Common use of Anti-Money Laundering Clause in Contracts

Anti-Money Laundering. (A) DTI shall provide for the establishment, maintenance and monitoring of accounts of investors in the Funds and perform reasonable actions necessary to assist the Funds in complying with Section 352 of the USA PATRIOT Act, as follows: (i) DTI shall establish and implement written policies, procedures and internal controls reasonably designed to help prevent the Funds from being used for money laundering or the financing of terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. (ii) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("AML") program or by an outside party, for compliance with DTI's written AML policies and procedures; (iii) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's AML program; and (iv) DTI shall provide ongoing training of DTI personnel relating to the prevention of money-laundering activities. (B) Upon the reasonable request of a Fund, DTI shall provide to the Fund: (x) a copy of DTI's written AML policies and procedures; (y) at the option of DTI, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund compliance with Section 352 of the USA PATRIOT Act and does not relate to any other obligation the Funds may have under the USA PATRIOT Act, including without limitation Section 326 thereof.

Anti-Money Laundering. (Aa) DTI shall provide for To the establishmentextent the other provisions of this Agreement require PNC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Fund consistent with securities laws, PNC shall perform reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : PNC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's PNC’s anti-money laundering ("“AML"”) program or by an outside party, for compliance with DTI's written PNC’s established AML policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's PNC’s AML program; and and (ivd) DTI shall provide ongoing training of DTI PNC personnel relating to the prevention of money-laundering activities. (Bb) Upon the reasonable request of a the Fund, DTI PNC shall provide to the Fund: (x) a copy of DTI's PNC’s written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to Confidential Information (as defined below); (y) at the option of DTIPNC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI PNC personnel. PNC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. (Cc) Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree provisions in this Section 3(b)(1) relates solely 3 shall relate only to Fund compliance with Section 352 of the USA PATRIOT Act and does do not relate to any apply other obligation the Funds may have under sections, including Section 326, of the USA PATRIOT ActAct or regulations promulgated thereunder. (d) Subject to mutually agreed upon procedures, PNC shall perform searches within applicable regulatory time periods of OFAC, EU, the Dutch Freeze List, FATF NCCT, OFSI and FinCEN databases and advise the MLRO of matches to any names in these databases, and perform any additional research or searches as reasonably requested by the MLRO or her authorized staff. (e) PNC shall operate screening procedures designed to prohibit, other than by Written Instructions from the Funds, the use of cash, third-party checks or cash equivalents to purchase shares of the Funds. Cash equivalents include, but are not limited, to cashier’s checks, money orders and traveler’s checks. (f) PNC shall provide to the Fund access to such files, wire orders, or regulatory filings as are created and maintained in accordance with its duties under Sections 3, 4, 5, 6 and 7, and shall provide reasonable assistance to ING in responding in a timely manner to the requests of independent auditors and regulators relating to such duties. For purposes of this Agreement, “access” with respect to such files, wire orders, filings or other books and records pertaining to the Fund that are in the possession or under the control of PNC means submission by the Fund of a reasonably detailed request of the books and records sought and PNC providing them to the fullest extent reasonably practicable pursuant to its document production procedures; provided, however, that it is expressly understood and acknowledged that nothing in this Agreement shall require PNC to furnish to the Funds contents of any files or other materials that constitute internal communications (including without limitation Section 326 thereofemails) of PNC, confidential material, information proprietary to PNC, material subject to attorney-client privilege or material prohibited by law from disclosure or distribution. (g) Provide a quarterly report that provides a summary of primary AML transaction processing metrics relating to the transfer agent’s AML Program.

Anti-Money Laundering. (A) DTI shall provide for the establishment, maintenance and monitoring of accounts of investors in the Funds and BNYM will perform reasonable actions necessary reasonably designed to assist the Funds Fund in complying with Section 352 of the USA PATRIOT Act, as amended, as follows: : BNYM will: (i) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for money laundering or the financing of terrorist activities, including, without limiting the generality activities and to achieve compliance with applicable provisions of the foregoingBank Secrecy Act (31 U.S.C. 5311, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedureset seq. ) ("Bank Secrecy Act") and implementing regulations thereunder; (ii) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIBNYM's anti-money laundering ("AML") program or by an a qualified outside party, for compliance with DTIBNYM's written AML policies and procedures; ; (iii) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIBNYM's AML program; and (iv) DTI shall provide ongoing training for appropriate persons, and (v) implement appropriate risk-based procedures for conducting ongoing shareholder due diligence to include but not be limited to (aa) understanding the nature and purpose of DTI personnel relating shareholder relationships for the purposes of developing a shareholder risk profile, and (bb) conducting ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update shareholder information, including information regarding the prevention beneficial owners of money-laundering activitieslegal entity shareholders. (B) Upon the reasonable request of a Fund, DTI shall BNYM will provide to the Fund: : (xi) a copy of DTIBNYM's written AML policies and procedures; , or, alternatively, access to such policies and procedures at a BNYM website; (yii) at the option of DTI, a copy of a written assessment or the report prepared by the party performing independent accountants covering the independent testing for compliance, or a summary thereof, or a certification that the findings accountants' examination of the independent party are satisfactoryBNYM's AML controls and control objectives; and and (ziii) a summary of the AML training provided for appropriate DTI personnelpursuant to clause (iv) of subsection (A) above. (C) BNYM agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund compliance with Section 352 of the USA PATRIOT Act and does not relate to any other obligation the Funds may have under the USA PATRIOT Act, including without limitation Section 326 thereof.or

Anti-Money Laundering. As of the Effective Date, the Agreement is amended by adding the following new provision: "Anti-Money Laundering. PFPC has implemented various anti-money laundering (A"AML") DTI shall provide for procedures as described below, which it has found to be reasonable, and the establishmentFund desires to delegate certain AML procedures to PFPC, maintenance as permitted by the USA PATRIOT Act (the "PATRIOT Act") and monitoring the regulations promulgated hereunder. Consequently, the Fund and PFPC desire to amend the Agreement to reflect such services explicitly as follows: To the extent the other provisions of this Agreement require PFPC to establish, maintain and monitor accounts of investors in the Funds and Fund consistent with securities laws, PFPC shall perform all reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of United States Federal AML laws applicable to investor activity, including the USA Bank Secrecy Act and the PATRIOT Act, Act as follows: : In this regard, PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or finance terrorist activities and to achieve compliance with the financing of terrorist activities, including, without limiting the generality applicable provisions of the foregoing, Bank Secrecy Act and the implementing regulations thereunder; (b) undertake to revise such AML procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account as necessary or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. appropriate; (iic) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIPFPC's anti-money laundering ("AML") AML program or by an outside party, for compliance with DTIPFPC's written AML established policies and procedures; ; (iiid) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIPFPC's AML program; and and (ive) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a the Fund, DTI PFPC shall provide to the Fund's AML Compliance Officer: (x) a copy of DTIPFPC's written AML policies and procedures; procedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement): (y) at the option of DTI, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, compliance (or a summary thereof, at PFPC's option), or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) Without limiting or expanding subsections (A) or (B) above. In addition, PFPC shall provide the parties agree this Section 3(b)(1) relates solely Fund with information necessary for the Fund to Fund compliance with Section 352 of the USA PATRIOT Act prepare and does not relate to file Form 8300 and any other obligation the Funds may have suspicious activity reports, required under the USA PATRIOT ActAML laws, including without limitation Section 326 thereofin connection with suspicious activity PFPC detects. PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request."

Anti-Money Laundering. (A) DTI shall provide for As of the establishmentEffective Date, maintenance the Agreement is amended by adding the following new provision: "Anti-Money Laundering. To the extent the other provisions of this agreement require PFPC to establish, maintain and monitoring of monitor accounts of investors in the Funds and Fund consistent with securities laws, PFPC shall perform reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of United States Federal anti-money laundering ("AML") laws applicable to investor activity, including the USA Bank Secrecy Act and the PATRIOT Act, as follows: : In this regard, PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIPFPC's anti-money laundering ("AML") AML program or by an outside party, for compliance with DTIPFPC's written AML established policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIPFPC's AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a the Fund, DTI PFPC shall provide to the Fund: (x) a copy of DTIPFPC's written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this agreement); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. (C) Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund compliance with Section 352 of the USA PATRIOT Act and does not relate to any other obligation the Funds may have under the USA PATRIOT Act, including without limitation Section 326 thereof."

Anti-Money Laundering. (A) DTI shall provide for To the establishmentextent the other provisions of this Agreement require the Distributor to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Trust consistent with securities laws, the Distributor shall perform all reasonable actions necessary to assist help the Funds Trust be in complying compliance with Section 352 of United States federal AML laws applicable to investor activity, including the USA Bank Secrecy Act and the PATRIOT Act, as follows: described hereinafter. In this regard, the Distributor shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Trust from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIthe Distributor's anti-money laundering ("AML") AML program or by an outside party, for compliance with DTIthe Distributor's written AML established policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIthe Distributor's AML program; and and (ivd) DTI shall provide ongoing training of DTI the Distributor's personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a Fundthe Trust, DTI the Distributor shall provide to the Fund: Trust's officer in charge of AML compliance (the "AML Compliance Officer"): (x) a copy of DTIthe Distributor's written AML policies and procedures; procedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement): (y) at the option of DTI, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) Without limiting or expanding subsections (A) or (B) above. Unless otherwise preformed by the Trust's transfer agent, the parties agree this Section 3(b)(1Distributor shall also: (i) relates solely to Fund collect and maintain investor information, verify the identity of investors and check investor identities against all government lists of known or suspected terrorists and terrorist organizations in compliance with Section 352 the procedures set forth in the Trust's AML program and the PATRIOT Act; (ii) provide notice of the USA Trust's customer identification procedures to prospective investors in the manner permitted by the PATRIOT Act before an account is opened; (iii) maintain records of the information collected and does not relate methods used to any other obligation verify investor identity in compliance with the Funds may have under the USA PATRIOT Act; (iv) monitor investor accounts for suspicious activity to the extent required by AML laws or the PATRIOT Act; and (v) make any required regulatory filings on behalf of the Trust including, including without limitation Section 326 thereofbut not limited to, Form 8300 and suspicious activity reports (to the extent required by AML laws) and promptly provide a copy of all such reports filed to the Trust's AML Compliance Officer. To the extent that a Trust regulator wishes to examine the Distributor regarding its services hereunder, the Distributor shall cooperate with and permit examinations of its records and personnel by such regulator, coordinating any such response with the Trust's AML Compliance Officer. The Distributor also agrees to make available to examiners from such regulatory agencies any information and records relating to the Trust's AML program as such examiners shall reasonably request.

Anti-Money Laundering. (A) DTI shall provide for To the establishmentextent the other provisions of this Agreement require PFPC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds GE Fund Products consistent with securities laws and other statutes, PFPC shall perform reasonable actions necessary to assist help the Funds GE Fund Products be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : In this regard, PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds GE Fund Products from being used for to launder money laundering or finance terrorist activities (the financing of terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. “PFPC AML Program”); (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("AML") program the PFPC AML Program, or by an outside party, for compliance with DTI's written AML of PFPC’s established policies and procedures; procedures as described in subsection (iiia) DTI shall above; (c) designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's the PFPC AML programProgram; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) PFPC AML Program . Upon the reasonable request of a Fundthe GE Fund Products, DTI PFPC shall provide to the FundGE Fund Products: (x) a copy of DTI's the PFPC AML Program written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such, and afforded all protections provided to confidential information under this Agreement); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the PFPC AML Program training provided for appropriate DTI personnel. (C) . PFPC agrees to permit inspections relating to the PFPC AML Program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to the PFPC AML Program as such examiners shall reasonably request. Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree this the provisions herein do not apply to Section 3(b)(1) relates solely to Fund compliance with Section 352 326 of the USA PATRIOT Act and does not relate to any (or other obligation the Funds may have under the USA PATRIOT Act, including without limitation sections other than Section 326 thereof352) or regulations promulgated thereunder.

Anti-Money Laundering. (A) DTI shall provide for To the establishmentextent the other provisions of this Agreement require USBFS to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and GE Stock XXX Accounts consistent with securities laws and other statutes, USBFS shall perform reasonable actions necessary to assist help the Funds GE Parties be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: (i) DTI USBFS shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds GE Parties from being used for to launder money laundering or finance terrorist activities (the financing of terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures.“USBFS AML Program”); (ii) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("AML") program the USBFS AML Program, or by an outside partythird-party vendor, for compliance with DTI's written AML of USBFS’s established policies and proceduresprocedures as described in subsection (i) above; (iii) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's the USBFS AML programProgram; (iv) provide ongoing training of USBFS personnel relating to the USBFS AML Program; and (ivv) DTI shall provide ongoing training certified annual and quarterly reports of DTI personnel relating to the prevention of money-laundering activities. (B) USBFS AML Program monitoring. Upon the reasonable request of a Fundthe GE Parties, DTI USBFS shall provide to the FundGE Parties: (x) a copy of DTI's the USBFS AML Program written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such, and afforded all protections provided to confidential information under this Agreement); (y) at the option of DTI, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the USBFS AML Program training provided for appropriate DTI personnel. (C) . USBFS agrees to permit inspections relating to the USBFS AML Program by U.S. federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to the USBFS AML Program as such examiners shall reasonably request. Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree this the provisions herein do not apply to Section 3(b)(1) relates solely to Fund compliance with Section 352 326 of the USA PATRIOT Act and does not relate to any (or sections other obligation the Funds may have under the USA PATRIOT Act, including without limitation than Section 326 thereof352) or regulations promulgated thereunder.

Anti-Money Laundering. (A) DTI shall provide for To the establishmentextent the other provisions of this Agreement require the Distributor to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Fund consistent with securities laws, the Distributor shall perform all reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of United States federal AML laws applicable to investor activity, including the USA Bank Secrecy Act and the PATRIOT Act, as follows: described hereinafter. In this regard, the Distributor shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIthe Distributor's anti-money laundering ("AML") AML program or by an outside party, for compliance with DTIthe Distributor's written AML established policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIthe Distributor's AML program; and and (ivd) DTI shall provide ongoing training of DTI the Distributor's personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a the Fund, DTI the Distributor shall provide to the Fund: 's officer in charge of AML compliance (the "AML Compliance Officer"): (x) a copy of DTIthe Distributor's written AML policies and procedures; procedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement): (y) at the option of DTI, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) Without limiting or expanding subsections (A) or (B) above. Unless otherwise preformed by the Fund's transfer agent, the parties agree this Section 3(b)(1Distributor shall also: (i) relates solely to Fund collect and maintain investor information, verify the identity of investors and check investor identities against all government lists of known or suspected terrorists and terrorist organizations in compliance with Section 352 the procedures set forth in the Fund's AML program and the PATRIOT Act; (ii) provide notice of the USA Fund's customer identification procedures to prospective investors in the manner permitted by the PATRIOT Act before an account is opened; (iii) maintain records of the information collected and does not relate methods used to any other obligation verify investor identity in compliance with the Funds may have under the USA PATRIOT Act; (iv) monitor investor accounts for suspicious activity to the extent required by AML laws or the PATRIOT Act; and (v) make any required regulatory filings on behalf of the Fund including, including without limitation Section 326 thereofbut not limited to, Form 8300 and suspicious activity reports (to the extent required by AML laws) and promptly provide a copy of all such reports filed to the Fund's AML Compliance Officer. To the extent that a Fund regulator wishes to examine the Distributor regarding its services hereunder, the Distributor shall cooperate with and permit examinations of its records and personnel by such regulator, coordinating any such response with the Fund's AML Compliance Officer. The Distributor also agrees to make available to examiners from such regulatory agencies any information and records relating to the Fund's AML program as such examiners shall reasonably request.

Anti-Money Laundering. (A) DTI shall provide for the establishment, maintenance and monitoring of accounts of investors in the Funds and BNYM will perform reasonable actions necessary reasonably designed to assist the Funds Fund in complying with Section 352 of the USA PATRIOT Act, as amended, as follows: : BNYM will: (i) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for money laundering or the financing of terrorist activities, including, without limiting the generality activities and to achieve compliance with applicable provisions of the foregoingBank Secrecy Act (31 U.S.C. 5311, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedureset seq. ) (“Bank Secrecy Act”) and implementing regulations thereunder; (ii) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's BNYM’s anti-money laundering ("“AML"”) program or by an outside party, for compliance with DTI's BNYM’s written AML policies and procedures; ; (iii) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's BNYM’s AML program; and (iv) DTI shall provide ongoing training for appropriate persons, and (v) implement appropriate risk-based procedures for conducting ongoing shareholder due diligence to include but not be limited to (aa) understanding the nature and purpose of DTI personnel relating shareholder relationships for the purposes of developing a shareholder risk profile, and (bb) conducting ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update shareholder information, including information regarding the prevention beneficial owners of money-laundering activitieslegal entity shareholders. (B) Upon the reasonable request of a Fund, DTI shall BNYM will provide to the Fund: : (xi) a copy of DTI's BNYM’s written AML policies and procedures; , or, alternatively, access to such policies and procedures at a BNYM website; (yii) at the option of DTI, a copy of a written assessment or the report prepared by the party performing independent accountants covering the independent testing for compliance, or a summary thereof, or a certification that the findings accountants’ examination of the independent party are satisfactoryBNYM’s AML controls and control objectives; and and (ziii) a summary of the AML training provided for appropriate DTI personnelpursuant to clause (iv) of subsection (A) above. (C) Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund compliance with Section 352 of the USA PATRIOT Act and does not relate to any other obligation the Funds Fund may have under the USA PATRIOT Act, including without limitation Section 326 thereof.

