Sub-Item 77Q1(e): Copies of any new or amended Registrant investment advisory
contracts
(e)(1) Amended and Restated Advisory Agreement dated November 18, 2010 between
the Registrant and Commerce Investment Advisors, Inc., is hereby incorporated by
reference to Exhibit (d)(1) in Registrants Post-Effective Amendment No. 35 filed
with the Commission on February 25, 2011 (Accession No. 0001193125-11-047322).
(e)(2) Fee Reduction Commitment dated February 22, 2011 by Commerce Investment
Advisors, Inc. relating to the Value Fund, is hereby incorporated by reference
to Exhibit (d)(2) in Registrants Post-Effective Amendment No. 35 filed with the
Commission on February 25, 2011 (Accession No. 0001193125-11-047322).
(e)(3) Amended and Restated Waiver and Reimbursement Agreement dated February
22, 2011 between the Registrant and Commerce Investment Advisors, Inc., is
hereby incorporated by reference to Exhibit (d)(3) in Registrants Post-Effective
Amendment No. 35 filed with the Commission on February 25, 2011 (Accession No.
0001193125-11-047322).