Common use of Rule 38a-1 Compliance Program Clause in Contracts

Rule 38a-1 Compliance Program. Transfer Agent will maintain written policies and procedures reasonably designed to prevent violations of the Federal Securities Laws, as that term is defined in Rule 38a-1, adopted by the Securities and Exchange Commission under the Investment Company Act of 1940, as amended (“Rule 38a-1”) with respect to the Services. On a quarterly basis, Transfer Agent will provide to Fund a certification certifying compliance with its responsibilities as Transfer Agent to the Funds under Rule 38a-1 or highlighting any material issue potentially impacting Transfer Agents services to the Funds. Upon Fund’s request, Transfer Agent will provide Fund with a summary of its policies and procedures in connection with Fund’s compliance with Rule 38a-1 and will provide such explanations of its policies and procedures as Fund may reasonably request. To the extent Transfer Agent makes any material changes to its written policies and procedures in order to address changing regulatory and industry developments that would impact Fund’s compliance with Rule 38a-1, Transfer Agent will notify Fund of any such changes in a timely manner. At least annually, Transfer Agent will also provide Fund a copy of third party audit reposts evaluating the Services (e.g. SSAE 18s or SOC 1s) and a copy of Transfer Agent’s annual assessment or review of Transfer Agent’s compliance programs.

Rule 38a-1 Compliance Program. Transfer Agent will maintain written policies and procedures reasonably designed to prevent violations of the Federal Securities Laws, as that term is defined in Rule 38a-1, adopted by the Securities and Exchange Commission under the Investment Company Act of 1940, as amended (“Rule 38a-1”) with 38a-1”)with respect to the Services. On a quarterly basis, Transfer Agent will provide to Fund a certification certifying compliance with its responsibilities as Transfer Agent to the Funds under Rule 38a-1 or highlighting any material issue potentially impacting Transfer Agents services to the Funds. Upon Fund’s request, Transfer Agent will provide Fund with a summary of its policies and procedures in connection with Fund’s compliance with Rule 38a-1 and will provide such explanations of its policies and procedures as Fund may reasonably request. To the extent Transfer Agent makes any material changes to its written policies and procedures in order to address changing regulatory and industry developments that would impact Fund’s compliance with Rule 38a-1, Transfer Agent will notify Fund of any such changes in a timely manner. At least annually, Transfer Agent will also provide Fund a copy of third party audit reposts evaluating the Services (e.g. SSAE 18s or SOC 1s) and a copy of Transfer Agent’s annual assessment or review of Transfer Agent’s compliance programs.