Common use of Anti-Money Laundering (“AML”) Delegation Clause in Contracts

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1number[1]; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. [1] An identification number may be, a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies Polices and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS MSS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS MSS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFSMSS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS MSS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS MSS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. 8 For purposes of verifying the identity of a Customer, GFS MSS may rely on documents, so long as, based on that information, GFS MSS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFSMSS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; and (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS MSS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS MSS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust Fund hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the TrustFund’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each the Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) Fund to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust Fund with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a the Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1number(1); · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.obtained

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · — detect and report suspicious activities; · — comply with “know your customer” requirements; · — monitor high-risk accounts; and · — maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · — risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · — before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · — procedures to verify the identity of a Customer within a reasonable time after the account is opened; · — procedures for maintenance of records relating to Customer identification and supporting the verification; and · — procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust Customer hereby delegates to GFS DTAC certain AML duties under this Agreement, as permitted by law and in accordance with the TrustCustomer’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS DTAC include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund Customer can have a reasonable belief that it knows the identity of each person or entity opening an account with the FundCustomer. GFSDTAC’s procedures will include, as appropriate, procedures to assist the Fund(sCustomer(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS DTAC shall provide for proper supervision and training of its personnel. With respect to assisting the Trust Customer with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account Account with a Fund prospective shareholder (a “CustomerProspect”), GFS DTAC will assist the Fund(sCustomer(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund Customer may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a CustomerProspect’s name, date of birth (for an individual), address, and identification number1number (tax identification number, passport number and country of issuance, or other document evidencing nationality or residents and bearing a photograph or other safeguards); · procedures to verify the identity of a Customer Prospect within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a CustomerProspect, GFS DTAC may rely on documents, so long as, based on that information, GFS DTAC can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFSDTAC, including, (i) contacting a CustomerProspect; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS DTAC is not able to verify the identity of a Customer Prospect sufficiently that it can form a reasonable belief that it knows the true identity of a CustomerProspect, then GFS DTAC may, as appropriate: · not open an account Account for the CustomerProspect; · apply limited terms under which a Customer Prospect may use an account until the CustomerProspect’s identity is verified; · close an accountAccount, after attempts to verify a CustomerProspect’s identity have failed; or · assist the Fund Customer in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the CustomerProspect. Each Fund Customer represents and agrees that it will provide Customers with adequate notice that the Fund Customer is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS DTAC pursuant to this Section, the Trust Customer agrees to pay GFS DTAC for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS ANST certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS ANST include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFSANST’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS ANST shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS ANST will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. 1 An identification number may be a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard. For purposes of verifying the identity of a Customer, GFS ANST may rely on documents, so long as, based on that information, GFS ANST can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFSANST, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS ANST is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS ANST may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS ANST pursuant to this Section, the Trust agrees to pay GFS ANST for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust Fund hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in Appendix III | 3 accordance with the TrustFund’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each the Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) Fund to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust Fund with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a the Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from ______________________ 1 An identification number may be, a consumer reporting agencytaxpayer identification number, public databasepassport number and country of issuance, alien identification card number, or number and country of issuance of any other source; (iii) checking references with other financial institutions; government-issued document evidencing nationality or residence and (iv) obtaining bearing a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; photograph or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional dutiessimilar safeguard.

