0001398344-17-010935 Sample Contracts

DISTRIBUTION AGREEMENT
Distribution Agreement • August 25th, 2017 • Caldwell & Orkin Funds Inc • Ohio

This Agreement, dated October 24, 2016 is between The Caldwell & Orkin Funds, Inc (the “Fund”), a Maryland corporation, C&O Funds Advisor, Inc. (the “Advisor”), a Georgia corporation, and Ultimus Fund Distributors, LLC (“Distributor”), a limited liability company organized under the laws of the State of Ohio.

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IDENTITY THEFT PREVENTION PROGRAM COMPLIANCE AGREEMENT
Identity Theft Prevention Program Compliance Agreement • August 25th, 2017 • Caldwell & Orkin Funds Inc

This Agreement dated as of this 24th day of October, 2016 is entered into by and among The Caldwell & Orkin Funds, Inc (the “Fund”) and Ultimus Fund Solutions, LLC, the Fund’s transfer agent (“Ultimus”).

MASTER SERVICES AGREEMENT
Master Services Agreement • August 25th, 2017 • Caldwell & Orkin Funds Inc • Ohio

This Agreement, dated October 24, 2016 is between The Caldwell & Orkin Funds, Inc. (the “Fund”), a Maryland corporation, and Ultimus Fund Solutions, LLC (“Ultimus”), a limited liability company organized under the laws of the State of Ohio.

COMPLIANCE CONSULTING AGREEMENT
Compliance Consulting Agreement • August 25th, 2017 • Caldwell & Orkin Funds Inc • Ohio

THIS AGREEMENT is made as of 24th day of October, 2016, by and between The Caldwell & Orkin Funds, Inc. (the “Fund”), a Maryland corporation, and Ultimus Fund Solutions, LLC (“Ultimus”), a limited liability company organized under the laws of the State of Ohio.

FIRST AMENDMENT TO NO-LOAD FUND SERVICES AGREEMENT
Fund Services Agreement • August 25th, 2017 • Caldwell & Orkin Funds Inc • New York

THIS AMENDMENT, effective as of March 1, 2017, by and between Ultimus Fund Distributors, LLC (the “Distributor”) and Merrill Lynch, Pierce, Fenner & Smith Incorporated (“Merrill Lynch”), is made to that certain No-Load Fund Services Agreement, dated March 11, 2011 by and between the Distributor and Merrill Lynch (the “Agreement”). Capitalized terms used herein but not otherwise defined shall have their respective meanings as set forth in the Agreement.

RE: CALDWELL & ORKIN NO-LOAD FUND SERVICES AGREEMENT
Fund Services Agreement • August 25th, 2017 • Caldwell & Orkin Funds Inc • New York

Merrill Lynch, Pierce, Fenner & Smith Incorporated (“we”, “us” or “Merrill Lynch”) has entered into an Operations Agreement (the “Operations Agreement”) with the principal underwriter of certain open-end investment companies (“mutual fund(s)”) with whom you are affiliated in order to facilitate our customers’ acquisition and/or disposition of shares of such mutual funds. The mutual funds subject to the Operations Agreement are identified on Schedule A thereto or on our or our affiliates’ books and records, as the case may be, as agreed to under such Operations Agreement (hereinafter referred to collectively as the “Funds”, and each a “Fund”).

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