Common use of Compliance Services Clause in Contracts

Compliance Services. (a) Subject to the approval of the Board, Ultimus shall make available a qualified person to act as the CCO who is competent and knowledgeable regarding the federal securities laws. Ultimus’ responsibility for the activities of the CCO is limited to the extent that the Board shall make all decisions regarding the designation and termination of the CCO as provided by Rule 38a-1. The CCO shall: (i) Report directly to the Board; (ii) Review and administer the Fund’s compliance program policies and procedures; (iii) Review at least annually the adequacy of the policies and procedures of the Fund and the effectiveness of their implementation; (iv) Establish a quarterly reporting process to the Board on the administration and enforcement of the Fund’s compliance program and attend regularly scheduled board meetings as well as special meetings on an as-needed basis; and (v) Prepare a written annual report for the Board that, at a minimum, addresses (1) the operation of the Fund since the last report to the Board; (2) any material changes to such policies and procedures since the last report; (3) any recommendations for material changes to the policies and procedures as a result of the periodic or annual reviews; and (4) any “Material Compliance Matters” (as defined in Rule 38a-1) since the date of the last report. (b) Ultimus Shall: (i) Work with Fund counsel and the Fund’s administrator to create and maintain investment company policies and procedures as required under Rule 38a-1 of the 1940 Act; (ii) Review compliance procedures for service providers to the Trust for compliance with Rule 38a-1; (iii) Assist the CCO in the preparation of the Annual Review of the Trust’s compliance procedures as well as those of each service provider and provide test results and recommendations to the CCO; (iv) Conduct due diligence of the key service providers to the Trust and document test results and recommendations to the CCO; (v) Maintain work papers and testing results as part of required books and records of the Fund; (vi) Periodically monitor Fund portfolio purchases and holdings with respect to the investment objectives, restrictions and limitations stated in the Fund’s registration statement; (vii) Periodically test that SEC filings are made and are maintained as part of the required books and records of the Fund; (viii) Assist in the review of communications with the public not otherwise required by the Distributor; (ix) Subject to the approval of the Board, make available a qualified person to act as the Fund’s Anti-Money Laundering Compliance Officer who is competent and knowledgeable regarding the anti-money laundering rules and regulations applicable to the Fund. (x) Design testing methods for the Fund’s compliance program policies and procedures;

Compliance Services. (a) Subject to the approval of the Board, Ultimus Atlantic shall make available a qualified person to act as the Trust’s CCO who is competent and knowledgeable regarding the federal securities laws. Ultimus’ Atlantic’s responsibility for the activities of the CCO is are limited to the extent that the Board shall make all decisions regarding the designation designation, termination, and termination level of compensation of the CCO as provided by Rule 38a-1. . (b) The CCO shall: (i) Report directly to the Board; (ii) Review and administer the FundTrust’s compliance program policies and procedures including those policies and procedures that provide for oversight of compliance by the Trust’s investment advisers, administrators (as that term is defined in Rule 0-1 of the 1940 Act), principal underwriters and transfer agent (collectively, “Service Providers”) that relate to the Trust; (iii) Conduct periodic reviews of the Trust’s compliance program to incorporate any new or changed regulations, best practice recommendations or other guidelines that may be appropriate; (iv) Review no less frequently than annually, the adequacy of the policies and procedures of the Trust and the Service Providers and the effectiveness of their implementation; (v) Apprise the Board of significant compliance events at the Trust or the Services Providers; (vi) Design testing methods for the Trust’s compliance program policies and procedures; (iiivii) Review at least annually Perform and document periodic testing of certain key control procedures (as appropriate to the adequacy circumstances), including reviewing reports, investigating exceptions, and making inquiries of the policies Trust management and procedures of the Fund and the effectiveness of their implementationService Providers; (ivviii) Conduct periodic site visits to Service Providers as necessary; (ix) Provide training and deliver updates to the Trust or the Service Providers, as necessary; (x) Establish a quarterly reporting process to the Board on the administration Board, including both written and enforcement of the Fund’s compliance program oral reports and attend regularly scheduled board meetings as well as special meetings on an as-needed basis; and; (vxi) Prepare a written annual report for the Board that, at a minimum, addresses address (1A) the operation of the Fund Trust’s and its Service Providers’ policies and procedures since the last report to the Board; (2B) any material changes to such policies and procedures since the last report; (3C) any recommendations for material changes to the policies and procedures as a result of the periodic or annual reviewsreviews referred to in Sections 2(b)(iii) and (iv) above; and (4D) any “Material Compliance Mattersmaterial compliance matters” (as defined in Rule 38a-1) since the date of the last