitled Customer Identification Programs for Mutual Funds issued on May 9, 2003 and subsequent guidance issued jointly by such agencies entitled Question and Answer Regarding the Mutual Fund Customer Identification Program Rule (31 CFR 103.131) issued on August 11, 2003.

Anti-Money Laundering Provisions. The Company acknowledges that it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism ("USA PATRIOT") Act of 2001 and the Bank Secrecy Act (collectively, the "AML Acts") and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the "Applicable AML Laws") in all relevant respects, subject to the delegation of certain responsibilities to CitiBISYS, as provided in the next paragraph below. The Company hereby delegates to Citi BISYS the performance, on behalf of the Company, of the anti-money laundering services set forth under Item 6 of Schedule D (the "AML Services") with respect to the shareholder accounts maintained by Citi BISYS pursuant to this Agreement, and Citi BISYS agrees to the foregoing delegation and agrees to perform such services in accordance with the Company's AML Program for the fee set forth on Schedule E to this Agreement. In connection therewith, Citi BISYS agrees to maintain policies and procedures, and related internal controls, that are consistent with the Company's AML Program and the requirement that the Company employ procedures reasonably designed to achieve compliance with the Applicable AML Laws. Citi's BISYS' obligations under this delegation shall be subject to Sections 19 and 21 of this Agreement21, which require that the AML Program and any material amendments thereto be submitted to Citi BISYS for its review and consent prior to adoption. The Company agrees and acknowledges that, notwithstanding the delegation provided for in the foregoing paragraph, the Company maintains full responsibility for ensuring that its AML Program is, and shall continue to be, reasonably designed to ensure compliance with the Applicable AML Laws, in light of the particular business of the Company, taking into account factors such as its size, location, activities and risks or vulnerabilities to money laundering. In connection with the foregoing delegation, the Company also acknowledges that the performance of the AML Services involves the exercise of discretion which in certain circumstances may result in consequences to the Company and its shareholders (such as in the case of the reporting of suspicious activities and the freezing of shareholder accounts). In this regard, (i) under circumstances in which the AML Program authorizes the taking of certain actions, Citi is granted the discretion to take any such action as may be authorized under the AML Program, and consultation with Company shall not be required in connection therewith unless specifically required under the AML Program, and (ii) the Company instructs Citi that it may avail the Company of any safe harbor from civil liability that may be available under Applicable AML Laws for making a disclosure or filing a report thereunder. As concerns Networked Level III accounts and omnibus accounts, the AML Services performed by Citi are subject to a more limited scope, as discussed in the Release concerning the final rule of the Department of the Treasury, 31 CFR 103 and of the XXX, 00 XXX 000, entitled Customer Identification Programs for Mutual Funds issued on May 9, 2003 and subsequent guidance issued jointly by such agencies entitled Question and Answer Regarding the Mutual Fund Customer Identification Program Rule (31 CFR 103.131) issued on August 11, 2003.shareholder

Anti-Money Laundering Provisions. The Company Trust acknowledges that it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism ("USA PATRIOTU.S.A. Patriot") Act of 2001 and the Bank Secrecy Act (collectively, the "AML Acts") and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the "Applicable AML Laws") in all relevant respects, subject to the delegation of certain responsibilities to CitiBISYS, as provided in the next paragraph below. The Company Trust hereby delegates to Citi BISYS the performance, on behalf of the CompanyTrust, of the anti-money laundering services set forth under Item 6 of Schedule D (the "AML Services") with respect to the shareholder accounts maintained by Citi BISYS pursuant to this Agreement, and Citi BISYS agrees to the foregoing delegation and agrees to perform such services in accordance with the CompanyTrust's AML Program for the fee set forth on Schedule E to this AgreementProgram. In connection therewith, Citi BISYS agrees to maintain policies and procedures, and related internal controls, that are consistent with the CompanyTrust's AML Program and the requirement that the Company Trust employ procedures reasonably designed to achieve compliance with the Applicable AML Laws. Citi's BISYS' obligations under this delegation shall be subject to Sections 19 and 21 of this Agreement21, which require that the AML Program and any material amendments thereto be submitted to Citi BISYS for its review and consent prior to adoption. The Company Trust agrees and acknowledges that, notwithstanding the delegation provided for in the foregoing paragraph, the Company Trust maintains