Common use of AML Procedures Clause in Contracts

AML Procedures. [1] 4.1 Consistent with the services provided by the Transfer Agent and with respect to the ownership of Shares in the Fund for which the Transfer Agent maintains the applicable Shareholder information, the Transfer Agent shall: (a) On a daily basis, submit all new customer account registrations and registration changes against the database of sanctioned persons administered by the Office of Foreign Assets Control (“OFAC”), the Politically Exposed Persons (“PEP”) database maintained by an external vendor, and such other lists or databases as may be required from time to time by applicable regulatory authorities; (b) Submit all account registrations through OFAC database, the PEP database, and such other lists or databases as may be required from time to time by applicable regulatory authorities; (c) On a daily basis, submit special payee information from outgoing wires and systematic withdrawal files through the OFAC database; (d) Review certain types of redemption transactions that occur within thirty-four (34) days of an account establishment, registration change, or banking information change (e.g. redemption by wire within 34 days of banking information change; rapid depletion of account balance after establishment; and redemption by check within 34 days of address change); (e) Review wires sent pursuant to banking instructions other than those on file with the Transfer Agent; (f) Review accounts with small balances followed by large purchases; (g) Review accounts with frequent activity within a specified date range followed by a large redemption; (h) Review purchase and redemption activity by check that meets or exceeds $100,000 threshold on any given day; (i) Determine when a suspicious activity report (“SAR”) should be filed as required by regulations applicable to the Fund; prepare and file the SAR; provide the Fund with a copy of the SAR within a reasonable time after filing; and notify the Fund if any further communication is received from the U.S. Department of the Treasury or other law enforcement agencies regarding such filing; (j) Compare account information to any Financial Crimes Enforcement Network (“FinCEN”) request received by the Fund and provided to the Transfer Agent pursuant to Applicable AML Law, including USA PATRIOT Act Sec. 314(a). Provide the Fund with the necessary information for it to respond to such requests within required time frame; (i) Take reasonable steps to verify the identity of any person seeking to become a new customer of the Fund and notify the Fund in the event such person cannot be verified, (ii) maintain records of the information used to verify the person’s identity, as required, and (iii) determine whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to the Fund by any government agency; (l) Conduct due diligence and if required, enhanced due diligence in accordance with 31 C.F.R. 103.176(b) for new and existing correspondent accounts for foreign financial institutions (as defined in 31 C.F.R. 103.175). The Transfer Agent will perform an assessment of the money laundering risk presented by the account based on a consideration of relevant factors in accordance with Applicable AML Law and information provided by the foreign financial institution in a financial institution questionnaire. If an account is determined to have a medium or above risk-ranking, the Transfer Agent will monitor the account on a monthly basis for unusual activity. In the situation where due diligence cannot be completed with respect to an account, the Transfer Agent will contact the Fund’s AML Officer for further instruction. (m) Upon the request by the Fund, conduct due diligence to determine if the Fund is involved with any foreign jurisdiction, institution, class of transactions and a type of account designated, from time to time, by the U.S. Department of Justice in order to identify and take certain “special measures” against such entities as required under Section 311 of the USA PATRIOT Act (Pub. Law 107-56). (n) Create and retain records required under 31 CFR 103.33 in connection with the transmittals of funds in amounts equal to or in excess of $3,000, and transmit such information on the transactions to the receiving financial institutions. 4.2 In the event that the Transfer Agent detects activity as a result of the foregoing procedures, which necessitates the filing by the Transfer Agent of a SAR or other similar report or notice to OFAC, FinCEN or other regulatory body, then the Transfer Agent shall also immediately notify the Fund, unless prohibited by Applicable Law. 4.3 The parties may agree from time to time to add additional duties to this Schedule 2.1(F)(8) pursuant to a mutually agreed upon written amendment to this Schedule, which reflects such duties and any fees or charges associated with the performance thereof.

AML Procedures. [1] 4.1 Consistent with the services provided by the Sub-Transfer Agent and with respect to the ownership of Shares shares in the Fund for which the Sub-Transfer Agent maintains the applicable Shareholder shareholder information, the Sub-Transfer Agent shall: (a) On a daily basis, submit Submit all new customer account registrations and registration changes against the database of sanctioned persons administered by through the Office of Foreign Assets Control (“OFAC”), the Politically Exposed Persons (“PEP”) database maintained by an external vendor, and such other lists or databases as may be required from time to time by applicable regulatory authoritiesauthorities on a daily basis; (b) Submit all account registrations through OFAC database, the PEP database, databases and such other lists or databases as may be required from time to time by applicable regulatory authorities; (c) On a daily basis, submit Submit special payee information from checks, outgoing wires and systematic withdrawal files through the OFAC databasedatabase on a daily basis; (d) Review certain types of redemption transactions that occur within thirty-four thirty (3430) days of an account establishment, establishment or registration change, change or banking information change (e.g. redemption by wire within 34 days of banking information change; rapid depletion of account balance after establishment; and redemption by check within 34 days of address change); (e) Review wires sent pursuant to banking instructions other than those on file with the Sub-Transfer Agent; (f) Review accounts with small balances followed by large purchases; (g) Review accounts with frequent activity within a specified date range followed by a large redemption; (h) Review purchase and redemption activity by check per tax identification number (“TIN”) within the Funds to determine if activity for that meets or exceeds TIN exceeded the $100,000 threshold on any given day; (i) Monitor and track cash equivalents under $10,000 for a rolling twelve-month period; if the threshold is exceeded, file IRS Form 8300 and issue the Shareholder notices as required by the IRS; (j) Determine when a suspicious activity report (“SAR”) should be filed as required by regulations applicable to the Fundmutual funds; prepare and file the SAR; provide the Fund Transfer Agent with a copy of the SAR within a reasonable time after filing; and notify the Fund Transfer Agent if any further communication is received from the U.S. Department of the Treasury or other law enforcement agencies regarding such filing; (jk) Compare account information to any Financial Crimes Enforcement Network (“FinCEN”) FinCEN request received by the Fund Transfer Agent and provided to the Sub-Transfer Agent pursuant to Applicable AML Law, including USA PATRIOT Act Sec. 314(a). Provide the Fund Transfer Agent with the documentation/information necessary information for it to respond to such requests under USA PATRIOT Act Sec. 314(a) within required time frame;frames; and (l) In accordance with procedures agreed upon by the parties (which may