Common use of CIP Services Clause in Contracts

CIP Services. So that each Fund will comply with its Customer Identification Program (which the Fund is required to have under regulations issued under Section 326 of the USA PATRIOT Act), Transfer Agent will do the following: (1) Implement procedures under which new accounts in the Fund are not established unless Transfer Agent has obtained the name, date of birth (for natural persons only), address and government-issued identification number (collectively, the "Data Elements") for each corresponding Customer (as defined in 31 CFR 103.131). (2) Use collected Data Elements to attempt to reasonably verify the identity of each new Customer promptly before or within a reasonable time (generally not in excess of thirty days) after each corresponding new account is opened. Methods will consist of non-documentary methods (for which Transfer Agent may use unaffiliated information vendors to assist with such verifications, providing that (i) Transfer Agent's contract with such vendor requires the vendor to keep and maintain the confidentiality of any information provided by or obtained about a Customer and (ii) Transfer Agent has and continues to forma reasonable belief that such vendors will maintain the confidentiality of any information so described in (i) and documentary methods (both of which Transfer Agent believes will meet the minimum requirements to comply with 31 CFR 13.131(b)(2) or any amendment thereof), and may include procedures under which Transfer Agent personnel conduct additional research to attempt to reasonably verify the identity of Customers who were not verified by Transfer Agent's initial attempt. (3) Determine whether the Customer's name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of Treasury in consultation with the federal functional regulators. (4) Record the Data Elements in an electronic repository (or other manner that satisfies the regulation and allows for reasonably easy and prompt retrieval of the Data Elements) designed for this purpose and maintain records relating to verification of new Customers consistent with 31 CFR 103.131(b)(3). (5) Regularly report to the Fund about measures taken, results obtained and Customers for which identities cannot be verified under (1)-(4) above. (6) If Transfer Agent provides services by which prospective Customers may subscribe for shares in the Fund via the Internet, telephone or application that is mailed to Transfer Agent, work with the Fund to notify prospective Customers, consistent with 31 CFR 103.131(b)(5), about the Fund's CIP. (7) Timely file suspicious activity reports ("SARs") with its or its affiliates' primary federal regulator, maintain the required records in compliance with 31 CFR 000.00 xxx xx xxxx time as applicable regulations are changed to permit such, Transfer Agent shall submit a copy of the filed SAR to the Fund within 30 days of its filing. (8) Not later than 15 calendar days after Transfer Agent reasonably determines that Customer transactions or activity is suspicious, report such information in reasonable detail to the Fund. (9) Certify no less frequently than annually to the Fund in a form that is mutually acceptable to the Fund and the Transfer Agent that Transfer Agent has implemented its anti-money laundering program, and that it will perform the specific requirements for the Fund discussed in this Agreement and as the Fund is required under 31 CFR 103.131. (10) Set forth on a separate fee schedule compensation amounts due for these CIP Services. Notwithstanding anything to the contrary, and without expanding the scope of the express language above, Transfer Agent need not collect the Data Elements for (or verify) prospective Customers beyond the requirements of 31 CFR 103.131 (for example Transfer Agent will not verify customers opening accounts through NSCC). Notwithstanding anything above to the contrary, Transfer Agent need not perform any of the steps in provisions (1)-(10) above (or any CIP measures) with respect to any Customer who becomes a Customer of a fund ("Fund A") via exchange from another fund ("Fund B") in accordance with the Customer's privilege to exchange shares of Fund B for Fund A, provided that the other Fund B is within the same family of funds as may be provided to the Transfer Agent from time to time. Transfer Agent agrees that it will permit federal or state examiners to inspect the (i) Funds' information and records pertaining to the anti-money laundering ("AML") program and CIP activities on behalf of the aforementioned funds and (ii) Transfer Agent's AML services program. Transfer Agent agrees that any AML information provided by or requested from Funds to Transfer Agent will be maintained by Transfer Agent and will be disclosed by Transfer Agent to its employees and agents on a need to know basis or to governmental authorities.

