Drafting of Compliance Program. No later than October 5, 2004, the CCO shall, with the assistance of PDR and the Trustee, draft written compliance policies and procedures (the “Compliance Program”) of the Trust, which shall address compliance with, and be reasonably designed to prevent violation of, “Federal Securities Laws.”1 In addition to provisions of Federal Securities Laws that apply to the Trust, the Compliance Program shall address compliance with, and be reasonably designed to prevent violation of, the Trust’s indenture and standard terms and conditions of trust (together, the “Indenture”) and all exemptive orders, no-action letters and other regulatory relief received by the Trust from the Securities and Exchange Commission (the “SEC”) and NASD, Inc. (the “NASD”) (all such items collectively, “Regulatory Relief”); provided, however, that the Compliance Program shall address only that Regulatory Relief afforded the Service Providers or the Trust or relevant to compliance by the Service Providers or the Trust, and shall not address the terms by which other parties may receive the benefits of any Regulatory Relief.
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Sources: Chief Compliance Officer Services Agreement (SPDR Dow Jones Industrial Average Etf Trust), Chief Compliance Officer Services Agreement (SPDR S&p 500 Etf Trust), Chief Compliance Officer Services Agreement (SPDR S&p Midcap 400 Etf Trust)