Common use of Anti-Money Laundering Compliance Programs Clause in Contracts

Anti-Money Laundering Compliance Programs. Each Dealer’s acceptance of this Agreement constitutes a representation to the Managing Broker-Dealer that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), in accordance with FINRA Rule 3310 and Section 352 of the Money Laundering Abatement Act, the Bank Secrecy Act, as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause reporting of suspicious transactions in connection with the sale of Shares. In addition, the Dealer represents that it has established and implemented a program (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer at any time, the Dealer hereby agrees to (i) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer for review and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Shares through the Dealer are “Customers” of the Dealer and not the Managing Broker-Dealer. Nonetheless, to the extent that the Managing Broker-Dealer deems it prudent, the Dealer shall cooperate with the Managing Broker-Dealer’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer hereby agrees, upon request by the Managing Broker-Dealer to (i) provide an annual certification to the Managing Broker-Dealer that, as of the date of such certification (A) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (C) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and (ii) perform and carry out, on behalf of both the Managing Broker-Dealer and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each DealerSelling Group Member’s acceptance of this Agreement constitutes a representation to the Managing Broker-Dealer that the Dealer Selling Group Member has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), in accordance with FINRA Rule 3310 and Section 352 of the Money Laundering Abatement Act, the Bank Secrecy Act, as amended, Act and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause reporting of suspicious transactions in connection with the sale of SharesBonds. In addition, the Dealer Selling Group Member represents that it has established and implemented a program (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer at any time, the Dealer Selling Group Member hereby agrees to (i) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer for review and (ii) furnish a copy of the findings and any remedial actions taken in connection with the DealerSelling Group Member’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Shares Bonds through the Dealer Selling Group Member are “Customers” of the Dealer Selling Group Member and not the Managing Broker-Dealer. Nonetheless, to the extent that the Managing Broker-Dealer deems it prudent, the Dealer Selling Group Member shall cooperate with the Managing Broker-Dealer’s auditing and monitoring of the DealerSelling Group Member’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors Investors introduced to, and serviced by, the Dealer Selling Group Member (the “Customers”). Such documentation could include, among other things: (i) copies of DealerSelling Group Member’s AML Program and its OFAC Program; , (ii) documents maintained pursuant to the DealerSelling Group Member’s AML Program and its OFAC Program related to the Customers; , (iii) any suspicious activity reports filed related to the Customers; , (iv) audits and any exception reports related to the DealerSelling Group Member’s AML activities; activities and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer Selling Group Member will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the DealerSelling Group Member’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer Selling Group Member shall not be required to provide to the Managing Broker-Dealer any documentation that, in the DealerSelling Group Member’s reasonable judgment, would cause the Dealer Selling Group Member to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer Selling Group Member hereby represents that it is currently in compliance with all AML rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer Selling Group Member hereby agrees, upon request by the Managing Broker-Dealer to (i) provide an annual certification to the Managing Broker-Dealer that, as of the date of such certification (A) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (C) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and (ii) perform and carry out, on behalf of both the Managing Broker-Dealer and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Participating Dealer’s acceptance of this Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Participating Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, Securities and Exchange Commission Rules (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Primary Shares. In additionParticipating Dealer covenants that it will perform all activities it is required to perform by applicable AML Rules and its AML Program with respect to all customers on whose behalf Participating Dealer submits orders to the Company. To the extent permitted by applicable law, Participating Dealer will share information with the Dealer represents that it has established Manager and implemented the Company for purposes of ascertaining whether a program suspicious activity report (“OFAC ProgramSAR”) for compliance is warranted with OFAC and will continue respect to maintain its OFAC Program during any suspicious transaction involving the term purchase or intended purchase of this AgreementPrimary Shares. Upon request by the Managing Broker-Dealer Manager at any time, the Participating Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Participating Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Shares through the Participating Dealer are “Customers” of the Dealer and not the Managing Broker-Dealer. Nonetheless, to the extent that the Managing Broker-Dealer deems it prudent, the Dealer shall cooperate with the Managing Broker-Dealer’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules and all OFAC requirementsRules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Money Laundering Abatement Act. The , and such Participating Dealer hereby agreescovenants to remain in compliance with such requirements and shall, upon request by the Managing Broker-Dealer to (i) Manager, provide an annual a certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are is consistent with the AML Rules and OFAC requirementsRules, (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirementsRules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and (ii) perform and carry out, on behalf of both the Managing Broker-Dealer and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunderMoney Laundering Abatement Act.

Anti-Money Laundering Compliance Programs. Each Selected Dealer’s acceptance of this Dealer Agreement constitutes a representation to the Managing Broker-Corporation and the Dealer Manager that the Selected Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, Securities and Exchange Commission Rules (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Offered Shares. In addition, the Selected Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Selected Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Selected Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the FINRA rules the Investors investors who purchase Offered Shares through the Selected Dealer are “Customerscustomers” of the Selected Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Selected Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the CompanyCorporation’s investors stockholders introduced to, and serviced by, the Selected Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Selected Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Selected Dealer’s reasonable judgment, would cause the Selected Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Selected Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Selected Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, ; (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the CompanyCorporation, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each DealerSelling Group Member’s acceptance of this Agreement constitutes a representation to the Managing Broker-Dealer Manager that the Dealer Selling Group Member has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), in accordance with FINRA Rule 3310 and Section 352 of the Money Laundering Abatement Act, the Bank Secrecy Act, as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause reporting of suspicious transactions in connection with the sale of Shares. In addition, the Dealer Selling Group Member represents that it has established and implemented a program (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Dealer Selling Group Member hereby agrees to (i) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review and (ii) furnish a copy of the findings and any remedial actions taken in connection with the DealerSelling Group Member’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Shares through the Dealer Selling Group Member are “Customers” of the Dealer Selling Group Member and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Dealer Selling Group Member shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the DealerSelling Group Member’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors introduced to, and serviced by, the Dealer Selling Group Member (the “Customers”). Such documentation could include, among other things: (i) copies of DealerSelling Group Member’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the DealerSelling Group Member’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the DealerSelling Group Member’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-DealerDealer Manager, a potential violation of the Managing Broker-DealerDealer Manager’s obligations in respect of its AML or OFAC requirements, the Dealer Selling Group Member will permit the Managing Broker-Dealer Manager to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the DealerSelling Group Member’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer Selling Group Member shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the DealerSelling Group Member’s reasonable judgment, would cause the Dealer Selling Group Member to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer Selling Group Member hereby represents that it is currently in compliance with all AML rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer Selling Group Member hereby agrees, upon request by the Managing Broker-Dealer Manager to (i) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (A) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (C) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and (ii) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each DealerSelling Group Member’s acceptance of this Agreement constitutes a representation to the Managing Broker-Dealer that the Dealer Selling Group Member has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), in accordance with FINRA Rule 3310 and Section 352 of the Money Laundering Abatement Act, the Bank Secrecy Act, as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause reporting of suspicious transactions in connection with the sale of Shares. In addition, the Dealer Selling Group Member represents that it has established and implemented a program (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer at any time, the Dealer Selling Group Member hereby agrees to (i) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer for review and (ii) furnish a copy of the findings and any remedial actions taken in connection with the DealerSelling Group Member’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Shares through the Dealer Selling Group Member are “Customers” of the Dealer Selling Group Member and not the Managing Broker-Dealer. Nonetheless, to the extent that the Managing Broker-Dealer deems it prudent, the Dealer Selling Group Member shall cooperate with the Managing Broker-Dealer’s auditing and monitoring of the DealerSelling Group Member’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors introduced to, and serviced by, the Dealer Selling Group Member (the “Customers”). Such documentation could include, among other things: (i) copies of DealerSelling Group Member’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the DealerSelling Group Member’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the DealerSelling Group Member’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer Selling Group Member will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the DealerSelling Group Member’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer Selling Group Member shall not be required to provide to the Managing Broker-Dealer any documentation that, in the DealerSelling Group Member’s reasonable judgment, would cause the Dealer Selling Group Member to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer Selling Group Member hereby represents that it is currently in compliance with all AML rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer Selling Group Member hereby agrees, upon request by the Managing Broker-Dealer to (i) provide an annual certification to the Managing Broker-Dealer that, as of the date of such certification (A) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (C) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and (ii) perform and carry out, on behalf of both the Managing Broker-Dealer and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Selected Dealer’s acceptance of this Agreement constitutes a representation to the Managing Broker-Fund and the Dealer Manager that the Selected Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, SEC Rules and Section 352 of the Money Laundering Abatement ActAML Rules, the Bank Secrecy Act, as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Offered Shares. In addition, the Selected Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by OFAC (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Selected Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Selected Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the FINRA rules the Investors investors who purchase Offered Shares through the Selected Dealer are “Customerscustomers” of the Selected Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Selected Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the CompanyFund’s investors shareholders introduced to, and serviced by, the Selected Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Selected Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Selected Dealer’s reasonable judgment, would cause the Selected Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Selected Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Selected Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification certification, (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (Bii) it has continued to implement its AML Program and its OFAC Program and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the CompanyFund, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and U.S. Department of Treasury Department Rules rules thereunder.