CIP Services. So that each Fund will comply with its Customer Identification Program (which the Fund is required to have under regulations issued under Section 326 of the USA PATRIOT Act), Transfer Agent will do the following: (1) Implement procedures under which new accounts in the Fund are not established unless Transfer Agent has obtained the name, date of birth (for natural persons only), address and government-issued identification number (collectively, the "“Data Elements"”) for each corresponding Customer (as defined in 31 CFR 103.131). (2) Use collected Data Elements to attempt to reasonably verify the identity of each new Customer promptly before or within a reasonable time (generally not in excess of thirty days) after each corresponding new account is opened. Methods will consist of non-documentary methods (for which Transfer Agent may use unaffiliated information vendors to assist with such verifications, providing that (i) Transfer Agent's ’s contract with such vendor requires the vendor to keep and maintain the confidentiality of any information provided by or obtained about a Customer and (ii) Transfer Agent has and continues to forma reasonable belief that such vendors will maintain the confidentiality of any information so described in (i) and documentary methods (both of which Transfer Agent believes will meet the minimum requirements to comply with 31 CFR 13.131(b)(2) or any amendment thereof), and may include procedures under which Transfer Agent personnel conduct additional research to attempt to reasonably verify the identity of Customers who were not verified by Transfer Agent's ’s initial attempt. (3) Determine whether the Customer's ’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of Treasury in consultation with the federal functional regulators. (4) Record the Data Elements in an electronic repository (or other manner that satisfies the regulation and allows for reasonably easy and prompt retrieval of the Data Elements) designed for this purpose and maintain records relating to verification of new Customers consistent with 31 CFR 103.131(b)(3). (5) Regularly report to the Fund about measures taken, results obtained and Customers for which identities cannot be verified under (1)-(4) above. (6) If Transfer Agent provides services by which prospective Customers may subscribe for shares in the Fund via the Internet, telephone or application that is mailed to Transfer Agent, work with the Fund to notify prospective Customers, consistent with 31 CFR 103.131(b)(5), about the Fund's ’s CIP. (7) Timely file suspicious activity reports ("“SARs"”) with its or its affiliates' ’ primary federal regulator, maintain the required records in compliance with 31 CFR 000.00 xxx xx xxxx 103.18 and at such time as applicable regulations are changed to permit such, Transfer Agent shall submit a copy of the filed SAR to the Fund within 30 days of its filing. (8) Not later than 15 calendar days after Transfer Agent reasonably determines that Customer transactions or activity is suspicious, report such information in reasonable detail to the Fund. (9) Certify no less frequently than annually to the Fund in a form that is mutually acceptable to the Fund and the Transfer Agent that Transfer Agent has implemented its anti-money laundering program, and that it will perform the specific requirements for the Fund discussed in this Agreement and as the Fund is required under 31 CFR 103.131. (10) Set forth on a separate fee schedule compensation amounts due for these CIP Services. Notwithstanding anything to the contrary, and without expanding the scope of the express language above, Transfer Agent need not collect the Data Elements for (or verify) prospective Customers beyond the requirements of 31 CFR 103.131 (for example Transfer Agent will not verify customers opening accounts through NSCC). Notwithstanding anything above to the contrary, Transfer Agent need not perform any of the steps in provisions (1)-(10) above (or any CIP measures) with respect to any Customer who becomes a Customer of a fund ("“Fund A"”) via exchange from another fund ("“Fund B"”) in accordance with the Customer's ’s privilege to exchange shares of Fund B for Fund A, provided that the other Fund B is within the same family of funds as may be provided to the Transfer Agent from time to time. Transfer Agent agrees that it will permit federal or state examiners to inspect the (i) Funds' ’ information and records pertaining to the anti-money laundering ("“AML"”) program and CIP activities on behalf of the aforementioned funds and (ii) Transfer Agent's ’s AML services program. Transfer Agent agrees that any AML information provided by or requested from Funds to Transfer Agent will be maintained by Transfer Agent and will be disclosed by Transfer Agent to its employees and agents on a need to know basis or to governmental authorities.