full responsibility for ensuring that its AML Program is, and shall continue to be, reasonably designed to ensure compliance with the Applicable AML Laws, in light of the particular business of the CompanyTrust, taking into account factors such as its size, location, activities and risks or vulnerabilities to money laundering. In connection with the foregoing delegation, the Company Trust also acknowledges that the performance of the AML Services involves the exercise of discretion which in certain circumstances may result in consequences to the Company Trust and its shareholders (such as in the case of the reporting of suspicious activities and the freezing of shareholder accounts). In this regard, (i) under circumstances in which the AML Program authorizes the taking of certain actions, Citi BISYS is granted the discretion to take any such action as may be authorized under the AML Program, and consultation with Company Trust shall not be required in connection therewith unless specifically required under the AML Program, and (ii) the Company Trust instructs Citi BISYS that it may avail the Company Trust of any safe harbor from civil liability that may be available under Applicable AML Laws for making a disclosure or filing a report thereunder. As concerns Networked Networking Level III accounts and omnibus accounts, the AML Services performed by Citi BISYS are subject to a more limited scope, as discussed in the Release concerning the final rule of the Department of the Treasury, 31 CFR 103 and of the XXXCommission, 00 XXX 00017 CFR 270, entitled Customer Identification Programs for Mutual Funds issued on May 9, 2003 and subsequent guidance issued jointly by such agencies entitled Question and Answer Regarding the Mutual Fund Customer Identification Program Rule (31 CFR 103.131) issued on August 11, 2003.

Anti-Money Laundering Provisions. The Company acknowledges that it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism ("“USA PATRIOT"”) Act of 2001 and the Bank Secrecy Act (collectively, the "“AML Acts"”) and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the "“Applicable AML Laws"”) in all relevant respects, subject to the delegation of certain responsibilities to CitiBISYS, as provided in the next paragraph below. The Company hereby delegates to Citi BISYS the performance, on behalf of the Company, of the anti-money laundering services set forth under Item 6 of Schedule D hereto (the "“AML Services"”) with respect to the shareholder accounts maintained by Citi BISYS pursuant to this Agreement, and Citi BISYS agrees to the foregoing delegation and agrees to perform such services in accordance with the Company's ’s AML Program for the fee set forth on Schedule E to this AgreementProgram. In connection therewith, Citi BISYS agrees to maintain policies and procedures, and related internal controls, that are consistent with the Company's ’s AML Program and the requirement that the Company employ procedures reasonably designed to achieve compliance with the Applicable AML Laws. Citi's BISYS’ obligations under this delegation shall be subject to Sections 19 and 21 of this Agreement21, which require that the AML Program and any material amendments thereto be submitted to Citi BISYS for its review and consent prior to adoption. The Company agrees and acknowledges that, notwithstanding the delegation provided for in the foregoing paragraph, the Company maintains full responsibility for ensuring that its AML Program is, and shall continue to be, reasonably designed to ensure compliance with the Applicable AML Laws, in light of the particular business of the Company, taking into account factors such as its size, location, activities and risks or vulnerabilities to money laundering. In connection with the foregoing delegation, the Company also acknowledges that the performance of the AML Services involves the exercise of discretion which in certain circumstances may result in consequences to the Company and its shareholders (such as in the case of the reporting of suspicious activities and the freezing of shareholder accounts). In this regard, (i) under circumstances in which the AML Program authorizes the taking of certain actions, Citi BISYS is granted the discretion to take any such action as may be authorized under the AML Program, and consultation with Company shall not be required in connection therewith unless specifically required under the AML Program, and (ii) the Company instructs Citi BISYS that it may avail the Company of any safe harbor from civil liability that may be available under Applicable AML Laws for making a disclosure or filing a report thereunder. As concerns Networked Level III accounts and omnibus accounts, the AML Services performed by Citi BISYS are subject to a more limited scope, as discussed in the Release concerning the final rule of the Department of the Treasury, 31 CFR 103 and of the XXXCommission, 00 XXX 00017 CFR 270, entitled Customer Identification Programs for Mutual Funds issued on May 9, 2003 and subsequent guidance issued jointly by such agencies entitled Question and Answer Regarding the Mutual Fund Customer Identification Program Rule (31 CFR 103.131) issued on August 11, 2003.