Anti-Money Laundering Compliance Programs. Each Participating Broker-Dealer’s acceptance of this Dealer Agreement constitutes a representation to the Managing Corporation and the Dealer Manager that Participating Broker-Dealer that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, U.S. Securities and Exchange Commission (the “SEC”) Rules (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Offered Shares. In addition, the Participating Broker-Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control Department of Commerce, Bureau of Industry and Security, or the Department of State (such regulations and program, “Sanctions,” and such program as established by the Participating Broker-Dealer, “OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Participating Broker-Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Participating Broker-Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the FINRA rules the Investors investors who purchase Offered Shares through the Participating Broker-Dealer are “Customerscustomers” of the Participating Broker-Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Participating Broker-Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the CompanyCorporation’s investors stockholders introduced to, and serviced by, the Participating Broker-Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Participating Broker-Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Participating Broker-Dealer’s reasonable judgment, would cause the Participating Broker-Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Participating Broker-Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Participating Broker-Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC Sanctions requirements, ; (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC Sanctions requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the CompanyCorporation, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Selected Dealer’s acceptance of this Dealer Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Selected Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, Securities and Exchange Commission Rules (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Offered Shares. In addition, the Selected Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of foreign Assets Control regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Selected Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Selected Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the FINRA rules the Investors investors who purchase Offered Shares through the Selected Dealer are “Customerscustomers” of the Selected Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Selected Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the Company’s investors stockholders introduced to, and serviced by, the Selected Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Selected Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Selected Dealer’s reasonable judgment, would cause the Selected Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Selected Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Selected Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, ; (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Selected Dealer’s acceptance of this Dealer Agreement constitutes a representation to the Managing Broker-Corporation and the Dealer Manager that the Selected Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, U.S. Securities and Exchange Commission (the “SEC”) Rules (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Offered Shares. In addition, the Selected Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Selected Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Selected Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the FINRA rules the Investors investors who purchase Offered Shares through the Selected Dealer are “Customerscustomers” of the Selected Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Selected Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the CompanyCorporation’s investors stockholders introduced to, and serviced by, the Selected Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Selected Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Selected Dealer’s reasonable judgment, would cause the Selected Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Selected Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Selected Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, ; (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the CompanyCorporation, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Participating Broker-Dealer’s acceptance of this Agreement constitutes a representation to the Managing Company and the Dealer Manager that Participating Broker-Dealer that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, rules promulgated by the Commission (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Primary Shares. In additionParticipating Broker-Dealer covenants that it will perform all activities it is required to perform by applicable AML Rules and its AML Program with respect to all customers on whose behalf Participating Broker-Dealer submits orders to the Company. To the extent permitted by applicable law, Participating Broker-Dealer will share information with the Dealer represents that it has established Manager and implemented the Company for purposes of ascertaining whether a program (“OFAC Program”) for compliance suspicious activity report is warranted with OFAC and will continue respect to maintain its OFAC Program during any suspicious transaction involving the term purchase or intended purchase of this AgreementPrimary Shares. Upon request by the Managing Broker-Dealer Manager at any time, the Participating Broker-Dealer hereby agrees to (i) furnish a copy provide annual certification to the Dealer Manager that Participating Broker-Dealer has complied with the provisions of its AML Program and OFAC Program to the Managing relevant legal requirements. Participating Broker-Dealer for review and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Shares through the Dealer are “Customers” of the Dealer and not the Managing Broker-Dealer. Nonetheless, to the extent that the Managing Broker-Dealer deems it prudent, the Dealer shall cooperate with the Managing Broker-Dealer’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules and all OFAC requirementsRules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Money Laundering Abatement Act. The , and Participating Broker-Dealer hereby agreescovenants to remain in compliance with such requirements and shall, upon request by the Managing Broker-Dealer to (i) Manager, provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Aa) its AML Program and its OFAC Program are is consistent with the AML Rules and OFAC requirementsRules, (Bb) it has continued to implement its AML Program and its OFAC Program Program, and (Cc) it is currently in compliance with all AML Rules and OFAC requirementsRules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and (ii) perform and carry out, on behalf of both the Managing Broker-Dealer and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunderMoney Laundering Abatement Act.

Anti-Money Laundering Compliance Programs. Each Selected Dealer’s acceptance of this Dealer Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Selected Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, U.S. Securities and Exchange Commission (the “SEC”) Rules (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Offered Shares. In addition, the Selected Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Selected Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Selected Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the FINRA rules the Investors investors who purchase Offered Shares through the Selected Dealer are “Customerscustomers” of the Selected Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Selected Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the Company’s investors stockholders introduced to, and serviced by, the Selected Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Selected Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Selected Dealer’s reasonable judgment, would cause the Selected Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Selected Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Selected Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, ; (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Selected Dealer’s acceptance of this Dealer Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Selected Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, Securities and Exchange Commission Rules (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Offered Shares. In addition, the Selected Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Selected Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Selected Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the FINRA rules the Investors investors who purchase Offered Shares through the Selected Dealer are “Customerscustomers” of the Selected Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Selected Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the Company’s investors shareholders introduced to, and serviced by, the Selected Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Selected Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Selected Dealer’s reasonable judgment, would cause the Selected Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Selected Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Selected Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, ; (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Participating Dealer’s acceptance of this Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Participating Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, rules promulgated by the Commission (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Primary Shares. In addition, Participating Dealer’s acceptance of this Agreement also constitutes a representation to the Company and the Dealer represents Manager that it has established and implemented a program (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer at any time, the Dealer hereby agrees to (i) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer for review and (ii) furnish a copy as of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Shares through the date hereof, Participating Dealer are “Customers” of the Dealer and not the Managing Broker-Dealer. Nonetheless, to the extent that the Managing Broker-Dealer deems it prudent, the Dealer shall cooperate with the Managing Broker-Dealer’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules and all OFAC requirementsRules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Money Laundering Abatement Act. The Participating Dealer hereby agreescovenants that it will perform all activities it is required to perform by applicable AML Rules and its AML Program with respect to all customers on whose behalf Participating Dealer submits orders to the Company. To the extent permitted by applicable law, upon Participating Dealer will share information with the Dealer Manager and the Company for purposes of ascertaining whether a suspicious activity report is warranted with respect to any suspicious transaction involving the purchase or intended purchase of Primary Shares. Upon request by the Managing Broker-Dealer Manager at any time, Participating Dealer hereby agrees to (i) provide an annual certification to the Managing Broker-Dealer that, as furnish a written copy of the date of such certification (A) its AML Program to the Dealer Manager for review, and its OFAC Program are consistent (ii) furnish a copy of the findings and any remedial actions taken in connection with the AML Rules and OFAC requirements, (B) it has continued to implement Participating Dealer’s most recent independent testing of its AML Program and its OFAC Program and (C) Program. Participating Dealer further represents that it is currently in compliance with all AML Rules and OFAC requirementsRules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Money Laundering Abatement Act, and Participating Dealer hereby covenants to remain in compliance with such requirements and shall, upon request by the Dealer Manager, provide a certification to Dealer Manager that, as of the date of such certification (i) its AML Program is consistent with the AML Rules, (ii) perform it has continued to implement its AML Program, and carry out(iii) it is currently in compliance with all AML Rules, on behalf of both the Managing Broker-Dealer and the Companyspecifically including, but not limited to, the Customer Identification Program requirements in accordance with under Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunderMoney Laundering Abatement Act.