CIP Services. So that each Fund will comply with its Customer Identification Program (which the Fund is required “CIP”) pursuant to have under regulations issued under Section 326 of the USA PATRIOT Act), Co-Transfer Agent will do shall perform the followingfollowing functions: (1) Implement procedures under which new accounts in the Fund are not established unless Co-Transfer Agent has obtained the name, date of birth (for natural persons only), physical address and government-issued identification number (collectively, the "“Data Elements"”) for each corresponding Customer (as defined in 31 CFR 103.131). (2) Use collected Data Elements to attempt to reasonably verify the identity of each new Customer promptly before or within a reasonable time (generally not in excess of thirty days) after each corresponding new account is opened. Methods will In compliance with Customer Identification Program regulations, methods shall consist of non-documentary methods (for which Co-Transfer Agent may use unaffiliated information vendors to assist with such verifications, providing that (i) Transfer Agent's the contract with such vendor under which the Co-Transfer Agent conducts non-documentary methods requires the vendor to keep and maintain the confidentiality of any information provided by or obtained about a Customer and (ii) Co-Transfer Agent has and continues to forma form a reasonable belief that such vendors will maintain the confidentiality of any information so described in (i) and documentary methods (both of which Co-Transfer Agent believes will meet the minimum requirements to comply with 31 CFR 13.131(b)(2103.131(b)(2) or any amendment thereof), and may include procedures under which Co-Transfer Agent personnel conduct additional research to attempt to reasonably verify the identity of Customers who were not verified by Co-Transfer Agent's ’s initial attempt. (3) Determine whether the Customer's ’s name appears on any list relevant lists of known or suspected terrorists or terrorist organizations issued by any applicable federal government agency agencies and designated as such by the Department of Treasury in consultation with the federal functional regulators. (4) Record the Data Elements in an electronic repository (or other manner that satisfies the regulation and allows for reasonably easy and prompt retrieval of the Data Elements) designed for this purpose and maintain records relating to verification of new Customers consistent with 31 CFR 103.131(b)(3). (5) Regularly report Report regularly to the Fund about measures taken, results obtained and Customers for which identities cannot be verified under paragraphs (1)-(4) above. (6) If Co-Transfer Agent provides services by which prospective Customers may subscribe for shares in the Fund via the Internet, by telephone or by application that is mailed to Co-Transfer Agent, Co-Transfer Agent shall work with the Fund to notify prospective Customers, consistent with 31 CFR 103.131(b)(5), about the Fund's ’s CIP. (7) Timely file suspicious activity reports ("“SARs") with its or its affiliates' primary federal regulator”), maintain the required records in compliance with 31 CFR 000.00 xxx xx xxxx time as applicable regulations are changed to permit such, Transfer Agent shall 103.15 and submit a copy of the filed SAR to the Fund within 30 days of its filing. (8) Not later than 15 calendar days after Consistent with CIP regulations and the August 11, 2003 Guidance from the Staffs of the Department of the Treasury and the U.S. Securities and Exchange Commission (the “August 11, 2003 Guidance”), the Co-Transfer Agent reasonably determines is not required to verify the identity of the customers of a broker-dealer or other financial intermediary that Customer transactions or activity is suspicious, report such information in reasonable detail to purchases shares of a Fund by opening an account for the intermediary through the Fund/SERV system operated by the National Securities Clearing Corporation. (9) Certify no less frequently than annually Consistent with CIP regulations and the August 11, 2003 Guidance, the Co-Transfer Agent is not required to verify the identity of a customer having an existing account with a Fund when such customer purchases shares from, or exchanges shares with, a Fund with which the customer has exchange privileges and such Fund is advised by Xxxx Xxxxx Partners Fund Advisor, LLC or an affiliate, Provided however, that the Fund in a form that is mutually acceptable to has furnished the Fund and the Co-Transfer Agent that Transfer Agent has implemented its anti-money laundering program, and that it will perform the specific requirements for the Fund discussed in this Agreement and as the Fund is required under 31 CFR 103.131with a list of such Funds. (10) Set forth on a separate fee schedule compensation amounts due for these CIP Services. Notwithstanding anything to the contrary, and without expanding the scope of the express language above, Transfer Agent need not collect the Data Elements for (or verify) prospective Customers beyond the requirements of 31 CFR 103.131 (for example Transfer Agent will not verify customers opening accounts through NSCC). Notwithstanding anything above to the contrary, Transfer Agent need not perform any of the steps in provisions (1)-(10) above (or any CIP measures) with respect to any Customer who becomes a Customer of a fund ("Fund A") via exchange from another fund ("Fund B") in accordance with the Customer's privilege to exchange shares of Fund B for Fund A, provided that the other Fund B is within the same family of funds as may be provided to the Transfer Agent from time to time. Transfer Agent agrees that it will permit federal or state examiners to inspect the (i) Funds' information and records pertaining to the anti-money laundering ("AML") program and CIP activities on behalf of the aforementioned funds and (ii) Transfer Agent's AML services program. Transfer Agent agrees that any AML information provided by or requested from Funds to Transfer Agent will be maintained by Transfer Agent and will be disclosed by Transfer Agent to its employees and agents on a need to know basis or to governmental authorities.