Anti-Money Laundering. (A) DTI shall provide for To the establishmentextent the other provisions of this Agreement require the Distributor to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Fund consistent with securities laws, the Distributor shall perform all reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of United States federal AML laws applicable to investor activity, including the USA Bank Secrecy Act and the PATRIOT Act, as follows: described hereinafter. In this regard, the Distributor shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("AML") the Distributor’s AML program or by an outside party, for compliance with DTI's written AML the Distributor’s established policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's the Distributor’s AML program; and and (ivd) DTI shall provide ongoing training of DTI the Distributor’s personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a the Fund, DTI the Distributor shall provide to the Fund: ’s officer in charge of AML compliance (the “AML Compliance Officer”): (x) a copy of DTI's the Distributor’s written AML policies and procedures; procedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement): (y) at the option of DTI, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) Without limiting or expanding subsections (A) or (B) above. Unless otherwise preformed by the Fund’s transfer agent, the parties agree this Section 3(b)(1Distributor shall also: (i) relates solely to Fund collect and maintain investor information, verify the identity of investors and check investor identities against all government lists of known or suspected terrorists and terrorist organizations in compliance with Section 352 the procedures set forth in the Fund’s AML program and the PATRIOT Act; (ii) provide notice of the USA Fund’s customer identification procedures to prospective investors in the manner permitted by the PATRIOT Act before an account is opened; (iii) maintain records of the information collected and does not relate methods used to any other obligation verify investor identity in compliance with the Funds may have under the USA PATRIOT Act; (iv) monitor investor accounts for suspicious activity to the extent required by AML laws or the PATRIOT Act; and (v) make any required regulatory filings on behalf of the Fund including, including without limitation Section 326 thereofbut not limited to, Form 8300 and suspicious activity reports (to the extent required by AML laws) and promptly provide a copy of all such reports filed to the Fund’s AML Compliance Officer. To the extent that a Fund regulator wishes to examine the Distributor regarding its services hereunder, the Distributor shall cooperate with and permit examinations of its records and personnel by such regulator, coordinating any such response with the Fund’s AML Compliance Officer. The Distributor also agrees to make available to examiners from such regulatory agencies any information and records relating to the Fund’s AML program as such examiners shall reasonably request.

Anti-Money Laundering. As of the Effective Date, the Agreement is amended by adding the following new provision: “Anti-Money Laundering. [BNY Mellon] has implemented various anti-money laundering (A“AML”) DTI shall provide for procedures as described below, which it has found to be reasonable, and the establishmentFund desires to delegate certain AML procedures to [BNY Mellon], maintenance as permitted by the USA PATRIOT Act (the “PATRIOT Act”) and monitoring the regulations promulgated hereunder. Consequently, the Fund and [BNY Mellon] desire to amend the Agreement to reflect such services explicitly as follows: To the extent the other provisions of this Agreement require [BNY Mellon] to establish, maintain and monitor accounts of investors in the Funds and Fund consistent with securities laws, [BNY Mellon] shall perform all reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of United States Federal AML laws applicable to investor activity, including the USA Bank Secrecy Act and the PATRIOT Act, Act as follows: : In this regard, [BNY Mellon] shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or finance terrorist activities and to achieve compliance with the financing of terrorist activities, including, without limiting the generality applicable provisions of the foregoing, Bank Secrecy Act and the implementing regulations thereunder; (b) undertake to revise such AML procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account as necessary or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. appropriate; (iic) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("AML") [BNY Mellon]’s AML program or by an outside party, for compliance with DTI's written AML [BNY Mellon]’s established policies and procedures; ; (iiid) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's [BNY Mellon]’s AML program; and and (ive) DTI shall provide ongoing training of DTI [BNY Mellon] personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a the Fund, DTI [BNY Mellon] shall provide to the Fund’s AML Compliance Officer: (x) a copy of DTI's [BNY Mellon]’s written AML policies and procedures; procedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement): (y) at the option of DTI, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, compliance (or a summary thereof, at [BNY Mellon]’s option), or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) Without limiting or expanding subsections (A) or (B) above. In addition, [BNY Mellon] shall provide the parties agree this Section 3(b)(1) relates solely Fund with information necessary for the Fund to Fund compliance with Section 352 of the USA PATRIOT Act prepare and does not relate to file Form 8300 and any other obligation the Funds may have suspicious activity reports, required under the USA PATRIOT ActAML laws, including without limitation Section 326 thereofin connection with suspicious activity [BNY Mellon] detects. [BNY Mellon] agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request.”

Anti-Money Laundering. (Aa) DTI shall provide for To the establishmentextent the other provisions of this Agreement require PNC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Fund consistent with securities laws, PNC shall perform reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : PNC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's PNC’s anti-money laundering ("“AML"”) program or by an outside party, for compliance with DTI's written PNC’s established AML policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's PNC’s AML program; and and (ivd) DTI shall provide ongoing training of DTI PNC personnel relating to the prevention of money-laundering activities. (Bb) Upon the reasonable request of a the Fund, DTI PNC shall provide to the Fund: (x) a copy of DTI's PNC’s written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement); (y) at the option of DTIPNC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI PNC personnel. PNC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. (Cc) Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree the provisions in this Section 3(b)(1) relates solely 14 relate only to Fund compliance with Section 352 of the USA PATRIOT Act and does do not relate to any apply other obligation the Funds may have under sections, including Section 326, of the USA PATRIOT Act, including without limitation Section 326 thereofAct or regulations promulgated thereunder.

Anti-Money Laundering. The Trust acknowledges that it is a financial institution subject to all applicable anti-money laundering laws, regulations, rules and government guidance and the Bank Secrecy Act (A) DTI shall provide for the establishment“BSA”), maintenance and monitoring of accounts of investors in the Funds and perform reasonable actions necessary to assist the Funds in complying with Section 352 of as amended by the USA PATRIOT ActAct of 2001, together with its implementing regulations, and related governmental and self-regulatory organization rules and regulations (collectively, the “Anti-Money Laundering Laws”). The Trust shall comply with the Anti-Money Laundering Laws in all relevant respects, subject to the delegation of certain responsibilities to TFS, as follows: provided in the paragraphs below. With respect to the services provided to the Trust under the Agreement, TFS agrees to perform certain duties in connection with the Anti-Money Laundering Program. TFS shall (i) DTI shall establish screen new business and implement written policiesexisting client databases against government sanction lists, procedures declining transactions and internal controls reasonably designed blocking assets and reporting any blocked assets in accordance with the Foreign Asset Control Regulations, (ii) maintain all records or other documentation related to help prevent Shareholder accounts and transactions therein that are required to be prepared and maintained pursuant to the Funds Anti-Money Laundering Program, and (iii) identify and report suspicious activities that are required to be so identified and reported pursuant to the Anti-Money Laundering Program. It is contemplated that the Anti-Money Laundering Program will be amended from being used for time to time, as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering responsibilities. The Trust agrees that no amendments will be made to the Anti-Money Laundering Program, which might have the effect of changing the procedures employed by TFS in providing the services agreed to hereunder, unless the Trust first obtains TFS’s approval of such amendments or the financing of terrorist activitieschanges, including, without limiting the generality which approval shall not be withheld unreasonably. In furtherance of the foregoing, the Trust hereby delegates to TFS the performance, on behalf of the Trust, of the Anti-Money Laundering Program set forth above as concerns the Shareholder accounts maintained by TFS pursuant to this Agreement. TFS agrees to the foregoing delegation and agrees to perform such services in accordance with the Anti-Money Laundering Program. In connection therewith, TFS agrees to maintain policies and procedures, and related internal controls, that are consistent with the Anti-Money Laundering Program and the requirement that the Trust employ procedures for the ongoing surveillance of shareholder accounts, reasonably designed to achieve compliance with the applicable Anti-Money Laundering Laws, including the requirements to have policies and procedures that can be reasonably expected to detect money laundering activity, that take into account and cause the money laundering risk level for an account or group reporting of accounts, e.g., foreign vs. domestic accounts or public vs. private companiestransactions under Section 5318 of the BSA. The procedures for the ongoing surveillance of shareholder accounts TFS’s obligations under this delegation shall be set forth in subject to the DTI Procedures. (ii) DTI shall provide requirement above that any material amendments to the Anti-Money Laundering Program be submitted to TFS for independent testingits review and consent. In connection with the foregoing delegation, by an employee who is not responsible for the operation Trust also acknowledges that the performance of DTI's the anti-money laundering ("AML") program or by an outside party, for compliance with DTI's written AML policies and procedures; (iii) DTI shall designate a person or persons responsible for implementing and monitoring services enumerated herein involves the operation and internal controls exercise of DTI's AML program; and (iv) DTI shall provide ongoing training of DTI personnel relating discretion which in some circumstances may result in consequences to the prevention of money-laundering activities. Trust and its Shareholders (B) Upon such as in the reasonable request of a Fund, DTI shall provide to the Fund: (x) a copy of DTI's written AML policies and procedures; (y) at the option of DTI, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings case of the independent party are satisfactory; reporting of suspicious activities and the freezing of Shareholder accounts). In this regard, (i) TFS is granted the discretion to take any such action as may be authorized under the Anti-Money Laundering Program, and consultation with the Trust shall not be required in connection therewith unless specifically required under the Anti-Money Laundering Program, and (zii) the Trust instructs TFS that it may avail the Trust of any safe harbor from civil liability that may be available under applicable Anti-Money Laundering Laws for making a summary of the AML training provided for appropriate DTI personneldisclosure or filing a report thereunder. (C) Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund compliance with Section 352 of the USA PATRIOT Act and does not relate to any other obligation the Funds may have under the USA PATRIOT Act, including without limitation Section 326 thereof.

Anti-Money Laundering. (A) DTI As of the Effective Date, the Agreement is amended by adding the following new provision: "Anti-Money Laundering. PFPC shall provide for the establishmentservices described in Section 15 of the Agreement consistent with the Securities Laws, maintenance and monitoring of accounts of investors in the Funds and perform reasonable actions necessary to assist the Funds in complying compliance with Section 352 of the USA PATRIOT Act, as follows: follows (ispecifically, PFPC undertakes to perform the services described in the attached ANTI-MONEY LAUNDERING SERVICES PROGRAM SUMMARY as stated therein): In this regard, PFPC shall: (a) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIPFPC's anti-money laundering ("AML") AML program or by an outside party, for compliance with DTIPFPC's written AML established policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIPFPC's AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a the Fund, DTI PFPC shall promptly provide to the Fund: (x) a copy of DTIPFPC's written AML policies and proceduresprocedures (a copy of which is attached hereto) (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this agreement); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, compliance (or a summary thereof, ) or a certification that the findings of the independent party are satisfactorysatisfactory (PFPC will also provide a copy of such a summary or certification upon the reasonable request of the Fund); and (z) a summary of the AML training provided for appropriate DTI personnel. PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. Upon the publication of additional final anti-money laundering regulations, PFPC will work with the Fund to offer, on reasonable terms, for the Fund's benefit services to help the Fund satisfy its obligations under such regulations. (C) Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund compliance with Section 352 of the USA PATRIOT Act and does not relate to any other obligation the Funds may have under the USA PATRIOT Act, including without limitation Section 326 thereof."

Anti-Money Laundering. (Aa) DTI shall provide for Each Trust acknowledges that it has had an opportunity to review, consider and comment upon the establishment, maintenance and monitoring of accounts of investors in the Funds and perform reasonable actions necessary to assist the Funds in complying with Section 352 of the USA PATRIOT Act, as follows: (i) DTI shall establish and implement written internal policies, procedures and internal controls provided by PFPC describing various tools designed to promote the detection and reporting of potential money laundering activity by monitoring shareholder activity, including the written procedures described in Section 17 below for verifying a customer’s identity (collectively, the “AML program”). Each Trust has determined that the AML program, as part of the Trust’s overall anti-money laundering program, is reasonably designed to help prevent the Funds from being used for money laundering or the financing of terrorist activities, including, without limiting activities and to achieve compliance with the generality applicable provision of the foregoingBank Secrecy Act and the implementing regulations thereunder. Based on this determination, procedures for each Trust hereby instructs and directs PFPC to implement the ongoing surveillance AML program on the Trust’s behalf, as such may be amended from time to time. PFPC shall perform reasonable actions necessary to help the Funds be in compliance with Section 352 of shareholder accountsthe USA PATRIOT Act. In this regard, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts PFPC shall be set forth in the DTI Procedures. (iii) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("AML") PFPC’s AML program or by an outside party, for compliance with DTI's written PFPC’s AML policies and procedures; Program; (iiiii) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's PFPC’s AML program; and and (iviii) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. PFPC shall provide to the Trusts a copy of PFPC’s written AML policies and procedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement). (Bb) Upon the reasonable request of a FundTrust, DTI PFPC shall provide to the Fund: (xi) a copy of DTI's written AML policies and procedures; (y) at the option of DTI, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (zii) a summary of the AML training provided for appropriate DTI personnel. PFPC also agrees to provide (i) prompt written notification of any transactions or combination of transactions that PFPC believes, based on its AML program, evidence money laundering activity in connection with a Fund or any shareholder of a Fund and (ii) prompt written notification of any customer(s) that PFPC reasonably believes, based upon its AML program, to be engaged in money laundering activity, provided that the Fund agrees not to communicate this information to the customer. PFPC shall provide such other reports on the monitoring and customer identification activities concluded at the direction of the Trusts as may be agreed to from time to time by PFPC and the Trusts. (Cc) Without limiting PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or expanding subsections (A) regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or (B) aboveregulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. Further, the parties agree Funds and Authorized Persons shall have reasonable access during normal business hours to information and records relating to anti-money laundering activities of PFPC performed pursuant to this Section 3(b)(1) relates solely to Fund compliance with Section 352 of the USA PATRIOT Act and does not relate to any other obligation the Funds may have under the USA PATRIOT Act, including without limitation Section 326 thereofAgreement.

Anti-Money Laundering. The Trust acknowledges that it is a financial institution subject to all applicable anti-money laundering laws, regulations, rules and government guidance and the Bank Secrecy Act (A) DTI shall provide for the establishment“BSA”), maintenance and monitoring of accounts of investors in the Funds and perform reasonable actions necessary to assist the Funds in complying with Section 352 of as amended by the USA PATRIOT ActAct of 2001, together with its implementing regulations, and related governmental and self-regulatory organization rules and regulations (collectively, the “Anti-Money Laundering Laws”). The Trust shall comply with the Anti-Money Laundering Laws in all relevant respects, subject to the delegation of certain responsibilities to TFS, as follows: provided in the paragraphs below. With respect to the services provided to the Trust under the Agreement, TFS agrees to perform certain duties in connection with the Anti-Money Laundering Program. TFS shall (i) DTI shall establish screen new business and implement written policiesexisting client databases against government sanction lists, procedures declining transactions and internal controls reasonably designed blocking assets and reporting any blocked assets in accordance with the Foreign Asset Control Regulations, (ii) maintain all records or other documentation related to help prevent Shareholder accounts and transactions therein that are required to be prepared and maintained pursuant to the Funds Anti-Money Laundering Program and (iii) identify and report suspicious activities that are required to be so identified and reported pursuant to the Anti-Money Laundering Program. It is contemplated that the Anti-Money Laundering Program will be amended from being used for time to time, as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering responsibilities. The Trust agrees that no amendments will be made to the Anti-Money Laundering Program, which might have the effect of changing the procedures employed by TFS in providing the services agreed to hereunder, unless the Trust first obtains TFS’s approval of such amendments or the financing of terrorist activitieschanges, including, without limiting the generality which approval shall not be withheld unreasonably. In furtherance of the foregoing, the Trust hereby delegates to TFS the performance, on behalf of the Trust, of the Anti-Money Laundering Program set forth above as concerns the Shareholder accounts maintained by TFS pursuant to this Agreement. TFS agrees to the foregoing delegation and agrees to perform such services in accordance with the Anti-Money Laundering Program. In connection therewith, TFS agrees to maintain policies and procedures, and related internal controls, that are consistent with the Anti-Money Laundering Program and the requirement that the Trust employ procedures for the ongoing surveillance of shareholder accounts, reasonably designed to achieve compliance with the applicable Anti-Money Laundering Laws, including the requirements to have policies and procedures that can be reasonably expected to detect money laundering activity, that take into account and cause the money laundering risk level for an account or group reporting of accounts, e.g., foreign vs. domestic accounts or public vs. private companiestransactions under Section 5318 of the BSA. The procedures for the ongoing surveillance of shareholder accounts TFS’s obligations under this delegation shall be set forth in subject to the DTI Procedures. (ii) DTI shall provide requirement above that any material amendments to the Anti-Money Laundering Program be submitted to TFS for independent testingits review and consent. In connection with the foregoing delegation, by an employee who is not responsible for the operation Trust also acknowledges that the performance of DTI's the anti-money laundering ("AML") program or by an outside party, for compliance with DTI's written AML policies and procedures; (iii) DTI shall designate a person or persons responsible for implementing and monitoring services enumerated herein involves the operation and internal controls exercise of DTI's AML program; and (iv) DTI shall provide ongoing training of DTI personnel relating discretion which in some circumstances may result in consequences to the prevention of money-laundering activities. Trust and its Shareholders (B) Upon such as in the reasonable request of a Fund, DTI shall provide to the Fund: (x) a copy of DTI's written AML policies and procedures; (y) at the option of DTI, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings case of the independent party are satisfactory; reporting of suspicious activities and the freezing of Shareholder accounts). In this regard, (i) TFS is granted the discretion to take any such action as may be authorized under the Anti-Money Laundering Program, and consultation with the Trust shall not be required in connection therewith unless specifically required under the Anti-Money Laundering Program, and (zii) the Trust instructs TFS that it may avail the Trust of any safe harbor from civil liability that may be available under applicable Anti-Money Laundering Laws for making a summary of the AML training provided for appropriate DTI personneldisclosure or filing a report thereunder. (C) Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund compliance with Section 352 of the USA PATRIOT Act and does not relate to any other obligation the Funds may have under the USA PATRIOT Act, including without limitation Section 326 thereof.

