0001193125-12-195145 Sample Contracts

CUSTODY AGREEMENT
Custody Agreement • April 30th, 2012 • Stratton Real Estate Fund, Inc. • New York

AGREEMENT, dated as of November 1, 2011 between each investment company listed on the signature page to this Agreement (each, the “Fund”) and The Bank of New York Mellon, a New York corporation authorized to do a banking business having its principal office and place of business at One Wall Street, New York, New York 10286 (“Custodian”).

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ADMINISTRATION AND ACCOUNTING SERVICES AGREEMENT
Administration and Accounting Services Agreement • April 30th, 2012 • Stratton Real Estate Fund, Inc.

THIS AGREEMENT is made as of November 1, 2011 by and between BNY MELLON INVESTMENT SERVICING (US) INC., a Massachusetts corporation (the “Administrator”), and each investment company listed on the signature page to this Agreement (each, the “Fund”) Capitalized terms not otherwise defined shall have the meanings set forth in Appendix A.

DISTRIBUTION SERVICES AGREEMENT
Distribution Services Agreement • April 30th, 2012 • Stratton Real Estate Fund, Inc.

THIS DISTRIBUTION SERVICES AGREEMENT is made effective as of November 1, 2011 by and between BNY MELLON DISTRIBUTORS INC., a Massachusetts corporation (“Distributor”), and STRATTON MANAGEMENT COMPANY (“Advisor”).

Underwriting Agreement for: Stratton Real Estate Fund, Inc.
Underwriting Agreement • April 30th, 2012 • Stratton Real Estate Fund, Inc.

Effective as of the closing of the sale of BNY Mellon Distributors LLC to Foreside Distributors, LLC by The Bank of New York Mellon Corporation, Stratton Real Estate Fund, Inc. (the “Fund Company”), on behalf of each series thereof (each a “Fund” and collectively, the “Funds”) and Foreside Funds Distributors LLC (formerly known as BNY Mellon Distributors LLC) (the “Distributor”) hereby enter into this Underwriting Agreement on terms identical to those of the underwriting agreement between the parties effective as of November 1, 2011 (the “Existing Agreement”) except as noted below. Capitalized terms used herein without definition have the meanings given them in the Existing Agreement.

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