Anti-Money Laundering (“AML”) Delegation. The Trust Customer hereby delegates to GFS TTA certain AML duties under this TA Agreement, as permitted by law and in accordance with the TrustCustomer’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS TTA include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund Customer can have a reasonable belief that it knows the identity of each person or entity opening an account with the FundCustomer. GFSTTA’s procedures will include, as appropriate, procedures to assist the Fund(sCustomer(s) to: · ● detect and report suspicious activities; · ● comply with “know your customer” requirements; · ● monitor high-risk accounts; and · ● maintain required records; and ● add Token Holders to the INX Whitelist Database that have successfully completed the AML and “know your customer” onboarding processes. GFS TTA shall provide for proper supervision and training of its personnel. With respect to assisting the Trust Customer with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account Account with a Fund prospective token holder (a “CustomerProspect”), GFS TTA will assist the Fund(sCustomer(s) through the use of the following: · ● risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund Customer may have a reasonable belief that it knows the true identity of each Customer; · ● before opening an account, obtain a CustomerProspect’s name, date of birth (for an individual), address, and identification number1number (tax identification number, passport number and country of issuance, or other document evidencing nationality or residents and bearing a photograph or other safeguards); · ● procedures to verify the identity of a Customer Prospect within a reasonable time after the account is opened; · ● procedures for maintenance of records relating to Customer identification and supporting the verification; and · ● procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a CustomerProspect, GFS TTA may rely on documents, so long as, based on that information, GFS TTA can form a reasonable belief that it knows the identity of the Customer, including: · ● an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · ● documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFSTTA, including, (i) contacting a CustomerProspect; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS TTA is not able to verify the identity of a Customer Prospect sufficiently that it can form a reasonable belief that it knows the true identity of a CustomerProspect, then GFS TTA may, as appropriate: · ● not open an account Account for the CustomerProspect; · ● apply limited terms under which a Customer Prospect may use an account until the CustomerProspect’s identity is verified; · ● close an accountAccount and remove the Prospect from the Whitelist Database, after attempts to verify a CustomerProspect’s identity have failed; or · ● assist the Fund Customer in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the CustomerProspect. Each Fund Customer represents and agrees that it will provide Customers with adequate notice that the Fund Customer is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS TTA pursuant to this Section, the Trust Customer agrees to pay GFS TTA for the reasonable administrative expenses that may be associated with such additional duties, including expenses associated with minting and distributing such as Ethereum gas fees.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies Polices and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1number[1]; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and [1] An identification number may be, a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard. · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS ANST certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS ANST include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFSANST’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS ANST shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS ANST will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1number 1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. 1 An identification number may be a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard. For purposes of verifying the identity of a Customer, GFS ANST may rely on documents, so long as, based on that information, GFS ANST can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFSANST, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS ANST is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS ANST may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund The Trust represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS ANST pursuant to this Section, the Trust agrees to pay GFS ANST for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS UFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS UFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFSUFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS UFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS UFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1number[1]; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and [1] An identification number may be, a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard. · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS UFS may rely on documents, so long as, based on that information, GFS UFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFSUFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS UFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS UFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS UFS pursuant to this Section, the Trust agrees to pay GFS UFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust Fund Family and underwriter hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the TrustFund Family’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · ● detect and report suspicious activities; · ● comply with “know your customer” requirements; · ● monitor high-risk accounts; and · ● maintain required records. ● Board reporting of activities and results quarterly GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust Fund Family with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · ● risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · ● before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · ● procedures to verify the identity of a Customer within a reasonable time after the account is opened; · ● procedures for maintenance of records relating to Customer identification and supporting the verification; and · ● procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. ● Provide board reporting of activities and results quarterly For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · ● an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.or

Anti-Money Laundering (“AML”) Delegation. The Trust Fund hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in Appendix III | 3 accordance with the TrustFund’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each the Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) Fund to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust Fund with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a the Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from 1 An identification number may be, a consumer reporting agencytaxpayer identification number, public databasepassport number and country of issuance, alien identification card number, or number and country of issuance of any other source; (iii) checking references with other financial institutions; government-issued document evidencing nationality or residence and (iv) obtaining bearing a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; photograph or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional dutiessimilar safeguard.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; 1 An identification number may be a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard. Appendix I Page | 4 · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund The Trust represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1number[1]; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from [1] An identification number may be, a consumer reporting agencytaxpayer identification number, public databasepassport number and country of issuance, alien identification card number, or number and country of issuance of any other source; (iii) checking references with other financial institutions; government-issued document evidencing nationality or residence and (iv) obtaining bearing a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; photograph or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional dutiessimilar safeguard.

Anti-Money Laundering (“AML”) Delegation. The Trust Company hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the TrustCompany’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund the Company can have a reasonable belief that it knows the identity of each person or entity opening an account with the FundCompany. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) Company to: · Appendix I | 3 • detect and report suspicious activities; · • comply with “know your customer” requirements; · • monitor high-risk accounts; and · • maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust Company with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund the Company (a “Customer”), GFS will assist the Fund(s) Company through the use of the following: · • risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund Company may have a reasonable belief that it knows the true identity of each Customer; · • before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · • procedures to verify the identity of a Customer within a reasonable time after the account is opened; · • procedures for maintenance of records relating to Customer identification and supporting the verification; and · • procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · • an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · • documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · • not open an account for the Customer; · 1 An identification number may be a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard. • apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · • close an account, after attempts to verify a Customer’s identity have failed; or · • assist the Fund Company in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund The Company represents and agrees that it will provide Customers with adequate notice that the Fund Company is requesting information to verify their identities. The notice will be included in the application or the prospectusProspectus, or a document accompanying the application or prospectus Prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust Company agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust Fund hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the TrustFund’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each the Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) Fund to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust Fund with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a the Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1number[1]; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; [1] An identification number may be, a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard. · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each The Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust Fund agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; Appendix III | 4 · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or __________________ 1 An identification number may be a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard. · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative out-of-pocket expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. 1 An identification number may be, a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · • detect and report suspicious activities; · • comply with “know your customer” requirements; · • monitor high-risk accounts; and · • maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · • risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · • before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · • procedures to verify the identity of a Customer within a reasonable time after the account is opened; · • procedures for maintenance of records relating to Customer identification and supporting the verification; and · • procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · • an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · • documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · • not open an account for the Customer; · • apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · • close an account, after attempts to verify a Customer’s identity have failed; or · • assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust Fund Family and underwriter hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the TrustFund Family’s Anti-Money Anti‐Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk high‐risk accounts; and · maintain required records. · Board reporting of activities and results quarterly GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust Fund Family with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based risk‐based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. · Provide board reporting of activities and results quarterly For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued government‐issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.or