Anti-Money Laundering. (A) DTI shall provide for In addition, to the establishmentservices listed in Section 14, maintenance to the extent the other provisions of this Agreement require PFPC to establish, maintain and monitoring of monitor accounts of investors in the Funds and Fund consistent with securities laws, PFPC shall perform reasonable actions necessary to assist help the Funds Trust be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Trust from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("AML") PFPC’s AML program or by an outside party, for compliance with DTI's written AML PFPC’s established policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's PFPC’s AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a Fundthe Trust, DTI PFPC shall provide to the FundTrust: (x) a copy of DTI's PFPC’s written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) . PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree this the provisions herein do not apply to Section 3(b)(1) relates solely to Fund compliance with Section 352 326 of the USA PATRIOT Act and does not relate to any (or other obligation the Funds may have under the USA PATRIOT Act, including without limitation sections other than Section 326 thereof352) or regulations promulgated thereunder.

Anti-Money Laundering. (A) DTI shall provide for To the establishmentextent the other provisions of this Agreement require CERES to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Fund consistent with the Securities Laws, CERES shall perform reasonable actions necessary to assist the Funds Fund in complying with Section 352 of the USA PATRIOT Act, as follows: : CERES shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("AML") CERES’s AML program or by an outside party, for compliance with DTI's CERES written AML policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's CERES AML program; and and (ivd) DTI shall provide ongoing training of DTI CERES personnel relating to the prevention of money-laundering activities. (B) Upon the reasonable request of a the Fund, DTI CERES shall provide to the Fund: (x) a copy of DTI's CERES’s written AML policies and procedures; (y) at the option of DTICERES, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI CERES personnel. (C) Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund compliance with Section 352 of the USA PATRIOT Act and does not relate to any other obligation the Funds Fund may have under the USA PATRIOT Act, including without limitation Section 326 thereof. (D) CERES will provide the Fund and the Company full access to all AML/CIP/FinCen testing results. (E) CERES will engage an independent accounting firm to complete a bi-annual AML audit and annual SOC 1 audit of the effectiveness of its policies and procedures.

Anti-Money Laundering. (A) DTI shall provide for In addition, to the establishmentservices listed in Section 14, maintenance to the extent the other provisions of this Agreement require PFPC to establish, maintain and monitoring of monitor accounts of investors in the Funds and Fund consistent with securities laws, PFPC shall perform reasonable actions necessary to assist help the Funds Trust be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Trust from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIPFPC's anti-money laundering ("AML") AML program or by an outside party, for compliance with DTIPFPC's written AML established policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIPFPC's AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a Fundthe Trust, DTI PFPC shall provide to the FundTrust: (x) a copy of DTIPFPC's written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) . PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree this the provisions herein do not apply to Section 3(b)(1) relates solely to Fund compliance with Section 352 326 of the USA PATRIOT Act and does not relate to any (or other obligation the Funds may have under the USA PATRIOT Act, including without limitation sections other than Section 326 thereof352) or regulations promulgated thereunder.

Anti-Money Laundering. The Underwriter agrees to comply with all applicable anti-money laundering laws, regulations, rules and government guidance, including the reporting, recordkeeping and compliance requirements of the Bank Secrecy Act (A) DTI shall provide for the establishment"BSA"), maintenance as amended by The International Money Laundering Abatement and monitoring Anti-Terrorism Financing Act of accounts of investors in the Funds and perform reasonable actions necessary to assist the Funds in complying with Section 352 2001, Title III of the USA PATRIOT ACT ("the Act"), its implementing regulations, and related Securities and Exchange Commission and Self-Regulatory Organization rules. These include requirements to identify and report currency transactions and suspicious activity, to verify customer identity, to conduct customer due diligence, and to implement anti-money laundering compliance programs. As required by the Act, as follows: (i) DTI shall establish and implement written the Underwriter certifies that it has a comprehensive anti-money laundering compliance program that includes policies, procedures and internal controls reasonably designed for complying with the BSA; policies, procedures and internal controls for identifying, evaluating and reporting suspicious activity; a designated compliance officer or officers; training for appropriate employees; and an independent audit function. Further, the Underwriter agrees to help prevent comply with the Funds from being used economic sanctions programs administered by the U.S. Treasury Department's Office of Foreign Assets Control ("OFAC"). The Underwriter certifies that it has an OFAC compliance program in place which includes procedures for money laundering checking customer names and persons with signature authority over accounts against the OFAC lists of sanctioned governments and specially-designated nationals, terrorists and traffickers; the screening of wire transfers and other payments against the OFAC lists; a designated compliance officer; an internal communication network; training of appropriate personnel; and an independent audit function. The Underwriter agrees to promptly notify the Fund whenever questionable activity or the financing potential indications of terrorist activities, including, without limiting the generality suspicious activity or OFAC matches are detected. The Underwriter agrees to investigate any potentially suspicious activity in connection with transactions in shares of the foregoingFund and to take appropriate action, procedures for including the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group blocking of accounts, e.g., foreign vs. domestic accounts or public vs. private companiesthe filing of Suspicious Activity Reports and reporting matches to OFAC. The procedures for Underwriter agrees that any order to purchase Fund shares through the ongoing surveillance of shareholder accounts Underwriter shall be set forth in the DTI Procedures. (ii) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("AML") program or by an outside party, for compliance with DTI's written AML policies and procedures; (iii) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's AML program; and (iv) DTI shall provide ongoing training of DTI personnel relating to the prevention of money-laundering activities. (B) Upon the reasonable request of a Fund, DTI shall provide to the Fund: (x) a copy of DTI's written AML policies and procedures; (y) at the option of DTI, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a constitute its continued certification that the findings of the independent party are satisfactory; matters it has certified above. The Underwriter further agrees to require similar certifications from broker-dealers which enter into Dealer Sales Agreements with the Underwriter in connection with the sale and (z) a summary distribution of the AML training provided for appropriate DTI personnelFund shares. (C) Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund compliance with Section 352 of the USA PATRIOT Act and does not relate to any other obligation the Funds may have under the USA PATRIOT Act, including without limitation Section 326 thereof.

Anti-Money Laundering. (A) DTI shall provide for To the establishmentextent the other provisions of the Agreement require Transfer Agent to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds Fund, the Fund hereby delegates to Transfer Agent the responsibility for the implementation and operation of the Fund AML Policy and Transfer Agent accepts such delegation and shall perform all reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of United States federal AML laws applicable to investor activity, including the USA Bank Secrecy Act and the PATRIOT Act, as follows: described hereinafter. In this regard, Transfer Agent shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("AML") Transfer Agent’s AML program or by an outside party, for compliance with DTI's written AML Transfer Agent’s established policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's Transfer Agent’s AML program; and and (ivd) DTI shall provide ongoing training of DTI Transfer Agent personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a the Fund, DTI Transfer Agent shall provide to the Fund: ’s AML Compliance Officer (the “Fund CO”): (x) a copy of DTI's Transfer Agent’s written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement); (y) at a report or make a presentation to the option of DTIFund CO periodically summarizing the Transfer Agent’s compliance with the Fund AML Policy as well as its own AML program, a copy of a written assessment or report prepared by any reports filed during the party performing year and any compliance problems encountered during the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactoryyear; and (z) a summary of the AML training provided for appropriate DTI personnel. . Transfer Agent shall also: (Ci) Without limiting collect and maintain investor information, verify the identity of investors and check investor identities against all government lists of known or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund suspected terrorists and terrorist organizations in compliance with Section 352 the procedures set forth in the Fund AML Policy and the PATRIOT Act; (ii) provide notice of the USA Fund’s customer identification procedures to prospective investors in the manner permitted by the PATRIOT Act before an account is opened; (iii) maintain records of the information collected and does not relate methods used to any other obligation verify investor identity in compliance with the Funds may have under the USA PATRIOT Act; (iv) monitor investor accounts for suspicious activity to the extent required by AML laws or the PATRIOT Act; and (v) make any required regulatory filings on behalf of the Fund including, including without limitation Section 326 thereofbut not limited to, Form 8300s and suspicious activity reports (to the extent required by AML laws) and promptly provide a copy of all such reports filed to the Fund CO. To the extent that a Fund regulator wishes to examine Transfer Agent regarding its services hereunder, Transfer Agent shall cooperate with and permit examinations of its records and personnel by such regulator, coordinating any such response with the Fund CO. Transfer Agent also agrees to make available to examiners from such regulatory agencies any information and records relating to the Fund AML Policy. The Transfer Agent also agrees to promptly notify the Fund if circumstances change which would prevent it from performing the functions described in this Amendment.

Anti-Money Laundering. (A) DTI shall provide for the establishment, maintenance and monitoring of accounts of investors in the Funds and BNYM will perform reasonable actions necessary reasonably designed to assist the Funds Fund in complying with Section 352 of the USA PATRIOT Act, as amended, as follows: : BNYM will: (i) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for money laundering or the financing of terrorist activities, including, without limiting the generality activities and to achieve compliance with applicable provisions of the foregoingBank Secrecy Act (31 U.S.C. 5311, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedureset seq. ) (“Bank Secrecy Act”) and implementing regulations thereunder; (ii) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's BNYM’s anti-money laundering ("“AML"”) program or by an a qualified outside party, for compliance with DTI's BNYM’s written AML policies and procedures; ; (iii) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's BNYM’s AML program; and (iv) DTI shall provide ongoing training for appropriate persons, and (v) implement appropriate risk- based procedures for conducting ongoing shareholder due diligence to include but not be limited to (aa) understanding the nature and purpose of DTI personnel relating shareholder relationships for the purposes of developing a shareholder risk profile, and (bb) conducting ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update shareholder information, including information regarding the prevention beneficial owners of money-laundering activitieslegal entity shareholders. (B) Upon the reasonable request of a Fund, DTI shall BNYM will provide to the Fund: : (xi) a copy of DTI's BNYM’s written AML policies and procedures; , or, alternatively, access to such policies and procedures at a BNYM website; (yii) at the option of DTI, a copy of a written assessment or the report prepared by the party performing independent accountants covering the independent testing for compliance, or a summary thereof, or a certification that the findings accountants’ examination of the independent party are satisfactoryBNYM’s AML controls and control objectives; and and (ziii) a summary of the AML training provided for appropriate DTI personnelpursuant to clause (iv) of subsection (A) above. (C) Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund compliance with Section 352 of the USA PATRIOT Act and does not relate to any other obligation the Funds Fund may have under the USA PATRIOT Act, including without limitation Section 326 thereof.

Anti-Money Laundering. (A) DTI shall provide for To the establishmentextent the other provisions of this Agreement require PFPC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Fund consistent with securities laws, PFPC shall perform reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : In this regard, PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("AML") PFPC’s AML program or by an outside party, for compliance with DTI's written AML PFPC’s established policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's PFPC’s AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a the Fund, DTI PFPC shall provide to the Fund: (x) a copy of DTI's PFPC’s written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) . PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree this the provisions herein do not apply to Section 3(b)(1) relates solely to Fund compliance with Section 352 326 of the USA PATRIOT Act and does not relate to any (or other obligation the Funds may have under the USA PATRIOT Act, including without limitation sections other than Section 326 thereof352) or regulations promulgated thereunder.

Anti-Money Laundering. (A) DTI shall provide for the establishment, maintenance and monitoring of accounts of investors in the Funds and BNYM will perform reasonable actions necessary reasonably designed to assist the Funds Fund in complying with Section 352 of the USA PATRIOT Act, as amended, as follows: : BNYM will: (i) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for money laundering or the financing of terrorist activities, including, without limiting the generality activities and to achieve compliance with applicable provisions of the foregoingBank Secrecy Act (31 U.S.C. 5311, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedureset seq. ) ("Bank Secrecy Act") and implementing regulations thereunder; (ii) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIBNYM's anti-money laundering ("AML") program or by an a qualified outside party, for compliance with DTIBNYM's written AML policies and procedures; ; (iii) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIBNYM's AML program; and (iv) DTI shall provide ongoing training for appropriate persons, and (v) implement appropriate risk-based procedures for conducting ongoing shareholder due diligence to include but not be limited to (aa) understanding the nature and purpose of DTI personnel relating shareholder relationships for the purposes of developing a shareholder risk profile, and (bb) conducting ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update shareholder information, including information regarding the prevention beneficial owners of money-laundering activitieslegal entity shareholders. (B) Upon the reasonable request of a Fund, DTI shall BNYM will provide to the Fund: : (xi) a copy of DTIBNYM's written AML policies and procedures; , or, alternatively, access to such policies and procedures at a BNYM website; (yii) at the option of DTI, a copy of a written assessment or the report prepared by the party performing independent accountants covering the independent testing for compliance, or a summary thereof, or a certification that the findings accountants' examination of the independent party are satisfactoryBNYM's AML controls and control objectives; and and (ziii) a summary of the AML training provided for appropriate DTI personnelpursuant to clause (iv) of subsection (A) above. (C) BNYM agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1(1) relates solely to Fund compliance with Section 352 of the USA PATRIOT Act and does not relate to any other obligation the Funds Fund may have under the USA PATRIOT Act, including without limitation Section 326 thereof.

Anti-Money Laundering. (A) DTI shall provide for To the establishmentextent the other provisions of the Agreement require Distributor to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds Fund, the Fund hereby delegates to Distributor the responsibility for the implementation and operation of the Fund AML Policy and Distributor accepts such delegation and shall perform all reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of United States federal AML laws applicable to investor activity, including the USA Bank Secrecy Act and the PATRIOT Act, as follows: described hereinafter. In this regard, Distributor shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("AML") Distributor’s AML program or by an outside party, for compliance with DTI's written AML Distributor’s established policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's Distributor’s AML program; and and (ivd) DTI shall provide ongoing training of DTI Distributor personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a the Fund, DTI Distributor shall provide to the Fund: ’s AML Compliance Officer (the “Fund CO”): (x) a copy of DTI's Distributor’s written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement); (y) at a report or make a presentation to the option of DTIFund CO periodically summarizing the Distributor’s compliance with the Fund AML Policy as well as its own AML program, a copy of a written assessment or report prepared by any reports filed during the party performing year and any compliance problems encountered during the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactoryyear; and (z) a summary of the AML training provided for appropriate DTI personnel. . Unless otherwise performed by the Fund’s transfer agent, Distributor shall also: (Ci) Without limiting collect and maintain investor information, verify the identity of investors and check investor identities against all government lists of known or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund suspected terrorists and terrorist organizations in compliance with Section 352 the procedures set forth in the Fund AML Policy and the PATRIOT Act; (ii) provide notice of the USA Fund’s customer identification procedures to prospective investors in the manner permitted by the PATRIOT Act before an account is opened; (iii) maintain records of the information collected and does not relate methods used to any other obligation verify investor identity in compliance with the Funds may have under the USA PATRIOT Act; (iv) monitor investor accounts for suspicious activity to the extent required by AML laws or the PATRIOT Act; and (v) make any required regulatory filings on behalf of the Fund including, including without limitation Section 326 thereofbut not limited to, Form 8300s and suspicious activity reports (to the extent required by AML laws) and promptly provide a copy of all such reports filed to the Fund CO. To the extent that a Fund regulator wishes to examine Distributor regarding its services hereunder, Distributor shall cooperate with and permit examinations of its records and personnel by such regulator, coordinating any such response with the Fund CO. Distributor also agrees to make available to examiners from such regulatory agencies any information and records relating to the Fund AML Policy. The Distributor also agrees to promptly notify the Fund if circumstances change which would prevent it from performing the functions described in this Amendment.

Anti-Money Laundering. (A) DTI shall provide for To the establishmentextent the other provisions of this Agreement require PFPC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and a Fund consistent with Securities Laws, PFPC shall perform reasonable actions necessary to assist the Funds help each Fund be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : In this regard, PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds a Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIPFPC's antiAnti-money laundering Money Laundering ("AML") program or by an outside party, for compliance with DTIPFPC's written AML established policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIPFPC's AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a Fund, DTI PFPC shall provide to the such Fund: (x) a copy of DTIPFPC's written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) . PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree this the provisions herein do not apply to Section 3(b)(1) relates solely to Fund compliance with Section 352 326 of the USA PATRIOT Act and does not relate to any (or other obligation the Funds may have under the USA PATRIOT Act, including without limitation sections other than Section 326 thereof352) or regulations promulgated thereunder.

