May 15, 2009Pioneer Fund /Ma/ • June 5th, 2009
This opinion is furnished to you pursuant to paragraph 8.5 of the Agreement and Plan of Reorganization, dated as of February 19, 2009 (the “Agreement”), by and between Pioneer Fund (the “Acquiring Trust”), a Delaware statutory trust, on behalf of Pioneer Fund, the sole series thereof (the “Acquiring Fund”), and Regions Morgan Keegan Select Funds (the “Acquired Trust”), a Massachusetts business trust, on behalf of Regions Morgan Keegan Select Core Equity Fund, a series thereof (the “Acquired Fund”). All capitalized terms not otherwise defined herein have the meanings ascribed to them in the Agreement. The Agreement contemplates the acquisition of all of the assets of the Acquired Fund by the Acquiring Fund in exchange for (a) the assumption by the Acquiring Fund of the stated liabilities of the Acquired Fund and (b) the issuance and delivery by the Acquiring Fund to the Acquired Fund, for distribution, in accordance with Section 1.4 of the Agreement, pro rata within each class of Acquir