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS UFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS UFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFSUFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · ● detect and report suspicious activities; · ● comply with “know your customer” requirements; · ● monitor high-risk accounts; and · ● maintain required records. GFS UFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS UFS will assist the Fund(s) through the use of the following: · ● risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · ● before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1number 1; · ● procedures to verify the identity of a Customer within a reasonable time after the account is opened; · ● procedures for maintenance of records relating to Customer identification and supporting the verification; and · ● procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS UFS may rely on documents, so long as, based on that information, GFS UFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.:

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. 1 An identification number may be, a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; 1 An identification number may be a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard. · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice disclosure that the Fund is requesting information to verify their identities. The notice disclosure will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional dutiesprospectus.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1number[1]; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. [1] An identification number may be, a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. 1 An identification number may be a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · 🌑 detect and report suspicious activities; · 🌑 comply with “know your customer” requirements; · 🌑 monitor high-risk accounts; and · 🌑 maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · 🌑 risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · 🌑 before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · 🌑 procedures to verify the identity of a Customer within a reasonable time after the account is opened; · 🌑 procedures for maintenance of records relating to Customer identification and supporting the verification; and · 🌑 procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · 🌑 an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · 🌑 documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust Fund Family and underwriter hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Fund Family's Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s 's procedures will include, as appropriate, procedures to assist the Fund(s) to: · ● detect and report suspicious activities; · ● comply with “"know your customer” " requirements; · ● monitor high-risk accounts; and · ● maintain required records; and ● Board reporting of activities and results quarterly. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust Fund Family with its Customer Identification Program (“"CIP”") designed to ensure the identity of any person opening a new account with a Fund (a “"Customer”"), GFS will assist the Fund(s) through the use of the following: · ● risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · ● before opening an account, obtain a Customer’s 's name, date of birth (for an individual), address, and identification number1; · ● procedures to verify the identity of a Customer within a reasonable time after the account is opened; · ● procedures for maintenance of records relating to Customer identification and supporting the verification; and · ● procedures to determine whether the Customer’s 's name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. ● Provide board reporting of activities and results quarterly For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · ● an individual’s 's unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s 's license or passport); or · ● documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust Fund Family instrument. To the extent that the Customer’s 's identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s 's identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. 1 An identification number may be, a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · ● not open an account for the Customer; · ● apply limited terms under which a Customer may use an account until the Customer’s 's identity is verified; · ● close an account, after attempts to verify a Customer’s 's identity have failed; or · assist the Fund in filing a ● File all Suspicious Activity Report Reports in accordance with applicable law and regulation, regarding the Customer. Customer Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust Fund Family agrees to pay GFS for the reasonable administrative expenses that may be associated in accordance with such additional dutiesAppendix III.

Anti-Money Laundering (“AML”) Delegation. The Trust Fund hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the TrustFund’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and Appendix III | 3 detect money laundering activities and to ensure that each the Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) Fund to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust Fund with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a the Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1number 1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.:

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · • detect and report suspicious activities; · • comply with “know your customer” requirements; · • monitor high-risk accounts; and · • maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · • risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · • before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · • procedures to verify the identity of a Customer within a reasonable time after the account is opened; · • procedures for maintenance of records relating to Customer identification and supporting the verification; and · • procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · • an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · • documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · ● detect and report suspicious activities; · ● comply with “know your customer” requirements; · ● monitor high-risk accounts; and · ● maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · ● risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · ● before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · ● procedures to verify the identity of a Customer within a reasonable time after the account is opened; · ● procedures for maintenance of records relating to Customer identification and supporting the verification; and · ● procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · ● detect and report suspicious activities; · ● comply with “know your customer” requirements; · ● monitor high-risk accounts; and · ● maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · ● risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · ● before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · ● procedures to verify the identity of a Customer within a reasonable time after the account is opened; · ● procedures for maintenance of records relating to Customer identification and supporting the verification; and · ● procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · ● an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · ● documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, : (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.information