be amended from time to time by mutual agreement of the parties) (i) Take reasonable take steps to verify the identity of any person seeking to become a new customer of open an account with the Fund Funds and notify the Fund Transfer Agent in the event such person cannot be verified, (ii) maintain records of the information used to verify the person’s identity, as required, and (iii) determine whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to the Fund Transfer Agent by any government agency;. (lm) Conduct due diligence and if required, enhanced due diligence in accordance with 31 C.F.R. 103.176(b) for new and existing correspondent accounts for foreign financial institutions (as defined in 31 C.F.R. 103.175). The Sub-Transfer Agent will perform an assessment of the money laundering risk presented by the account based on a consideration of relevant factors in accordance with Applicable AML Law applicable law and information provided by the foreign financial institution in a financial institution questionnaire. If an account is determined to have a medium or above risk-ranking, the Sub-Transfer Agent will monitor the account on a monthly basis for unusual activity. In the situation where due diligence cannot be completed with respect to an account, the Sub-Transfer Agent will contact the FundTransfer Agent’s AML Officer for further instruction. (mn) Upon the request by the FundTransfer Agent, conduct due diligence to determine if the Fund is involved with any foreign jurisdiction, institution, class of transactions and a type of account designated, from time to time, by the U.S. Department of Justice in order to identify and take certain “special measures” against such entities as required under Section 311 of the USA PATRIOT Act (Pub. Law 107-5631 C.F.R. 103.193). (n) Create and retain records required under 31 CFR 103.33 in connection with the transmittals of funds in amounts equal to or in excess of $3,000, and transmit such information on the transactions to the receiving financial institutions. 4.2 In the event that the Sub-Transfer Agent detects suspicious activity as a result of the foregoing proceduresAML Procedures, which necessitates the filing by the Sub-Transfer Agent of a SAR SAR, a Form 8300 or other similar report or notice to OFAC, FinCEN or other regulatory body, then the Sub-Transfer Agent shall also immediately notify the FundTransfer Agent, unless prohibited by Applicable Lawapplicable law. 4.3 A. The parties may agree from time Transfer Agent shall provide the following information to time the Sub-Transfer Agent: 1. The name and contact information for each Financial Intermediary with which the Funds have a “shareholder information agreement” (under which the Financial Intermediary agrees to add additional duties to this Schedule 2.1(F)(8) pursuant to a mutually agreed upon written amendment to this Scheduleprovide, which reflects such duties at the Transfer Agent’s request, identity and any fees or charges associated transaction information about shareholders who hold their shares through an account with the performance thereofFinancial Intermediary (an “accountlet”)), that is to receive an information request; 2. The Funds to be included, along with each Fund’s frequent trading policy, under surveillance for the Financial Intermediary; 3. The frequency of supplemental data requests from the Sub-Transfer Agent; 4. The duration of supplemental data requests (e.g. 60 days, 90 days); and 5. The expected turnaround time for a response from the Financial Intermediary to an information request (including requests for supplemental data). B. Upon receipt of the foregoing information, the Transfer Agent hereby authorizes and instructs the Sub-Transfer Agent to perform the following Services:

AML Procedures. [1] 4.1 Consistent with the services provided by the Transfer Agent and with respect to the ownership of Shares in the Fund for which the Transfer Agent maintains the applicable Shareholder information, the Transfer Agent shall: (a) On a daily basis, submit all new customer account registrations and registration changes against the database of sanctioned persons administered by the Office of Foreign Assets Control (“OFAC”), the Politically Exposed Persons (“PEP”) database maintained by an external vendor, and such other lists or databases as may be required from time to time by applicable regulatory authorities; (b) Submit all account registrations through OFAC database, the PEP database, databases and such other lists or databases as may be required from time to time by applicable regulatory authorities; (c) On a daily basis, submit special payee information from checks, outgoing wires and systematic withdrawal files through the OFAC database; (d) Review certain types of redemption transactions that occur within thirty-four thirty (3430) days of an account establishment, registration change, or banking information change (e.g. redemption by check after address change; redemption by wire within 34 days of after banking information change; rapid depletion of account balance or redemptions over a certain% after establishment; and redemption by check within 34 days of address change); (e) Review wires sent pursuant to banking instructions other than those on file with the Transfer Agent; (f) Review accounts with small balances followed by large purchases; (g) Review accounts with frequent activity within a specified date range followed by a large redemption; (h) Review purchase and redemption activity by check that meets or exceeds $100,000 threshold on any given day; (i) Determine when a suspicious activity report (“SAR”) should be filed as required by regulations applicable to the Fundmutual funds; prepare and file the SAR; provide the Fund with a copy of the SAR within a reasonable time after filing; and notify the Fund if any further communication is received from the U.S. Department of the Treasury or other law enforcement agencies regarding such filing; (j) Compare account information to any Financial Crimes Enforcement Network (“FinCEN”) FinCEN request received by the Fund and provided to the Transfer Agent pursuant to Applicable AML Law, including USA PATRIOT Act Sec. 314(a). Provide the Fund with the necessary information for it to respond to such requests request within required time frame; (i) Take reasonable steps to verify the identity of any person seeking to become a new customer of the Fund and notify the Fund in the event such person cannot be verified, (ii) maintain Maintain records of the information used to verify the person’s identity, as required, and (iii) determine Determine whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to the Fund by any government agency; (l) Conduct due diligence and if required, enhanced due diligence in accordance with 31 C.F.R. 103.176(b) for new and existing correspondent accounts for foreign financial institutions (as defined in 31 C.F.R. 103.175). The Transfer Agent will perform an assessment of the money laundering risk presented by the account based on a consideration of relevant factors in accordance with Applicable AML Law applicable law and information provided by the foreign financial institution in a financial institution questionnaire. If an account is determined to have a medium or above risk-ranking, the Transfer Agent will monitor the account on a monthly basis for unusual activity. In the situation where due diligence cannot be completed with respect to an account, the Transfer Agent will contact the Fund’s AML Officer for further instruction. (m) Upon the request by the Fund, conduct due diligence to determine if the Fund is involved with any foreign jurisdiction, institution, class of transactions and a type of account designated, from time to time, by the U.S. Department of Justice in order to identify and take certain “special measures” against such entities as required under Section 311 of the USA PATRIOT Act (Pub. Law 107-5631 C.F.R. 103.193). (n) Create and retain records required under 31 CFR 103.33 in connection with the transmittals of funds in amounts equal to or in excess of $3,000, and transmit such information on the transactions to the receiving financial institutions. 4.2 In the event that the Transfer Agent detects activity as a result of the foregoing procedures, which necessitates the filing by the Transfer Agent of a SAR or other similar report or notice to OFAC, FinCEN or other regulatory body, then the Transfer Agent shall also immediately notify the Fund, unless prohibited by Applicable Law.applicable law. EACH OF THE ENTITIES, INDIVIDUALLY AND NOT JOINTLY, AS LISTED ON SCHEDULE A BOSTON FINANCIAL DATA SERVICES, INC. By: By: Name: Name: ▇▇▇▇▇▇▇ ▇. ▇▇▇ Title: Title: Senior Vice President As an Authorized Officer on behalf of each of the Funds indicated on Schedule A 4.3 (i) OMNIBUS TRANSPARENCY SERVICES Dated: December 8th, 2010 A. The parties may agree from time Funds shall provide the following information to time the Transfer Agent: 1. The name and contact information for the Financial Intermediary, with which the Funds have a “shareholder information agreement” (under which the Financial Intermediary agrees to add additional duties to this Schedule 2.1(F)(8) pursuant to a mutually agreed upon written amendment to this Scheduleprovide, which reflects such duties at the Fund’s request, identity and any fees or charges associated transaction information about shareholders who hold their shares through an account with the performance thereof.Financial Intermediary (an “accountlet”)), that is to receive an information request; 2. The Funds to be included, along with each Fund’s frequency trading policy, under surveillance for the Financial Intermediary; 3. The frequency of supplemental data requests from the Transfer Agent; 4. The duration of supplemental data requests (e.g. 60 days, 90 days); and 5. The expected turnaround time for a response from the Financial Intermediary to an information request (including requests for supplemental data) B. Upon receipt of the foregoing information, the Funds hereby authorize and instruct the Transfer Agent to perform the following Services:

AML Procedures. [1] 4.1 Consistent with the services provided by the Transfer Agent DST and with respect to the ownership of Shares in the Fund for which the Transfer Agent DST maintains the applicable Shareholder information, the Transfer Agent DST shall: (a) On a daily basis, submit all new customer account registrations and registration changes against the database of sanctioned persons administered by the Office of Foreign Assets Control (“OFAC”)) database, the Politically Exposed Persons (“PEP”) database maintained by an external vendordatabase, and such other lists or databases as may be required from time to time by applicable regulatory authorities; (b) Submit all account registrations through OFAC database, the PEP database, and such other lists or databases as may be required from time to time by applicable regulatory authorities; (c) On a daily basis, submit special payee information from checks, outgoing wires and systematic withdrawal files through the OFAC database; (d) Review certain types of redemption transactions that occur within thirty-four (34) days of an account establishment, registration change, or banking information change (e.g. redemption by wire within 34 days of banking information change; rapid depletion of account balance after establishment; and redemption by check within 34 days of address change); (e) Review wires sent pursuant to banking instructions other than those on file with the Transfer AgentDST; (f) Review accounts with small balances followed by large purchases; (g) Review accounts with frequent activity within a specified date range followed by a large redemption; (h) Review purchase and redemption activity by check that meets or exceeds $100,000 threshold on any given day; (i) Determine when a suspicious activity report (“SAR”) should be filed as required by regulations applicable to the Fundmutual funds; prepare and file the SAR; provide the Fund with a copy of the SAR within a reasonable time after filing; and notify the Fund if any further communication is received from the U.S. Department of the Treasury or other law enforcement agencies regarding such filing; (j) Compare account information to any Financial Crimes Enforcement Network (“FinCEN”) FinCEN request received by the Fund and provided to the Transfer Agent DST pursuant to Applicable AML Law, including USA PATRIOT Act Sec. 314(a). Provide the Fund with the necessary information for it to respond to such requests request within required time frame; (i) Take reasonable steps to verify the identity of any person seeking to become a new customer of the Fund and notify the Fund in the event such person cannot be verified, (ii) maintain Maintain records of the information used to verify the person’s identity, as required, and (iii) determine Determine whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to the Fund by any government agency; (l) Except with respect to any entities excluded under applicable regulation: (i) take reasonable steps to verify the identity of legal entities seeking to become new customers of the Fund, including verifying the identity of the natural person(s) retaining ownership or controlling interest in such legal entity (the “ Beneficial Owner(s)”), as such ownership and controlling interests are defined in 31 C.F.R. 1010.230, (ii) notify the Fund in the event that the identity of such Beneficial Owner(s) is not provided upon request to such entity or cannot be verified, (iii) maintain records of the information used to verify such Beneficial Owners, as required, and (iv) determine whether such persons appear on any lists of known or suspected terrorists or terrorist organizations provided to the Fund by any government agency; (m) Conduct due diligence and if required, enhanced due diligence in accordance with 31 C.F.R. 103.176(b) for new and existing correspondent accounts for foreign financial institutions (as defined in 31 C.F.R. 103.175). The Transfer Agent DST will perform an assessment of the money laundering risk presented by the account based on a consideration of relevant factors in accordance with Applicable AML Law applicable law and information provided by the foreign financial institution in a financial institution questionnaire. If an account is determined to have a medium or above risk-ranking, the Transfer Agent DST will monitor the account on a monthly basis for unusual activity. In the situation where due diligence cannot be completed with respect to an account, the Transfer Agent DST will contact the Fund’s AML Officer for further instruction. (mn) Upon the request by the Fund, conduct due diligence to determine if the Fund is involved with any foreign jurisdiction, institution, class of transactions and a type of account designated, from time to time, by the U.S. Department of Justice in order to identify and take certain “special measures” against such entities as required under Section 311 of the USA PATRIOT Act (Pub. Law 107-5631 C.F.R. 103.193). (no) Create and retain records required under 31 CFR 103.33 in connection with the transmittals of funds in amounts equal to or in excess of $3,000, and transmit such information on the transactions to the receiving financial institutions. 4.2 4.1 In the event that the Transfer Agent DST detects activity as a result of the foregoing procedures, which necessitates the filing by the Transfer Agent DST of a SAR or other similar report or notice to OFAC, FinCEN or other regulatory body, then the Transfer Agent DST shall also immediately notify the Fund, unless prohibited by Applicable Lawapplicable law. 4.3 The parties may agree from time to time to add additional duties to this Schedule 2.1(F)(8) pursuant to a mutually agreed upon written amendment to this Schedule, which reflects such duties and any fees or charges associated with the performance thereof.