report; and (xii) No less than annually, meet separately with the Trust’s independent Trustees. (bc) Ultimus ShallAtlantic shall: (i) Work with Fund counsel Provide compliance support for intermediary agreements that pertain to the Trust, such as shareholder service and the Fund’s administrator to create and maintain investment company policies and procedures as required under Rule 38a-1 of the 1940 Actsimilar service agreements; (ii) Review compliance procedures for service providers to the Trust for compliance with Rule 38a-1; (iii) Assist the CCO in the preparation of the Annual Review of the Trust’s compliance procedures as well as those of each service provider and provide test results and recommendations to the CCO; (iv) Conduct due diligence of the key service providers to the Trust and document test results and recommendations to the CCO; (v) Maintain work papers and testing results as part of required books and records of the Fund; (vi) Periodically monitor Fund portfolio purchases and holdings with respect to the investment objectives, restrictions and limitations stated in the Fund’s registration statement; (vii) Periodically test that SEC filings are made and are maintained as part of the required books and records of the Fund; (viii) Assist in the review of communications with the public not otherwise required by the Distributor; (ix) Subject to the approval of the Board, make available a qualified person to act as the FundTrust’s Anti-Money Laundering Compliance Officer who is competent and knowledgeable regarding the anti-money laundering rules and regulations applicable to mutual funds; and (iii) Assist the FundTrust with compliance matters as requested. (xd) Design testing methods for Atlantic shall, subject to the Fundapproval of the Board, make available qualified persons who are competent and knowledgeable regarding the management and internal controls of the Trust to serve as (i) the Trust’s Chief Financial Officer, who will have the authority normally incident to such office, including the authority to execute documents required to be executed by the Trust’s “principal financial officer” (PFO), and the Trust’s Treasurer, who will have the authority normally incident to such office including the authority to execute documents required to be executed by the Trust’s Treasurer. (e) Atlantic shall provide such other services and assistance relating to the affairs of the Trust as the Trust may, from time to time, reasonably request pursuant to mutually acceptable compensation and implementation agreements. (f) Atlantic shall maintain records relating to its services, such as compliance program policies and procedures;, relevant Board presentations, annual reviews, and other records, as are required to be maintained under the 1940 Act and Rule 38a-1 thereunder, as well as under the USA PATRIOT Act. Such reports shall be maintained in the manner and for the periods as are required under the applicable rule or regulation. (g) Atlantic will coordinate reasonable Trust Disclosure Controls and Procedures, including coordination of receipt of Trust service provider certifications, and applicable meetings as required by the procedures.

Compliance Services. The Service Provider shall provide FAFLIC with the following compliance services: (a) Subject to any restrictions set forth in the Agreement, the development and filing of policy forms, riders, endorsements, and disclosure statements as may be required from time to time by Applicable Law; (b) Filing of rate changes, as required; (c) Subject to receiving all information and records from FAFLIC reasonably necessary to prepare such data, preparation and submission of(and provision of financial data required for) all reports required by or data requests of the SEC (including, without limitation, forms N-SAR and N-CSR, 485(b) registration statement updates, fund and Registered Separate Account annual reports and 24f-2 Notices), the NASD (including, without limitation, compilation of information, if any, related to the Contracts that would be reflected in any quarterly schedule 1 or Customer Complaints Rule 3070 Report), and the states (in each case only after review and approval thereof by FAFLIC), with all of the foregoing to be accomplished within such time periods as are necessary to comply with Applicable Law after giving allowance, in the cases of information relevant to reports of filings of FAFLIC that are not specific to the Contracts, for time periods reasonably specified by FAFLIC to permit integration of the subject information related to the Contracts; (d) Provide data to Xxxx Xxxx Investments, Inc. ("Xxxx Xxxx") reasonably necessary for Xxxx Xxxx, and available to the Service Provider, to prepare and submit quarterly FOCUS II/IIA and annual FOCUS reports. (e) Review and approval of customer communications by appropriately licensed personnel; (f) Coordination of mailings in respect of Contracts required by Applicable Law or contract forms, including, among other things, the Board, Ultimus shall make available a qualified person periodic mailing of privacy notices; (g) Subject to act as the CCO who is competent and knowledgeable regarding the federal securities laws. Ultimus’ responsibility for the activities provisions of Section 10.03 of the CCO is limited SPA, handling any written communication primarily expressing a grievance against FAFLIC or the Service Provider with respect to the extent that the Board shall make all decisions regarding the designation and termination of the CCO Contracts, as provided by Rule 38a-1. The CCO shallfollows: (i) Report directly to The Service Provider shall advise FAFLIC of any written customer complaint threatening