Compliance Policies and Procedures. To assist the Fund in complying with Rule 38a-1 of the 1940 Act, BBH&Co. represents that it has adopted written policies and procedures reasonably designed to prevent violation of the federal securities laws in fulfilling its obligations under the Agreement and that it has in place a compliance program to monitor its compliance with those policies and procedures. BBH&Co will upon request provide the Fund with information about our compliance program as mutually agreed.
Compliance Policies and Procedures. The Subadviser shall promptly provide The Vantagepoint Funds’ Chief Compliance Officer (“CCO”), upon request, copies of its policies and procedures for compliance by the Subadviser and the Fund with the Federal Securities Laws as defined in Rule 38a-1 under the 1940 Act and promptly provide the CCO with copies of any material changes to those policies and procedures. The Subadviser shall fully cooperate with the CCO as to facilitate the CCO’s performance of his/her responsibilities under Rule 38a-1 to review, evaluate and report to The Vantagepoint Funds’ Board of Directors on the operation of the Subadviser’s compliance policies and procedures and shall promptly report to the CCO any “Material Compliance Matter” as defined by Rule 38a-1(e)(2). At least annually, the Subadviser shall provide a certification to the CCO to the effect that the Subadviser has in place and has implemented policies and procedures that are reasonably designed to ensure compliance by the Fund and the Subadviser with the Federal Securities Laws.
Compliance Policies and Procedures. To assist the Custodian in complying with Rule 38a-1 of the 1940 Act, the Company represents that it has adopted written policies and procedures reasonably designed to prevent violation of the federal securities laws in fulfilling its obligations under the Agreement and that it has in place a compliance program to monitor its compliance with those policies and procedures. The Company will upon request provide the Custodian with information about our compliance program as mutually agreed.
Compliance Policies and Procedures. To assist the Custodian in complying with Rule 38a-1 of the 1940 Act, Trust represents that it has adopted written policies and procedures reasonably designed to prevent violation of the federal securities laws in fulfilling its obligations under the Agreement and that it has in place a compliance program to monitor its compliance with those policies and procedures. Trust will upon request provide the Custodian with information about our compliance program as mutually agreed.
Compliance Policies and Procedures. To assist the Trust in complying with Rule 38a-1 of the 1940 Act, BBH&Co. represents that it has adopted written policies and procedures reasonably designed to prevent violation of the federal securities laws in fulfilling its obligations under the Agreement and that it has in place a compliance program to monitor its compliance with those policies and procedures. BBH&Co will upon request provide the Trust with information about our compliance program as mutually agreed.
Compliance Policies and Procedures. To assist the Fund in complying with Rule 38a-1 of the 1940 Act, the Custodian represents that it has adopted written policies and procedures reasonably designed to prevent violation of the federal securities laws in fulfilling its obligations under the Agreement and that it has in place a compliance program to monitor its compliance with those policies and procedures. The Custodian will upon request provide the Fund with information about our compliance program as mutually agreed.
Compliance Policies and Procedures. The Adviser shall have, in accordance with Rule 206(4)-7 under the Advisers Act, adopted and implemented written policies and procedures reasonably designed to prevent violation by the Adviser and its supervised persons of the Advisers Act and rules thereunder. The Adviser shall provide the Trust’s Chief Compliance Officer with copies of such written policies and procedures, and any amendments thereto, upon request. The Adviser shall review, at least annually, the adequacy of its written policies and procedures and the effectiveness of their implementation, and the Adviser shall provide the Trust’s Chief Compliance Officer with a summary of such annual review upon request.
Compliance Policies and Procedures. To assist the Fund in complying with Rule 38a-1 of the 1940 Act, the Administrator represents that it has adopted written policies and procedures reasonably designed to prevent violation of the federal securities laws in fulfilling its obligations under the Agreement and that it has in place a compliance program to monitor its compliance with those policies and procedures. BBH&Co will upon request provide the Fund with information about our compliance program as mutually agreed.
Compliance Policies and Procedures. The Subadviser shall promptly provide The Vantagepoint Funds’ Chief Compliance Officer (“CCO”), upon request, copies or written summaries of its policies and procedures for compliance by the Subadviser and the Fund with the Federal Securities Laws as defined in Rule 38a-1 under the 1940 Act and promptly provide the CCO with copies or a summary of any material changes to those policies and procedures. The Subadviser shall fully cooperate with the CCO as to facilitate the CCO’s performance of his/her responsibilities under Rule 38a-1 to review, evaluate and report to The Vantagepoint Funds’ Board of Directors on the operation of the Subadviser’s compliance policies and procedures and shall promptly report to the CCO any “Material Compliance Matter” as defined by Rule 38a-1(e)(2). At least annually, the Subadviser shall provide a certification to the CCO to the effect that the Subadviser has in place and has implemented policies and procedures that are reasonably designed to ensure compliance by the Fund and the Subadviser with the Federal Securities Laws.
Compliance Policies and Procedures. To assist the Company in complying with Rule 38a-1 of the 1940 Act, the Custodian shall provide the Company annually with the written report of an independent accountant engaged by the Custodian to conduct of an attestation examination with respect to the Custodian's internal controls over compliance which will report on the suitability of the design, at the end of a specified period, and the operating effectiveness, during the specified period, of the Custodian's controls in achieving compliance control objectives (i.e. a SOC 1 – System and Organization Controls for Service Organizations report) . The Custodian will upon request provide the Company with further information about the Custodian's compliance program in the form of responses to the Company's annual compliance review questionnaire, and otherwise as mutually agreed.