Anti-Money Laundering Provisions. The Company Trust acknowledges that it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism ("USA PATRIOT") Act of 2001 and the Bank Secrecy Act (collectively, the "AML Acts") and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the "Applicable AML Laws") in all relevant respects, subject to the delegation of certain responsibilities to CitiBISYS, as provided in the next paragraph below. The Company Trust hereby delegates to Citi BISYS the performance, on behalf of the CompanyTrust, of the anti-money laundering services set forth under Item 6 of Schedule D (the "AML Services") with respect to the shareholder accounts maintained by Citi BISYS pursuant to this Agreement, and Citi BISYS agrees to the foregoing delegation and agrees to perform such services in accordance with the CompanyTrust's AML Program for the fee set forth on Schedule E to this AgreementProgram. In connection therewith, Citi BISYS agrees to maintain policies and procedures, and related internal controls, that are consistent with the CompanyTrust's AML Program and the requirement that the Company Trust employ procedures reasonably designed to achieve compliance with the Applicable AML Laws. Citi's BISYS' obligations under this delegation shall be subject to Sections 19 and 21 of this Agreement21, which require that the AML Program and any material amendments thereto be submitted to Citi BISYS for its review and consent prior to adoption. The Company Trust agrees and acknowledges that, notwithstanding the delegation provided for in the foregoing paragraph, the Company Trust maintains full responsibility for ensuring that its AML Program is, and shall continue to be, reasonably designed to ensure compliance with the Applicable AML Laws, in light of the particular business of the CompanyTrust, taking into account factors such as its size, location, activities and risks or vulnerabilities to money laundering. In connection with the foregoing delegation, the Company Trust also acknowledges that the performance of the AML Services involves the exercise of discretion which in certain circumstances may result in consequences to the Company Trust and its shareholders (such as in the case of the reporting of suspicious activities and the freezing of shareholder accounts). In this regard, (i) under circumstances in which the AML Program authorizes the taking of certain actions, Citi BISYS is granted the discretion to take any such action as may be authorized under the AML Program, and consultation with Company Trust shall not be required in connection therewith unless specifically required under the AML Program, and (ii) the Company Trust instructs Citi BISYS that it may avail the Company Trust of any safe harbor from civil liability that may be available under Applicable AML Laws for making a disclosure or filing a report thereunder. As concerns Networked Networking Level III accounts and omnibus accounts, the AML Services performed by Citi BISYS are subject to a more limited scope, as discussed in the Release concerning the final rule of the Department of the Treasury, 31 CFR 103 and of the XXXCommission, 00 XXX 00017 CFR 270, entitled Customer Identification Programs for Mutual Funds issued on May 9, 2003 and subsequent guidance issued jointly by such agencies entitled Question and Answer Regarding the Mutual Fund Customer Identification Program Rule (31 CFR 103.131) issued on August 11, 2003.