the Boardcommencement of legal action or regulatory action or of any inquiry or complaint received from or forwarded by a state insurance department or other government agency, better business bureau or an attorney representing any customer within five (5) Business Days from receipt thereof, and shall, if requested by FAFLIC, provide FAFLIC with copies of all pertinent files and correspondence relating thereto; (ii) Review The Service Provider shall be responsible for the investigation and administer preparation of responses to all customer complaints and regulatory inquiries or complaints, provided that no response (other than acknowledging receipt of the Fund’s compliance program policies complaint) to a customer complaint threatening the commencement of legal action or regulatory action or an inquiry or complaint received from or forwarded by a state insurance department or other government agency, better business bureau or any attorney representing any customer shall be sent to said customer, government agency, better business bureau or attorney if FAFLIC promptly notifies the Service Provider that FAFLIC intends to respond to such complaint and proceduresthe Service Provider receives such notification prior to responding; (iii) Review at least annually the adequacy of the policies and procedures of the Fund and the effectiveness of their implementation; (iv) Establish a quarterly reporting process Subject to the Board on foregoing, all customer complaints shall be handled in accordance with Applicable Law (including, without limitation, NASD requirements and any response time requirements applicable thereto); the administration and enforcement Service Provider shall provide written acknowledgment of the Fund’s compliance program and attend regularly scheduled board meetings as well as special meetings on an as-needed basis; and (v) Prepare a written annual report for the Board that, at a minimum, addresses such customer complaint within one (1) Business Day after receipt thereof and shall use best efforts to provide final response within ten (10) Business Days, unless otherwise required by Applicable Law or Order or the operation terms of the Fund since complaint; and a record of all customer complaints shall be maintained in a log showing the last report to date received, the Board; (2) any material changes to such policies and procedures since the last report; (3) any recommendations for material changes to the policies and procedures as a result nature of the periodic or annual reviews; complaint, the action taken (if any) and (4) any “Material Compliance Matters” (as defined in Rule 38a-1) since the date of the last report.response; (bh) Ultimus Shall:Drafting and filing registration statements and other SEC related documents, where required, and performing services necessary to meet SEC requirements and distributing all required prospectuses, post-effective amendments or supplements to the registration statements of the Registered Separate Accounts or of any underlying funds as well as annual and semi-annual reports; (i) Work Making all filings and obtaining all regulatory approvals required with Fund counsel and the Fund’s administrator regard to create and maintain investment company policies and procedures as required under Rule 38a-1 advertising of the 1940 ActContracts, including, without limitation, all filings and approvals required by Applicable Laws and NASD requirements (except to the extent that such services are performed by other entities pursuant to written agreements with FAFLIC); (iij) Review Providing regulatory supervision and compliance procedures for service providers to the Trust for compliance with Rule 38a-1; (iii) Assist the CCO in the preparation of the Annual Review of the Trust’s compliance procedures as well as those of each service provider and provide test results and recommendations to the CCO; (iv) Conduct due diligence of the key service providers to the Trust and document test results and recommendations to the CCO; (v) Maintain work papers and testing results as part of required books and records of the Fund; (vi) Periodically monitor Fund portfolio purchases and holdings with respect to the investment objectivesService Provider's employees, restrictions and limitations stated in to the Fund’s registration statementextent the Service Provider is legally permitted, as to all servicing functions contemplated by this Agreement; (viik) Periodically test that Ensuring SEC filings are made and are maintained as part NASD compliance for variable contracts, prospectuses, and registration statements including the submission of any required information; quarterly complaint reporting; and, the Service Provider and FAFLIC shall work together to develop appropriate practical procedures in light of the required books and records fact that FAFLIC is the legal owner of the FundSeparate Accounts, to comply with Section 38a-1 of the Investment Company Act of 1940 and provisions requiring annual compliance audits, in each case either by or at the expense of the Service Provider, but in any case only with respect to the Contracts and to the extent permitted by Law; (viii1) Assist Monitoring statutes and regulations of the insurance departments in the review of various states in which the policyholders or the Contracts are located to ensure compliance therewith and to ensure that any actions or communications with the public not otherwise required by the Distributorsuch regulations or statutes are properly made; (ix) Subject to the approval of the Board, make available a qualified person to act as the Fund’s Anti-Money Laundering Compliance Officer who is competent and knowledgeable regarding the anti-money laundering rules and regulations applicable to the Fund. (x) Design testing methods for the Fund’s compliance program policies and procedures;