CIP Services. So that each Fund will comply with its Customer Identification Program (which the Fund is required “CIP”) pursuant to have under regulations issued under Section 326 of the USA PATRIOT Act), Co-Transfer Agent will do shall perform the followingfollowing functions: (1) Implement procedures under which new accounts in the Fund are not established unless Co-Transfer Agent has obtained the name, date of birth (for natural persons only), physical address and government-issued identification number (collectively, the "“Data Elements"”) for each corresponding Customer (as defined in 31 CFR 103.131)) . (2) Use collected Data Elements to attempt to reasonably verify the identity of each new Customer promptly before or within a reasonable time (generally not in excess of thirty days) after each corresponding new account is opened. Methods will In compliance with Customer Identification Program regulations, methods shall consist of non-documentary methods (for which Co-Transfer Agent may use unaffiliated information vendors to assist with such verifications, providing that (i) Transfer Agent's the contract with such vendor under which the Co-Transfer Agent conducts non-documentary methods requires the vendor to keep and maintain the confidentiality of any information provided by or obtained about a Customer and (ii) Co-Transfer Agent has and continues to forma form a reasonable belief that such vendors will maintain the confidentiality of any information so described in (i) and documentary methods (both of which Co-Transfer Agent believes will meet the minimum requirements to comply with 31 CFR 13.131(b)(2103.131(b)(2) or any amendment thereof), and may include procedures under which Co-Transfer Agent personnel conduct additional research to attempt to reasonably verify the identity of Customers who were not verified by Co-Transfer Agent's ’s initial attempt. (3) Determine whether the Customer's ’s name appears on any list relevant lists of known or suspected terrorists or terrorist organizations issued by any applicable federal government agency agencies and designated as such by the Department of Treasury in consultation with the federal functional regulators. (4) Record the Data Elements in an electronic repository (or other manner that satisfies the regulation and allows for reasonably easy and prompt retrieval of the Data Elements) designed for this purpose and maintain records relating to verification of new Customers consistent with 31 CFR 103.131(b)(3). (5) Regularly report Report regularly to the Fund about measures taken, results obtained and Customers for which identities cannot be verified under paragraphs (1)-(4) above. (6) If Co-Transfer Agent provides services by which prospective Customers may subscribe for shares in the Fund via the Internet, by telephone or by application that is mailed to Co-Transfer Agent, Co-Transfer Agent shall work with the Fund to notify prospective Customers, consistent with 31 CFR 103.131(b)(5), about the Fund's ’s CIP. (7) Timely file suspicious activity reports ("“SARs") with its or its affiliates' primary federal regulator”), maintain the required records in compliance with 31 CFR 000.00 xxx xx xxxx time as applicable regulations are changed to permit such, Transfer Agent shall 103.15 and submit a copy of the filed SAR to the Fund within 30 days of its filing. (8) Not later than 15 calendar days after Consistent with CIP regulations and the August 11, 2003 Guidance from the Staffs of the Department of the Treasury and the U.S. Securities and Exchange Commission (the “August 11, 2003 Guidance”), the Co-Transfer Agent reasonably determines is not required to verify the identity of the customers of a broker-dealer or other financial intermediary that Customer transactions or activity is suspicious, report such information in reasonable detail to purchases shares of a Fund by opening an account for the intermediary through the Fund/SERV system operated by the National Securities Clearing Corporation. (9) Certify no less frequently than annually Consistent with CIP regulations and the August 11, 2003 Guidance, the Co-Transfer Agent is not required to verify the identity of a customer having an existing account with a Fund when such customer purchases shares from, or exchanges shares with, a Fund with which the customer has exchange privileges and such Fund is advised by Xxxx Xxxxx Partners Fund Advisor, LLC or an affiliate, Provided however, that the Fund in a form that is mutually acceptable to has furnished the Fund and the Co-Transfer Agent that Transfer Agent has implemented its anti-money laundering program, and that it will perform the specific requirements for the Fund discussed in this Agreement and as the Fund is required under 31 CFR 103.131with a list of such Funds. (10) Set forth on a separate fee schedule compensation amounts due for these CIP Services. Notwithstanding anything to the contrary, and without expanding the scope of the express language above, Transfer Agent need not collect the Data Elements for (or verify) prospective Customers beyond the requirements of 31 CFR 103.131 (for example Transfer Agent will not verify customers opening accounts through NSCC). Notwithstanding anything above to the contrary, Transfer Agent need not perform any of the steps in provisions (1)-(10) above (or any CIP measures) with respect to any Customer who becomes a Customer of a fund ("Fund A") via exchange from another fund ("Fund B") in accordance with the Customer's privilege to exchange shares of Fund B for Fund A, provided that the other Fund B is within the same family of funds as may be provided to the Transfer Agent from time to time. Transfer Agent agrees that it will permit federal or state examiners to inspect the (i) Funds' information and records pertaining to the anti-money laundering ("AML") program and CIP activities on behalf of the aforementioned funds and (ii) Transfer Agent's AML services program. Transfer Agent agrees that any AML information provided by or requested from Funds to Transfer Agent will be maintained by Transfer Agent and will be disclosed by Transfer Agent to its employees and agents on a need to know basis or to governmental authorities.