Anti-Money Laundering Compliance Programs. Each Participating Broker-Dealer’s acceptance of this Agreement constitutes a representation and warranty to the Managing Company and the Dealer Manager that Participating Broker-Dealer that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, rules promulgated by the SEC and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Primary Shares. In additionParticipating Broker-Dealer covenants that it will perform all activities it is required to perform by applicable AML Rules and its AML Program with respect to all customers on whose behalf Participating Broker-Dealer submits orders to the Company. To the extent permitted by applicable law, Participating Broker-Dealer will share information with the Dealer represents that it has established Manager and implemented the Company for purposes of ascertaining whether a program (“OFAC Program”) for compliance suspicious activity report is warranted with OFAC and will continue respect to maintain its OFAC Program during any suspicious transaction involving the term purchase or intended purchase of this AgreementPrimary Shares. Upon request by the Managing Broker-Dealer Manager at any time, the Participating Broker-Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program relevant legal requirements to the Managing Broker-Dealer Manager for review review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Participating Broker-Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Shares through the Dealer are “Customers” of the Dealer and not the Managing Broker-Dealer. Nonetheless, to the extent that the Managing Participating Broker-Dealer deems it prudent, the Dealer shall cooperate with the Managing Broker-Dealer’s auditing further represents and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things: warrants that (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules and all OFAC requirementsRules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT ActMoney Laundering Abatement Act and Participating Broker-Dealer will remain in compliance with such requirements, (ii) it has Know Your Customer (KYC) policies and procedures in place, (iii) the Participating Broker-Dealer’s AML Program has been adopted by a person with sufficient authority to oversee the AML policies and procedures, and (iv) the Participating Broker-Dealer’s AML Program has education and/or training programs for officers and employees regarding AML policies and procedures. The Participating Dealer hereby agreesshall, upon request by the Managing Broker-Dealer to (i) Manager, provide an annual a certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are is consistent with the AML Rules and OFAC requirementsRules, (Bii) it has continued to implement its AML Program and has complied with the provisions of its OFAC Program AML Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirementsRules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and (ii) perform and carry out, on behalf of both the Managing Broker-Dealer and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunderMoney Laundering Abatement Act.

Anti-Money Laundering Compliance Programs. Each Dealer’s acceptance of this Selected Dealer Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program and customer identification program (“AML Program”), ) in accordance with applicable FINRA Rule 3310 rules, including NASD Conduct Rules, SEC Rules and Section 352 of the Money Laundering Abatement Act, the Bank Secrecy Act, Title 31 U.S.C. Sections 5311-5355, as amendedamended by the USA PATRIOT Act, and Section 326 of the Patriot Act of 2001related regulations (31 C.F.R. Part 103), which are specifically including, but not limited to, 31 U.S.C. 5318(h) (Anti-Money Laundering Programs) requiring financial institutions, including securities broker-dealers, to establish anti-money laundering programs reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of SharesShares of the Company and 31 C.F.R. 103.122 (Customer Identification Programs for broker-dealers) (the “AML Rules”). In addition, the Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC ), and will continue to maintain its AML and OFAC Program Programs consistent with AML Rules and OFAC requirements during the term of this Selected Dealer Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Dealer hereby agrees to (iA) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (iiB) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for Dealer Manager shall have the purposes of the FINRA rules the Investors who purchase Shares through the Dealer are “Customers” of the Dealer and right, upon reasonable notice to Dealer, but not the Managing Broker-Dealer. Nonethelessobligation, to the extent that the Managing Broker-audit and/or monitor Dealer’s AML Program and OFAC Program. In any such event, Dealer deems it prudent, the Dealer shall agrees to cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, reports related to any customers of Dealer purchasing Shares in the CompanyCompany (“Dealer’s investors introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things, copies of: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Dealer’s Customers; (iii) any suspicious activity reports filed related to the Dealer’s Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Dealer’s Customers. In the event that such documents reflect, in the opinion of the Managing Broker-DealerDealer Manager, a potential violation of the Managing Broker-DealerDealer Manager’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer Manager to further inspect relevant books and records related to the Dealer’s Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may Dealer would be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act31 C.F.R. 103.122. The Dealer hereby agrees: (A) to perform and carry out, upon request by on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with 31 C.F.R. 103.122 and applicable Securities and Exchange Commission (“SEC”), FINRA, including NASD, and Treasury Department Rules thereunder, and (B) to (i) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification certification, (A1) it has implemented and is continuing to implement its AML Program and its OFAC Program, (2) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (C3) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and (ii) perform and carry out, on behalf of both the Managing Broker-Dealer and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder31 C.F.R. 103.122.

Anti-Money Laundering Compliance Programs. Each Participating Dealer’s acceptance of this Participating Dealer Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Participating Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, Securities and Exchange Commission Rules (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Offered Shares. In addition, the Participating Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of foreign Assets Control regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Participating Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Participating Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the FINRA rules the Investors investors who purchase Offered Shares through the Participating Dealer are “Customerscustomers” of the Participating Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Participating Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the Company’s investors stockholders introduced to, and serviced by, the Participating Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Participating Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Participating Dealer’s reasonable judgment, would cause the Participating Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Participating Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Participating Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, ; (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Participating Dealer’s acceptance of this Agreement constitutes a representation to the Managing Broker-Dealer Company and the Distributor that the Participating Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, rules promulgated by the Commission (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 5 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Primary Shares. In addition, the Participating Dealer represents covenants that it has established will perform all activities it is required to perform by applicable AML Rules and implemented its AML Program with respect to all customers on whose behalf Participating Dealer submits orders to the Company. To the extent permitted by applicable law, Participating Dealer will share information with the Distributor and the Company for purposes of ascertaining whether a program (“OFAC Program”) for compliance suspicious activity report is warranted with OFAC and will continue respect to maintain its OFAC Program during any suspicious transaction involving the term purchase or intended purchase of this AgreementPrimary Shares. Upon request by the Managing Broker-Dealer Distributor at any time, the Participating Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Managing Broker-Dealer Distributor for review review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Participating Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Shares through the Participating Dealer are “Customers” of the Dealer and not the Managing Broker-Dealer. Nonetheless, to the extent that the Managing Broker-Dealer deems it prudent, the Dealer shall cooperate with the Managing Broker-Dealer’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules and all OFAC requirementsRules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Money Laundering Abatement Act. The , and Participating Dealer hereby agreescovenants to remain in compliance with such requirements and shall, upon request by the Managing Broker-Dealer to (i) Distributor, provide an annual a certification to the Managing Broker-Dealer Distributor that, as of the date of such certification (Ai) its AML Program and its OFAC Program are is consistent with the AML Rules and OFAC requirementsRules, (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirementsRules, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and (ii) perform and carry out, on behalf of both the Managing Broker-Dealer and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunderMoney Laundering Abatement Act.