Compliance Services. (a) Subject The Trust hereby appoints the Sub-Manager to administer the Trust’s compliance program, subject to the approval direction of the BoardBoard and the officers of the Trust, Ultimus shall for the period, in the manner, and on the terms hereinafter set forth. (i) The Sub-Manager shall, from time to time as requested by the Trust, make available a qualified person to act as the CCO who is competent and knowledgeable regarding the federal securities laws. Ultimus’ responsibility for laws to act as the activities CCO, subject to the approval of the CCO is limited to the extent that the Board. The Board shall make all decisions regarding the designation and termination of the CCO and shall review and approve the compensation of the CCO as provided by Rule 38a-1. The CCO shall: (i) Report directly to 38a-1 under the Board;1940 Act. (ii) Review The Sub-Manager and administer the Fund’s CCO will perform the following compliance program services: (1) develop, in consultation with counsel to the Trust (as necessary or appropriate), compliance policies and proceduresprocedures for the Trust designed to meet the requirements of Rule 38a-1; (iii2) Review at least annually in consultation with counsel to the Trust (as necessary or appropriate), conduct periodic reviews of the adequacy of the Trust’s compliance policies and procedures of the Fund and determine the effectiveness of their implementation; (iv3) Establish a quarterly reporting process in consultation with counsel to the Board on the administration and enforcement Trust (as necessary or appropriate), conduct periodic reviews of the Fund’s compliance program adequacy and attend regularly scheduled board meetings as well as special meetings on an as-needed basis; and (v) Prepare a written annual report for the Board that, at a minimum, addresses (1) the operation effectiveness of the Fund since the last report to the Board; (2) any material changes to such following service providers’ compliance policies and procedures since procedures: the last report; Manager, the Sub-Manager, any Money Manager, the distributor, the administrator and the transfer agent (3) any recommendations for material changes to the policies and procedures as a result of the periodic or annual reviews; and “Service Providers”); (4) any “Material Compliance Matters” (as defined in Rule 38a-1) since the date of the last report. (b) Ultimus Shall: (i) Work consultation with Fund counsel and the Fund’s administrator to create and maintain investment company policies and procedures as required under Rule 38a-1 of the 1940 Act; (ii) Review compliance procedures for service providers to the Trust for compliance with Rule 38a-1; (iii) Assist as necessary or appropriate), recommend the CCO in the preparation incorporation of the Annual Review of any new or amended regulations or “best practice” initiatives into the Trust’s compliance policies and procedures that may be appropriate; (5) evaluate the controls in place and any testing being performed by the Service Providers, of key fund compliance policies and procedures, which may include collecting and organizing relevant compliance data, reviewing reports, investigating exceptions, and making inquiries of Trust management and the Service Providers; (6) conduct on-site visits of the Service Providers as well as those appropriate in the discretion of each service provider and provide test results and recommendations to the CCO; (iv7) Conduct due diligence meet periodically with personnel of the key service providers to Service Providers, as appropriate in the Trust and document test results and recommendations to discretion of the CCO; (v) Maintain work papers 8) prepare quarterly and testing results annual CCO reports for the Board and attend Board and Board Committee meetings as part appropriate, which attendance may be by means of required books and records of the Fundvideoconference facilities; (vi9) Periodically monitor Fund portfolio purchases and holdings no less frequently than annually, meet separately with respect to those members of the investment objectives, restrictions and limitations stated in Board who are not “interested persons” of the Fund’s registration statementTrust; (vii10) Periodically test that SEC filings are made provide such other services and are maintained as part assistance relating to the affairs of the required books and records of Trust as the FundBoard may, from time to time, reasonably request in connection with the CCO’s compliance responsibilities; (viii11) Assist in maintain records relating to the review of communications with the public not otherwise compliance program as required by the Distributor; (ix) Subject to the approval of the Board, make available a qualified person to act as the Fund’s Anti-Money Laundering Compliance Officer who is competent applicable laws and knowledgeable regarding the anti-money laundering rules and regulations applicable to the Fundregulations. (xiii) Design testing methods In order for the Fund’s compliance program policies Sub-Manager to perform the services required by this Agreement, the Manager shall (1) instruct its personnel and procedures;all service providers, including the Service Providers, to furnish any and all information to the Sub-Manager as reasonably requested by the Sub-Manager or the CCO; and (2) ensure that the Sub-Manager and the CCO have timely access to all records and documents maintained by the Trust, the Manager or any other service provider, including the Service Providers.