CIP Services. So that each Fund will comply with its Customer Identification Program (which the Fund is required to have under regulations issued under Section 326 of the USA PATRIOT Act), Transfer Agent will do the following: (1) Implement procedures under which new accounts in the Fund are not established unless Transfer Agent has obtained the name, date of birth (for natural persons only), address and government-issued identification number (collectively, the "Data Elements") for each corresponding Customer (as defined in 31 CFR 103.131). (2) Use collected Data Elements to attempt to reasonably verify the identity of each new Customer promptly before or within a reasonable time (generally not in excess of thirty days) after each corresponding new account is opened. Methods will consist of non-documentary methods (for which Transfer Agent may use unaffiliated information vendors to assist with such verifications, providing that (i) Transfer Agent's contract with such vendor requires the vendor to keep and maintain the confidentiality of any information provided by or obtained about a Customer and (ii) Transfer Agent has and continues to forma reasonable belief that such vendors will maintain the confidentiality of any information so described in (i) and documentary methods (both of which Transfer Agent believes will meet the minimum requirements to comply with 31 CFR 13.131(b)(2) or any amendment thereof), and may include procedures under which Transfer Agent personnel conduct additional research to attempt to reasonably verify the identity of Customers who were not verified by Transfer Agent's initial attempt. (3) Determine whether the Customer's name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of Treasury in consultation with the federal functional regulators. (4) Record the Data Elements in an electronic repository (or other manner that satisfies the regulation and allows for reasonably easy and prompt retrieval of the Data Elements) designed for this purpose and maintain records relating to verification of new Customers consistent with 31 CFR 103.131(b)(3). (5) Regularly report to the Fund about measures taken, results obtained and Customers for which identities cannot be verified under (1)-(4) above. (6) If Transfer Agent provides services by which prospective Customers may subscribe for shares in the Fund via the Internet, telephone or application that is mailed to Transfer Agent, work with the Fund to notify prospective Customers, consistent with 31 CFR 103.131(b)(5), about the Fund's CIP. (7) Timely file suspicious activity reports ("SARs") with its or its affiliates' primary federal regulator, maintain the required records in compliance with 31 CFR 000.00 xxx xx xxxx 103.18 and at such time as applicable regulations are changed to permit such, Transfer Agent shall submit a copy of the filed SAR to the Fund within 30 days of its filing. (8) Not later than 15 calendar days after Transfer Agent reasonably determines that Customer transactions or activity is suspicious, report such information in reasonable detail to the Fund. (9) Certify no less frequently than annually to the Fund in a form that is mutually acceptable to the Fund and the Transfer Agent that Transfer Agent has implemented its anti-money laundering program, and that it will perform the specific requirements for the Fund discussed in this Agreement and as the Fund is required under 31 CFR 103.131. (10) Set forth on a separate fee schedule compensation amounts due for these CIP Services. Notwithstanding anything to the contrary, and without expanding the scope of the express language above, Transfer Agent need not collect the Data Elements for (or verify) prospective Customers beyond the requirements of 31 CFR 103.131 (for example Transfer Agent will not verify customers opening accounts through NSCC). Notwithstanding anything above to the contrary, Transfer Agent need not perform any of the steps in provisions (1)-(10) above (or any CIP measures) with respect to any Customer who becomes a Customer of a fund ("Fund A") via exchange from another fund ("Fund B") in accordance with the Customer's privilege to exchange shares of Fund B for Fund A, provided that the other Fund B is within the same family of funds as may be provided to the Transfer Agent from time to time. Transfer Agent agrees that it will permit federal or state examiners to inspect the (i) Funds' information and records pertaining to the anti-money laundering ("AML") program and CIP activities on behalf of the aforementioned funds and (ii) Transfer Agent's AML services program. Transfer Agent agrees that any AML information provided by or requested from Funds to Transfer Agent will be maintained by Transfer Agent and will be disclosed by Transfer Agent to its employees and agents on a need to know basis or to governmental authorities.

