Common use of Omnibus Account Transaction Monitoring Clause in Contracts

Omnibus Account Transaction Monitoring. If the optional Rule 22c-2 support services are to be provided with respect to a Fund, perform the following with respect to omnibus Shareholder accounts: (a) Identify omnibus Shareholder accounts; (b) Analyze trading activity to determine if arbitrage opportunities exist triggering underlying account transaction data request of an intermediary; (c) Manage the request and flow of underlying data; (d) Customize file feed/format translations; (e) Store underlying account transaction data; (f) Apply each Fund's market timing rules upon receipt of the underlying account transaction data to flag violations; (g) Report "red flag" violations to the applicable Fund and CCO; and (h) Provide standard report package for on-going review and monitoring of data.

Omnibus Account Transaction Monitoring. If the optional Rule 22c-2 support services are to be provided with respect to a Fund, perform the following with respect to omnibus Shareholder accounts: (a) Identify omnibus Shareholder accounts; (b) Analyze trading activity to determine if arbitrage opportunities exist triggering underlying account transaction data request of an intermediary; (c) Manage the request and flow of underlying data; (d) Customize file feed/format translations; (e) Store underlying account transaction data; (f) Apply each Fund's ’s market timing rules upon receipt of the underlying account transaction data to flag violations; (g) Report "“red flag" ” violations to the applicable Fund and CCO; and (h) Provide standard report package for on-going review and monitoring of data.

Omnibus Account Transaction Monitoring. If the optional Rule 22c-2 support services are to be provided with respect to a Fund, perform the following with respect to omnibus Shareholder accountsservices: (a) Identify omnibus Shareholder accounts;Omnibus account identification. (b) Analyze Analysis of omnibus account trading activity to determine if arbitrage opportunities exist triggering underlying account transaction data request of an intermediary;. (c) Manage Managing the request and flow of underlying data;. (d) Customize Customized file feed/format translations;. (e) Store Storage of underlying account transaction data;. (f) Apply Applying each Fund's market timing rules upon receipt of the underlying account transaction data to flag violations;. (g) Report Reporting of "red flag" violations to the applicable Fund and CCO; and. (h) Provide Providing standard report package for on-going review and monitoring of data.