Compliance Services. (a) Subject to the approval of the Board, Ultimus Atlantic shall make available a qualified person to act as the Fund’s CCO who is competent and knowledgeable regarding the federal securities laws. Ultimus’ Atlantic’s responsibility for the activities of the CCO is are limited to the extent that the Board shall make all decisions regarding the designation and termination termination, of the CCO as provided by Rule 38a-1. . (b) The CCO shall: (i) Report directly to the Board; (ii) Review and administer the Fund’s compliance program policies and procedures; (iii) Review at least annually Conduct periodic reviews of the Fund’s compliance program to incorporate any new or changed regulations, best practice recommendations or other guidelines that may be appropriate; (iv) Review, the adequacy of the policies and procedures of the Fund and the effectiveness of their implementation; (ivv) Establish a quarterly reporting process to Apprise the Board on of significant compliance events of the administration and enforcement of Fund; (vi) Design testing methods for the Fund’s compliance program policies and procedures; (vii) Perform and document periodic testing of certain key control procedures (as appropriate to the circumstances), including reviewing reports, investigating exceptions, and making inquiries of Fund management; (viii) Establish a reporting process to the Board, including both written and oral reports and attend regularly scheduled board meetings as well as special meetings on an as-needed basis; and (vix) Prepare a written annual report for the Board that, at a minimum, addresses address (1A) the operation of the Fund since the last report to the Board; (2B) any material changes to such policies and procedures since the last report; (3C) any recommendations for material changes to the policies and procedures as a result of the periodic or annual reviews; and (4D) any “Material Compliance Mattersmaterial compliance matters” (as defined in Rule 38a-1) since the date of the last report. (bc) Ultimus ShallAtlantic shall: (i) Work with Fund counsel and Provide compliance support for intermediary agreements that pertain to the Fund’s administrator to create , such as investor service and maintain investment company policies and procedures as required under Rule 38a-1 of the 1940 Actsimilar agreements; (ii) Review compliance procedures for service providers to the Trust for compliance with Rule 38a-1; (iii) Assist the CCO in the preparation of the Annual Review of the Trust’s compliance procedures as well as those of each service provider and provide test results and recommendations to the CCO; (iv) Conduct due diligence of the key service providers to the Trust and document test results and recommendations to the CCO; (v) Maintain work papers and testing results as part of required books and records of the Fund; (vi) Periodically monitor Fund portfolio purchases and holdings with respect to the investment objectives, restrictions and limitations stated in the Fund’s registration statement; (vii) Periodically test that SEC filings are made and are maintained as part of the required books and records of the Fund; (viii) Assist in the review of communications with the public not otherwise required by the Distributor; (ix) Subject to the approval of the Board, make available a qualified person to act as the Fund’s Anti-Money Laundering Compliance Officer who is competent and knowledgeable regarding the anti-money laundering rules and regulations applicable to the Fund; and (iii) Assist the Fund with compliance matters as requested. (xd) Design testing methods for Atlantic shall, subject to the approval of the Board, make available qualified persons who are competent and knowledgeable regarding the management and internal controls of the Fund to serve as (i) the Fund’s Chief Financial Officer, who will have the authority normally incident to such office, including the authority to execute documents required to be executed by the Fund’s “principal financial officer” (PFO), and the Fund’s Treasurer, who will have the authority normally incident to such office including the authority to execute documents required to be executed by the Fund’s Treasurer. (e) Atlantic shall provide such other services and assistance relating to the affairs of the Fund as the Fund may, from time to time, reasonably request pursuant to mutually acceptable compensation and implementation agreements. (f) Atlantic shall maintain records relating to its services, such as compliance program policies and procedures;, relevant Board presentations, annual reviews, and other records, as are required to be maintained under the 1940 Act and Rule 38a-1 thereunder, as well as under the USA PATRIOT Act. Such reports shall be maintained in the manner and for the periods as are required under the applicable rule or regulation. (g) Atlantic will coordinate reasonable Fund Disclosure Controls and Procedures, including coordination of receipt of Fund service provider certifications, and applicable meetings as required by the procedures.