Anti-Money Laundering Provisions. The Company acknowledges that it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism ("USA PATRIOT"') Act of 2001 and the Bank Secrecy Act (collectively, the "AML Acts") and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the "Applicable AML Laws") in all relevant respects, subject to the delegation of certain responsibilities to CitiBISYS, as provided in the next paragraph below. The Company hereby delegates to Citi BISYS the performance, on behalf of the Company, of the anti-money laundering services set forth under Item 6 of Schedule D (the "AML Services") with respect to the shareholder accounts maintained by Citi BISYS pursuant to this Agreement, and Citi BISYS agrees to the foregoing delegation and agrees to perform such services in accordance with the Company's AML Program for the fee set forth on Schedule E to this Agreement. In connection therewith, Citi BISYS agrees to maintain policies and procedures, and related internal controls, that are consistent with the Company's AML Program and the requirement that the Company employ procedures reasonably designed to achieve compliance with the Applicable AML Laws. Citi's BISYS' obligations under this delegation shall be subject to Sections 19 and 21 of this Agreement21, which require that the AML Program and any material amendments thereto be submitted to Citi BISYS for its review and consent prior to adoption. The Company agrees and acknowledges that, notwithstanding the delegation provided for in the foregoing paragraph, the Company maintains full responsibility for ensuring that its AML Program is, and shall continue to be, reasonably designed to ensure compliance with the Applicable AML Laws, in light of the particular business of the Company, taking into account factors such as its size, location, activities and risks or vulnerabilities to money laundering. In connection with the foregoing delegation, the Company also acknowledges that the performance of the AML Services involves the exercise of discretion which in certain circumstances may result in consequences to the Company and its shareholders (such as in the case of the reporting of suspicious activities and the freezing of shareholder accounts). In this regard, (i) under circumstances in which the AML Program authorizes the taking of certain actions, Citi BISYS is granted the discretion to take any such action as may be authorized under the AML Program, and consultation with Company shall not be required in connection therewith unless specifically required under the AML Program, and (ii) the Company instructs Citi BISYS that it may avail the Company of any safe harbor from civil liability that may be available under Applicable AML Laws for making a disclosure or filing a report thereunder. As concerns Networked Level III accounts and omnibus accounts, the AML Services performed by Citi BISYS are subject to a more limited scope, as discussed in the Release concerning the final rule of the Department of the Treasury, 31 CFR 103 and of the XXXCommission, 00 XXX 00017 CFR 270, entitled Customer Identification Programs for Mutual Funds issued on May 9, 2003 and subsequent guidance issued jointly by such agencies entitled Question and Answer Regarding the Mutual Fund Customer Identification Program Rule (31 CFR 103.131) issued on August 11, 2003.11,2003

Anti-Money Laundering Provisions. The Company acknowledges that it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism ("“USA PATRIOT"”) Act of 2001 and the Bank Secrecy Act (collectively, the "“AML Acts"”) and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the "“Applicable AML Laws"”) in all relevant respects, subject to the delegation of certain responsibilities to CitiBISYS, as provided in the next paragraph below. The Company hereby delegates to Citi BISYS the performance, on behalf of the Company, of the anti-money laundering services set forth under Item 6 of Schedule D (the "“AML Services"”) with respect to the shareholder accounts maintained by Citi BISYS pursuant to this Agreement, and Citi BISYS agrees to the foregoing delegation and agrees to perform such services in accordance with the Company's ’s AML Program for the fee set forth on Schedule E to this Agreement. In connection therewith, Citi BISYS agrees to maintain policies and procedures, and related internal controls, that are consistent with the Company's ’s AML Program and the requirement that the Company employ procedures reasonably designed to achieve compliance with the Applicable AML Laws. Citi's BISYS’ obligations under this delegation shall be subject to Sections 19 and 21 of this Agreement21, which require that the AML Program and any material amendments thereto be submitted to Citi BISYS for its review and consent prior to adoptionreview. The Company agrees and acknowledges that, notwithstanding the delegation provided for in the foregoing paragraph, the Company maintains full responsibility for ensuring that its AML Program is, and shall continue to be, reasonably designed to ensure compliance with the Applicable AML Laws, in light of the particular business of the Company, taking into account factors such as its size, location, activities and risks or vulnerabilities to money laundering. In connection with the foregoing