CIP Services. So that each Fund will comply with its Customer Identification Program (which the Fund is required to have under regulations issued under Section 326 of the USA PATRIOT Act), Transfer Agent will do the following: (1) Implement procedures under which new accounts in the Fund are not established unless Transfer Agent has obtained the name, date of birth (for natural persons only), address and government-issued identification number (collectively, the "Data Elements") for each corresponding Customer (as defined in 31 CFR 103.131)) . (2) Use collected Data Elements to attempt to reasonably verify the identity of each new Customer promptly before or within a reasonable time (generally not in excess of thirty days) after each corresponding new account is opened. Methods will consist of non-documentary methods (for which Transfer Agent may use unaffiliated information vendors to assist with such verifications, providing that (i) Transfer Agent's contract with such vendor requires the vendor to keep and maintain the confidentiality of any information provided by or obtained about a Customer and (ii) Transfer Agent has and continues to forma reasonable belief that such vendors will maintain the confidentiality of any information so described in (i) and documentary methods (both of which Transfer Agent believes will meet the minimum requirements to comply with 31 CFR 13.131(b)(2) or any amendment thereof), and may include procedures under which Transfer Agent personnel conduct additional research to attempt to reasonably verify the identity of Customers who were not verified by Transfer Agent's initial attempt. (3) Determine whether the Customer's name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of Treasury in consultation with the federal functional regulators. (4) Record the Data Elements in an electronic repository (or other manner that satisfies the regulation and allows for reasonably easy and prompt retrieval of the Data Elements) designed for this purpose and maintain records relating to verification of new Customers consistent with 31 CFR 103.131(b)(3). (5) Regularly report to the Fund about measures taken, results obtained and Customers for which identities cannot be verified under (1)-(4) above. (6) If Transfer Agent provides services by which prospective Customers may subscribe for shares in the Fund via the Internet, telephone or application that is mailed to Transfer Agent, work with the Fund to notify prospective Customers, consistent with 31 CFR 103.131(b)(5), about the Fund's CIP. (7) Timely file suspicious activity reports ("SARs") with its or its affiliates' primary federal regulator, maintain the required records in compliance with 31 CFR 000.00 xxx xx xxxx 103.18 and at such time as applicable regulations are changed to permit such, Transfer Agent shall submit a copy of the filed SAR to the Fund within 30 days of its filing. (8) Not later than 15 calendar days after Transfer Agent reasonably determines that Customer transactions or activity is suspicious, report such information in reasonable detail to the Fund. (9) Certify no less frequently than annually to the Fund in a form that is mutually acceptable to the Fund and the Transfer Agent that Transfer Agent has implemented its anti-money laundering program, and that it will perform the specific requirements for the Fund discussed in this Agreement and as the Fund is required under 31 CFR 103.131. (10) Set forth on a separate fee schedule compensation amounts due for these CIP Services. Notwithstanding anything to the contrary, and without expanding the scope of the express language above, Transfer Agent need not collect the Data Elements for (or verify) prospective Customers beyond the requirements of 31 CFR 103.131 (for example Transfer Agent will not verify customers opening accounts through NSCC). Notwithstanding anything above to the contrary, Transfer Agent need not perform any of the steps in provisions (1)-(10) above (or any CIP measures) with respect to any Customer who becomes a Customer of a fund ("Fund A") via exchange from another fund ("Fund B") in accordance with the Customer's privilege to exchange shares of Fund B for Fund A, provided that the other Fund B is within the same family of funds as may be provided to the Transfer Agent from time to time. Transfer Agent agrees that it will permit federal or state examiners to inspect the (i) Funds' information and records pertaining to the anti-money laundering ("AML") program and CIP activities on behalf of the aforementioned funds and (ii) Transfer Agent's AML services program. Transfer Agent agrees that any AML information provided by or requested from Funds to Transfer Agent will be maintained by Transfer Agent and will be disclosed by Transfer Agent to its employees and agents on a need to know basis or to governmental authorities.