Compliance Services. (a) Subject The Trust hereby appoints the Sub-Manager to administer the Trust’s compliance program, subject to the approval direction of the BoardBoard and the officers of the Trust, Ultimus shall for the period, in the manner, and on the terms hereinafter set forth. (i) The Sub-Manager shall, from time to time as requested by the Trust, make available a qualified person to act as the CCO who is competent and knowledgeable regarding the federal securities laws. Ultimus’ responsibility for laws to act as the activities CCO, subject to the approval of the CCO is limited to the extent that the Board. The Board shall make all decisions regarding the designation and termination of the CCO and shall review and approve the compensation of the CCO as provided by Rule 38a-1. The CCO shall: (i) Report directly to 38a-1 under the Board;1940 Act. (ii) Review The Sub-Manager and administer the Fund’s CCO will perform the following compliance program services: (1) develop, in consultation with counsel to the Trust (as necessary or appropriate), compliance policies and proceduresprocedures for the Trust designed to meet the requirements of Rule 38a-1; (iii2) Review at least annually in consultation with counsel to the Trust (as necessary or appropriate), conduct periodic reviews of the adequacy of the Trust’s compliance policies and procedures of the Fund and determine the effectiveness of their implementation; (iv3) Establish a quarterly reporting process in consultation with counsel to the Board on the administration and enforcement Trust (as necessary or appropriate), conduct periodic reviews of the Fund’s compliance program adequacy and attend regularly scheduled board meetings as well as special meetings on an as-needed basis; and (v) Prepare a written annual report for the Board that, at a minimum, addresses (1) the operation effectiveness of the Fund since the last report to the Board; (2) any material changes to such following service providers’ compliance policies and procedures since procedures: the last report; Manager, the Sub-Adviser, the Sub-Manager, any Money Manager, the distributor, the administrator and the transfer agent (3) any recommendations for material changes to the policies and procedures as a result of the periodic or annual reviews; and “Service Providers”); (4) any “Material Compliance Matters” (as defined in Rule 38a-1) since the date of the last report. (b) Ultimus Shall: (i) Work consultation with Fund counsel and the Fund’s administrator to create and maintain investment company policies and procedures as required under Rule 38a-1 of the 1940 Act; (ii) Review compliance procedures for service providers to the Trust for compliance with Rule 38a-1; (iii) Assist as necessary or appropriate), recommend the CCO in the preparation incorporation of the Annual Review of any new or amended regulations or “best practice” initiatives into the Trust’s compliance policies and procedures that may be appropriate; (5) evaluate the controls in place and any testing being performed by the Service Providers, of key fund compliance policies and procedures, which may include collecting and organizing relevant compliance data, reviewing reports, investigating exceptions, and making inquiries of Trust management and the Service Providers; (6) conduct on-site visits of the Service Providers as well as those appropriate in the discretion of each service provider and provide test results and recommendations to the CCO; (iv7) Conduct due diligence meet periodically with personnel of the key service providers to Service Providers, as appropriate in the Trust and document test results and recommendations to discretion of the CCO; (v) Maintain work papers 8) prepare quarterly and testing results annual CCO reports for the Board and attend Board and Board Committee meetings as part appropriate, which attendance may be by means of required books and records of the Fundvideoconference facilities; (vi9) Periodically monitor Fund portfolio purchases and holdings no less frequently than annually, meet separately with respect to those members of the investment objectives, restrictions and limitations stated in Board who are not “interested persons” of the Fund’s registration statementTrust; (vii10) Periodically test that SEC filings are made provide such other services and are maintained as part assistance relating to the affairs of the required books and records of Trust as the FundBoard may, from time to time, reasonably request in connection with the CCO’s compliance responsibilities; (viii11) Assist in maintain records relating to the review of communications with the public not otherwise compliance program as required by the Distributor; (ix) Subject to the approval of the Board, make available a qualified person to act as the Fund’s Anti-Money Laundering Compliance Officer who is competent applicable laws and knowledgeable regarding the anti-money laundering rules and regulations applicable to the Fundregulations. (xiii) Design testing methods In order for the Fund’s compliance program policies Sub-Manager to perform the services required by this Agreement, the Manager and procedures;Sub-Adviser each shall (1) instruct its personnel and all service providers, including the Service Providers, to furnish any and all information to the Sub-Manager as reasonably requested by the Sub-Manager or the CCO; and (2) ensure that the Sub-Manager and the CCO have timely access to all records and documents maintained by the Trust, the Manager or any other service provider, including the Service Providers.