AML Procedures. [1] 4.1 Consistent with the services provided by the Sub-Transfer Agent and with respect to the ownership of Shares shares in the Fund for which the Sub-Transfer Agent maintains the applicable Shareholder shareholder information, the Sub-Transfer Agent shall: (a) On a daily basis, submit Submit all new customer account registrations and registration changes against the database of sanctioned persons administered by through the Office of Foreign Assets Control (“OFAC”), the Politically Exposed Persons (“PEP”) database maintained by an external vendor, and such other lists or databases as may be required from time to time by applicable regulatory authoritiesauthorities on a daily basis; (b) Submit all account registrations through OFAC database, the PEP database, databases and such other lists or databases as may be required from time to time by applicable regulatory authorities; (c) On a daily basis, submit Submit special payee information from checks, outgoing wires and systematic withdrawal files through the OFAC databasedatabase on a daily basis; (d) Review certain types of redemption transactions that occur within thirty-four thirty (3430) days of an account establishment, establishment or registration change, change or banking information change (e.g. redemption by wire within 34 days of banking information change; rapid depletion of account balance after establishment; and redemption by check within 34 days of address change); (e) Review wires sent pursuant to banking instructions other than those on file with the Sub-Transfer Agent; (f) Review accounts with small balances followed by large purchases; (g) Review accounts with frequent activity within a specified date range followed by a large redemption; (h) Review purchase and redemption activity by check per tax identification number (“TIN”) within the Funds to determine if activity for that meets or exceeds TIN exceeded the $100,000 threshold on any given day; (i) Monitor and track cash equivalents under $10,000 for a rolling twelve-month period; if the threshold is exceeded, file IRS Form 8300 and issue the Shareholder notices as required by the IRS; (j) Determine when a suspicious activity report (“SAR”) should be filed as required by regulations applicable to the Fundmutual funds; prepare and file the SAR; provide the Fund Transfer Agent with a copy of the SAR within a reasonable time after filing; and notify the Fund Transfer Agent if any further communication is received from the U.S. Department of the Treasury or other law enforcement agencies regarding such filing; (jk) Compare account information to any Financial Crimes Enforcement Network (“FinCEN”) FinCEN request received by the Fund Transfer Agent and provided to the Sub-Transfer Agent pursuant to Applicable AML Law, including USA PATRIOT Act Sec. 314(a). Provide the Fund Transfer Agent with the documentation/information necessary information for it to respond to such requests under USA PATRIOT Act Sec. 314(a) within required time frame;frames; and (if) Take reasonable steps to verify the identity of any person seeking to become a new customer of the Fund and notify the Fund in the event such person cannot be verified, (ii) maintain records of the information used to verify the person’s identity, as required, and (iii) determine whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to the Fund by any government agency; (l) Conduct due diligence and if required, enhanced due diligence in accordance with 31 C.F.R. 103.176(b) for new and existing correspondent accounts for foreign financial institutions (as defined in 31 C.F.R. 103.175). The Transfer Agent will perform an assessment of the money laundering risk presented by the account based on a consideration of relevant factors in accordance with Applicable AML Law and information provided by the foreign financial institution in a financial institution questionnaire. If an account is determined to have a medium or above risk-ranking, the Transfer Agent will monitor the account on a monthly basis for unusual activity. In the situation where due diligence cannot be completed with respect to an account, the Transfer Agent will contact the Fund’s AML Officer for further instruction. (m) Upon the request by the Fund, conduct due diligence to determine if the Fund is involved with any foreign jurisdiction, institution, class of transactions and a type of account designated, from time to time, by the U.S. Department of Justice in order to identify and take certain “special measures” against such entities as required under Section 311 of the USA PATRIOT Act (Pub. Law 107-56). (n) Create and retain records required under 31 CFR 103.33 in connection with the transmittals of funds in amounts equal to or in excess of $3,000, and transmit such information on the transactions to the receiving financial institutions. 4.2 In the event that the Transfer Agent detects activity as a result of the foregoing procedures, which necessitates the filing by the Transfer Agent of a SAR or other similar report or notice to OFAC, FinCEN or other regulatory body, then the Transfer Agent shall also immediately notify the Fund, unless prohibited by Applicable Law. 4.3 The parties may agree from time to time to add additional duties to this Schedule 2.1(F)(8) pursuant to a mutually agreed upon written amendment to this Schedule, which reflects such duties and any fees or charges associated with the performance thereof.DELEGATION

AML Procedures. [1] 4.1 Consistent with the services provided by the Transfer Agent and with respect to the ownership of Shares in the Fund Funds for which the Transfer Agent maintains the applicable Shareholder information, the Transfer Agent shall: (a) On a daily basis, submit all new customer account registrations and registration changes against the database of sanctioned persons administered by the Office of Foreign Assets Control (“"OFAC”)") database, the Politically Exposed Persons (“"PEP”") database maintained by an external vendordatabase, and such other lists or databases as may be required from time to time by applicable regulatory authorities; (b) Submit all account registrations through OFAC database, the PEP database, and such other lists or databases as may be required from time to time by applicable regulatory authorities; (c) On a daily basis, submit special payee information from checks, outgoing wires and systematic withdrawal files through the OFAC database; (d) Review certain types of redemption transactions that occur within thirty-four (34) days of an account establishment, registration change, or banking information change (e.g. redemption by wire within 34 days of banking information change; rapid depletion of account balance after establishment; and redemption by check within 34 days of address change); (e) Review wires sent pursuant to banking instructions other than those on file with the Transfer Agent; (f) Review accounts with small balances followed by large purchases; (g) Review accounts with frequent activity within a specified date range followed by a large redemption;; ____________________ 1 The accounts, transactions, items and activity reviewed in each case are subject to certain standard exclusions as set forth in written procedures of the Transfer Agent, which have been made available to the Fund and which may be modified from time to time. SCHEDULE l.2(f) AML DELEGATION Dated: July 15, 2016 (h) Review purchase and redemption activity by check that meets or exceeds $100,000 threshold on any given day; (i) Review high risk work types that warrant a second look when an item has been reviewed in the past. (In connection with this review, the Transfer Agent shall periodically provide the Fund with a listing of the work types that are viewed as high risk.) (j) Determine when a suspicious activity report (“"SAR”") should be filed as required by regulations applicable to the Fundmutual funds; prepare and file the SAR; provide the such Fund with a copy of the SAR within a reasonable time after filing; and notify the Fund if any further communication