Anti-Money Laundering Compliance Programs. Each Dealer’s acceptance of this Selected Dealer Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program and customer identification program (“AML Program”), ) in accordance with applicable FINRA Rule 3310 rules, including NASD Conduct Rules, SEC Rules and Section 352 of the Money Laundering Abatement Act, the Bank Secrecy Act, as amendedTitle 31 U.S.C. Sections 5311-5355 and related regulations (31 C.F.R. Part 103) (collectively, the “AML Rules”), specifically including, but not limited to, 31 U.S.C. 5318(h) (“Anti-money laundering programs”) requiring financial institutions, including securities broker-dealers, to establish anti-money laundering programs, 31 U.S.C. 5318(g) (“Reporting of suspicious transactions”) requiring financial institutions, including securities broker-dealers, to report suspicious transactions relevant to a possible violation of law or regulation, and Section 326 31 U.S.C. 5318(l) (“Identification and verification of the Patriot Act of 2001accountholders”) and C.F.R. 103.122 (“Customer identification programs for broker-dealers”) requiring financial institutions, which are reasonably expected including securities broker-dealers, to detect establish, document and cause reporting of suspicious transactions in connection with the sale of Shares. maintain written “Customer Identification Programs.” In addition, the Dealer represents that it has established and implemented a program for compliance with all regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC ), and will continue to maintain its AML and OFAC Program Programs consistent with AML Rules and OFAC requirements during the term of this Selected Dealer Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Dealer hereby agrees to (iA) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (iiB) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for Dealer Manager shall have the purposes of the FINRA rules the Investors who purchase Shares through the Dealer are “Customers” of the Dealer and right, upon reasonable notice to Dealer, but not the Managing Broker-Dealer. Nonethelessobligation, to the extent that the Managing Broker-audit and/or monitor Dealer’s AML Program and OFAC Program. In any such event, Dealer deems it prudent, the Dealer shall agrees to cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, reports related to any customers of Dealer purchasing Shares in the CompanyCompany (“Dealer’s investors introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things: (i) , copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Dealer’s Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the CustomersDealer’s Customers (except Suspicious Activity Reports filed or to be filed with FinCEN). In the event that such documents reflect, in the opinion of the Managing Broker-DealerDealer Manager, a potential violation of the Managing Broker-DealerDealer Manager’s obligations in respect of its AML or OFAC requirementsobligations, the Dealer will permit the Managing Broker-Dealer Manager to further inspect relevant books and records related to the Dealer’s Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may Dealer would be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently subject to a rule implementing 31 U.S.C. 5318(h), and that it is in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act31 C.F.R. 103.122. The Dealer hereby agrees: (A) to perform and carry out, upon request by on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with 31 C.F.R. 103.122 and applicable SEC, FINRA, including NASD, and Treasury Department Rules thereunder, and (B) to (i) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification certification, (A1) it has implemented and is continuing to implement its AML Program and its OFAC Program, (2) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (C3) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, ; and (4) that Dealer will perform all of the specified requirements for Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and (ii) perform and carry out, on behalf of both the Managing Broker-Dealer and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunderPrograms as required by 31 C.F.R. 103.122.

Anti-Money Laundering Compliance Programs. Each Selected Dealer’s acceptance of this Dealer Agreement constitutes a representation to the Managing Broker-Fund and the Dealer Manager that the Selected Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, Securities and Exchange Commission Rules (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Offered Shares. In addition, the Selected Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Selected Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Selected Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the FINRA rules the Investors investors who purchase Offered Shares through the Selected Dealer are “Customerscustomers” of the Selected Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Selected Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the CompanyFund’s investors shareholders introduced to, and serviced by, the Selected Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Selected Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Selected Dealer’s reasonable judgment, would cause the Selected Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Selected Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Selected Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, ; (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the CompanyFund, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Dealer’s acceptance of this Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program and customer identification program (“AML Program”), ) in accordance with applicable law, including rules of the SEC, FINRA Rule 3310 rules and the USA PATRIOT Act, specifically including, but not limited to, Section 352 of the Money Laundering Abatement ActAct (collectively, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Shares. In addition, the Dealer represents that it has established and implemented a program for compliance with all regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Dealer hereby agrees to (ia) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (iib) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors investors who purchase Shares through the Dealer are “Customerscustomers” of the Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors shareholders introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things: (i) , copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-DealerDealer Manager, a potential violation of the Managing Broker-DealerDealer Manager’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer Manager to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each The Dealer’s acceptance of this Selected Dealer Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program and customer identification program (“AML Program”), ) in accordance with applicable FINRA Rule 3310 rules, SEC Rules and Section 352 of the Money Laundering Abatement Act, the Bank Secrecy Act, Title 31 U.S.C. Sections 5311-5355, as amendedamended by the USA PATRIOT Act, and Section 326 of the Patriot Act of 2001related regulations (31 C.F.R. Part 103), which are specifically including, but not limited to, 31 U.S.C. 5318(h) (Anti-Money Laundering Programs) requiring financial institutions, including securities broker-dealers, to establish anti-money laundering programs reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of SharesShares of the Company and 31 C.F.R. 103.122 (Customer Identification Programs for broker-dealers) (the “AML Rules”). In addition, the Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC” and such program is hereinafter referred to as the “OFAC Program”) for compliance with OFAC ), and will continue to maintain its AML Program and OFAC Program consistent with AML Rules and OFAC requirements during the term of this Selected Dealer Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Dealer hereby agrees to (ia) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (iib) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the FINRA rules the Investors investors who purchase Shares through the Dealer are “Customerscustomers” of the Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the Company’s investors stockholders introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, ; (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Dealer’s acceptance of this Agreement constitutes a representation to the Managing Broker-Broker Dealer that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), in accordance with FINRA Rule 3310 and Section 352 of the Money Laundering Abatement Act, the Bank Secrecy Act, as amended, Act and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause reporting of suspicious transactions in connection with the sale of SharesSecurities. In addition, the Dealer represents that it has established and implemented a program (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Broker Dealer at any time, the Dealer hereby agrees to (i) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Broker Dealer for review and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Shares Securities through the Dealer are “Customers” of the Dealer and not the Managing Broker-Broker Dealer. Nonetheless, to the extent that the Managing Broker-Broker Dealer deems it prudent, the Dealer shall cooperate with the Managing Broker-Broker Dealer’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors bond holders introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Broker Dealer, a potential violation of the Managing Broker-Broker Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Broker Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, when so directed by his or her legal counsel, the Dealer shall not be required to provide to the Managing Broker-Broker Dealer any documentation that, in the Dealer’s reasonable judgment, would that could potentially cause the Dealer to lose the benefit of an attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer hereby agrees, upon request by the Managing Broker-Broker Dealer to (i) provide an annual certification to the Managing Broker-Broker Dealer that, as of the date of such certification (A) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (C) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and (ii) perform and carry out, on behalf of both the Managing Broker-Broker Dealer and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Selected Dealer’s acceptance of this Dealer Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Selected Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, Securities and Exchange Commission Rules (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Offered Shares. In addition, the Selected Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Selected Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Selected Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the FINRA rules the Investors investors who purchase Offered Shares through the Selected Dealer are “Customerscustomers” of the Selected Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Selected Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the Company’s investors shareholders introduced to, and serviced by, the Selected Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Selected Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Selected Dealer’s reasonable judgment, would cause the Selected Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Selected Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Selected Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Dealer’s acceptance of this Participating Dealer Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable NASD Conduct Rules under FINRA Rule 3310 and other applicable FINRA Rules, Securities and Exchange Commission Rules (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of the Shares. In addition, the Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Participating Dealer Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. Dealer undertakes to promptly notify the Dealer Manager of any material changes to such Dealer’s AML program. The parties acknowledge that for the purposes of FINRA Rules, the FINRA rules the Investors investors who purchase Shares through the Dealer are “Customerscustomers” of the Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the Company’s investors stockholders introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, ; (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Dealer’s 's acceptance of this Agreement constitutes a representation to the Managing Broker-Dealer Placement Agent that the Dealer has established and implemented an anti-money laundering (“"AML”") compliance program (“"AML Program”"), in accordance with FINRA Rule 3310 and Section 352 of the Money Laundering Abatement Act, the Bank Secrecy Act, as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause reporting of suspicious transactions in connection with the sale of Shares. In addition, the Dealer represents that it has established and implemented a program (“"OFAC Program”") for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Placement Agent at any time, the Dealer hereby agrees to (i) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer Placement Agent for review and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s 's most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Shares through the Dealer are “"Customers” " of the Dealer and not the Managing Broker-DealerPlacement Agent. Nonetheless, to the extent that the Managing Broker-Dealer Placement Agent deems it prudent, the Dealer shall cooperate with the Managing Broker-Dealer’s Placement Agent's auditing and monitoring of the Dealer’s 's AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s 's investors introduced to, and serviced by, the Dealer (the “"Customers”"). Such documentation could include, among other things: (i) copies of Dealer’s 's AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s 's AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s 's AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-DealerPlacement Agent, a potential violation of the Managing Broker-Dealer’s Placement Agent's obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer Placement Agent to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s 's compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer Placement Agent any documentation that, in the Dealer’s 's reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer hereby agrees, upon request by the Managing Broker-Dealer Placement Agent to (i) provide an annual certification to the Managing Broker-Dealer Placement Agent that, as of the date of such certification (A) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (C) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and (ii) perform and carry out, on behalf of both the Managing Broker-Dealer Placement Agent and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Dealer’s acceptance of this Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program and customer identification program (“AML Program”), ) in accordance with applicable law, including rules of the SEC, FINRA Rule 3310 rules and the USA PATRIOT Act, specifically including, but not limited to, Section 352 of the Money Laundering Abatement ActAct (collectively, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Shares. In addition, the Dealer represents that it has established and implemented a program (“OFAC Program”) for compliance with OFAC Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC”) and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Dealer hereby agrees to (ia) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (iib) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors investors who purchase Shares through the Dealer are “Customerscustomers” of the Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors stockholders introduced to, and serviced by, the Dealer (the “Customers”). Such The documentation could include, among other things: (i) , copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such these documents reflect, in the opinion of the Managing Broker-DealerDealer Manager, a potential violation of the Managing Broker-DealerDealer Manager’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer Manager to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Dealer’s acceptance of this Selected Dealer Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program and customer identification program (“AML Program”), ) in accordance with applicable FINRA Rule 3310 rules, including NASD Conduct Rules, SEC Rules and Section 352 of the Money Laundering Abatement Act, the Bank Secrecy Act, Title 31 U.S.C. Sections 5311-5355, as amendedamended by the USA PATRIOT Act, and Section 326 of the Patriot Act of 2001related regulations (31 C.F.R. Part 103), which are specifically including, but not limited to, 31 U.S.C. 5318(h) (Anti-Money Laundering Programs) requiring financial institutions, including securities broker-dealers, to establish anti-money laundering programs reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of SharesShares of the Company and 31 C.F.R. 103.122 (Customer Identification Programs for broker-dealers) (the “AML Rules”). In addition, the Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC ), and will continue to maintain its AML and OFAC Program Programs consistent with AML Rules and OFAC requirements during the term of this Agreement. Selected Dealer Agreement Upon request by the Managing Broker-Dealer Manager at any time, the Dealer hereby agrees to (ia) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (iib) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for Dealer Manager shall have the purposes of the FINRA rules the Investors who purchase Shares through the Dealer are “Customers” of the Dealer and right, upon reasonable notice to Dealer, but not the Managing Broker-Dealer. Nonethelessobligation, to the extent that the Managing Broker-audit and/or monitor Dealer’s AML Program and OFAC Program. In any such event, Dealer deems it prudent, the Dealer shall agrees to cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC OFAC, Program by providing, upon request, information, records, data and exception reports, reports related to any customers of Dealer purchasing Shares in the CompanyCompany (“Dealer’s investors introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things: (i) , copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Dealer’s Customers; (iii) any suspicious activity reports filed related to the Dealer’s Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Dealer’s Customers. In the event that such documents reflect, in the opinion of the Managing Broker-DealerDealer Manager, a potential violation of the Managing Broker-DealerDealer Manager’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer Manager to further inspect relevant books and records related to the Dealer’s Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may Dealer would be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act31 C.F.R. 103.122. The Dealer hereby agrees: (A) to perform and carry out, upon request by on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with 31 C.F.R. 103.122 and applicable SEC, FINRA, including NASD, and Treasury Department Rules thereunder, and (B) to (i) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification certification, (A1) it has implemented and is continuing to implement its AML Program and its OFAC Program, (2) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (C3) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and (ii) perform and carry out, on behalf of both the Managing Broker-Dealer and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder31 C.F.R. 103.122.

Anti-Money Laundering Compliance Programs. Each Dealer’s acceptance of this Selected Dealer Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program and customer identification program (“AML Program”), ) in accordance with FINRA Rule 3310 applicable law, including applicable NASD Rules, SEC Rules and the USA PATRIOT Act, specifically including, but not limited to, Section 352 of the Money Laundering Abatement ActAct (collectively, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of SharesShares of the Company. In addition, the Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this the Selected Dealer Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Dealer hereby agrees to (i1) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (ii2) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for Dealer Manager shall have the purposes of the FINRA rules the Investors who purchase Shares through the Dealer are “Customers” of the Dealer and right, upon reasonable notice to Dealer, but not the Managing Broker-Dealer. Nonethelessobligation, to the extent that the Managing Broker-audit and/or monitor Dealer’s AML Program and OFAC Program. In any such event, Dealer deems it prudent, the Dealer shall agrees to cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors introduced to, and shareholders serviced by, the by Dealer (the “Dealer’s Customers”). Such documentation could include, among other things, copies of: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Dealer’s Customers; (iii) any suspicious activity reports filed related to the Dealer’s Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Dealer’s Customers. In the event that such documents reflect, in the opinion of the Managing Broker-DealerDealer Manager, a potential violation of the Managing Broker-DealerDealer Manager’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer Manager to further inspect relevant books and records related to the Dealer’s Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may Dealer would be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer hereby agrees, upon request by the Managing Broker-Dealer : (A) to (i) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) to perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC Securities and Exchange Commission (“SEC”), NASD and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Dealer’s acceptance of this Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program and customer identification program (“AML Program”), ) in accordance with FINRA Rule 3310 applicable law, including rules of the Securities and Exchange Commission (“SEC”), NASD rules and the USA PATRIOT Act, specifically including, but not limited to, Section 352 of the Money Laundering Abatement ActAct (collectively, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Shares. In addition, the Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Dealer hereby agrees to (ia) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (iib) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA NASD rules the Investors investors who purchase Shares through the Dealer are “Customerscustomers” of the Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors shareholders introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things: (i) , copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-DealerDealer Manager, a potential violation of the Managing Broker-DealerDealer Manager’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer Manager to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Dealer’s acceptance of this Selected Dealer Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program and customer identification program (“AML Program”), ) in accordance with FINRA Rule 3310 applicable NASD Rules, SEC Rules and Section 352 of the Money Laundering Abatement Act, the Bank Secrecy Act, Title 31 U.S.C. Sections 5311-5355, as amendedamended by the USA PATRIOT Act, and Section 326 of the Patriot Act of 2001related regulations (31 C.F.R. Part 103), which are specifically including, but not limited to, 31 U.S.C. 5318(h) (Anti-Money Laundering Programs) requiring financial institutions, including securities broker-dealers, to establish anti-money laundering programs reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of SharesShares of the Company and 31 C.F.R. 103.122 (Customer Identification Programs for broker-dealers) (the “AML Rules”). In addition, the Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC ), and will continue to maintain its AML and OFAC Program Programs consistent with AML Rules and OFAC requirements during the term of this Selected Dealer Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Dealer hereby agrees to (i1) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (ii2) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for Dealer Manager shall have the purposes of the FINRA rules the Investors who purchase Shares through the Dealer are “Customers” of the Dealer and right, upon reasonable notice to Dealer, but not the Managing Broker-Dealer. Nonethelessobligation, to the extent that the Managing Broker-audit and/or monitor Dealer’s AML Program and OFAC Program. In any such event, Dealer deems it prudent, the Dealer shall agrees to cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, reports related to any customers of Dealer purchasing Shares in the CompanyCompany (“Dealer’s investors introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things, copies of: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Dealer’s Customers; (iii) any suspicious activity reports filed related to the Dealer’s Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Dealer’s Customers. In the event that such documents reflect, in the opinion of the Managing Broker-DealerDealer Manager, a potential violation of the Managing Broker-DealerDealer Manager’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer Manager to further inspect relevant books and records related to the Dealer’s Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may Dealer would be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act31 C.F.R. 103.122. The Dealer hereby agrees: (A) to perform and carry out, upon request by on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with 31 C.F.R. 103.122 and applicable Securities and Exchange Commission (“SEC”), NASD and Treasury Department Rules thereunder, and (B) to (i) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification certification, (Ai) it has implemented and is continuing to implement its AML Program and its OFAC Program, (ii) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and (ii) perform and carry out, on behalf of both the Managing Broker-Dealer and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder31 C.F.R. 103.122.

Anti-Money Laundering Compliance Programs. Each Dealer’s acceptance of this Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program and customer identification program (“AML Program”), ) in accordance with applicable law, including rules of the SEC, FINRA Rule 3310 rules and the USA PATRIOT Act, specifically including, but not limited to, Section 352 of the Money Laundering Abatement ActAct (collectively, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Shares. In addition, the Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Dealer hereby agrees to (ia) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (iib) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or and its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors investors who purchase Shares through the Dealer are “Customerscustomers” of the Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors stockholders introduced to, and serviced by, the Dealer (the “Customers”). Such The documentation could include, among other things: (i) , copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such these documents reflect, in the opinion of the Managing Broker-DealerDealer Manager, a potential violation of the Managing Broker-DealerDealer Manager’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer Manager to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the or Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (Bii) it has continued to implement its AML Program and its OFAC Program and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each The Dealer’s acceptance of this Selected Dealer Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program and customer identification program (“AML Program”), ) in accordance with applicable FINRA Rule 3310 rules, SEC Rules and Section 352 of the Money Laundering Abatement Act, Regulations and the Bank Secrecy Act, Title 31 U.S.C. Sections 5311-5355, as amendedamended by the USA PATRIOT Act, and Section 326 of the Patriot Act of 2001related regulations (31 C.F.R. Chapter X), which are specifically including, but not limited to, 31 U.S.C. 5318(h) (Anti-Money Laundering Programs) requiring financial institutions, including securities broker-dealers, to establish anti-money laundering programs reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of SharesShares of the Company and 31 C.F.R. 1023.220 (Customer Identification Programs for broker-dealers) (the “AML Rules”). In addition, the Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC” and such program is hereinafter referred to as the “OFAC Program”) for compliance with OFAC ), and will continue to maintain its AML Program and OFAC Program consistent with AML Rules and OFAC requirements during the term of this Selected Dealer Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Dealer hereby agrees to (ia) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (iib) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the FINRA rules the Investors investors who purchase Shares through the Dealer are “Customerscustomers” of the Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the Company’s investors stockholders introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, ; (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC Rules and Regulations and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Participating Dealer’s acceptance of this Participating Dealer Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Participating Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, Securities and Exchange Commission Rules (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Offered Shares. In addition, the Participating Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of foreign Assets Control regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Participating Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Participating Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the FINRA rules the Investors investors who purchase Offered Shares through the Participating Dealer are “Customerscustomers” of the Participating Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Participating Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the Company’s investors stockholders introduced to, and serviced by, the Participating Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Participating Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Participating Dealer’s reasonable judgment, would cause the Participating Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Participating Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Participating Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, ; (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC Commission and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Participating Dealer’s acceptance of this Participating Dealer Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Participating Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, Securities and Exchange Commission Rules (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Offered Shares. In addition, the Participating Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of foreign Assets Control regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Participating Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Participating Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the FINRA rules the Investors investors who purchase Offered Shares through the Participating Dealer are “Customerscustomers” of the Participating Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Participating Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the Company’s investors stockholders introduced to, and serviced by, the Participating Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Participating Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Participating Dealer’s reasonable judgment, would cause the Participating Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Participating Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Participating TP Flexible Income Fund, Inc. Dealer Manager Agreement Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, ; (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC Commission and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Dealer’s 's acceptance of this Agreement constitutes a representation to the Managing Broker-Dealer that the Dealer has established and implemented an anti-money laundering (“"AML”") compliance program (“"AML Program”"), in accordance with FINRA Rule 3310 and Section 352 of the Money Laundering Abatement Act, the Bank Secrecy Act, as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause reporting of suspicious transactions in connection with the sale of Shares. In addition, the Dealer represents that it has established and implemented a program (“"OFAC Program”") for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer at any time, the Dealer hereby agrees to (i) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer for review and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s 's most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Shares through the Dealer are “"Customers” " of the Dealer and not the Managing Broker-Dealer. Nonetheless, to the extent that the Managing Broker-Dealer deems it prudent, the Dealer shall cooperate with the Managing Broker-Dealer’s 's auditing and monitoring of the Dealer’s 's AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s 's investors introduced to, and serviced by, the Dealer (the “"Customers”"). Such documentation could include, among other things: (i) copies of Dealer’s 's AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s 's AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s 's AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s 's obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s 's compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer any documentation that, in the Dealer’s 's reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer hereby agrees, upon request by the Managing Broker-Dealer to (i) provide an annual certification to the Managing Broker-Dealer that, as of the date of such certification (A) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (C) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and (ii) perform and carry out, on behalf of both the Managing Broker-Dealer and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each DealerSelling Group Member’s acceptance of this Agreement constitutes a representation to the Managing Broker-Dealer that the Dealer Selling Group Member has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), in accordance with FINRA Rule 3310 and Section 352 of the Money Laundering Abatement Act, the Bank Secrecy Act, as amended, Act and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause reporting of suspicious transactions in connection with the sale of SharesSeries A Units. In addition, the Dealer Selling Group Member represents that it has established and implemented a program (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer at any time, the Dealer Selling Group Member hereby agrees to (i) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer for review and (ii) furnish a copy of the findings and any remedial actions taken in connection with the DealerSelling Group Member’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Shares Series A Units through the Dealer Selling Group Member are “Customers” of the Dealer Selling Group Member and not the Managing Broker-Dealer. Nonetheless, to the extent that the Managing Broker-Dealer deems it prudent, the Dealer Selling Group Member shall cooperate with the Managing Broker-Dealer’s auditing and monitoring of the DealerSelling Group Member’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors Investors introduced to, and serviced by, the Dealer Selling Group Member (the “Customers”). Such documentation could include, among other things: (i) copies of DealerSelling Group Member’s AML Program and its OFAC Program; , (ii) documents maintained pursuant to the DealerSelling Group Member’s AML Program and its OFAC Program related to the Customers; , (iii) any suspicious activity reports filed related to the Customers; , (iv) audits and any exception reports related to the DealerSelling Group Member’s AML activities; activities and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer Selling Group Member will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the DealerSelling Group Member’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer Selling Group Member shall not be required to provide to the Managing Broker-Dealer any documentation that, in the DealerSelling Group Member’s reasonable judgment, would cause the Dealer Selling Group Member to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer Selling Group Member hereby represents that it is currently in compliance with all AML rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer Selling Group Member hereby agrees, upon request by the Managing Broker-Dealer to (i) provide an annual certification to the Managing Broker-Dealer that, as of the date of such certification (A) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (C) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and (ii) perform and carry out, on behalf of both the Managing Broker-Dealer and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Dealer’s acceptance of this Agreement constitutes a representation to the Managing Broker-Dealer that the Dealer has established and implemented an anti-money laundering (“"AML”") compliance program (“"AML Program”"), in accordance with FINRA Rule 3310 and Section 352 of the Money Laundering Abatement Act, the Bank Secrecy Act, as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause reporting of suspicious transactions in connection with the sale of Shares. In addition, the Dealer represents that it has established and implemented a program (“"OFAC Program”") for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer at any time, the Dealer hereby agrees to (i) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer for review and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Shares through the Dealer are “"Customers” " of the Dealer and not the Managing Broker-Dealer. Nonetheless, to the extent that the Managing Broker-Dealer deems it prudent, the Dealer shall cooperate with the Managing Broker-Dealer’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors introduced to, and serviced by, the Dealer (the “"Customers”"). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer hereby agrees, upon request by the Managing Broker-Dealer to (i) provide an annual certification to the Managing Broker-Dealer that, as of the date of such certification (A) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (C) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and (ii) perform and carry out, on behalf of both the Managing Broker-Dealer and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each The Dealer’s acceptance of this Selected Dealer Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program and customer identification program (“AML Program”), ) in accordance with applicable FINRA Rule 3310 rules, SEC Rules and Section 352 of the Money Laundering Abatement Act, the Bank Secrecy Act, Title 31 U.S.C. Sections 5311-5355, as amendedamended by the USA PATRIOT Act, and Section 326 of the Patriot Act of 2001related regulations (31 C.F.R. Chapter X), which are specifically including, but not limited to, 31 U.S.C. 5318(h) (Anti-Money Laundering Programs) requiring financial institutions, including securities broker-dealers, to establish anti-money laundering programs reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of SharesShares of the Company and 31 C.F.R. 1023.220 (Customer Identification Programs for broker-dealers) (the “AML Rules”). In addition, the Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC” and such program is hereinafter referred to as the “OFAC Program”) for compliance with OFAC ), and will continue to maintain its AML Program and OFAC Program consistent with AML Rules and OFAC requirements during the term of this Selected Dealer Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Dealer hereby agrees to (ia) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (iib) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the FINRA rules the Investors investors who purchase Shares through the Dealer are “Customerscustomers” of the Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the Company’s investors stockholders introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, ; (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Participating Broker-Dealer’s acceptance of this Dealer Agreement constitutes a representation to the Managing Trust and the Dealer Manager that Participating Broker-Dealer that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, U.S. Securities and Exchange Commission (the “SEC”) Rules (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Shares. In addition, the Participating Broker-Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control Department of Commerce, Bureau of Industry and Security, or the Department of State (such regulations and program, “Sanctions,” and such program as established by the Participating Broker-Dealer, “OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Participating Broker-Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Participating Broker-Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the FINRA rules the Investors investors who purchase Shares through the Participating Broker-Dealer are “Customerscustomers” of the Participating Broker-Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Participating Broker-Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the CompanyTrust’s investors stockholders introduced to, and serviced by, the Participating Broker-Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Participating Broker-Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Participating Broker-Dealer’s reasonable judgment, would cause the Participating Broker-Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Participating Broker-Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Participating Broker-Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC Sanctions requirements, ; (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC Sanctions requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the CompanyTrust, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Dealer’s acceptance of this Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program and customer identification program (“AML Program”), ) in accordance with FINRA Rule 3310 applicable law, including rules of the SEC, NASD rules and the USA PATRIOT Act, specifically including, but not limited to, Section 352 of the Money Laundering Abatement ActAct (collectively, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Shares. In addition, the Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Dealer hereby agrees to (ia) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (iib) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA NASD rules the Investors investors who purchase Shares through the Dealer are “Customerscustomers” of the Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors shareholders introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things: (i) , copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-DealerDealer Manager, a potential violation of the Managing Broker-DealerDealer Manager’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer Manager to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Participating Broker-Dealer’s acceptance of this Dealer Agreement constitutes a representation to the Managing Corporation and the Dealer Manager that Participating Broker-Dealer that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, U.S. Securities and Exchange Commission (the “SEC”) Rules (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Offered Shares. In addition, the Participating Broker-Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Participating Broker-Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Participating Broker-Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the FINRA rules the Investors investors who purchase Offered Shares through the Participating Broker-Dealer are “Customerscustomers” of the Participating Broker-Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Participating Broker-Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the CompanyCorporation’s investors stockholders introduced to, and serviced by, the Participating Broker-Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Participating Broker-Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Participating Broker-Dealer’s reasonable judgment, would cause the Participating Broker-Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Participating Broker-Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Participating Broker-Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, ; (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the CompanyCorporation, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Participating Dealer’s acceptance of this Participating Dealer Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Participating Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, Securities and Exchange Commission Rules (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Offered Shares. In addition, the Participating Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of foreign Assets Control regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Participating Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Participating Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the FINRA rules the Investors investors who purchase Offered Shares through the Participating Dealer are “Customerscustomers” of the Participating Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Participating Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the Company’s investors stockholders introduced to, and serviced by, the Participating Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Participating Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Participating Dealer’s reasonable judgment, would Triton Pacific Investment Corporation, Inc. Dealer Manager Agreement cause the Participating Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Participating Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Participating Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, ; (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC Commission and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Selected Dealer’s acceptance of this Dealer Agreement constitutes a representation to the Managing Broker-Corporation and the Dealer Manager that the Selected Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, Securities and Exchange Commission Rules (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection A-7 with the sale of Offered Shares. In addition, the Selected Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Selected Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Selected Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the FINRA rules the Investors investors who purchase Offered Shares through the Selected Dealer are “Customerscustomers” of the Selected Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Selected Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the CompanyCorporation’s investors stockholders introduced to, and serviced by, the Selected Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Selected Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Selected Dealer’s reasonable judgment, would cause the Selected Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Selected Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Selected Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, ; (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the CompanyCorporation, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each DealerSelling Group Member’s acceptance of this Agreement constitutes a representation to the Managing Broker-Dealer that the Dealer Selling Group Member has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), in accordance with FINRA Rule 3310 and Section 352 of the Money Laundering Abatement Act, the Bank Secrecy Act, as amended, Act and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause reporting of suspicious transactions in connection with the sale of SharesBonds. In addition, the Dealer Selling Group Member represents that it has established and implemented a program (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer at any time, the Dealer Selling Group Member hereby agrees to (i) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer for review and (ii) furnish a copy of the findings and any remedial actions taken in connection with the DealerSelling Group Member’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Shares Bonds through the Dealer Selling Group Member are “Customers” of the Dealer Selling Group Member and not the Managing Broker-Dealer. Nonetheless, to the extent that the Managing Broker-Dealer deems it prudent, the Dealer Selling Group Member shall cooperate with the Managing Broker-Dealer’s auditing and monitoring of the DealerSelling Group Member’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors Investors introduced to, and serviced by, the Dealer Selling Group Member (the “Customers”). Such documentation could include, among other things: (i) copies of DealerSelling Group Member’s AML Program and its OFAC Program; , (ii) documents maintained pursuant to the DealerSelling Group Member’s AML Program and its OFAC Program related to the Customers; , (iii) any suspicious activity reports filed related to the Customers; , (iv) audits and any exception reports related to the DealerSelling Group Member’s AML activities; activities and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer Selling Group Member will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the DealerSelling Group Member’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer Selling Group Member shall not be required to provide to the Managing Broker-Dealer any documentation that, in the DealerSelling Group Member’s reasonable judgment, would cause the Dealer Selling Group Member to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer Selling Group Member hereby represents that it is currently in compliance with all AML rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the ofthe USA PATRIOT Act. The Dealer Selling Group Member hereby agrees, upon request by the Managing Broker-Dealer to (i) provide an annual certification to the Managing Broker-Dealer that, as of the date of such certification (A) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (C) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and (ii) perform and carry out, on behalf of both the Managing Broker-Dealer and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each DealerSelling Group Member’s acceptance of this Agreement constitutes a representation to the Managing Broker-Dealer Manager that the Dealer Selling Group Member has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), in accordance with FINRA Rule 3310 and Section 352 of the Money Laundering Abatement Act, the Bank Secrecy Act, as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause reporting of suspicious transactions in connection with the sale of Shares. In addition, the Dealer Selling Group Member represents that it has established and implemented a program (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Dealer Selling Group Member hereby agrees to (i) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review and (ii) furnish a copy of the findings and any remedial actions taken in connection with the DealerSelling Group Member’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Shares through the Dealer Selling Group Member are “Customers” of the Dealer Selling Group Member and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Dealer Selling Group Member shall A-11 cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the DealerSelling Group Member’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors introduced to, and serviced by, the Dealer Selling Group Member (the “Customers”). Such documentation could include, among other things: (i) copies of DealerSelling Group Member’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the DealerSelling Group Member’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the DealerSelling Group Member’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-DealerDealer Manager, a potential violation of the Managing Broker-DealerDealer Manager’s obligations in respect of its AML or OFAC requirements, the Dealer Selling Group Member will permit the Managing Broker-Dealer Manager to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the DealerSelling Group Member’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer Selling Group Member shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the DealerSelling Group Member’s reasonable judgment, would cause the Dealer Selling Group Member to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer Selling Group Member hereby represents that it is currently in compliance with all AML rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer Selling Group Member hereby agrees, upon request by the Managing Broker-Dealer Manager to (i) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (A) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (C) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and (ii) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Dealer’s acceptance of this Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program and customer identification program (“AML Program”), ) in accordance with FINRA Rule 3310 applicable law, including rules of the Securities and Exchange Commission (“SEC”), NASD rules and the USA PATRIOT Act, specifically including, but not limited to, Section 352 of the Money Laundering Abatement ActAct (collectively, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Shares. In addition, the Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department's Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Dealer hereby agrees to (ia) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (iib) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA NASD rules the Investors investors who purchase Shares through the Dealer are “Customerscustomers” of the Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors shareholders introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things: (i) , copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-DealerDealer Manager, a potential violation of the Managing Broker-DealerDealer Manager’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer Manager to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Participating Broker-Dealer’s acceptance of this Dealer Agreement constitutes a representation to the Managing Fund and the Dealer Manager that Participating Broker-Dealer that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with FINRA Rule 3310 and Section 352 of the Money Laundering Abatement Actapplicable law, including the Bank Secrecy Act, as amendedamended by the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (the “USA PATRIOT Act”), Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act”) and the Anti-Money Laundering Act of 2020 (each as may be amended from time to time , and Section 326 implementing regulations thereunder promulgated by the U.S. Department of the Patriot Act of 2001Treasury, which are the Financial Crimes Enforcement Network, FINRA, and the U.S. Securities and Exchange Commission (the “SEC”) Rules (the “Commission Rules”) (collectively, the “AML Rules”) reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Offered Shares. In addition, the Participating Broker-Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control Department of Commerce, Bureau of Industry and Security, or the Department of State (such regulations and program, “Sanctions,” and such program as established by the Participating Broker-Dealer, “OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Participating Broker-Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Participating Broker-Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of AML Rules, the FINRA rules the Investors investors who purchase Offered Shares through the Participating Broker-Dealer are “Customerscustomers” of the Participating Broker-Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Participating Broker-Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the CompanyFund’s investors stockholders introduced to, and serviced by, the Participating Broker-Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Participating Broker-Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Participating Broker-Dealer’s reasonable judgment, would cause the Participating Broker-Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Participating Broker-Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Due Diligence requirements under 31 C.F.R. § 1023.210(b)(5) and the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Participating Broker-Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC Sanctions requirements, ; (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC Sanctions requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and beneficial ownership requirements under 31 C.F.R. § 1010.220; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the CompanyFund, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Dealer’s acceptance of this Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with FINRA Rule 3310 and Section 352 of the Money Laundering Abatement Actapplicable law, including the Bank Secrecy Act, as amendedamended by the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (the “USA PATRIOT Act”), Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act”) and the Anti-Money Laundering Act of 2020 (each as may be amended from time to time , and Section 326 implementing regulations thereunder promulgated by the U.S. Department of the Patriot Act of 2001Treasury, which are the Financial Crimes Enforcement Network, FINRA, and the SEC Rules (the “Commission Rules”) (collectively, the “AML Rules”) , reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of SharesShares of the Company. In addition, the Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control Department of Commerce, Bureau of Industry and Security, or the Department of State (such regulations and program, “Sanctions,” and such program as established by the Participating Broker-Dealer, “OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer at any time, the Dealer hereby agrees to (i) furnish furnish, upon request, a copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review and (ii) furnish a copy to promptly notify the Dealer Manager of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of material changes to its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Shares through the Dealer are “Customers” of the Dealer and not the Managing Broker-Dealer. Nonetheless, to the extent that the Managing Broker-Dealer deems it prudent, the Dealer shall cooperate with the Managing Broker-Dealer’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer hereby agrees, upon request by the Managing Broker-Dealer to (i) provide an annual certification to the Managing Broker-Dealer that, as of the date of such certification (A) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (C) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and (ii) perform and carry out, on behalf of both the Managing Broker-Dealer and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Dealer’s acceptance of this Agreement constitutes a representation to the Managing Broker-The Dealer represents that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), in accordance with FINRA Rule 3310 and Section 352 of the Money Laundering Abatement Act, the Bank Secrecy Act, as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause reporting of suspicious transactions in connection with the sale of SharesSecurities. In addition, the Dealer represents that it has established and implemented a program (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Issuer at any time, the Dealer hereby agrees to (i) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer Issuer for review and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Shares Securities through the Dealer are “Customers” of the Dealer and not the Managing Broker-Dealer. Nonetheless, to the extent that the Managing Broker-Dealer Issuer deems it prudent, the Dealer shall cooperate with the Managing Broker-DealerIssuer’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the CompanyIssuer’s investors introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of the Dealer’s AML Program and its OFAC Program; , (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; , (iii) any suspicious activity reports filed related to the Customers; , (iv) audits and any exception reports related to the Dealer’s AML activities; activities and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-DealerIssuer, a potential violation of the Managing Broker-Dealer’s obligations in respect of any Issuer, its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer Issuer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer Issuer any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer hereby agrees, upon request by the Managing Broker-Dealer Issuer to (i) provide an annual certification to the Managing Broker-Dealer Issuer that, as of the date of such certification (A) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (C) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and (ii) perform and carry out, on behalf of both the Managing Broker-Dealer and the CompanyIssuer, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Participating Dealer’s acceptance of this Participating Dealer Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Participating Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, Securities and Exchange Commission Rules (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Offered Shares. In addition, the Participating Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of foreign Assets Control regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Participating Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Participating Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the FINRA rules the Investors investors who purchase Offered Shares through the Participating Dealer are “Customerscustomers” of the Participating Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Participating Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the Company’s investors stockholders introduced to, and serviced by, the Participating Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Participating Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Participating Dealer’s reasonable judgment, would Triton Pacific Investment Corporation, Inc. cause the Participating Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Participating Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Participating Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, ; (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC Commission and Treasury Department Rules thereunder.

Anti-Money Laundering Compliance Programs. Each Participating Dealer’s acceptance of this Participating Dealer Agreement constitutes a representation to the Managing Broker-Company and the Dealer Manager that the Participating Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), ) in accordance with applicable law, including applicable FINRA Rule 3310 Rules, Securities and Exchange Commission Rules (the “Commission Rules”) and the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001, as amended by the USA Patriot Improvement and Reauthorization Act of 2005 (the “USA PATRIOT Act”), specifically including, but not limited to, Section 352 of the International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 (the “Money Laundering Abatement Act,” and together with the USA PATRIOT Act, the Bank Secrecy Act“AML Rules”), as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause the reporting of suspicious transactions in connection with the sale of Offered Shares. In addition, the Participating Dealer represents that it has established and implemented a program for compliance with Executive Order 13224 and all regulations and programs administered by the Treasury Department’s Office of foreign Assets Control regulations and programs administered by the Treasury Department’s Office of Foreign Assets Control (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer Manager at any time, the Participating Dealer hereby agrees to (i) furnish a written copy of its AML Program and OFAC Program to the Managing Broker-Dealer Manager for review review, and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Participating Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of FINRA Rules, the FINRA rules the Investors investors who purchase Offered Shares through the Participating Dealer are “Customerscustomers” of the Participating Dealer and not the Managing Broker-DealerDealer Manager. Nonetheless, to the extent that the Managing Broker-Dealer Manager deems it prudent, the Participating Dealer shall cooperate with the Managing Broker-DealerDealer Manager’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, reasonable requests for information, records, records and data and exception reports, related to the Company’s investors stockholders introduced to, and serviced by, the Participating Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Participating Dealer shall not be required to provide to the Managing Broker-Dealer Manager any documentation that, in the Participating Dealer’s reasonable judgment, would Triton Pacific Investment Corporation, Inc. Dealer Manager Agreement cause the Participating Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Participating Dealer hereby represents that it is currently in compliance with all AML rules Rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Participating Dealer hereby agrees, upon request by the Managing Broker-Dealer Manager to (iA) provide an annual certification to the Managing Broker-Dealer Manager that, as of the date of such certification (Ai) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, ; (Bii) it has continued to implement its AML Program and its OFAC Program Program, and (Ciii) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act Act; and (iiB) perform and carry out, on behalf of both the Managing Broker-Dealer Manager and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.