delegation, the Company also acknowledges that the performance of the AML Services involves the exercise of discretion which in certain circumstances may result in consequences to the Company and its shareholders (such as in the case of the reporting of suspicious activities and the freezing of shareholder accounts). In this regard, (i) under circumstances in which the AML Program authorizes the taking of certain actions, Citi BISYS is granted the discretion to take any such action as may be authorized under the AML Program, and consultation with Company shall not be required in connection therewith unless specifically required under the AML Program, and (ii) the Company instructs Citi BISYS that it may avail the Company of any safe harbor from civil liability that may be available under Applicable AML Laws for making a disclosure or filing a report thereunder. As concerns Networked Networking Level III accounts and omnibus accounts, the AML Services performed by Citi BISYS are subject to a more limited scope, as discussed provided in the Release concerning the final rule of the Department of the Treasury, 31 CFR 103 and of the XXXCommission, 00 XXX 00017 CFR 270, entitled Customer Identification Programs for Mutual Funds issued on May 9, 2003 and subsequent guidance issued jointly by such agencies entitled Question and Answer Regarding the Mutual Fund Customer Identification Program Rule (31 CFR 103.131) issued on August 11, 2003. For example, (i) trading in omnibus accounts in most instances cannot be attributed to underlying individuals, and (ii) when broker-dealers and other intermediaries open accounts through the NSCC Fund/SERV system, the intermediary’s customers would not be customers of a mutual fund, unless the Fund’s account application has been completed and received by the relevant fund or its transfer agent.

Anti-Money Laundering Provisions. The Company Trust acknowledges that it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism ("USA PATRIOTPatriot") Act of 2001 and the Bank Secrecy Act (collectively, the "AML Acts") and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the "Applicable AML Laws") in all relevant respects, subject to the delegation of certain responsibilities to CitiBISYS, as provided in the next paragraph below. The Company Trust hereby delegates to Citi BISYS the performance, on behalf of the CompanyTrust, of the anti-money laundering services set forth under Item 6 of Schedule D (the "AML Services") with respect to the shareholder accounts maintained by Citi BISYS pursuant to this Agreement, and Citi BISYS agrees to the foregoing delegation and agrees to perform such services in accordance with the CompanyTrust's AML Program for the fee set forth on Schedule E to this AgreementProgram. In connection therewith, Citi BISYS agrees to maintain policies and procedures, and related internal controls, that are consistent with the CompanyTrust's AML Program and the requirement that the Company Trust employ procedures reasonably designed to achieve compliance with the Applicable AML Laws. Citi's BISYS' obligations under this delegation shall be subject to Sections 19 and 21 of this Agreement21, which require that the AML Program and any material amendments thereto be submitted to Citi BISYS for its review and consent prior to adoption. The Company Trust agrees and acknowledges that, notwithstanding the delegation provided for in the foregoing paragraph, the Company Trust maintains full responsibility for ensuring that its AML Program is, and shall continue to be, reasonably designed to ensure compliance with the Applicable AML Laws, in light of the particular business of the CompanyTrust, taking into account factors such as its size, location, activities and risks or vulnerabilities to money laundering. In connection with the foregoing delegation, the Company Trust also acknowledges that the performance of the AML Services involves the exercise of discretion which in certain circumstances may result in consequences to the Company Trust and its shareholders (such as in the case of the reporting of suspicious activities and the freezing of shareholder accounts). In this regard, (i) under circumstances in which the AML Program authorizes the taking of certain actions, Citi BISYS is granted the discretion to take any such action as may be authorized under the AML Program, and consultation with Company Trust shall not be required in connection therewith unless specifically required under the AML Program, and (ii) the Company Trust instructs Citi BISYS that it may avail the Company Trust of any safe harbor from civil liability that may be available under Applicable AML Laws for making a disclosure or filing a report thereunder. As concerns Networked Networking Level III accounts and omnibus accounts, the AML Services performed by Citi BISYS are subject to a more limited scope, as discussed in the Release concerning the final rule of the Department of the Treasury, 31 CFR 103 and of the XXXCommission, 00 XXX 00017 CFR 270, entitled Customer Identification Programs for Mutual Funds issued on May 9, 2003 and subsequent guidance issued jointly by such agencies entitled Question and Answer Regarding the Mutual Fund Customer Identification Program Rule (31 CFR 103.131) issued on August 11, 2003.

Anti-Money Laundering Provisions. The Company acknowledges that it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism ("“USA PATRIOT"”) Act of 2001 and the Bank Secrecy Act (collectively, the "“AML Acts"”) and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the "“Applicable AML Laws"”) in all relevant respects, subject to the delegation of certain responsibilities to Citi, as provided in the next paragraph below. The Company hereby delegates to Citi the performance, on behalf of the Company, of the anti-money laundering services set forth under Item 6 of Schedule D C (the "“AML Services"”) with respect to the shareholder accounts maintained by Citi pursuant to this Agreement, and Citi agrees to the foregoing delegation and agrees to perform such services in accordance with the Company's ’s AML Program for the fee set forth on Schedule E D to this Agreement. In connection therewith, Citi agrees to maintain policies and procedures, and related internal controls, that are consistent with the Company's ’s AML Program and the requirement that the Company employ procedures reasonably designed to achieve compliance with the Applicable AML Laws. Citi's ’s obligations under this delegation shall be subject to Sections 19 and 21 of this Agreement, which require that the AML Program and any material amendments thereto be submitted to Citi for its review and consent prior to adoption. The Company agrees and acknowledges that, notwithstanding the delegation provided for in the foregoing paragraph, the Company maintains full responsibility for ensuring that its AML Program is, and shall continue to be, reasonably designed to ensure compliance with the Applicable AML Laws, in light of the particular business of the Company, taking into account factors such as its size, location, activities and risks or vulnerabilities to money laundering. In connection with the foregoing delegation, the Company also acknowledges that the performance of the AML Services involves the exercise of discretion which in certain circumstances may result in consequences to the Company and its shareholders (such as in the case of the reporting of suspicious activities and the freezing of shareholder accounts). In this regard, (i) under circumstances in which the AML Program authorizes the taking of certain actions, Citi is granted the discretion to take any such action as may be authorized under the AML Program, and consultation with Company shall not be required in connection therewith unless specifically required under the AML Program, and (ii) the Company instructs Citi that it may avail the Company of any safe harbor from civil liability that may be available under Applicable AML Laws for making a disclosure or filing a report thereunder. As concerns Networked Level III accounts and omnibus accounts, the AML Services performed by Citi are subject to a more limited scope, as discussed in the Release concerning the final rule of the Department of the Treasury, 31 CFR 103 and of the XXXCommission, 00 XXX 00017 CFR 270, entitled Customer Identification Programs for Mutual Funds issued on May 9, 2003 and subsequent guidance issued jointly by such agencies entitled Question and Answer Regarding the Mutual Fund Customer Identification Program Rule (31 CFR 103.131) issued on August 11, 2003.