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies Polices and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1number[1]; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: [1] An identification number may be, a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard. · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1number[1]; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. _________________ [1] An identification number may be, a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS UFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS UFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFSUFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS UFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS UFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1number[1]; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS UFS may rely on documents, so long as, based on that information, GFS UFS can form a reasonable belief that it knows the identity of the Customer, including: [1] An identification number may be, a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard. · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFSUFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS UFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS UFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS UFS pursuant to this Section, the Trust agrees to pay GFS UFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust Fund hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the TrustFund’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each the Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) Fund to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust Fund with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a the Fund (a “Customer”), GFS will assist the Fund(s) Fund through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. 1 An identification number may be, a taxpayer identification number, passport number and country of issuance, alien identification card number, or number and country of issuance of any other government-issued document evidencing nationality or residence and bearing a photograph or similar safeguard. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each The Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust Fund agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.____________________________

Anti-Money Laundering (“AML”) Delegation. The Trust Company hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the TrustCompany’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust Company with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · detect and report suspicious activities; · comply with “know your customer” requirements; · monitor high-risk accounts; and · maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · procedures to verify the identity of a Customer within a reasonable time after the account is opened; · procedures for maintenance of records relating to Customer identification and supporting the verification; and · procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.:

Anti-Money Laundering (“AML”) Delegation. The Trust hereby delegates to GFS certain AML duties under this Agreement, as permitted by law and in accordance with the Trust’s Anti-Money Laundering Policies and Procedures as may be amended from time to time. Such duties delegated to GFS include procedures reasonably designed to prevent and detect money laundering activities and to ensure that each Fund can have a reasonable belief that it knows the identity of each person or entity opening an account with the Fund. GFS’s procedures will include, as appropriate, procedures to assist the Fund(s) to: · • detect and report suspicious activities; · • comply with “know your customer” requirements; · • monitor high-risk accounts; and · • maintain required records. GFS shall provide for proper supervision and training of its personnel. With respect to assisting the Trust with its Customer Identification Program (“CIP”) designed to ensure the identity of any person opening a new account with a Fund (a “Customer”), GFS will assist the Fund(s) through the use of the following: · • risk-based procedures to verify the identity of each Customer to the extent reasonable and practicable, such that the Fund may have a reasonable belief that it knows the true identity of each Customer; · • before opening an account, obtain a Customer’s name, date of birth (for an individual), address, and identification number1; · • procedures to verify the identity of a Customer within a reasonable time after the account is opened; · • procedures for maintenance of records relating to Customer identification and supporting the verification; and · • procedures to determine whether the Customer’s name appears on any list of known or suspected terrorists or terrorist organizations issued by any federal government agency and designated as such by the Department of the Treasury in consultation with the federal functional regulators, within a reasonable period of time after the account is opened. For purposes of verifying the identity of a Customer, GFS may rely on documents, so long as, based on that information, GFS can form a reasonable belief that it knows the identity of the Customer, including: · • an individual’s unexpired government-issued identification evidencing nationality or residence and bearing a photograph or similar safeguard, (such as a driver’s license or passport); or · • documents showing the existence of an entity, such as articles of incorporation, a government-issued business license, a partnership agreement, or trust instrument. To the extent that the Customer’s identity cannot be verified by relying on documents, other methods may be used by GFS, including, (i) contacting a Customer; (ii) independently verifying the Customer’s identity through the comparison of information provided by the Customer with information obtained from a consumer reporting agency, public database, or other source; (iii) checking references with other financial institutions; and (iv) obtaining a financial statement. In the event that GFS is not able to verify the identity of a Customer sufficiently that it can form a reasonable belief that it knows the true identity of a Customer, then GFS may, as appropriate: · not open an account for the Customer; · apply limited terms under which a Customer may use an account until the Customer’s identity is verified; · close an account, after attempts to verify a Customer’s identity have failed; or · assist the Fund in filing a Suspicious Activity Report in accordance with applicable law and regulation, regarding the Customer. Each Fund represents and agrees that it will provide Customers with adequate notice that the Fund is requesting information to verify their identities. The notice will be included in the application or the prospectus, or a document accompanying the application or prospectus provided it is reasonably designed to ensure that the customer views or otherwise receives the notice before opening the account. In consideration of the performance of the duties by GFS pursuant to this Section, the Trust agrees to pay GFS for the reasonable administrative expenses that may be associated with such additional duties.: