0001104659-13-093051 Sample Contracts

DATE] Scotia Institutional Funds Suite 301 Berwyn, PA 19312 The RBB Fund, Inc. Bellevue Corporate Center Wilmington, DE 19809

Agreement and Plan of Reorganization • December 31st, 2013 • RBB Fund Inc

• Contract Type
  Agreement and Plan of Reorganization
• Filed
  December 31st, 2013
• Company
  RBB Fund Inc

You have asked for our opinion as to certain Federal income tax consequences of transactions contemplated in the above Agreement and Plan of Reorganization (the “Reorganization Agreement”).