Anti-Money Laundering Provisions. The Company Trust acknowledges that it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism ("USA PATRIOT") Act of 2001 and the Bank Secrecy Act (collectively, the "AML Acts") and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the "Applicable AML Laws") in all relevant respects, subject to the delegation of certain responsibilities to CitiBISYS, as provided in the next paragraph below. The Company Trust hereby delegates to Citi BISYS the performance, on behalf of the CompanyTrust, of the anti-money laundering services set forth under Item 6 of Schedule D (the "AML Services") with respect to the shareholder accounts maintained by Citi BISYS pursuant to this Agreement, and Citi BISYS agrees to the foregoing delegation and agrees to perform such services in accordance with the CompanyTrust's AML Program for the fee set forth on Schedule E to this Agreement. In connection therewith, Citi BISYS agrees to maintain policies and procedures, and related internal controls, that are consistent with the CompanyTrust's AML Program and the requirement that the Company Trust employ procedures reasonably designed to achieve compliance with the Applicable AML LawsLaws including the requirement to have policies and procedures that can be reasonably expected to detect and cause the reporting of transactions under Section 5318 of the Bank Secrecy Act. Citi's BISYS' obligations under this delegation shall be subject to Sections 19 and 21 of this Agreement, which require that the AML Program and any material amendments thereto be submitted to Citi BISYS for its review and consent prior to adoption. The Company Trust agrees and acknowledges that, notwithstanding the delegation provided for in the foregoing paragraph, the Company Trust maintains full responsibility for ensuring that its AML Program is, and shall continue to be, reasonably designed to ensure compliance with the Applicable AML Laws, in light of the particular business of the CompanyTrust, taking into account factors such as its size, location, activities and risks or vulnerabilities to money laundering. In connection with the foregoing delegation, the Company Trust also acknowledges that the performance of the AML Services involves the exercise of discretion which in certain circumstances may result in consequences to the Company Trust and its shareholders (such as in the case of the reporting of suspicious activities and the freezing of shareholder accounts). In this regard, (i) under circumstances in which the AML Program authorizes the taking of certain actions, Citi BISYS is granted the discretion to take any such action as may be authorized under the AML Program, and consultation with Company Trust shall not be required in connection therewith unless specifically required under the AML Program, and (ii) the Company Trust instructs Citi BISYS that it may avail the Company Trust of any safe harbor from civil liability that may be available under Applicable AML Laws for making a disclosure or filing a report thereunder. As concerns Networked Level III accounts and omnibus accounts, the AML Services performed by Citi BISYS are subject to a more limited scope, as discussed in the Release concerning the final rule of the Department of the Treasury, 31 CFR 103 and of the XXXCommission, 00 XXX 00017 CFR 270, entitled Customer Identification Programs for Mutual Funds issued on May 9, 2003 and subsequent guidance issued jointly by such agencies entitled Question and Answer Regarding the Mutual Fund Customer Identification Program Rule (31 CFR 103.131) issued on August 11, 2003.

Anti-Money Laundering Provisions. The Company Trust acknowledges that it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism ("USA PATRIOTU.S.A. Patriot") Act of 2001 and the Bank Secrecy Act (collectively, the "AML Acts") and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the "Applicable AML Laws") in all relevant respects, subject to the delegation of certain responsibilities to CitiBISYS, as provided in the next paragraph below. The Company Trust hereby delegates to Citi BISYS the performance, on behalf of the CompanyTrust, of the anti-money laundering services set forth under Item 6 of Schedule D (the "AML Services") with respect to the shareholder accounts maintained by Citi BISYS pursuant to this Agreement, and Citi BISYS agrees to the foregoing delegation and agrees to perform such services in accordance with the CompanyTrust's AML Program for the fee set forth on Schedule E to this AgreementProgram. In connection therewith, Citi BISYS agrees to maintain policies and procedures, and related internal controls, that are consistent with the CompanyTrust's AML Program and the requirement that the Company Trust employ procedures reasonably designed to achieve compliance with the Applicable AML Laws. Citi's BISYS' obligations under this delegation shall be subject to Sections 19 and 21 of this Agreement21, which require that the AML Program and any material amendments thereto be submitted to Citi BISYS for its review and consent prior to adoption. The Company Trust agrees and acknowledges that, notwithstanding the delegation provided for in the foregoing paragraph, the Company Trust maintains full responsibility for ensuring that its AML Program is, and shall continue to be, reasonably designed to ensure compliance with the Applicable AML