Anti-Money Laundering. A. The Administrator acknowledges that the Trust is a financial institution subject to the law entitled United and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (A“USA PATRIOT”) DTI Act of 2001 and the Bank Secrecy Act (collectively, the “AML Acts”) and shall provide for comply with the establishmentAML Acts and applicable regulations adopted thereunder (collectively, maintenance and monitoring the “Applicable AML Laws”) in all relevant respects, subject to the delegation of accounts of investors certain responsibilities to JPMorgan as provided in the Funds next sub-paragraph below. B. The Administrator and perform reasonable actions necessary the Trust hereby delegate to assist JPMorgan the Funds in complying with Section 352 performance, on behalf of the USA PATRIOT ActTrust, as follows: (i) DTI shall establish and implement written policies, procedures and internal controls reasonably designed to help prevent of the Funds from being used for anti-money laundering or the financing of terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be services set forth in the DTI ProceduresAnti-Money Laundering Program Service Addendum (the “AML Services”) with respect to the shareholder accounts maintained by JPMorgan pursuant to this Agreement. JPMorgan agrees to the foregoing delegation and agrees to perform such services in accordance with the Trust’s AML Program. In connection therewith, JPMorgan agrees to maintain policies and procedures, and related internal controls, that are consistent with the Trust’s AML Program and the requirement that the Trust employ procedures reasonably designed to achieve compliance with the Applicable AML Laws, 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. JPMorgan’s obligations under this delegation shall be subject to Paragraphs 2.L. and 2.M., which require that the AML Program and any material amendments thereto be submitted to JPMorgan for its review and consent. C. The Trust agrees and acknowledges that, notwithstanding the delegation provided for in the foregoing paragraph, the 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 Trust’s particular business, taking into account factors such as its size, location, activities and risks or vulnerabilities to money laundering. D. In connection with the foregoing delegation, the Trust also acknowledges that the performance of the AML Services involves the exercise of discretion which in some circumstances may result in consequences to the 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, JPMorgan is granted the discretion to take any such action as may be authorized under the AML Program, and consultation with the Trust shall not be required in connection therewith unless specifically required under the AML Program, and (ii) DTI shall provide the Trust instructs JPMorgan that it may avail the Trust of any safe harbor from civil liability that may be available under Applicable AML Laws for independent testingmaking a disclosure or filing a report thereunder. E. As concerns Networking Level III accounts and omnibus accounts, the AML Services performed by an employee who is not responsible for JPMorgan are subject to a more limited scope, as contemplated under the operation release concerning the interim final rule of DTI's antithe Department of the Treasury, 31 CFR 103, effective April 24, 2002 (the “Interim Final Rule”) and the performance by the Trust of the risk-money laundering ("AML") program or by an outside partybased evaluation of entities holding such accounts, for compliance with DTI's written AML policies and procedures; (iii) DTI shall designate a person or persons responsible for implementing and monitoring as contemplated under the operation and internal controls of DTI's AML program; and (iv) DTI shall provide ongoing training of DTI personnel relating release pertaining to the prevention of money-laundering activities. (B) Upon the reasonable request of a Fund, DTI shall provide Interim Final Rule. The foregoing reference to the Fund: (x) a copy of DTI's written AML policies Interim Final Rule shall be deemed to include laws and procedures; (y) at regulations adopted subsequent to the option of DTIInterim Final Rule, a copy of a written assessment or report prepared by if and to the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnelextent consistent therewith. (C) Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund compliance with Section 352 of the USA PATRIOT Act and does not relate to any other obligation the Funds may have under the USA PATRIOT Act, including without limitation Section 326 thereof.

Anti-Money Laundering. (A) DTI shall provide for To the establishmentextent the other provisions of this Agreement require PFPC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Fund consistent with securities laws, PFPC shall perform reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: In this regard, PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("AML") PFPC’s AML program or by an outside party, for compliance with DTI's written AML PFPC’s established policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's PFPC’s AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a the Fund, DTI PFPC shall provide to the Fund: (x) a copy of DTI's PFPC’s written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) . PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree this the provisions herein do not apply to Section 3(b)(1) relates solely to Fund compliance with Section 352 326 of the USA PATRIOT Act and does not relate to any (or other obligation the Funds may have under the USA PATRIOT Act, including without limitation sections other than Section 326 thereof352) or regulations promulgated thereunder.

Anti-Money Laundering. (A) DTI As of the Effective Date, the Agreement is amended by adding the following new provision: "Anti-Money Laundering. PFPC shall provide for perform the establishment, maintenance and monitoring of accounts of investors in the Funds and perform reasonable following actions necessary to assist ensure that the Funds Fund is in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or finance terrorist activities and to ensure the financing of terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. Fund's compliance with Section 352; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIPFPC's anti-money laundering ("AML") AML program or by an a qualified outside party, for compliance with DTIPFPC's written AML established policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIPFPC's AML program; and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. ; and (Be) unless restricted by law, notify the Fund (specifically, endeavor to notify the Fund's designee as specified by the Fund to the PFPC Relationship Manager assigned to with which the Fund interacts) promptly whenever PFPC determines activity of a shareholder within the Fund to be suspicious and reportable, consistent with PFPC's established criteria (as attached hereto subject to being revised from time to time)(without limitation, this includes when shareholder names match names on OFAC lists and such matches are confirmed). Upon the reasonable request of a the Fund, DTI PFPC shall provide to the Fund: (x) a copy of DTIPFPC's written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this agreement); (y) at to the option of DTIextent permitted by PFPC's parent company, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) . PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree this the provisions herein do not apply to Section 3(b)(1) relates solely to Fund compliance with Section 352 326 of the USA PATRIOT Act and does not relate to any (or other obligation the Funds may have under the USA PATRIOT Act, including without limitation sections other than Section 326 thereof352) or regulations promulgated thereunder."

Anti-Money Laundering. (A) DTI shall provide for 24.1. To the establishmentextent the other provisions of this Agreement require PFPC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Portfolios consistent with securities laws, PFPC shall perform reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Portfolios from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIPFPC's anti-money laundering ("AML") program or by an outside party, for compliance with DTIPFPC's written established AML policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIPFPC's AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a the Fund, DTI PFPC shall provide to the Fund: (x) a copy of DTIPFPC's written AML policies and proceduresprocedures (it being understood such information is confidential and proprietary information of PFPC and shall not be disclosed without PFPC's prior written consent); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI PFPC personnel. (C) Without limiting . PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or expanding subsections (A) regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or (B) above, the regulatory agencies such information and records relating to PFPC's AML program as such examiners shall reasonably request. The parties agree the provisions of this Section 3(b)(1) relates solely 24.1 do not apply to Fund compliance with Section 326 of the USA PATRIOT Act (or other sections other than Section 352 of the USA PATRIOT Act and does Act) or to regulations not relate to any other obligation the Funds may have promulgated under Section 352 of the USA PATRIOT Act. 24.2. To help the Fund comply with its requirements to establish and implement a due diligence program for "foreign financial institution" accounts (which the Fund is required to have under regulations issued under Section 312 of the USA PATRIOT Act), PFPC will do the following with respect to the Portfolios: (i) Implement and operate a due diligence program that includes appropriate, specific, risk-based policies, procedures and controls that are reasonably designed to enable the Fund to detect and report, on an ongoing basis, any known or suspected money laundering activity conducted through or involving any correspondent account established, maintained, administered or managed by a Portfolio for a "foreign financial institution" (as defined in 31 CFR 103.175(h)) ("Foreign Financial Institution"); (ii) Conduct due diligence to identify and detect any such Foreign Financial Institution accounts in connection with new accounts and account maintenance; (iii) Assess the money laundering risk presented by each such Foreign Financial Institution account, based on a consideration of all appropriate relevant factors (as generally outlined in 31 CFR 103.176) and assign a risk category to each such Foreign Financial Institution account; (iv) Apply risk-based procedures and controls to each such Foreign Financial Institution account reasonably designed to detect and report known or suspected money laundering activity, including a periodic review of the Foreign Financial Institution account activity sufficient to determine consistency with information obtained about the type, purpose and anticipated activity of the account; (v) Include procedures to be followed in circumstances in which the appropriate due diligence cannot be performed with respect to a Foreign Financial Institution account; (vi) Adopt and operate enhanced due diligence policies, where necessary, as may be required by future regulations pending for Foreign Financial Institution accounts; (vii) Record due diligence program and maintain due diligence records relating to Foreign Financial Institution accounts; (viii) Report to the Fund about measures taken under (i)-(vii) above; and (ix) Set forth on a separate fee schedule compensation amounts due for these Foreign Financial Institution services. Notwithstanding anything in this Agreement or otherwise to the contrary, and without limitation expanding the scope of the express language in this Section 24.2, PFPC need not complete any due diligence beyond the requirements of the relevant Foreign Financial Institution due diligence program regulations and PFPC need not perform any task that need not be performed for the Fund to be in compliance with relevant Foreign Financial Institution due diligence program regulations. The parties agree the provisions of this Section 24.2 do not apply to Section 326 thereof.of the USA PATRIOT Act (or other sections other than Section 312 of the USA PATRIOT Act) or to regulations not promulgated under Section 312 of the USA PATRIOT Act. Notwithstanding anything in this Section 24.2 to the contrary, the provisions of this

Anti-Money Laundering. (A) DTI shall provide for To the establishmentextent the other provisions of this Agreement require PFPC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Trust consistent with securities laws, PFPC shall perform reasonable actions necessary to assist help the Funds Trust be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : PFPC : (ia) DTI shall establish has established and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Trust from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide has provided for independent testing, by an employee who is not responsible for the operation of DTIPFPC's anti-money laundering ("“AML"”) program or by an outside party, for compliance with DTIPFPC's written established AML policies and procedures; ; (iiic) DTI shall designate has designated a person or persons responsible for implementing and monitoring the operation and internal controls of DTIPFPC's AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a Fundthe Trust, DTI PFPC shall provide to the FundTrust: (x) a copy of DTIPFPC's written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI PFPC personnel. (C) . PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree this the provisions herein do not apply to Section 3(b)(1) relates solely to Fund compliance with Section 352 326 of the USA PATRIOT Act (or other sections other than Section 352) or regulations promulgated thereunder. 11.1. To help the Trust comply with its requirements to establish and does not relate implement a due diligence program for “foreign financial institution” accounts (which the Trust is required to any other obligation the Funds may have under regulations issued under Section 312 of the USA PATRIOT Act), PFPC will do the following: (i) Implement and operate a due diligence program that includes appropriate, specific, risk-based policies, procedures and controls that are reasonably designed to enable the Trust to detect and report, on an ongoing basis, any known or suspected money laundering activity conducted through or involving any correspondent account established, maintained, administered or managed by the Trust for a “foreign financial institution” (as defined in 31 CFR 103.175(h))(“Foreign Financial Institution”); (ii) Conduct due diligence to identify and detect any Foreign Financial Institution accounts in connection with new accounts and account maintenance; (iii) Assess the money laundering risk presented by each such Foreign Financial Institution account, based on a consideration of all appropriate relevant factors (as generally outlined in 31 CFR 103.176), and assign a risk category to each such Foreign Financial Institution account; (iv) Apply risk-based procedures and controls to each such Foreign Financial Institution account reasonably designed to detect and report known or suspected money laundering activity, including a periodic review of the Foreign Financial Institution account activity sufficient to determine consistency with information obtained about the type, purpose and anticipated activity of the account; (v) Include procedures to be followed in circumstances in which the appropriate due diligence cannot be performed with respect to a Foreign Financial Institution account; (vi) Adopt and operate enhanced due diligence policies, where necessary, as may be required by future regulations pending for Foreign Financial Institution accounts; (vii) Record due diligence program and maintain due diligence records relating to Foreign Financial Institution accounts; and (viii) Report to the Trust about measures taken under (i)-(vii) above. Notwithstanding anything to the contrary, and without limitation expanding the scope of the express language in this subsection 11.1, PFPC need not complete any due diligence beyond the requirements of the relevant Foreign Financial Institution due diligence program regulations and PFPC need not perform any task that need not be performed for the Trust to be in compliance with relevant Foreign Financial Institution due diligence program regulations. Without limiting or expanding the foregoing, the parties agree the provisions herein do not apply to Section 326 thereofof the USA PATRIOT Act (or other sections other than Section 312) or regulations promulgated thereunder. This Section 11 specifically excludes private bank account provisions of Section 312 of the USA PATRIOT Act.

Anti-Money Laundering. (A) DTI shall provide for 15.1 To the establishmentextent the other provisions of this Agreement require PFPC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Fund consistent with securities laws, PFPC shall perform reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's PFPC’s anti-money laundering ("“AML"”) program or by an outside party, for compliance with DTI's written PFPC’s established AML policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's PFPC’s AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a the Fund, DTI PFPC shall provide to the Fund: (x) a copy of DTI's PFPC’s written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to Confidential Information under this Agreement); (y) at the option of DTI, a copy of a written assessment or report prepared by the party performing the independent testing for compliancecompliance (or, or if the independent testing is performed internally by PFPC, at PFPC’s option a summary thereof, of such written assessment or a certification that the findings of the independent party are satisfactoryreport); and (z) a summary of the AML training provided for appropriate DTI PFPC personnel. (C) Without limiting . PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or expanding subsections (A) regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or (B) above, the regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. The parties agree the provisions of this subsection 15.1 do not apply to Section 3(b)(1) relates solely to Fund compliance with 326 of the USA PATRIOT Act (or other sections other than Section 352 of the USA PATRIOT Act and does Act) or to regulations not relate to any other obligation the Funds may have promulgated under Section 352 of the USA PATRIOT Act. 15.2 To help the Fund comply with its requirements to establish and implement a due diligence program for “foreign financial institution” accounts (which the Fund is required to have under regulations issued under Section 312 of the USA PATRIOT Act), PFPC will do the following with respect to the Fund: (i) Implement and operate a due diligence program that includes appropriate, specific, risk-based policies, procedures and controls that are reasonably designed to enable the Fund to detect and report, on an ongoing basis, any known or suspected money laundering activity conducted through or involving any correspondent account established, maintained, administered or managed by the Fund for a “foreign financial institution” (as defined in 31 CFR 103.175(h))(“Foreign Financial Institution”); (ii) Conduct due diligence to identify and detect any Foreign Financial Institution accounts in connection with new accounts and account maintenance; (iii) Assess the money laundering risk presented by each such Foreign Financial Institution account, based on a consideration of all appropriate relevant factors (as generally outlined in 31 CFR 103.176), and assign a risk category to each such Foreign Financial Institution account; (iv) Apply risk-based procedures and controls to each such Foreign Financial Institution account reasonably designed to detect and report known or suspected money laundering activity, including a periodic review of the Foreign Financial Institution account activity sufficient to determine consistency with information obtained about the type, purpose and anticipated activity of the account; (v) Include procedures to be followed in circumstances in which the appropriate due diligence cannot be performed with respect to a Foreign Financial Institution account; (vi) Adopt and operate enhanced due diligence policies, where necessary, as may be required by future regulations pending for Foreign Financial Institution accounts; (vii) Record due diligence program and maintain due diligence records relating to Foreign Financial Institution accounts; and (viii) Report to the Fund about measures taken under (i)-(vii) above. Notwithstanding anything in this Agreement to the contrary, and without limitation expanding the scope of the express language in this subsection 15.2, PFPC need not complete any due diligence beyond the requirements of the relevant Foreign Financial Institution due diligence program regulations and PFPC need not perform any task that need not be performed for the Fund to be in compliance with relevant Foreign Financial Institution due diligence program regulations. The parties agree the provisions of this subsection 15.2 do not apply to Section 326 thereofof the USA PATRIOT Act (or other sections other than Section 312 of the USA PATRIOT Act) or to regulations not promulgated under Section 312 of the USA PATRIOT Act. Notwithstanding anything in this subsection 15.2 to the contrary, the provisions of this subsection 15.2 specifically exclude private bank account provisions of Section 312 of the USA PATRIOT Act.

Anti-Money Laundering. (A) DTI shall provide for To the establishmentextent the other provisions of this Agreement _____________________ require PFPC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Fund consistent with securities laws, PFPC shall perform reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : In this regard, PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIPFPC's anti-money laundering ("AML") AML program or by an outside party, for compliance with DTIPFPC's written AML established policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIPFPC's AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a Fundthe Fund or TIA, DTI PFPC shall provide to the FundFund or TIA: (x) a copy of DTIPFPC's written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) . PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree this the provisions herein do not apply to Section 3(b)(1) relates solely to Fund compliance with Section 352 326 of the USA PATRIOT Act and does not relate to any (or other obligation the Funds may have under the USA PATRIOT Act, including without limitation sections other than Section 326 thereof352) or regulations promulgated thereunder.

Anti-Money Laundering. (A) DTI shall provide for 16.1 To the establishmentextent the other provisions of this Agreement require PFPC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Fund consistent with securities laws, PFPC shall perform reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's PFPC’s anti-money laundering ("“AML"”) program or by an outside party, for compliance with DTI's written PFPC’s established AML policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's PFPC’s AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a the Fund, DTI PFPC shall provide to the Fund: (x) a copy of DTI's PFPC’s written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI PFPC personnel. (C) . PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree this the provisions herein do not apply to Section 3(b)(1) relates solely to Fund compliance with Section 352 326 of the USA PATRIOT Act (or other sections other than Section 352) or regulations promulgated thereunder. 16.2 To help the Fund comply with its requirements to establish and does not relate implement a due diligence program for “foreign financial institution” accounts (which the Fund is required to any other obligation the Funds may have under regulations issued under Section 312 of the USA PATRIOT Act), PFPC will do the following: (i) Implement and operate a due diligence program that includes appropriate, specific, risk-based policies, procedures and controls that are reasonably designed to enable the Fund to detect and report, on an ongoing basis, any known or suspected money laundering activity conducted through or involving any correspondent account established, maintained, administered or managed by the Fund for a “foreign financial institution” (as defined in 31 CFR 103.175(h))(“Foreign Financial Institution”); (ii) Conduct due diligence to identify and detect any Foreign Financial Institution accounts in connection with new accounts and account maintenance; (iii) Assess the money laundering risk presented by each such Foreign Financial Institution account, based on a consideration of all appropriate relevant factors (as generally outlined in 31 CFR 103.176), and assign a risk category to each such Foreign Financial Institution account; (iv) Apply risk-based procedures and controls to each such Foreign Financial Institution account reasonably designed to detect and report known or suspected money laundering activity, including a periodic review of the Foreign Financial Institution account activity sufficient to determine consistency with information obtained about the type, purpose and anticipated activity of the account; (v) Include procedures to be followed in circumstances in which the appropriate due diligence cannot be performed with respect to a Foreign Financial Institution account; (vi) Adopt and operate enhanced due diligence policies, where necessary, as may be required by future regulations pending for Foreign Financial Institution accounts; (vii) Record due diligence program and maintain due diligence records relating to Foreign Financial Institution accounts; and (viii) Report to the Fund about measures taken under (i)-(vii) above. Notwithstanding anything to the contrary, and without limitation expanding the scope of the express language in this subsection 16.2, PFPC need not complete any due diligence beyond the requirements of the relevant Foreign Financial Institution due diligence program regulations and PFPC need not perform any task that need not be performed for the Fund to be in compliance with relevant Foreign Financial Institution due diligence program regulations. Without limiting or expanding the foregoing, the parties agree the provisions herein do not apply to Section 326 thereofof the USA PATRIOT Act (or other sections other than Section 312) or regulations promulgated thereunder. This amendment specifically excludes private bank account provisions of Section 312 of the USA PATRIOT Act.

Anti-Money Laundering. (A) DTI shall provide for The Service Organization is in compliance with the establishmentBank Secrecy Act of 1970, maintenance and monitoring of accounts of investors in the Funds and perform reasonable actions necessary to assist the Funds in complying with Section 352 of as amended by the USA PATRIOT Act of 2001 (“Patriot Act”), as followscodified at 31 USC § 5311 et seq., and the regulations promulgated thereunder (together, the “BSA”). The Service Organization agrees that it will fully comply with such regulations and it further represents the following: (ia) DTI shall establish and implement written policies, procedures and internal controls reasonably designed to help prevent the Funds from being used for money laundering or the financing of terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for That it has implemented an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. (ii) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("“AML"”) program or by consistent with the BSA, which includes, inter alia, a designated AML Compliance Officer, an outside partyindependent audit function, for compliance with DTI's written AML policies and procedureson-going employee training; (b) That it has implemented a Customer Identification Program (“CIP”), which complies with Section 326 of the Patriot Act and enables the Service Organization to form a reasonable belief that it knows the true identity of its Customers and includes policies, procedures, and controls to: (i) obtain information from and verify the identity of its Customers; (ii) maintain records of the information used to verify the identity of its Customers; (iii) DTI shall designate a person determine whether any Customer appears on any U.S. government list of known or persons responsible for implementing suspected terrorists or terrorist organizations; and monitoring (iv) provide its Customers with adequate notice that the operation Service Organization is requesting information to verify their identities; (c) That it has implemented policies, procedures, and internal controls to identify and report suspicious activity in accordance with the requirements of DTI's AML programthe BSA; and (ivd) DTI shall provide ongoing training of DTI personnel relating That it has implemented policies, procedures, and controls to ensure compliance with the prevention of money-laundering activities. (B) Upon the reasonable request of a Fund, DTI shall provide to the Fund: (x) a copy of DTI's written AML policies laws and procedures; (y) at the option of DTI, a copy of a written assessment or report prepared regulations administered by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings U.S. Department of the independent party are satisfactoryTreasury’s Office of Foreign Assets Control (“OFAC”). Such policies, procedures, and controls include screening Customers on an ongoing basis against the Specially Designated Nationals and Blocked Persons List and the other lists of prohibited persons and sanctioned countries maintained by OFAC; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) Without limiting or expanding subsections (A) or (B) aboveUpon request, but not more than once per year, the parties agree this Section 3(b)(1) relates solely Service Organization shall represent, warrant, and covenant to Fund Depository Institution in writing that it remains in compliance with Section 352 of the USA PATRIOT Act BSA and does not relate to any other obligation the Funds may have under the USA PATRIOT Act, including without limitation Section 326 thereoflaws and regulations administered by OFAC.

Anti-Money Laundering. (A) DTI shall provide for the establishment, maintenance and monitoring of accounts of investors in the Funds and BNYM will perform reasonable actions necessary reasonably designed to assist the Funds Trust in complying with Section 352 of the USA PATRIOT Act, as amended, as follows: : BNYM will: (i) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Trust from being used for money laundering or the financing of terrorist activities, including, without limiting the generality activities and to achieve compliance with applicable provisions of the foregoingBank Secrecy Act (31 U.S.C. 5311, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedureset seq. ) (“Bank Secrecy Act”) and implementing regulations thereunder; (ii) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's BNYM’s anti-money laundering ("“AML"”) program or by an outside party, for compliance with DTI's BNYM’s written AML policies and procedures; ; (iii) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's BNYM’s AML program; and (iv) DTI shall provide ongoing training for appropriate persons, and (v) implement appropriate risk-based procedures for conducting ongoing unitholder due diligence to include but not be limited to (aa) understanding the nature and purpose of DTI personnel relating unitholder relationships for the purposes of developing a unitholder risk profile, and (bb) conducting ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update unitholder information, including information regarding the prevention beneficial owners of money-laundering activitieslegal entity unitholders. (B) Upon the reasonable request of a Fund, DTI shall BNYM will provide to the Fund: Trust: (xi) a copy of DTI's BNYM’s written AML policies and procedures; , or, alternatively, access to such policies and procedures at a BNYM website; (yii) at the option of DTI, a copy of a written assessment or the report prepared by the party performing independent accountants covering the independent testing for compliance, or a summary thereof, or a certification that the findings accountants’ examination of the independent party are satisfactoryBNYM’s AML controls and control objectives; and and (ziii) a summary of the AML training provided for appropriate DTI personnelpursuant to clause (iv) of subsection (A) above. (C) Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund Trust compliance with Section 352 of the USA PATRIOT Act and does not relate to any other obligation the Funds Trust may have under the USA PATRIOT Act, including without limitation Section 326 thereof.

Anti-Money Laundering. a. Dealer represents that it has policies, procedures, and internal controls in place that are reasonably designed to comply with applicable anti-money laundering laws, rules and regulations, including applicable provisions of the USA PATRIOT Act. Dealer represents that it has a Customer Identification Program (A) DTI shall provide for "CIP"), which requires the establishment, maintenance performance of CIP due diligence in accordance with applicable USA PATRIOT Act requirements and monitoring of accounts of investors regulatory guidance. Dealer represents that it has policies and procedures in the Funds and perform reasonable actions necessary place reasonably designed to assist the Funds in complying comply with Section 352 312 of the USA PATRIOT Act, including processes reasonably designed to identify clients that are senior foreign political figures4 ("SFPF") and to conduct enhanced scrutiny on such clients. Dealer represents that its anti-money laundering program contains processes, procedures and systems reasonably designed to comply with economic sanctions programs administered by the Department of Treasury's Office of Foreign Assets Control ("OFAC"), including prohibitions set forth in the list of specially designated nationals and blocked persons (the "SDN List"), as follows: (i) DTI shall establish well as sanctions programs administered by the European Union and implement written the United Nations. Additionally, Dealer represents and warrants that it has policies, procedures and internal controls reasonably designed to help prevent ensure that it does not accept or introduce an investor to a Fund that is a person, government, organization or entity that is the Funds from being used for subject of any sanctions programs administered by OFAC, as well as sanctions programs administered by the European Union and United Nations. b. Dealer represents that: (i) it will apply its anti-money laundering or the financing program, as described in Section 9(a) of terrorist activitiesthis Agreement, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures.its clients; (ii) DTI shall provide for independent testingit will, upon written request of Distributor, notify Distributor within a reasonable time if any clients of Dealer who desire to make an investment in a Fund ("Prospective Dealer Members") or Dealer Members appear on any OFAC sanctions list or if any such Prospective Dealer Members or Dealer Members are SFPFs; and (iii) upon written request of Distributor, Dealer will furnish an AML representation letter substantially in the form attached hereto as set forth in Schedule 2. c. In the event of a court order or an inquiry from or examination or other audit or request by an employee who is not responsible for the operation of DTI's governmental, regulatory or self-regulatory authorities in any competent jurisdiction, or as may be otherwise required by Distributor to meet its legal or regulatory obligations, including without limitation any anti-money laundering ("AML") program or by an outside partylaws, for compliance with DTI's written AML policies and procedures; (iii) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's AML program; and (iv) DTI shall provide ongoing training of DTI personnel relating to the prevention of money-laundering activities. (B) Upon the reasonable request of a Fund, DTI shall provide to the Fund: (x) a copy of DTI's written AML policies and procedures; (y) at the option of DTI, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund compliance with Section 352 of the USA PATRIOT Act and does not relate to or any other obligation the Funds may have under the USA PATRIOT Actprivacy laws, including without limitation Section 326 thereof.Dealer will, upon request from Distributor or such governmental, regulatory or self-regulatory authority, furnish to

Anti-Money Laundering. (A) DTI shall provide for 17.1 To the establishmentextent the other provisions of this Agreement require PFPC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Trust consistent with securities laws, PFPC shall perform reasonable actions necessary to assist help the Funds Trust be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : In this regard, PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Trust from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIPFPC's anti-money laundering ("AML") AML program or by an outside party, for compliance with DTIPFPC's written AML established policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIPFPC's AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a Fundthe Trust, DTI PFPC shall provide to the FundTrust: (x) a copy of DTIPFPC's written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) . PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree the provisions of this subsection 17.1 does do not apply to Section 3(b)(1) relates solely to Fund compliance with Section 352 326 of the USA PATRIOT Act (or other sections other than Section 352) or regulations promulgated thereunder. 17.2 To help the Trust comply with its requirements to establish and does not relate implement a due diligence program for "foreign financial institution" accounts (which the Trust is required to any other obligation the Funds may have under regulations issued under Section 312 of the USA PATRIOT Act), PFPC will do the following: (i) Implement and operate a due diligence program that includes appropriate, specific, risk-based policies, procedures and controls that are reasonably designed to enable the Trust to detect and report, on an ongoing basis, any known or suspected money laundering activity conducted through or involving any correspondent account established, maintained, administered or managed by the Trust for a "foreign financial institution" (as defined in 31 CFR 103.175(h)) ("Foreign Financial Institution"); (ii) Conduct due diligence to identify and detect any Foreign Financial Institution accounts in connection with new accounts and account maintenance; (iii) Assess the money laundering risk presented by such Foreign Financial Institution account, based on a consideration of all appropriate relevant factors, (as generally outlined in 31 CFR 103.176), and assign a risk category to each Foreign Financial Institution account; (iv) Apply risk-based procedures and controls to each such Foreign Financial Institution account reasonably designed to detect and report known or suspected money laundering activity, including a periodic review of the Foreign Financial Institution account activity sufficient to determine consistency with information obtained about the type, purpose and anticipated activity of the account; (v) Include procedures to be followed in circumstances in which the appropriate due diligence cannot be performed with respect to a Foreign Financial Institution account; (vi) Adopt and operate enhanced due diligence policies, where necessary, as may be required by future regulations pending for Foreign Financial Institution accounts; (vii) Record due diligence program and maintain due diligence records relating to Foreign Financial Institution accounts; (viii) Report to the Trust about measures taken under (i)-(vii) above; and (ix) Set forth on a separate fee schedule compensation amounts due for these Foreign Financial Institution services. Notwithstanding anything to the contrary, and without limitation expanding the scope of the express language above, PFPC need not complete a due diligence beyond the requirements of the relevant regulations and PFPC need not perform any task that need not be performed for the Trust to be in compliance with relevant regulation. Without limiting or expanding the foregoing, the parties agree the provisions of this subsection 17.2 do not apply to Section 326 thereofof the USA PATRIOT Act (or other sections other than Section 312) or regulations promulgated thereunder. The provisions of this subsection 17.2 specifically exclude private bank account provisions of Section 312 of the USA PATRIOT Act.

Anti-Money Laundering. (A) DTI shall provide for the establishment, maintenance and monitoring of accounts of investors in the Funds and BNYM will perform reasonable actions necessary reasonably designed to assist the Funds Fund in complying with Section 352 of the USA PATRIOT Act, as amended, as follows: : BNYM will: (i) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for money laundering or the financing of terrorist activities, including, without limiting the generality activities and to achieve compliance with applicable provisions of the foregoingBank Secrecy Act (31 U.S.C. 5311, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedureset seq. ) (“Bank Secrecy Act”) and implementing regulations thereunder; (ii) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's BNYM’s anti-money laundering ("“AML"”) program or by an outside party, for compliance with DTI's BNYM’s written AML policies and procedures; ; (iii) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's BNYM’s AML program; and (iv) DTI shall provide ongoing training for appropriate persons, and (v) implement appropriate risk-based procedures for conducting ongoing shareholder due diligence to include but not be limited to (aa) understanding the nature and purpose of DTI personnel relating shareholder relationships for the purposes of developing a shareholder risk profile, and (bb) conducting ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update shareholder information, including information regarding the prevention beneficial owners of money-laundering activitieslegal entity shareholders. (B) Upon the reasonable request of a Fund, DTI shall BNYM will provide to the Fund: : (xi) a copy of DTI's BNYM’s written AML policies and procedures; , or, alternatively, access to such policies and procedures at a BNYM website; (yii) at the option of DTI, a copy of a written assessment or the report prepared by the party performing independent accountants covering the independent testing for compliance, or a summary thereof, or a certification that the findings accountants’ examination of the independent party are satisfactoryBNYM’s AML controls and control objectives; and and (ziii) a summary of the AML training provided for appropriate DTI personnelpursuant to clause (iv) of subsection (A) above. (C) Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund compliance with Section 352 of the USA PATRIOT Act and does not relate to any other obligation the Funds Fund may have under the USA PATRIOT Act, including without limitation Section 326 thereof.

Anti-Money Laundering. (Aa) DTI shall provide for To the establishmentextent the other provisions of this Agreement require PNC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Fund consistent with securities laws, PNC shall perform reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : PNC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIPNC's anti-money laundering ("AML") program or by an outside party, for compliance with DTIPNC's written established AML policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIPNC's AML program; and and (ivd) DTI shall provide ongoing training of DTI PNC personnel relating to the prevention of money-laundering activities. (Bb) Upon the reasonable request of a the Fund, DTI PNC shall provide to the Fund: (x) a copy of DTIPNC's written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to Confidential Information (as defined below); (y) at the option of DTIPNC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI PNC personnel. PNC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. (Cc) Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree provisions in this Section 3(b)(1) relates solely 3 shall relate only to Fund compliance with Section 352 of the USA PATRIOT Act and does do not relate to any apply other obligation the Funds may have under sections, including Section 326, of the USA PATRIOT ActAct or regulations promulgated thereunder. (d) Subject to mutually agreed upon procedures, PNC shall perform searches within applicable regulatory time periods of OFAC, EU, the Dutch Freeze List, FATF NCCT, OFSI and FinCEN databases and advise the MLRO of matches to any names in these databases, and perform any additional research or searches as reasonably requested by the MLRO or her authorized staff. (e) PNC shall operate screening procedures designed to prohibit, other than by Written Instructions from the Funds, the use of cash, third-party checks or cash equivalents to purchase shares of the Funds. Cash equivalents include, but are not limited, to cashier's checks, money orders and traveler's checks. (f) PNC shall provide to the Fund access to such files, wire orders, or regulatory filings as are created and maintained in accordance with its duties under Sections 3, 4, 5, 6 and 7, and shall provide reasonable assistance to ING in responding in a timely manner to the requests of independent auditors and regulators relating to such duties. For purposes of this Agreement, "access" with respect to such files, wire orders, filings or other books and records pertaining to the Fund that are in the possession or under the control of PNC means submission by the Fund of a reasonably detailed request of the books and records sought and PNC providing them to the fullest extent reasonably practicable pursuant to its document production procedures; provided, however, that it is expressly understood and acknowledged that nothing in this Agreement shall require PNC to furnish to the Funds contents of any files or other materials that constitute internal communications (including without limitation Section 326 thereofemails) of PNC, confidential material, information proprietary to PNC, material subject to attorney-client privilege or material prohibited by law from disclosure or distribution. (g) Provide a quarterly report that provides a summary of primary AML transaction processing metrics relating to the transfer agent's AML Program.

Anti-Money Laundering. (Ai) DTI PFPC shall provide for the establishment, maintenance and monitoring of accounts of investors in the Funds and perform reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of United States federal anti-money laundering (“AML”) laws applicable to mutual funds (i.e., the Bank Secrecy Act as amended by the USA PATRIOT Act, Act of 2001) as follows: : (iA) DTI shall establish and implement written policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iiB) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("AML") PFPC’s AML program or by an outside party, for compliance with DTI's written PFPC’s established AML policies and procedures; ; (iiiC) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's PFPC’s AML program; and and (ivD) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a the Fund, DTI PFPC shall provide to the Fund: (xX) a copy of DTI's PFPC’s written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to Confidential Information under this Agreement); (yY) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (zZ) a summary of the AML training provided for appropriate DTI PFPC personnel. PFPC agrees to permit inspections relating to PFPC’s AML program by United States federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to PFPC’s AML program as such examiners shall reasonably request. (ii) To help the Fund comply with its requirements to establish and implement a due diligence program for “foreign financial institution” accounts (which the Fund is required to have under regulations issued under Section 312 of the USA PATRIOT Act), PFPC will do the following with respect to the Fund: (A) Implement and operate a due diligence program that includes appropriate, specific, risk-based policies, procedures and controls that are reasonably designed to enable the Fund to detect and report, on an ongoing basis, any known or suspected money laundering activity conducted through or involving any correspondent account established, maintained, administered or managed by the Fund for a “foreign financial institution” (as defined in 31 CFR 103.175(h)) (“Foreign Financial Institution”); (B) Conduct due diligence to identify and detect any Foreign Financial Institution accounts in connection with new accounts and account maintenance; (C) Without limiting Assess the money laundering risk presented by each such Foreign Financial Institution account, based on a consideration of all appropriate relevant factors (as generally outlined in 31 CFR 103.176), and assign a risk category to each such Foreign Financial Institution account; (D) Apply risk-based procedures and controls to each such Foreign Financial Institution account reasonably designed to detect and report known or expanding subsections suspected money laundering activity, including a periodic review of the Foreign Financial Institution account activity sufficient to determine consistency with information obtained about the type, purpose and anticipated activity of the account; (AE) or Include procedures to be followed in circumstances in which the appropriate due diligence cannot be performed with respect to a Foreign Financial Institution account; (BF) Adopt and operate enhanced due diligence policies, where necessary, as may be required by future regulations pending for Foreign Financial Institution accounts; (G) Record due diligence program and maintain due diligence records relating to Foreign Financial Institution accounts; and (H) Report to the Fund about measures taken under (A)-(G) above. Notwithstanding anything in this Agreement or otherwise to the contrary, and without expanding the scope of the express language in this Section 14(q)(ii), PFPC need not complete any due diligence beyond the requirements of the relevant Foreign Financial Institution due diligence program regulations and PFPC need not perform any task that need not be performed for the Fund to be in compliance with relevant Foreign Financial Institution due diligence program regulations. Notwithstanding anything in this Section 14(q)(ii) to the contrary, the parties agree provisions of this Section 3(b)(114(q)(ii) relates solely to Fund compliance with specifically excludes private bank account provisions of Section 352 312 of the USA PATRIOT Act and does not relate to any other obligation the Funds may have under the USA PATRIOT Act, including without limitation Section 326 thereof.