is received from the U.S. Department of the Treasury or other law enforcement agencies regarding such filing; ; (jk) Compare account information to any Financial Crimes Enforcement Network (“FinCEN”) FinCEN request received by the a Fund and provided to the Transfer Agent pursuant to Applicable AML Law, including USA PATRIOT Act Sec. 314(a). Provide the Fund with the necessary information for it to respond to such requests request within required time frame;; (1) (i) Take reasonable steps to verify the identity of any person seeking to become a new customer of the a Fund and notify the Fund in the event such person cannot be verified, (ii) maintain Maintain records of the information used to verify the person’s 's identity, as required, and (iii) determine Determine whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to the such Fund by any government agency; ; (lm) Conduct due diligence and if required, enhanced due diligence in accordance with 31 C.F.R. 103.176(b) for new and existing correspondent accounts for foreign financial institutions (as defined in 31 C.F.R. 103.175). The Transfer Agent will perform an assessment of the money laundering risk presented by the account based on a consideration of relevant factors in accordance with Applicable AML Law applicable law and information provided by the foreign financial institution in a financial institution questionnaire. If an account is determined to have a medium or above risk-ranking, the Transfer Agent will monitor the account on a monthly basis for unusual activity. In the situation where due diligence cannot be completed with respect to an account, the Transfer Agent will contact the a Fund’s 's AML Officer for further instruction. (m) Upon the request by the Fund, conduct due diligence to determine if the Fund is involved with any foreign jurisdiction, institution, class of transactions and a type of account designated, from time to time, by the U.S. Department of Justice in order to identify and take certain “special measures” against such entities as required under Section 311 of the USA PATRIOT Act (Pub. Law 107-56). (n) Create and retain records required under 31 CFR 103.33 in connection with the transmittals of funds in amounts equal to or in excess of $3,000, and transmit such information on the transactions to the receiving financial institutions. 4.2 In the event that the Transfer Agent detects activity as a result of the foregoing procedures, which necessitates the filing by the Transfer Agent of a SAR or other similar report or notice to OFAC, FinCEN or other regulatory body, then the Transfer Agent shall also immediately notify the Fund, unless prohibited by Applicable Law. 4.3 The parties may agree from time to time to add additional duties to this Schedule 2.1(F)(8) pursuant to a mutually agreed upon written amendment to this Schedule, which reflects such duties and any fees or charges associated with the performance thereof.

AML Procedures. [1] 4.1 Consistent with the services provided by the Transfer Agent and with respect to the ownership of Shares in the Fund for which the Transfer Agent maintains the applicable Shareholder information, the Transfer Agent shall: (a) On a daily basis, submit all new customer account registrations and registration changes against the database of sanctioned persons administered by the Office of Foreign Assets Control (“OFAC”), the Politically Exposed Persons (“PEP”) database maintained by an external vendor, and such other lists or databases as may be required from time to time by applicable regulatory authorities; (b) Submit all new and existing account registrations through OFAC database, the PEP database, databases and such other lists or databases as may be required such lists or databases are updated from time to time by applicable regulatory authoritiesauthorities and notify the Fund of any matches to these lists; (c) On a daily basis, submit special payee information from checks, outgoing wires and systematic withdrawal files through the OFAC database; (d) Review certain types of redemption transactions that occur within thirty-four thirty (3430) days of an account establishment, registration change, or banking information change (e.g. redemption by check after address change; redemption by wire within 34 days of after banking information change; rapid depletion of account balance or redemptions over a certain % after establishment; and redemption by check within 34 days of address change); (e) Review wires sent pursuant to banking instructions other than those on file with the Transfer Agent; (f) Review accounts with small balances followed by large purchases; (g) Review accounts with frequent activity within a specified date range thirty (30) days followed by a large redemption; (h) Review purchase and redemption activity by check that meets or exceeds $100,000 threshold on any given day; (i) Determine when a suspicious activity report (“SAR”) should be filed as required by regulations applicable to the Fundmutual funds; prepare and file the SAR; provide the Fund with a copy of the SAR within a reasonable time after filing; and notify the Fund if any further communication is received from the U.S. Department of the Treasury or other law enforcement agencies regarding such filing; (j) Compare account information to any Financial Crimes Enforcement Network (“FinCEN”) FinCEN request received by the Fund and provided to the Transfer Agent pursuant to Applicable AML Law, including USA PATRIOT Act Sec. 314(a). Provide the Fund with the necessary information for it to respond to such requests request within required time frame; (i) Take reasonable steps to verify the identity of any person seeking to become a new customer of the Fund and notify the Fund in the event such person cannot be verified, (ii) maintain Maintain records of the information used to verify the person’s identity, as required, and (iii) determine Determine whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to the Fund by any government agency; (l) Conduct due diligence and if required, enhanced due diligence in accordance with 31 C.F.R. 103.176(b) for new and existing correspondent accounts for foreign financial institutions (as defined in 31 C.F.R. 103.175). The Transfer Agent will perform an assessment of the money laundering risk presented by the account based on a consideration of relevant factors in accordance with Applicable AML Law applicable law and information provided by the foreign financial institution in a financial institution questionnaire. If an account is determined to have a medium or above risk-ranking, the Transfer Agent will monitor the account on a monthly basis for unusual activity. In the situation where due diligence cannot be completed with respect to an account, the Transfer Agent will contact the Fund’s AML Officer for further instruction. (m) Upon the request by the Fund, conduct due diligence to determine if the Fund is involved with any foreign jurisdiction, institution, class of transactions and a type of account designated, from time to time, by the U.S. Department of Justice in order to identify and take certain “special measures” against such entities as required under Section 311 of the USA PATRIOT Act (Pub. Law 107-56). (n) Create and retain records required under 31 CFR 103.33 in connection with the transmittals of funds in amounts equal to or in excess of $3,000, and transmit such information on the transactions to the receiving financial institutions. 4.2 In the event that the Transfer Agent detects activity as a result of the foregoing procedures, which necessitates the filing by the Transfer Agent of a SAR or other similar report or notice to OFAC, FinCEN or other regulatory body, then the Transfer Agent shall also immediately notify the Fund, unless prohibited by Applicable Law. 4.3 The parties may agree from time to time to add additional duties to this Schedule 2.1(F)(8) pursuant to a mutually agreed upon written amendment to this Schedule, which reflects such duties and any fees or charges associated with the performance thereof.