Laws, in light of the particular business of the CompanyTrust, taking into account factors such as its size, location, activities and risks or vulnerabilities to money laundering. In connection with the foregoing delegation, the Company Trust also acknowledges that the performance of the AML Services involves the exercise of discretion which in certain circumstances may result in consequences to the Company Trust and its shareholders (such as in the case of the reporting of suspicious activities and the freezing of shareholder accounts). In this regard, (i) under circumstances in which the AML Program authorizes the taking of certain actions, Citi BISYS is granted the discretion to take any such action as may be authorized under the AML Program, and consultation with Company Trust shall not be required in connection therewith unless specifically required under the AML Program, and (ii) the Company Trust instructs Citi BISYS that it may avail the Company Trust of any safe harbor from civil liability that may be available under Applicable AML Laws for making a disclosure or filing a report thereunder. As concerns Networked Networking Level III accounts and omnibus accounts, the AML Services performed by Citi BISYS are subject to a more limited scope, as discussed in the Release concerning the final rule of the Department of the Treasury, 31 CFR 103 and of the XXXCommission, 00 XXX 00017 CFR 270, entitled Customer Identification Programs for Mutual Funds issued on May 9, 2003 and subsequent guidance issued jointly by such agencies entitled Question and Answer Regarding the Mutual Fund Customer Identification Program Rule (31 CFR 103.131) issued on August 11, 2003.Mutual

Anti-Money Laundering Provisions. The Company Trust acknowledges that it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism ("USA PATRIOT") Act of 2001 and the Bank Secrecy Act (collectively, the "AML Acts") and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the "Applicable AML Laws") in all relevant respects, subject to the delegation of certain responsibilities to CitiBISYS, as provided in the next paragraph below. The Company Trust hereby delegates to Citi BISYS the performance, on behalf of the CompanyTrust, of the anti-money laundering services set forth under Item 6 of Schedule D (the "AML Services") with respect to the shareholder accounts maintained by Citi BISYS pursuant to this Agreement, and Citi BISYS agrees to the foregoing delegation and agrees to perform such services in accordance with the CompanyTrust's AML Program for the fee set forth on Schedule E F to this Agreement. In connection therewith, Citi BISYS agrees to maintain policies and procedures, and related internal controls, that are consistent with the CompanyTrust's AML Program and the requirement that the Company Trust employ procedures reasonably designed to achieve compliance with the Applicable AML Laws. Citi's BISYS' obligations under this delegation shall be subject to Sections 19 18 and 21 20 of this Agreement, which require that the AML Program and any material amendments thereto be submitted to Citi BISYS for its review and consent prior to adoption. The Company Trust agrees and acknowledges that, notwithstanding the delegation provided for in the foregoing paragraph, the Company Trust maintains full responsibility for ensuring that its AML Program is, and shall continue to be, reasonably designed to ensure compliance with the Applicable AML Laws, in light of the particular business of the CompanyTrust, taking into account factors such as its size, location, activities and risks or vulnerabilities to money laundering. BISYS represents that its Anti-Money Laundering and Fraud Program is reasonably designed to ensure compliance with the Applicable AML Laws related to its Transfer Agency Services to the Trust and, specifically, those detailed in section 6 of Schedule D. In connection with the foregoing delegation, the Company Trust also acknowledges that the performance of the AML Services involves the exercise of discretion which in certain circumstances may result in consequences to the Company Trust and its shareholders (such as in the case of the reporting of suspicious activities and the freezing of shareholder accounts). In this regard, (i) under circumstances in which the AML Program authorizes the taking of certain actions, Citi BISYS is granted the discretion to take any such action as may be authorized under the AML Program, and consultation with Company Trust shall not be required in connection therewith unless specifically required under the AML Program, and (ii) the Company Trust instructs Citi BISYS that it may avail the Company Trust of any safe harbor from civil liability that may be available under Applicable AML Laws for making a disclosure or filing a report thereunder. As concerns Networked Level III accounts and omnibus accounts, the AML Services performed by Citi BISYS are subject to a more limited scope, as discussed in the Release concerning the final rule of the Department of the Treasury, 31 CFR 103 and of the XXXSEC, 00 XXX 00017 CFR 270, entitled Customer Identification Cuxxxxxx Xxxxxxxxcation Programs for Mutual Funds issued on May 9, 2003 and subsequent guidance issued jointly by such agencies entitled Question and Answer Regarding the Mutual Fund Customer Identification Program Rule (31 CFR 103.131) issued on August 11, 2003.