Anti-Money Laundering. (Aa) DTI shall provide for To the establishmentextent the other provisions of this Agreement require PNC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Fund consistent with securities laws, PNC shall perform reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : PNC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's PNC’s anti-money laundering ("“AML"”) program or by an outside party, for compliance with DTI's written PNC’s established AML policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's PNC’s AML program; and and (ivd) DTI shall provide ongoing training of DTI PNC personnel relating to the prevention of money-laundering activities. (Bb) Upon the reasonable request of a the Fund, DTI PNC shall provide to the Fund: (x) a copy of DTI's PNC’s written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement); (y) at the option of DTIPNC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI PNC personnel. PNC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. (Cc) Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties Parties agree the provisions in this Section 3(b)(1) relates solely 14 relate only to Fund compliance with Section 352 of the USA PATRIOT Act and does do not relate to any apply other obligation the Funds may have under sections, including Section 326, of the USA PATRIOT Act, including without limitation Section 326 thereofAct or regulations promulgated thereunder.

Anti-Money Laundering. (A) DTI As of the Effective Date, the Agreement is amended by adding the following new provision: "Anti-Money Laundering. PFPC shall provide for the establishmentservices described in Section 15 of the Agreement consistent with the Securities Laws, maintenance and monitoring of accounts of investors in the Funds and perform reasonable actions necessary to assist the Funds in complying compliance with Section 352 of the USA PATRIOT Act, as follows: follows (ispecifically, PFPC undertakes to perform the services described in the attached ANTI-MONEY LAUNDERING SERVICES PROGRAM SUMMARY as stated therein): In this regard, PFPC shall: (a) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIPFPC's anti-money laundering ("AML") AML program or by an outside party, for compliance with DTIPFPC's written AML established policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIPFPC's AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a the Fund, DTI PFPC shall promptly provide to the Fund: (x) a copy of DTIPFPC's written AML policies and proceduresprocedures (a copy of which is attached hereto) (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this agreement); (y) at the option of DTI, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, compliance (or a summary thereof, ) or a certification that the findings of the independent party are satisfactorysatisfactory (PFPC will also provide a copy of such a summary or certification upon the reasonable request of the Fund); and (z) a summary of the AML training provided for appropriate DTI personnel. PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. Upon the publication of additional final anti-money laundering regulations, PFPC will work with the Fund to offer, on reasonable terms, for the Fund's benefit services to help the Fund satisfy its obligations under such regulations. (C) Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund compliance with Section 352 of the USA PATRIOT Act and does not relate to any other obligation the Funds may have under the USA PATRIOT Act, including without limitation Section 326 thereof."

Anti-Money Laundering. (A) DTI shall provide for the establishment, maintenance and monitoring of accounts of investors in the Funds and BNY Mellon will perform reasonable actions necessary reasonably designed to assist the Funds Fund in complying with Section 352 552 of the USA PATRIOT Act, as amended, as follows: : BNY Mellon will: (i) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (ii) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's BNY Mellon’s anti-money laundering ("“AML"”) program or by an outside party, for compliance with DTI's BNY Mellon’s written AML policies and procedures; ; (iii) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's BNY Mellon’s AML program; and and (iv) DTI shall provide ongoing training of DTI BNY Mellon personnel relating to the prevention of money-laundering activities. (B) Upon the reasonable request of a Fund, DTI shall BNY Mellon will provide to the Fund: : (xi) a copy of DTI's BNY Mellon’s written AML policies and procedures; , or, alternatively, access to such policies and procedures at a BNY Mellon website; (yii) at the option of DTI, a copy of a written assessment or the report prepared by the party performing independent accountants covering the independent testing for compliance, or a summary thereof, or a certification that the findings accountants’ examination of the independent party are satisfactoryBNY Mellon’s AML controls and control objectives; and and (ziii) a summary of the AML training provided for appropriate DTI BNY Mellon personnel. (C) Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(14(b)(1) relates solely to Fund compliance with Section 352 552 of the USA PATRIOT Act and does not relate to any other obligation the Funds Fund may have under the USA PATRIOT Act, including without limitation Section 326 526 thereof.

Anti-Money Laundering. (A) DTI shall provide Promptly following any request therefor, information and documentation reasonably requested by the Administrative Agent or any Lender for the establishment, maintenance purposes of compliance with applicable “know your customer” and monitoring of accounts of investors in the Funds anti-money-laundering rules and perform reasonable actions necessary to assist the Funds in complying with Section 352 of the USA PATRIOT Act, as follows: (i) DTI shall establish and implement written policies, procedures and internal controls reasonably designed to help prevent the Funds from being used for money laundering or the financing of terrorist activitiesregulations, including, without limiting limitation, the generality Act. Documents required to be delivered pursuant to Section 6.01(a) or (b) or Section 6.02(d) (to the extent any such documents are included in materials otherwise filed with the SEC) may be delivered electronically and if so delivered, shall be deemed to have been delivered on the date (a) on which the Borrower posts such documents, or provides a link thereto on the Borrower’s website on the Internet at the website address listed on Schedule 1.01; or (b) on which such documents are posted on the Borrower’s behalf on an Internet or intranet website, if any, to which each Lender and the Administrative Agent have access (whether a commercial, third-party website or whether sponsored by the Administrative Agent); provided that: (i) the Borrower shall deliver paper copies of such documents to the Administrative Agent or any Lender upon its request to the Borrower to deliver such paper copies until a written request to cease delivering paper copies is given by the Administrative Agent or such Lender and (ii) the Borrower shall notify the Administrative Agent and each Lender (by fax transmission or e-mail transmission) of the posting of any such documents and provide to the Administrative Agent by e-mail electronic versions (i.e., soft copies) of such documents. The Administrative Agent shall have no obligation to request the delivery of or to maintain paper copies of the documents referred to above, and in any event shall have no responsibility to monitor compliance by the Borrower with any such request by a Lender for delivery, and each Lender shall be solely responsible for requesting delivery to it or maintaining its copies of such documents. The Borrower hereby acknowledges that (A) the Administrative Agent and/or an Affiliate thereof may, but shall not be obligated to, make available to the Lenders and the L/C Issuer materials and/or information provided by or on behalf of the Borrower hereunder (collectively, “Borrower Materials”) by posting the Borrower Materials on IntraLinks, Syndtrak, ClearPar or a substantially similar electronic transmission system (the “Platform”) and (B) certain of the Lenders (each, a “Public Lender”) may have personnel who do not wish to receive material non-public information with respect to the Borrower or its Affiliates, or the respective securities of any of the foregoing, procedures and who may be engaged in investment and other market-related activities with respect to such Persons’ securities. The Borrower hereby agrees that it will use commercially reasonable efforts to identify that portion of the Borrower Materials that may be distributed to the Public Lenders and that (1) all such Borrower Materials shall be clearly and conspicuously marked “PUBLIC” which, at a minimum, shall mean that the word “PUBLIC” shall appear prominently on the first page thereof; (2) by marking Borrower Materials “PUBLIC,” the Borrower shall be deemed to have authorized the Administrative Agent, any Affiliate thereof, the Arranger, the L/C Issuer and the Lenders to treat such Borrower Materials as not containing any material non-public information (although it may be sensitive and proprietary) with respect to the Borrower or its securities for the ongoing surveillance purposes of shareholder accountsUnited States federal and state securities Laws (provided, designed to detect money laundering activityhowever, that take into account to the money laundering risk level for an account or group of accountsextent such Borrower Materials constitute Information, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts they shall be treated as set forth in the DTI Procedures. (ii) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("AML") program or by an outside party, for compliance with DTI's written AML policies and procedures; (iii) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's AML program; and (iv) DTI shall provide ongoing training of DTI personnel relating to the prevention of money-laundering activities. (B) Upon the reasonable request of a Fund, DTI shall provide to the Fund: (x) a copy of DTI's written AML policies and proceduresSection 11.07); (y3) at the option of DTI, all Borrower Materials marked “PUBLIC” are permitted to be made available through a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings portion of the independent party are satisfactory; Platform designated “Public Side Information;” and (z4) the Administrative Agent and any Affiliate thereof and the Arranger shall be entitled to treat any Borrower Materials that are not marked “PUBLIC” as being suitable only for posting on a summary portion of the AML training provided for appropriate DTI personnelPlatform not designated “Public Side Information. (C) Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund compliance with Section 352 of the USA PATRIOT Act and does not relate to any other obligation the Funds may have under the USA PATRIOT Act, including without limitation Section 326 thereof.”

Anti-Money Laundering. (A) DTI shall provide for To the establishmentextent the other provisions of this Agreement require PFPC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Trust consistent with securities laws, PFPC shall perform reasonable actions necessary to assist help the Funds Trust be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Trust from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIPFPC's anti-money laundering ("“AML"”) program or by an outside party, for compliance with DTIPFPC's written established AML policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIPFPC's AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a Fundthe Trust, DTI PFPC shall provide to the FundTrust: (x) a copy of DTIPFPC's written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI PFPC personnel. (C) . PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree this the provisions herein do not apply to Section 3(b)(1) relates solely to Fund compliance with Section 352 326 of the USA PATRIOT Act and does not relate to any (or other obligation the Funds may have under the USA PATRIOT Act, including without limitation sections other than Section 326 thereof352) or regulations promulgated thereunder.

Anti-Money Laundering. (Aa) DTI shall provide for To the establishmentextent the other provisions of this Agreement require PFPC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Fund consistent with securities laws, PFPC shall perform reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's PFPC’s anti-money laundering ("“AML"”) program or by an outside party, for compliance with DTI's written PFPC’s established AML policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's PFPC’s AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (Bb) Upon the reasonable request of a the Fund, DTI PFPC shall provide to the Fund: (x) a copy of DTI's PFPC’s written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI PFPC personnel. PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. (Cc) Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree the provisions in this Section 3(b)(1) relates solely 14 relate only to Fund compliance with Section 352 of the USA PATRIOT Act and does do not relate to any apply other obligation the Funds may have under sections, including Section 326, of the USA PATRIOT Act, including without limitation Section 326 thereofAct or regulations promulgated thereunder.

Anti-Money Laundering. (A) DTI shall provide for 16.1 To the establishmentextent the other provisions of this Agreement require PFPC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Trust consistent with securities laws, PFPC shall perform reasonable actions necessary to assist help the Funds Trust be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Trust from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIPFPC's anti-money laundering ("AML") AML program or by an outside party, for compliance with DTIPFPC's written established AML policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIPFPC's AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a Fundthe Trust, DTI PFPC shall provide to the FundTrust: (x) a copy of DTIPFPC's written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) . PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree the provisions of this subsection 16.1 do not apply to Section 3(b)(1) relates solely to Fund compliance with Section 352 326 of the USA PATRIOT Act (or other sections other than Section 352) or regulations promulgated thereunder. 16.2 To help the Trust comply with its requirements to establish and does not relate implement a due diligence program for "foreign financial institution" accounts (which the Trust is required to any other obligation the Funds may have under regulations issued under Section 312 of the USA PATRIOT Act), PFPC will do the following: (i) Implement and operate a due diligence program that includes appropriate, specific, risk-based policies, procedures and controls that are reasonably designed to enable the Trust to detect and report, on an ongoing basis, any known or suspected money laundering activity conducted through or involving any correspondent account established, maintained, administered or managed by the Trust for a "foreign financial institution" (as defined in 31 CFR 103.175(h)) ("Foreign Financial Institution"); (ii) Conduct due diligence to identify and detect any Foreign Financial Institution accounts in connection with new accounts and account maintenance; (iii) Assess the money laundering risk presented by each such Foreign Financial Institution account, based on a consideration of all appropriate relevant factors (as generally outlined in 31 CFR 103.176) and assign a risk category to each such Foreign Financial Institution account; (iv) Apply risked-based procedures and controls to each such Foreign Financial Institution account reasonably designed to detect and report known or suspected money laundering activity, including a periodic review of the Foreign Financial Institution account activity sufficient to determine consistency with information obtained about the type, purpose and anticipated activity of the account; (v) Include procedures to be followed in circumstances in which the appropriate due diligence cannot be performed with respect to a Foreign Financial Institution account; (vi) Adopted and operate enhanced due diligence policies, where necessary, as may be required by future regulations pending for Foreign Financial Institution accounts; (vii) Record due diligence program and maintain due diligence records relating to Foreign Financial Institution accounts; (viii) Report to the Trust about measures taken under (i)-(vii) above; and (ix) Set forth on a separate fee schedule compensation amounts due for these Foreign Financial Institution services. Notwithstanding anything to the contrary, and without limitation expanding the scope of the express language in this sub-section 16.2, PFPC need not complete any due diligence beyond the requirements of the relevant Foreign Financial Institution due diligence program regulations and PFPC need not perform any task that need not be performed for the Trust to be in compliance with relevant Foreign Financial Institution due diligence program regulations. Without limiting or expanding the foregoing, the parties agree the provisions of this subsection 16.2 do not apply to Section 326 thereofof the USA PATRIOT Act (or other sections other than Section 312) or regulations promulgated thereunder. The provisions of this subsection 16.2 specifically exclude private bank account provisions of Section 312 of the USA PATRIOT Act.

Anti-Money Laundering. (Aa) DTI shall provide for To the establishmentextent the other provisions of this Agreement require PFPC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Fund consistent with securities laws, PFPC shall perform reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's PFPC’s anti-money laundering ("“AML"”) program or by an outside party, for compliance with DTI's written PFPC’s established AML policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's PFPC’s AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (Bb) Upon the reasonable request of a the Fund, DTI PFPC shall provide to the Fund: (x) a copy of DTI's PFPC’s written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to Confidential Information under this Agreement); (y) at the option of DTI, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI PFPC personnel. PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. (Cc) Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree the provisions in this Section 3(b)(1) relates solely 14 relate only to Fund compliance with Section 352 of the USA PATRIOT Act and does do not relate to any apply other obligation the Funds may have under sections, including Section 326, of the USA PATRIOT Act, including without limitation Section 326 thereofAct or regulations promulgated thereunder.

Anti-Money Laundering. (A) DTI shall provide for the establishment, maintenance and monitoring of accounts of investors in the Funds and BNYM will perform reasonable actions necessary reasonably designed to assist the Funds Fund in complying with Section 352 of the USA PATRIOT Act, as amended, as follows: : BNYM will: (i) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for money laundering or the financing of terrorist activities, including, without limiting the generality activities and to achieve compliance with applicable provisions of the foregoingBank Secrecy Act (31 U.S.C. 5311, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedureset seq. ) (“Bank Secrecy Act”) and implementing regulations thereunder; (ii) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's BNYM’s anti-money laundering ("“AML"”) program or by an a qualified outside party, for compliance with DTI's BNYM’s written AML policies and procedures; ; (iii) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's BNYM’s AML program; and (iv) DTI shall provide ongoing training for appropriate persons, and (v) implement appropriate risk-based procedures for conducting ongoing shareholder due diligence to include but not be limited to (aa) understanding the nature and purpose of DTI personnel relating shareholder relationships for the purposes of developing a shareholder risk profile, and (bb) conducting ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update shareholder information, including information regarding the prevention beneficial owners of money-laundering activitieslegal entity shareholders. (B) Upon the reasonable request of a Fund, DTI shall BNYM will provide to the Fund: : (xi) a copy of DTI's BNYM’s written AML policies and procedures; , or, alternatively, access to such policies and procedures at a BNYM website; (yii) at the option of DTI, a copy of a written assessment or the report prepared by the party performing independent accountants covering the independent testing for compliance, or a summary thereof, or a certification that the findings accountants’ examination of the independent party are satisfactoryBNYM’s AML controls and control objectives; and Confidential And Proprietary EXECUTION (ziii) a summary of the AML training provided for appropriate DTI personnelpursuant to clause (iv) of subsection (A) above. (C) Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund compliance with Section 352 of the USA PATRIOT Act and does not relate to any other obligation the Funds Fund may have under the USA PATRIOT Act, including without limitation Section 326 thereof.

Anti-Money Laundering. (A) DTI shall provide for To the establishmentextent the other provisions of this Agreement require PFPC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Fund consistent with securities laws, PFPC shall perform reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIPFPC's anti-money laundering ("AML") program or by an outside party, for compliance with DTIPFPC's written established AML policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIPFPC's AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a the Fund, DTI PFPC shall provide to the Fund: (x) a copy of DTIPFPC's written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI PFPC personnel. (C) . PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree this the provisions herein do not apply to Section 3(b)(1) relates solely to Fund compliance with Section 352 326 of the USA PATRIOT Act and does not relate to any (or other obligation the Funds may have under the USA PATRIOT Act, including without limitation sections other than Section 326 thereof352) or regulations promulgated thereunder.

Anti-Money Laundering. (A) DTI shall provide for To the establishmentextent the other provisions of this Agreement require the Distributor to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Fund consistent with securities laws, the Distributor shall perform all reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of United States federal AML laws applicable to investor activity, including the USA Bank Secrecy Act and the PATRIOT Act, as follows: described hereinafter. In this regard, the Distributor shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("AML") the Distributor’s AML program or by an outside party, for compliance with DTI's written AML the Distributor’s established policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's the Distributor’s AML program; and and (ivd) DTI shall provide ongoing training of DTI the Distributor’s personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a the Fund, DTI the Distributor shall provide to the Fund: ’s officer in charge of AML compliance (the “AML Compliance Officer”): (x) a copy of DTI's the Distributor’s written AML policies and procedures; procedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement): (y) at the option of DTI, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) Without limiting or expanding subsections (A) or (B) above. Unless otherwise performed by the Fund’s transfer agent, the parties agree this Section 3(b)(1Distributor shall also: (i) relates solely to Fund collect and maintain investor information, verify the identity of investors and check investor identities against all government lists of known or suspected terrorists and terrorist organizations in compliance with Section 352 the procedures set forth in the Fund’s AML program and the PATRIOT Act; (ii) provide notice of the USA Fund’s customer identification procedures to prospective investors in the manner permitted by the PATRIOT Act before an account is opened; (iii) maintain records of the information collected and does not relate methods used to any other obligation verify investor identity in compliance with the Funds may have under the USA PATRIOT Act; (iv) monitor investor accounts for suspicious activity to the extent required by AML laws or the PATRIOT Act; and (v) make any required regulatory filings on behalf of the Fund including, including without limitation Section 326 thereofbut not limited to, Form 8300 and suspicious activity reports (to the extent required by AML laws) and promptly provide a copy of all such reports filed to the Fund’s AML Compliance Officer. To the extent that a Fund regulator wishes to examine the Distributor regarding its services hereunder, the Distributor shall cooperate with and permit examinations of its records and personnel by such regulator, coordinating any such response with the Fund’s AML Compliance Officer. The Distributor also agrees to make available to examiners from such regulatory agencies any information and records relating to the Fund’s AML program as such examiners shall reasonably request.

Anti-Money Laundering. (A) DTI shall provide for 16.1 To the establishmentextent the other provisions of this Agreement require PFPC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Trust consistent with securities laws, PFPC shall perform reasonable actions necessary to assist help the Funds Trust be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Trust from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's PFPC’s anti-money laundering ("“AML"”) program or by an outside party, for compliance with DTI's written PFPC’s established AML policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's PFPC’s AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a Fundthe Trust, DTI PFPC shall provide to the FundTrust: (x) a copy of DTI's PFPC’s written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI PFPC personnel. (C) . PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree this the provisions herein do not apply to Section 3(b)(1) relates solely to Fund compliance with Section 352 326 of the USA PATRIOT Act (or other sections other than Section 352) or regulations promulgated thereunder. 16.2 To help the Trust comply with its requirements to establish and does not relate implement a due diligence program for “foreign financial institution” accounts (which the Trust is required to any other obligation the Funds may have under regulations issued under Section 312 of the USA PATRIOT Act), PFPC will do the following: (i) Implement and operate a due diligence program that includes appropriate, specific, risk-based policies, procedures and controls that are reasonably designed to enable the Trust to detect and report, on an ongoing basis, any known or suspected money laundering activity conducted through or involving any correspondent account established, maintained, administered or managed by the Trust for a “foreign financial institution” (as defined in 31 CFR 103.175(h))(“Foreign Financial Institution”); (ii) Conduct due diligence to identify and detect any Foreign Financial Institution accounts in connection with new accounts and account maintenance; (iii) Assess the money laundering risk presented by each such Foreign Financial Institution account, based on a consideration of all appropriate relevant factors (as generally outlined in 31 CFR 103.176), and assign a risk category to each such Foreign Financial Institution account; (iv) Apply risk-based procedures and controls to each such Foreign Financial Institution account reasonably designed to detect and report known or suspected money laundering activity, including a periodic review of the Foreign Financial Institution account activity sufficient to determine consistency with information obtained about the type, purpose and anticipated activity of the account; (v) Include procedures to be followed in circumstances in which the appropriate due diligence cannot be performed with respect to a Foreign Financial Institution account; (vi) Adopt and operate enhanced due diligence policies, where necessary, as may be required by future regulations pending for Foreign Financial Institution accounts; (vii) Record due diligence program and maintain due diligence records relating to Foreign Financial Institution accounts; and (viii) Report to the Trust about measures taken under (i)-(iii) above. Notwithstanding anything to the contrary, and without limitation expanding the scope of the express language in this subsection 16.2, PFPC need not complete any due diligence beyond the requirements of the relevant Foreign Financial Institution due diligence program regulations and PFPC need not perform any task that need not be performed for the Trust to be in compliance with relevant Foreign Financial Institution due diligence program regulations. Without limiting or expanding the foregoing, the parties agree the provisions herein do not apply to Section 326 thereofof the USA PATRIOT Act (or other sections other than Section 312) or regulations promulgated thereunder. This amendment specifically excludes private bank account provisions of Section 312 of the USA PATRIOT Act.

Anti-Money Laundering. (Ai) DTI PFPC shall provide for the establishment, maintenance and monitoring of accounts of investors in the Funds and perform reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : PFPC shall: (iA) DTI shall establish and implement written policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iiB) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("AML") PFPC’s AML program or by an outside party, for compliance with DTI's written PFPC’s established AML policies and procedures; ; (iiiC) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's PFPC’s AML program; and and (ivD) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a the Fund, DTI PFPC shall provide to the Fund: (xX) a copy of DTI's PFPC’s written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to Confidential Information under this Agreement); (yY) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (zZ) a summary of the AML training provided for appropriate DTI PFPC personnel. (C) Without limiting . PFPC agrees to permit inspections relating to PFPC’s AML program by United States federal departments or expanding subsections (A) regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or (B) above, the regulatory agencies such information and records relating to PFPC’s AML program as such examiners shall reasonably request. The parties agree the provisions of this Section 3(b)(114(q)(i) relates solely do not apply to Fund compliance with Section 326 of the USA PATRIOT Act (or other sections other than Section 352 of the USA PATRIOT Act and does ) or to regulations not relate to any other obligation the Funds may have promulgated under Section 352 of the USA PATRIOT Act. (ii) To help the Fund comply with its requirements to establish and implement a due diligence program for “foreign financial institution” accounts (which the Fund is required to have under regulations issued under Section 312 of the USA PATRIOT Act), PFPC will do the following with respect to the Fund: (A) Implement and operate a due diligence program that includes appropriate, specific, risk-based policies, procedures and controls that are reasonably designed to enable the Fund to detect and report, on an ongoing basis, any known or suspected money laundering activity conducted through or involving any correspondent account established, maintained, administered or managed by the Fund for a “foreign financial institution” (as defined in 31 CFR 103.175(h))(“Foreign Financial Institution”); (B) Conduct due diligence to identify and detect any Foreign Financial Institution accounts in connection with new accounts and account maintenance; (C) Assess the money laundering risk presented by each such Foreign Financial Institution account, based on a consideration of all appropriate relevant factors (as generally outlined in 31 CFR 103.176), and assign a risk category to each such Foreign Financial Institution account; (D) Apply risk-based procedures and controls to each such Foreign Financial Institution account reasonably designed to detect and report known or suspected money laundering activity, including a periodic review of the Foreign Financial Institution account activity sufficient to determine consistency with information obtained about the type, purpose and anticipated activity of the account; (E) Include procedures to be followed in circumstances in which the appropriate due diligence cannot be performed with respect to a Foreign Financial Institution account; (F) Adopt and operate enhanced due diligence policies, where necessary, as may be required by future regulations pending for Foreign Financial Institution accounts; (G) Record due diligence program and maintain due diligence records relating to Foreign Financial Institution accounts; and (H) Report to the Fund about measures taken under (i)-(vii) above. Notwithstanding anything in this Agreement or otherwise to the contrary, and without limitation expanding the scope of the express language in this Section 14(q)(ii), PFPC need not complete any due diligence beyond the requirements of the relevant Foreign Financial Institution due diligence program regulations and PFPC need not perform any task that need not be performed for the Fund to be in compliance with relevant Foreign Financial Institution due diligence program regulations.. The parties agree the provisions of this Section 14(q)(ii) do not apply to Section 326 thereofof the USA PATRIOT Act (or other sections other than Section 312 of the USA PATRIOT Act) or to regulations not promulgated under Section 312 of the USA PATRIOT Act. Notwithstanding anything in this Section 14(q)(ii) to the contrary, the provisions of this Section 14(q)(ii) specifically excludes private bank account provisions of Section 312 of the USA PATRIOT Act.

Anti-Money Laundering. (A) DTI shall provide for To the establishmentextent the other provisions of this Agreement require PFPC to establish, maintenance maintain and monitoring of monitor accounts of investors shareholders in the Funds and Trust consistent with securities laws, PFPC shall perform reasonable actions necessary to assist help the Funds Trust be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : In this regard, PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Trust from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI activities (“AML Procedures. ”); (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("AML") PFPC’s AML program or by an outside party, for compliance with DTI's written AML PFPC’s established policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's PFPC’s AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering and terrorist financing activities. (B) . Upon the reasonable request of a Fundthe Trust, DTI PFPC shall provide to the FundTrust: (x) a copy of DTI's PFPC’s written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this agreement); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) . PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree this the provisions herein do not apply to Section 3(b)(1) relates solely to Fund compliance with Section 352 326 of the USA PATRIOT Act (or other sections other than Section 352) or regulations promulgated thereunder. The following is a general description of the anti-money laundering services that the Trust has delegated to PFPC and does not relate PFPC agrees to any other obligation implement and operate on behalf of the Funds may have under Trust in accordance with the USA PATRIOT Act, including without limitation Section 326 thereof.AML Procedures pertaining to the delegated services below:

Anti-Money Laundering. a. Dealer represents that it has policies, procedures, and internal controls in place that are reasonably designed to comply with applicable anti-money laundering laws, rules and regulations, including applicable provisions of the USA PATRIOT Act. Dealer represents that it has a Customer Identification Program (A) DTI shall provide for "CIP"), which requires the establishment, maintenance performance of CIP due diligence in accordance with applicable USA PATRIOT Act requirements and monitoring of accounts of investors regulatory guidance. Dealer represents that it has policies and procedures in the Funds and perform reasonable actions necessary place reasonably designed to assist the Funds in complying comply with Section 352 312 of the USA PATRIOT Act, including processes reasonably designed to identify clients that are senior foreign political figures4 ("SFPF") and to conduct enhanced scrutiny on such clients. Dealer represents that its anti-money laundering program contains processes, procedures and systems reasonably designed to comply with economic sanctions programs administered by the Department of Treasury's Office of Foreign Assets Control ("OFAC"), including prohibitions set forth in the list of specially designated nationals and blocked persons (the "SDN List"), as follows: (i) DTI shall establish well as sanctions programs administered by the European Union and implement written the United Nations. Additionally, Dealer represents and warrants that it has policies, procedures and internal controls reasonably designed to help prevent ensure that it does not accept or introduce an investor to a Fund that is a person, government, organization or entity that is the Funds from being used for subject of any sanctions programs administered by OFAC, as well as sanctions programs administered by the European Union and United Nations. b. Dealer represents that: (i) it will apply its anti-money laundering or the financing program, as described in Section 9(a) of terrorist activitiesthis Agreement, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures.its clients; (ii) DTI shall provide for independent testingit will, upon written request of Distributor, notify Distributor within a reasonable time if any clients of Dealer who desire to make an investment in a Fund ("Prospective Dealer Members") or Dealer Members appear on any OFAC sanctions list or if any such Prospective Dealer Members or Dealer Members are SFPFs; and (iii) upon written request of Distributor, Dealer will furnish an AML representation letter substantially in the form attached hereto as set forth in Schedule 2. c. In the event of a court order or an inquiry from or examination or other audit or request by an employee who is not responsible for the operation of DTI's governmental, regulatory or self-regulatory authorities in any competent jurisdiction, or as may be otherwise required by Distributor to meet its legal or regulatory obligations, including without limitation any anti-money laundering laws, the USA PATRIOT Act or any privacy laws, Dealer will, upon request from Distributor or such governmental, regulatory or self-regulatory authority, furnish to ________________________ 4 Senior foreign political figure means a current or former senior official in the executive, legislative, administrative, military or judicial branches of a foreign government ("AML") program whether elected or by an outside not), a senior official of a major foreign political party, or a senior executive of a foreign government-owned commercial enterprise. In addition, a senior foreign political figure includes any corporation, business or other entity that has been formed by, or for compliance with DTI's written AML policies the benefit of, a senior foreign political figure, as well as immediate family members of a senior foreign political figure. The immediate family members of a senior foreign political figure typically include the political figure’s parents, siblings, spouse, children and procedures; (iii) DTI shall designate spouse’s parents or siblings. A close associate of a senior foreign political figure is a person who is widely and publicly known to be a close associate of the senior foreign political figure, and includes a person who is in a position to conduct substantial financial transactions on behalf of the senior foreign political figure. Distributor or persons responsible for implementing and monitoring the operation and internal controls applicable governmental, regulatory or self-regulatory authority a copy of DTIthe client's AML program; and (iv) DTI shall provide ongoing training of DTI personnel relating CIP documents, to the prevention of money-laundering activitiesextent permitted by applicable law. (Bd. Dealer acknowledges and agrees that if Dealer declines at any time to deliver to Distributor, or give Distributor or its representatives access to customer information requested by Distributor or a governmental, regulatory or self-regulatory authority pursuant to Section 9(b) Upon or Section 9(c), as applicable, except where Dealer is not permitted under applicable law to provide such customer information, a Fund, or the reasonable request Distributor on behalf of a Fund, DTI shall provide may, without liability of any kind: i. refuse to establish any account or accept any subscription amounts with respect to any affected Prospective Dealer member or affected Dealer Member; ii. delay the establishment of any account or the acceptance of any subscription amounts with respect to any affected Prospective Dealer Member or affected Dealer Member; iii. close accounts previously established for any affected Prospective Dealer Member or affected Dealer Member; iv. refuse to engage in any transactions for any affected Prospective Dealer Member or affected Dealer Member; v. freeze the account" (either by prohibiting additional subscriptions, restricting any distributions and/or declining any repurchase requests) or cancel any pending transactions with respect to any affected Prospective Dealer Member or affected Dealer Member; vi. liquidate the account of any affected Prospective Dealer Member or affected Deal Member, including through a compulsory repurchase; and vii. return to the Fund: (x) a copy of DTIappropriate person securities or other property held in such affected Prospective Dealer Member or affected Dealer Member's written AML policies and procedures; (y) at the option of DTI, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnelaccount. (C) Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund compliance with Section 352 of the USA PATRIOT Act and does not relate to any other obligation the Funds may have under the USA PATRIOT Act, including without limitation Section 326 thereof.

Anti-Money Laundering. As of the Effective Date, the Agreement is amended by adding the following new provision: “Anti-Money Laundering. BNY Mellon has implemented various anti-money laundering (A“AML”) DTI shall provide for procedures as described below, which it has found to be reasonable, and the establishmentFund desires to delegate certain AML procedures to BNY Mellon, maintenance as permitted by the USA PATRIOT Act (the “PATRIOT Act”) and monitoring the regulations promulgated hereunder. Consequently, the Fund and BNY Mellon desire to amend the Agreement to reflect such services explicitly as follows: To the extent the other provisions of this Agreement require BNY Mellon to establish, maintain and monitor accounts of investors in the Funds and Fund consistent with securities laws, BNY Mellon shall perform all reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of United States Federal AML laws applicable to investor activity, including the USA Bank Secrecy Act and the PATRIOT Act, Act as follows: : In this regard, BNY Mellon shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or finance terrorist activities and to achieve compliance with the financing of terrorist activities, including, without limiting the generality applicable provisions of the foregoing, Bank Secrecy Act and the implementing regulations thereunder; (b) undertake to revise such AML procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account as necessary or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. appropriate; (iic) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("AML") BNY Mellon’s AML program or by an outside party, for compliance with DTI's written AML BNY Mellon’s established policies and procedures; ; (iiid) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's BNY Mellon’s AML program; and and (ive) DTI shall provide ongoing training of DTI BNY Mellon personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a the Fund, DTI BNY Mellon shall provide to the Fund’s AML Compliance Officer: (x) a copy of DTI's BNY Mellon’s written AML policies and procedures; procedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement): (y) at the option of DTI, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, compliance (or a summary thereof, at BNY Mellon’s option), or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) Without limiting or expanding subsections (A) or (B) above. In addition, BNY Mellon shall provide the parties agree this Section 3(b)(1) relates solely Fund with information necessary for the Fund to Fund compliance with Section 352 of the USA PATRIOT Act prepare and does not relate to file Form 8300 and any other obligation the Funds may have suspicious activity reports, required under the USA PATRIOT ActAML laws, including without limitation Section 326 thereofin connection with suspicious activity BNY Mellon detects. BNY Mellon agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request.”

Anti-Money Laundering. (Aa) DTI shall provide for To the establishmentextent the other provisions of this Agreement require PNC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Fund consistent with securities laws, PNC shall perform reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of the USA PATRIOT Act, applicable United States Federal anti-money laundering (“AML”) laws related to investor activity as follows: : PNC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("AML") PNC’s AML program or by an outside party, for compliance with DTI's written PNC’s established AML policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's PNC’s AML program; and and (ivd) DTI shall provide ongoing training of DTI PNC personnel relating to the prevention of money-money- laundering activities. (Bb) Upon the reasonable request of a the Fund, DTI PNC shall provide to the Fund: : (xi) a copy of DTI's PNC’s written AML policies and procedures; procedures (yit being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement); (ii) at the option of DTIPNC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and and (ziii) a summary of the AML training provided for appropriate DTI PNC personnel. PNC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. (Cc) Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree the provisions in this Section 3(b)(1) relates solely 14 relate only to Fund compliance with Section 352 of the USA PATRIOT Act and does do not relate apply to any other obligation the Funds may have under sections, including Section 326, of the USA PATRIOT Act, including without limitation Section 326 thereofAct or regulations promulgated thereunder.

Anti-Money Laundering. (Ai) DTI PNC shall provide for the establishment, maintenance and monitoring of accounts of investors in the Funds and perform reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of United States federal anti-money laundering (“AML”) laws applicable to mutual funds (i.e., the Bank Secrecy Act as amended by the USA PATRIOT Act, Act of 2001) as follows: : (iA) DTI shall establish and implement written policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iiB) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("AML") PNC’s AML program or by an outside party, for compliance with DTI's written PNC’s established AML policies and procedures; ; (iiiC) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's PNC’s AML program; and and (ivD) DTI shall provide ongoing training of DTI PNC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a the Fund, DTI PNC shall provide to the Fund: (xX) a copy of DTI's PNC’s written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to Confidential Information under this Agreement); (yY) at the option of DTIPNC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (zZ) a summary of the AML training provided for appropriate DTI PNC personnel. PNC agrees to permit inspections relating to PNC’s AML program by United States federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to PNC’s AML program as such examiners shall reasonably request. (ii) To help the Fund comply with its requirements to establish and implement a due diligence program for “foreign financial institution” accounts (which the Fund is required to have under regulations issued under Section 312 of the USA PATRIOT Act), PNC will do the following with respect to the Fund: (A) Implement and operate a due diligence program that includes appropriate, specific, risk-based policies, procedures and controls that are reasonably designed to enable the Fund to detect and report, on an ongoing basis, any known or suspected money laundering activity conducted through or involving any correspondent account established, maintained, administered or managed by the Fund for a “foreign financial institution” (as defined in 31 CFR 103.175(h)) (“Foreign Financial Institution”); (B) Conduct due diligence to identify and detect any Foreign Financial Institution accounts in connection with new accounts and account maintenance; (C) Without limiting Assess the money laundering risk presented by each such Foreign Financial Institution account, based on a consideration of all appropriate relevant factors (as generally outlined in 31 CFR 103.176), and assign a risk category to each such Foreign Financial Institution account; (D) Apply risk-based procedures and controls to each such Foreign Financial Institution account reasonably designed to detect and report known or expanding subsections suspected money laundering activity, including a periodic review of the Foreign Financial Institution account activity sufficient to determine consistency with information obtained about the type, purpose and anticipated activity of the account; (AE) or Include procedures to be followed in circumstances in which the appropriate due diligence cannot be performed with respect to a Foreign Financial Institution account; (BF) Adopt and operate enhanced due diligence policies, where necessary, as may be required by future regulations pending for Foreign Financial Institution accounts; (G) Record due diligence program and maintain due diligence records relating to Foreign Financial Institution accounts; and (H) Report to the Fund about measures taken under (A)-(G) above. Notwithstanding anything in this Agreement or otherwise to the contrary, and without expanding the scope of the express language in this Section 14(q)(ii), PNC need not complete any due diligence beyond the requirements of the relevant Foreign Financial Institution due diligence program regulations and PNC need not perform any task that need not be performed for the Fund to be in compliance with relevant Foreign Financial Institution due diligence program regulations. Notwithstanding anything in this Section 14(q)(ii) to the contrary, the parties agree provisions of this Section 3(b)(114(q)(ii) relates solely to Fund compliance with specifically excludes private bank account provisions of Section 352 312 of the USA PATRIOT Act and does not relate to any other obligation the Funds may have under the USA PATRIOT Act, including without limitation Section 326 thereof.

Anti-Money Laundering. As of the Effective Date, the Agreement is amended by adding the following new provision: "Anti-Money Laundering. PFPC has implemented various anti-money laundering (A"AML") DTI shall provide for procedures as described below, which it has found to be reasonable, and the establishmentTrust desires to delegate certain AML procedures to PFPC, maintenance as permitted by the USA PATRIOT Act (the "PATRIOT Act") and monitoring the regulations promulgated hereunder. Consequently, the Trust and PFPC desire to amend the Agreement to reflect such services explicitly as follows: To the extent the other provisions of this Agreement require PFPC to establish, maintain and monitor accounts of investors in the Funds and Trust consistent with securities laws, PFPC shall perform all reasonable actions necessary to assist help the Funds Trust be in complying compliance with Section 352 of United States Federal AML laws applicable to investor activity, including the USA Bank Secrecy Act and the PATRIOT Act, Act as follows: : In this regard, PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Trust from being used for to launder money laundering or finance terrorist activities and to achieve compliance with the financing of terrorist activities, including, without limiting the generality applicable provisions of the foregoing, Bank Secrecy Act and the implementing regulations thereunder; (b) undertake to revise such AML procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account as necessary or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. appropriate; (iic) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIPFPC's anti-money laundering ("AML") AML program or by an outside party, for compliance with DTIPFPC's written AML established policies and procedures; ; (iiid) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIPFPC's AML program; and and (ive) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a Fundthe Trust, DTI PFPC shall provide to the FundTrust's AML Compliance Officer: (x) a copy of DTIPFPC's written AML policies and procedures; procedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement): (y) at the option of DTI, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, compliance (or a summary thereof, at PFPC's option), or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) Without limiting or expanding subsections (A) or (B) above. In addition, PFPC shall provide the parties agree this Section 3(b)(1) relates solely Trust with information necessary for the Trust to Fund compliance with Section 352 of the USA PATRIOT Act prepare and does not relate to file Form 8300 and any other obligation the Funds may have suspicious activity reports, required under the USA PATRIOT ActAML laws, including without limitation Section 326 thereofin connection with suspicious activity PFPC detects. PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request."

Anti-Money Laundering. (A) DTI shall provide for To the establishmentextent the other provisions of this Agreement require PFPC to establish, maintenance maintain and monitoring of monitor accounts of investors shareholders in the Funds and Trust consistent with securities laws, PFPC shall perform reasonable actions necessary to assist help the Funds Trust be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : In this regard, PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Trust from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's anti-money laundering ("AML") PFPC’s AML program or by an outside party, for compliance with DTI's written AML PFPC’s established policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's PFPC’s AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a Fundthe Trust, DTI PFPC shall provide to the FundTrust: (x) a copy of DTI's PFPC’s written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this agreement); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) . PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree this the provisions herein do not apply to Section 3(b)(1) relates solely to Fund compliance with Section 352 326 of the USA PATRIOT Act and does not relate to any (or other obligation the Funds may have under the USA PATRIOT Act, including without limitation sections other than Section 326 thereof352) or regulations promulgated thereunder.

Anti-Money Laundering. (A) DTI shall provide for 24.1. To the establishmentextent the other provisions of this Agreement require PFPC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Portfolios consistent with securities laws, PFPC shall perform reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Portfolios from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's PFPC’s anti-money laundering ("“AML"”) program or by an outside party, for compliance with DTI's written PFPC’s established AML policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's PFPC’s AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a the Fund, DTI PFPC shall provide to the Fund: (x) a copy of DTI's PFPC’s written AML policies and proceduresprocedures (it being understood such information is confidential and proprietary information of PFPC and shall not be disclosed without PFPC’s prior written consent); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI PFPC personnel. (C) Without limiting . PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or expanding subsections (A) regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or (B) above, the regulatory agencies such information and records relating to PFPC’s AML program as such examiners shall reasonably request. The parties agree the provisions of this Section 3(b)(1) relates solely 24.1 do not apply to Fund compliance with Section 326 of the USA PATRIOT Act (or other sections other than Section 352 of the USA PATRIOT Act and does Act) or to regulations not relate to any other obligation the Funds may have promulgated under Section 352 of the USA PATRIOT Act. 24.2. To help the Fund comply with its requirements to establish and implement a due diligence program for “foreign financial institution” accounts (which the Fund is required to have under regulations issued under Section 312 of the USA PATRIOT Act), PFPC will do the following with respect to the Portfolios: (i) Implement and operate a due diligence program that includes appropriate, specific, risk-based policies, procedures and controls that are reasonably designed to enable the Fund to detect and report, on an ongoing basis, any known or suspected money laundering activity conducted through or involving any correspondent account established, maintained, administered or managed by a Portfolio for a “foreign financial institution” (as defined in 31 CFR 103.175(h)) (“Foreign Financial Institution”); (ii) Conduct due diligence to identify and detect any such Foreign Financial Institution accounts in connection with new accounts and account maintenance; (iii) Assess the money laundering risk presented by each such Foreign Financial Institution account, based on a consideration of all appropriate relevant factors (as generally outlined in 31 CFR 103.176) and assign a risk category to each such Foreign Financial Institution account; (iv) Apply risk-based procedures and controls to each such Foreign Financial Institution account reasonably designed to detect and report known or suspected money laundering activity, including a periodic review of the Foreign Financial Institution account activity sufficient to determine consistency with information obtained about the type, purpose and anticipated activity of the account; (v) Include procedures to be followed in circumstances in which the appropriate due diligence cannot be performed with respect to a Foreign Financial Institution account; (vi) Adopt and operate enhanced due diligence policies, where necessary, as may be required by future regulations pending for Foreign Financial Institution accounts; (vii) Record due diligence program and maintain due diligence records relating to Foreign Financial Institution accounts; (viii) Report to the Fund about measures taken under (i)-(vii) above; and (ix) Set forth on a separate fee schedule compensation amounts due for these Foreign Financial Institution services. Notwithstanding anything in this Agreement or otherwise to the contrary, and without limitation expanding the scope of the express language in this Section 24.2, PFPC need not complete any due diligence beyond the requirements of the relevant Foreign Financial Institution due diligence program regulations and PFPC need not perform any task that need not be performed for the Fund to be in compliance with relevant Foreign Financial Institution due diligence program regulations. The parties agree the provisions of this Section 24.2 do not apply to Section 326 thereof.of the USA PATRIOT Act (or other sections other than Section 312 of the USA PATRIOT Act) or to regulations not promulgated under Section 312 of the USA PATRIOT Act. Notwithstanding anything in this Section 24.2 to the contrary, the provisions of this

Anti-Money Laundering. (A) DTI shall provide for To the establishmentextent the other provisions of this Agreement require PFPC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Fund consistent with securities laws, PFPC shall perform reasonable actions necessary to assist help the Funds Fund be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : In this regard, PFPC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIPFPC's anti-money laundering ("AML") program or by an outside party, for compliance with DTIPFPC's written established AML policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIPFPC's AML program; and and (ivd) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a the Fund, DTI PFPC shall provide to the Fund: (x) a copy of DTIPFPC's written AML policies and proceduresprocedures (it being understood such information is confidential and proprietary information of PFPC and may not be disclosed without PFPC's prior written consent); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI PFPC personnel. (C) . PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to PFPC's AML program as such examiners shall reasonably request. Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree this the provisions herein do not apply to Section 3(b)(1) relates solely to Fund compliance with Section 352 326 of the USA PATRIOT Act and does not relate to any (or other obligation the Funds may have under the USA PATRIOT Act, including without limitation sections other than Section 326 thereof352) or regulations promulgated thereunder."

Anti-Money Laundering. (A) DTI shall provide for the establishment, maintenance and monitoring of accounts of investors in the Funds and BNYM will perform reasonable actions necessary reasonably designed to assist the Funds Fund in complying with Section 352 of the USA PATRIOT Act, as amended, as follows: : BNYM will: (i) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for money laundering or the financing of terrorist activities, including, without limiting the generality activities and to achieve compliance with applicable provisions of the foregoingBank Secrecy Act (31 U.S.C. 5311, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedureset seq. ) ("Bank Secrecy Act") and implementing regulations thereunder; (ii) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIBNYM's anti-money laundering ("AML") program or by an outside party, for compliance with DTIBNYM's written AML policies and procedures; ; (iii) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIBNYM's AML program; and (iv) DTI shall provide ongoing training of DTI personnel for appropriate persons relating to the prevention of money-money laundering activities., and (v) implement appropriate risk-based procedures for conducting ongoing shareholder due diligence to include but not be limited to (aa) understanding the nature and purpose of shareholder relationships for the purposes of developing a shareholder risk profile, and (bb) conducting ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update shareholder information, including information regarding the beneficial owners of legal entity shareholders. Confidential And Proprietary Execution Version (B) Upon the reasonable request of a Fund, DTI shall BNYM will provide to the Fund: : (xi) a copy of DTIBNYM's written AML policies and procedures; , or, alternatively, access to such policies and procedures at a BNYM website; (yii) at the option of DTI, a copy of a written assessment or the report prepared by the party performing independent accountants covering the independent testing for compliance, or a summary thereof, or a certification that the findings accountants' examination of the independent party are satisfactoryBNYM's AML controls and control objectives; and and (ziii) a summary of the AML training provided for appropriate DTI personnelpursuant to clause (iv) of subsection (A) above. (C) Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund compliance with Section 352 of the USA PATRIOT Act and does not relate to any other obligation the Funds Fund may have under the USA PATRIOT Act, including without limitation Section 326 thereof.

Anti-Money Laundering. (A) DTI shall provide for To the establishmentextent the other provisions of this Agreement require PNC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Fund consistent with the Securities Laws, PNC shall perform reasonable actions necessary to assist the Funds Fund in complying with Section 352 of the USA PATRIOT Act, as follows: : PNC shall: (ia) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (iib) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIPNC's anti-money laundering ("“AML"”) program or by an outside party, for compliance with DTIPNC's written AML policies and procedures; ; (iiic) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIPNC's AML program; and and (ivd) DTI shall provide ongoing training of DTI PNC personnel relating to the prevention of money-laundering activities. (B) Upon the reasonable request of a Fund, DTI PNC shall provide to the FundFund on an annual basis: (xw) a copy of DTIPNC's written AML policies and procedures; (yx) at the option of DTIPNC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or ; (y) a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI PNC personnel. (C) Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund compliance with Section 352 of the USA PATRIOT Act and does not relate to any other obligation the Funds Fund may have under the USA PATRIOT Act, including without limitation Section 326 thereof. (D) PNC agrees to cooperate with, and provide reasonable assistance to, any party designated by the Investment Company to perform the Investment Company’s annual audit of its AML program (“AML Auditor” and “AML Audit”). The Fund shall provide PNC with at least four (4) weeks’ written notice of any onsite AML Audit. In connection with any AML Audit, the Fund shall provide PNC a written information request, to which PNC shall be afforded at least two (2) weeks to respond. The Fund and the AML Auditor shall cooperate with PNC in order to ensure that any request in connection with an AML Audit shall not be unduly burdensome to PNC and that any AML Audit shall not adversely affect PNC’s business operations.

Anti-Money Laundering. (A) DTI shall provide for the establishment, maintenance and monitoring of accounts of investors in the Funds and BNYM will perform reasonable actions necessary reasonably designed to assist the Funds Fund in complying with Section 352 of the USA PATRIOT Act, as amended, as follows: : BNYM will: (i) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Fund from being used for money laundering or the financing of terrorist activities, including, without limiting the generality activities and to achieve compliance with applicable provisions of the foregoingBank Secrecy Act (31 U.S.C. 5311, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedureset seq. ) (”Bank Secrecy Act”) and implementing regulations thereunder; (ii) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTI's BNYM’s anti-money laundering ("”AML"”) program or by an outside party, for compliance with DTI's BNYM’s written AML policies and procedures; ; (iii) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTI's BNYM’s AML program; and (iv) DTI shall provide ongoing training for appropriate persons, and (v) implement appropriate risk-based procedures for conducting ongoing shareholder due diligence to include but not be limited to (aa) understanding the nature and purpose of DTI personnel relating shareholder relationships for the purposes of developing a shareholder risk profile, and (bb) conducting ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update shareholder information, including information regarding the prevention beneficial owners of money-laundering activitieslegal entity shareholders. (B) Upon the reasonable request of a Fund, DTI shall BNYM will provide to the Fund: : (xi) a copy of DTI's BNYM’s written AML policies and procedures; , or, alternatively, access to such policies and procedures at a BNYM website; (yii) at the option of DTI, a copy of a written assessment or the report prepared by the party performing independent accountants covering the independent testing for compliance, or a summary thereof, or a certification that the findings accountants’ examination of the independent party are satisfactoryBNYM’s AML controls and control objectives; and and (ziii) a summary of the AML training provided for appropriate DTI personnelpursuant to clause (iv) of subsection (A) above. (C) Without limiting or expanding subsections (A) or (B) above, the parties agree this Section 3(b)(1) relates solely to Fund compliance with Section 352 of the USA PATRIOT Act and does not relate to any other obligation the Funds Fund may have under the USA PATRIOT Act, including without limitation Section 326 thereof.

Anti-Money Laundering. (A) DTI shall provide for To the establishmentextent the other provisions of this Agreement require PFPC to establish, maintenance maintain and monitoring of monitor accounts of investors in the Funds and Trust consistent with securities laws, PFPC shall perform reasonable actions necessary to assist help the Funds Trust be in complying compliance with Section 352 of the USA PATRIOT Act, as follows: : In this regard, PFPC shall: (i) DTI shall establish and implement written internal policies, procedures and internal controls reasonably designed to help prevent the Funds Trust from being used for to launder money laundering or the financing of finance terrorist activities, including, without limiting the generality of the foregoing, procedures for the ongoing surveillance of shareholder accounts, designed to detect money laundering activity, that take into account the money laundering risk level for an account or group of accounts, e.g., foreign vs. domestic accounts or public vs. private companies. The procedures for the ongoing surveillance of shareholder accounts shall be set forth in the DTI Procedures. ; (ii) DTI shall provide for independent testing, by an employee who is not responsible for the operation of DTIPFPC's anti-money laundering ("AML") AML program or by an outside party, for compliance with DTIPFPC's written AML established policies and procedures; ; (iii) DTI shall designate a person or persons responsible for implementing and monitoring the operation and internal controls of DTIPFPC's AML program; and and (iv) DTI shall provide ongoing training of DTI PFPC personnel relating to the prevention of money-laundering activities. (B) . Upon the reasonable request of a Fundthe Trust, DTI PFPC shall provide to the FundTrust: (x) a copy of DTIPFPC's written AML policies and proceduresprocedures (it being understood such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this Agreement); (y) at the option of DTIPFPC, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate DTI personnel. (C) . PFPC agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request. Without limiting or expanding subsections (A) or (B) abovethe foregoing, the parties agree this the provisions herein do not apply to Section 3(b)(1) relates solely to Fund compliance with Section 352 326 of the USA PATRIOT Act and does not relate to any (or other obligation the Funds may have under the USA PATRIOT Act, including without limitation sections other than Section 326 thereof352) or regulations promulgated thereunder.