AML Procedures. [1] 4.1 Consistent with the services provided by the Transfer Agent M3Sixty and with respect to the ownership of Shares shares in the Fund Trust for which the Transfer Agent M3Sixty maintains the applicable Shareholder information, the Transfer Agent M3Sixty shall: (a) On a daily basis, submit all new customer account registrations and registration changes against the database of sanctioned persons administered by the Office of Foreign Assets Control (“OFAC”)) database, the Politically Exposed Persons (“PEP”) database maintained by an external vendordatabase, and such other lists or databases as may be required from time to time by applicable regulatory authorities; (b) Submit all account registrations through OFAC database, the PEP database, and such other lists or databases as may be required from time to time by applicable regulatory authorities; (c) On a daily basis, submit special payee information from checks, outgoing wires and systematic withdrawal files through the OFAC database; (d) Review certain types of redemption transactions that occur within thirty-four thirty (3430) days of an account establishment, registration change, or banking information change (e.g. redemption by wire within 34 30 days of banking information change; rapid depletion of account balance after establishment; and redemption by check within 34 30 days of address change); (e) Review wires sent pursuant to banking instructions other than those on file with the Transfer AgentM3Sixty; (f) Review accounts with small balances followed by large purchases; (g) Review accounts with frequent activity within a specified date range followed by a large redemption; (h) Review purchase and redemption activity by check that meets or exceeds $100,000 threshold on any given day; (i) Determine when a suspicious activity report (“SAR”) should be filed as required by regulations applicable to the Fundmutual funds; prepare and file the SAR; provide the Fund Trust with a copy of the SAR within a reasonable time after filing; and notify the Fund Trust if any further communication is received from the U.S. Department of the Treasury or other law enforcement agencies regarding such filing; 1 The accounts, transactions, items and activity reviewed in each case are subject to certain standard exclusions as set forth in written procedures of the Transfer Agent, which have been made available to the Fund and which may be modified from time to time. (j) Compare account information to any Financial Crimes Enforcement Network (“FinCEN”) FinCEN request received by the Fund Trust and provided to the Transfer Agent M3Sixty pursuant to Applicable AML Law, including USA PATRIOT Act Sec. 314(a). Provide the Fund Trust with the necessary information for it to respond to such requests request within required time frame; (i) Take reasonable steps to verify the identity of any person seeking to become a new customer of the Fund Trust and notify the Fund Trust in the event such person cannot be verified, (ii) maintain Maintain records of the information used to verify the person’s identity, as required, and (iii) determine Determine whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to the Fund Trust by any government agency; (l) Conduct due diligence and if required, enhanced due diligence in accordance with 31 C.F.R. 103.176(b) applicable regulations for new and existing correspondent accounts for foreign financial institutions (as defined in 31 C.F.R. 103.175the applicable regulations). The Transfer Agent M3Sixty will perform an assessment of the money laundering risk presented by the account based on a consideration of relevant factors in accordance with Applicable AML Law applicable law and information provided by the foreign financial institution in a financial institution questionnaire. If an account is determined to have a medium or above risk-ranking, the Transfer Agent M3Sixty will monitor the account on a monthly basis for unusual activity. In the situation where due diligence cannot be completed with respect to an account, the Transfer Agent M3Sixty will contact the FundTrust’s AML Officer for further instruction. (m) Upon the request by the FundTrust, conduct due diligence to determine if the Fund Trust is involved with any foreign jurisdiction, institution, class of transactions and a type of account designated, from time to time, by the U.S. Department of Justice in order to identify and take certain “special measures” against such entities as required under Section 311 of the USA PATRIOT Act (Pub. Law 107-56)Act. (n) Create and retain records required under 31 CFR 103.33 the “Travel Rule” in connection with the transmittals of funds in amounts equal to or in excess of $3,000, and transmit such information on the transactions to the receiving financial institutions. 4.2 In the event that the Transfer Agent M3Sixty detects activity as a result of the foregoing procedures, which necessitates the filing by the Transfer Agent M3Sixty of a SAR or other similar report or notice to OFAC, FinCEN or other regulatory body, then the Transfer Agent M3Sixty shall also immediately notify the FundTrust, unless prohibited by Applicable Lawapplicable law. 4.3 The parties may agree from time to time to add additional duties to this Schedule 2.1(F)(8) pursuant to a mutually agreed upon written amendment to this Schedule, which reflects such duties and any fees or charges associated with the performance thereof.

AML Procedures. [1] 4.1 Consistent with the services provided by the Transfer Agent and with respect to the ownership of Shares in the Fund Funds for which the Transfer Agent maintains the applicable Shareholder information, the Transfer Agent shall: (a) On a daily basis, submit all new customer account registrations and registration changes against the database of sanctioned persons administered by the Office of Foreign Assets Control (“OFAC”)) database, the Politically Exposed Persons (“PEP”) database maintained by an external vendordatabase, and such other lists or databases as may be required from time to time by pursuant to the risk-based procedures applicable regulatory authoritiesto the Funds; (b) Submit all account registrations through OFAC database, the PEP database, and such other lists or databases as may be required from time to time by pursuant to the risk-based procedures applicable regulatory authoritiesto the Funds; (c) On a daily basis, submit special payee information from checks, outgoing wires and systematic withdrawal files through the OFAC database; (d) Review certain types of redemption transactions that occur within thirty-four (34) days of an account establishment, registration change, or banking information change (e.g. e.g., redemption by wire within 34 days of banking information change; rapid depletion of account balance after establishment; and redemption by check within 34 days of address change); (e) Review wires sent pursuant to banking instructions other than those on file with the Transfer Agent; (f) Review accounts with small balances followed by large purchases; (g) Review accounts with frequent activity within a specified date range followed by a large redemption; (h) Review purchase and redemption activity by check that meets or exceeds $100,000 threshold on any given day; (h) Review high risk work types that warrant a second look when an item has been reviewed in the past. (In connection with this review, the Transfer Agent shall periodically provide the Fund with a listing of the work types that are viewed as high risk.); 1 The accounts, transactions, items and activity reviewed in each case are subject to certain standard exclusions as set forth in written procedures of the Transfer Agent, which have been made available to the Fund and which may be modified from time to time. (i) Determine when a suspicious activity report (“SAR”) should be filed as required by regulations applicable to the Fundmutual funds; prepare and file the SAR; provide the Fund Funds with a copy of the SAR within a reasonable time after filing; and notify the Fund Funds if any further communication is received from the U.S. Department of the Treasury or other law enforcement agencies regarding such filingfiling (31 CFR 1024.320); (j) Compare account information to any Financial Crimes Enforcement Network (“FinCEN”) FinCEN request received by the Fund Funds and provided to the Transfer Agent pursuant to Applicable AML Law, including USA PATRIOT Act Sec. 314(a). Provide the Fund Funds with the necessary information for it to respond to such requests request within required time frameframe (31 CFR 1010.520); (i) Take reasonable steps to obtain customer identifying information and verify the identity of any person or entity seeking to become a new customer of the Fund and notify the Fund Funds and, in the event such person or entity cannot be verified, place a stop purchase on the account and request instruction from the Trust as to the disposition of such account, (ii) maintain Maintain records of the information used to verify the person’s identityor entity’s identity for the greater of (A) five years from the date of redemption of such investor or (B) such longer period as may be required by applicable law, as required, and (iii) determine Determine whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to the Fund Funds by any government agency; and (iv) Provide any relevant documentation maintained pursuant to this Schedule 1.6 to the Trust upon request; (l) With regards to legal entities meeting the definition of “legal entity customer” in 31 C.F.R. 1010.230 seeking to open a new account with a Fund, take reasonable steps to verify the identity of each “beneficial owner” (as such term is defined in 31 C.F.R. 1010.230, including at least one beneficial owner, if any, and one control person) in such legal entity customer (the “Beneficial Owner(s)”). In the event the proper identity of a natural person Beneficial Owner cannot be verified, a stop purchase shall be placed on the account by the Transfer Agent. If the required information is not provided by the Beneficial Owner within 21 business days, the Transfer Agent shall request instruction from the Trust as to the disposition of such account; (m) Conduct customer due diligence pursuant to risk-based procedures, which include, at a minimum, conducting ongoing monitoring to identify and report suspicious transactions and, on a risk basis, to maintain and update customer information, including beneficial ownership information of legal entity customers. The Transfer Agent will perform an assessment of the money laundering risk presented by the account based on a consideration of relevant factors in accordance with applicable law and information provided by the customer at account opening; (n) Conduct due diligence and if required, enhanced due diligence in accordance with 31 C.F.R. 103.176(b) 1010.610 for new and existing correspondent accounts for foreign financial institutions (as defined in 31 C.F.R. 103.1751010.605(f)). The Transfer Agent will perform an assessment of the money laundering risk presented by the account based on a consideration of relevant factors in accordance with Applicable AML Law applicable law and information provided by the foreign financial institution in a financial institution questionnaire. If an account is determined to have a risk ranking at a level of medium or above risk-rankingabove, the Transfer Agent will monitor the account on a monthly basis for unusual activity. In the situation where due diligence cannot be completed within a commercially reasonable period of time with respect to an account, the Transfer Agent will contact the Fund’s AML Funds’ Chief Compliance Officer for further instruction.; (mo) Upon the request by the FundFunds, conduct due diligence to determine if the Fund is Funds are involved with any foreign jurisdiction, institution, class of transactions and a type of account designated, from time to time, by the U.S. Department of Justice in order to identify and take certain “special measures” against such entities as required under Section 311 of the USA PATRIOT Act (Pub. Law 107-56).Act; (np) Create and retain records required under 31 CFR 103.33 1010.410 in connection with the transmittals of funds in amounts equal to or in excess of $3,000, and transmit such information on the transactions to the receiving financial institutions; and (q) When a foreign account has been opened with the consent of the Fund, send the shareholder a due diligence questionnaire in order to determine the risk ranking of the account and whether or not it is a foreign shell bank. The Transfer Agent will notify the Fund if the account has a moderate or high risk ranking and follow instruction from the Fund (e.g., open, close, file SAR, etc.) with respect to the account. 4.2 In the event that the Transfer Agent detects activity as a result of the foregoing procedures, which necessitates the filing by the Transfer Agent of a SAR on behalf of a Fund or other similar report or notice to OFAC, FinCEN or other regulatory body, then the Transfer Agent shall also first immediately notify the FundFunds, unless prohibited by Applicable Law. 4.3 The applicable law and shall then work with the applicable Fund(s) as to the appropriate next steps, including but not limited to, making required filings with OFAC. Notwithstanding the foregoing, the Transfer Agent shall obtain the prior approval of the applicable Fund(s) before filing a SAR on behalf of such Fund(s). All capitalized terms not defined in this State Street Client Information Security Schedule (this “Security Schedule”) will have the meanings given to them in the Agreement, as applicable. State Street implements data security measures consistent in all material respects with applicable prevailing industry practices and standards as well as laws, rules and regulations applicable to State Street. However, as information security is a highly dynamic space where threats are constantly changing, State Street reserves the right to make changes to its information security controls at any time in a manner that does not materially reduce its protection of the Client’s data (“Client Data”). State Street will use commercially reasonable efforts to cause any Delegates or other delegates and third parties may agree from time to time whom State Street provides Client Data to add additional duties implement and maintain security measures that State Street reasonably believes are at least as protective as those described in this Security Schedule. For Delegates as well as other delegates or third parties who collect, transmit, share, store, control, process or manage Client Data, State Street is responsible for assessing their control environments. Notwithstanding the foregoing, State Street shall be responsible for any Delegate’s as well as such other delegate’s or third party’s conduct with respect to this Schedule 2.1(F)(8) pursuant to a mutually agreed upon written amendment to this Schedulethe protection of Client Data, which reflects such duties and any fees or charges associated with the performance thereofif done by State Street, would be a breach of its commitment under this Security Schedule.

AML Procedures. [1] 4.1 Consistent with the services provided by the Transfer Agent and with respect to the ownership of Shares in the Fund for which the Transfer Agent maintains the applicable Shareholder information, the Transfer Agent shall: (a) On a daily basis, submit all new customer account registrations and registration changes against the database of sanctioned persons administered by the Office of Foreign Assets Control (“OFAC”), the Politically Exposed Persons (“PEP”) database maintained by an external vendor, and such other lists or databases as may be required from time to time by applicable regulatory authorities; (b) Submit all account registrations through OFAC database, the PEP database, databases and such other lists or databases as may be required from time to time by applicable regulatory authorities; (c) On a daily basis, submit special payee information from checks, outgoing wires and systematic withdrawal files through the OFAC database; (d) Review certain types of redemption transactions that occur within thirty-four thirty (3430) days of an account establishment, registration change, or banking information change (e.g. redemption by check after address change; redemption by wire within 34 days of after banking information change; rapid depletion of account balance or redemptions over a certain % after establishment; and redemption by check within 34 days of address change); (e) Review wires sent pursuant to banking instructions other than those on file with the Transfer Agent; (f) Review accounts with small balances followed by large purchases; (g) Review accounts with frequent activity within a specified date range followed by a large redemption; (h) Review purchase and redemption activity by check that meets or exceeds $100,000 threshold on any given day; (i) Determine when a suspicious activity report (“SAR”) should be filed as required by regulations applicable to the Fundmutual funds; prepare and file the SAR; provide the Fund with a copy of the SAR within a reasonable time after filing; and notify the Fund if any further communication is received from the U.S. Department of the Treasury or other law enforcement agencies regarding such filing; (j) Compare account information to any Financial Crimes Enforcement Network (“FinCEN”) FinCEN request received by the Fund and provided to the Transfer Agent pursuant to Applicable AML Law, including USA PATRIOT Act Sec. 314(a). Provide the Fund with the necessary information for it to respond to such requests request within required time frame; (i) Take reasonable steps to verify the identity of any person seeking to become a new customer of the Fund and notify the Fund in the event such person cannot be verified, (ii) maintain Maintain records of the information used to verify the person’s identity, as required, and (iii) determine Determine whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to the Fund by any government agency; (l1) Conduct due diligence and if required, enhanced due diligence in accordance with 31 C.F.R. 103.176(b) for new and existing correspondent accounts for foreign financial institutions (as defined in 31 C.F.R. 103.175). The Transfer Agent will perform an assessment of the money laundering risk presented by the account based on a consideration of relevant factors in accordance with Applicable AML Law applicable law and information provided by the foreign financial institution in a financial institution questionnaire. If an account is determined to have a medium or above risk-ranking, the Transfer Agent will monitor the account on a monthly basis for unusual activity. In the situation where due diligence cannot be completed with respect to an account, the Transfer Agent will contact the Fund’s AML Officer for further instruction. (m) Upon the request by the Fund, conduct due diligence to determine if the Fund is involved with any foreign jurisdiction, institution, class of transactions and a type of account designated, from time to time, by the U.S. Department of Justice in order to identify and take certain “special measures” against such entities as required under Section 311 of the USA PATRIOT Act (Pub. Law 107-5631 C.F.R. 103.193). (n) Create and retain records required under 31 CFR 103.33 in connection with the transmittals of funds in amounts equal to or in excess of $3,000, and transmit such information on the transactions to the receiving financial institutions. 4.2 In the event that the Transfer Agent detects activity as a result of the foregoing procedures, which necessitates the filing by the Transfer Agent of a SAR or other similar report or notice to OFAC, FinCEN or other regulatory body, then the Transfer Agent shall also immediately notify the Fund, unless prohibited by Applicable Lawapplicable law. 4.3 (i) OMNIBUS TRANSPARENCY SERVICES Dated: October 23, 2010 A. The parties may agree from time Funds shall provide the following information to time the Transfer Agent: 1. The name and contact information for the Financial Intermediary, with which the Funds have a “shareholder information agreement” (under which the Financial Intermediary agrees to add additional duties to this Schedule 2.1(F)(8) pursuant to a mutually agreed upon written amendment to this Scheduleprovide, which reflects such duties at the Fund’s request, identity and any fees or charges associated transaction information about shareholders who hold their shares through an account with the performance thereof.Financial Intermediary (an “accountlet”)), that is to receive an information request; 2. The Funds to be included, along with each Fund’s frequency trading policy, under surveillance for the Financial Intermediary; 3. The frequency of supplemental data requests from the Transfer Agent; 4. The duration of supplemental data requests (e.g. 60 days, 90 days); and 5. The expected turnaround time for a response from the Financial Intermediary to an information request (including requests for supplemental data) B. Upon receipt of the foregoing information, the Funds hereby authorize and instruct the Transfer Agent to perform the following Services: