Common use of Anti-Money Laundering Program Clause in Contracts

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer will cooperate with the Distributor and deliver information reasonably requested by the Distributor concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary for the Distributor or the Company to comply with the USA Patriot Act; and (iv) Broker/Dealer will notify the Distributor, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with USA Patriot Act in which case Broker/Dealer agrees to cooperate with the Distributor or the Company and deliver information reasonably requested by the Distributor or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section sec. 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer will cooperate with the Distributor ADI and deliver information reasonably requested by the Distributor ADI concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary for the Distributor ADI or the Company to comply with the USA Patriot Act; and (iv) Broker/Dealer will notify the DistributorADI, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with USA Patriot Act in which case Broker/Dealer agrees to cooperate with the Distributor ADI or the Company and deliver information reasonably requested by the Distributor ADI or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor ADI and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor ADI or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act.

Anti-Money Laundering Program. Broker/Dealer Servicer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer Servicer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section sec. 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer Servicer will cooperate with the Distributor ADI and deliver information reasonably requested by the Distributor ADI concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer Servicer necessary for the Distributor ADI or the Company to comply with the USA Patriot Act; and (iv) Broker/Dealer Servicer will notify the DistributorADI, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer Servicer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with the USA Patriot Act in which case Broker/Dealer Servicer agrees to cooperate with the Distributor ADI or the Company and deliver information reasonably requested by the Distributor ADI or the Company concerning shareholders that purchased shares sold by Broker/Dealer Servicer necessary for the Distributor ADI and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer Servicer acknowledges that the Distributor ADI or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer Servicer serves as nominee if Broker/Dealer Servicer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands Each of Distributor and the Trust acknowledges that pursuant to various U.S. regulations, it is required a financial institution subject to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism USA Patriot Act of 2001 (and the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Bank Secrecy Act, and will comply with all applicable laws and regulations designed as amended, which require among other things, that financial institutions adopt compliance programs to guard against money laundering activities set out in laundering. Each of Distributor and the Trust agrees that it will take such program; (iii) Broker/Dealer will further steps, and cooperate with the other to facilitate such compliance. The Distributor acknowledges that it is a “Covered Service Provider” as defined in the Trust’s Anti-Money Laundering Program (“Trust AML Program”) and deliver information reasonably requested by the Distributor concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary shall assume responsibility for the implementation of the requirements of the Trust AML Program with respect to the services provided under this Agreement. The Distributor or the Company represents and warrants that it has adopted policies and procedures reasonably designed to comply detect and prevent money laundering activities in compliance with applicable laws, regulations and regulatory interpretations. The Distributor undertakes that it shall (a) conduct its operations in accordance with the USA Patriot Act; and (iv) Broker/Dealer will notify the Distributor, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation provisions of the USA Patriot ActTrust AML Program and applicable laws, any regulation implementing the USA Patriot Actregulations and regulatory interpretations; (b) provide access to its books, or records and operations relating to its anti-money laundering program. Notwithstanding anything compliance only with respect to the contraryFunds, if Broker/Dealer is exempt from by appropriate regulatory authorities, the requirement to develop, implementFunds, and maintain the Trust’s anti-money laundering policies that comply with USA Patriot Act in which case Broker/Dealer agrees Compliance Officer (the Trust’s Compliance Officer shall have no access to cooperate with the Distributor or the Company and deliver information reasonably requested by the Distributor or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor and the Company to comply with eitherany of Distributor’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering policies operations, books or records pertaining to other clients of Distributor); (c) certify, in writing, no less frequently than annually, that it is in compliance with applicable anti-money laundering laws, rules, regulations and regulatory interpretations with respect to the services provided under this Agreement; (d) upon request, provide a copy of its anti-money laundering program (or a summary of its program) to the Trust’s anti-money laundering Compliance Officer; (e) provide periodic reports to the Trust’s Board of Trustees concerning anti-money laundering activities and compliance exceptions, as the parties may agree from time to time; and (f) ensure that selling group agreements require selling group members to adopt, as applicable, reasonable anti-money laundering procedures as required by and otherwise comply with applicable anti-money laundering regulations and regulatory interpretations with respect to the USA Patriot Actsale and redemption of Shares. The Trust represents and warrants that it will conduct its operations in accordance with the provisions of the Trust AML Program and applicable laws, regulations and regulatory interpretations.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer will cooperate with the Distributor and deliver information reasonably requested by the Distributor concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary for the Distributor or the Company to comply with the USA Patriot Act; and (iv) Broker/Dealer will notify the Distributor, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program; and (v) Broker/Dealer is not, as of the date of this Agreement, aware of any material violations of the USA Patriot Act at Broker/Dealer. Notwithstanding anything to the contrary, if Broker/Dealer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with the USA Patriot Act in which case Broker/Dealer agrees to cooperate with the Distributor or the Company and deliver information reasonably requested by the Distributor or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer The Distributor has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer will cooperate with the Distributor and deliver information reasonably requested by the Distributor concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary for the Distributor or the Company to comply with the USA Patriot Act; and (iv) Broker/Dealer will notify the Distributor, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or implemented its anti-money laundering program. Notwithstanding anything program pursuant to the contrarySection 352 of the USA PATRIOT Act and all applicable implementing regulations; as well as the implementing regulations of the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”). The Distributor is dependent upon your cooperation for your customers’ identification and behavior evaluation. Upon request, if Broker/Dealer is exempt from the requirement to develop, implement, you will promptly provide us such documentation regarding your know your customer and maintain anti-money laundering policies that comply with USA Patriot Act in which case Broker/Dealer agrees policies, and /or evidencing the identity of the beneficial owners of Funds shares as is necessary to cooperate with permit the Distributor or Distributor, the Company and deliver information reasonably requested by the Distributor or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor Funds, and the Company Transfer Agent to comply with either’s internal policies, the USA Patriot Act applicable “know your customer” and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering laws and regulations. You agree to monitor for suspicious transactions and to assist the Transfer Agent in monitoring for such transactions upon the Transfer Agent’s request, to include sharing relevant information as may be permissible by applicable law. You further represent and warrant that you: (i) have established policies and procedures as required designed to prevent and detect money laundering and to meet the applicable anti-money laundering legal and regulatory requirements; (ii) have identified, will continue to identify and will retain all documentation necessary to identify your customers, including the beneficial owners and control persons of legal entity accounts; (iii) do not believe, have no current reason to believe and will notify us immediately if you come to have reason to believe that any of your customers holding Fund shares through you are engaged in money laundering activities or are associated with any terrorist or terrorist organization; (iv) have financial transaction surveillance procedures for FinCEN reporting purposes; (v) have a protocol to facilitate appropriate federal regulatory examiners’ inspections; and (vi) have established policies and controls that prohibit the sale of Fund shares to: (a) any investor listed on the various OFAC lists of prohibited persons, entities, and countries, and for which any Fund shares transaction is prohibited under the various economic sanctions laws and regulations administered by the USA Patriot ActOFAC, or (b) a foreign “shell bank” (i.e., a bank that does not maintain a physical presence in any jurisdiction; and is not an affiliate of a bank that maintains a physical presence; or is not subject to regulation by relevant local governmental authority).

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such programactivities; (iii) Broker/Dealer will cooperate with the Distributor and deliver information reasonably requested by the Distributor concerning shareholders that purchased a the Fund’s shares sold by Broker/Dealer necessary for the Distributor or the Company Fund to comply with the USA Patriot Act; and (iv) Broker/Dealer will notify the Distributor, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with USA Patriot Act in which case Act, Broker/Dealer agrees to cooperate with the Distributor or the Company Fund and deliver information reasonably requested by the Distributor or the Company Fund concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor and the Company Fund to comply with either’s internal policies, the USA Patriot Act and relevant any other applicable anti-money laundering rules and regulations. Broker/Dealer acknowledges that the Distributor or the Company Fund may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot ActAct or other applicable anti-money laundering rules and regulations.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer The Distributor has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer will cooperate with the Distributor and deliver information reasonably requested by the Distributor concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary for the Distributor or the Company to comply with the USA Patriot Act; and (iv) Broker/Dealer will notify the Distributor, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or implemented its anti-money laundering program. Notwithstanding anything program pursuant to the contrarySection 352 of the USA PATRIOT Act and all applicable implementing regulations; as well as the implementing regulations of the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”). The Distributor is dependent upon your cooperation for your customers’ identification and behavior evaluation. Upon request, if Broker/Dealer is exempt from the requirement to develop, implement, you will promptly provide us such documentation regarding your know your customer and maintain anti-money laundering policies that comply with USA Patriot Act in which case Broker/Dealer agrees policies, and /or evidencing the identity of the beneficial owners of Funds shares as is necessary to cooperate with permit the Distributor or Distributor, the Company and deliver information reasonably requested by the Distributor or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor Funds, and the Company Transfer Agent to comply with either’s internal policies, the USA Patriot Act applicable “know your customer” and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering laws and regulations. You agree to monitor for suspicious transactions and to assist the Transfer Agent in monitoring for such transactions upon the Transfer Agent’s request, to include sharing relevant information as may be permissible by applicable law. You further represent and warrant that you: (i) have established policies and procedures as required designed to prevent and detect money laundering and to meet the applicable anti-money laundering legal and regulatory requirements; (ii) have identified, will continue to identify and will retain all documentation necessary to identify your customers and their sources of funds; (iii) do not believe, have no current reason to believe and will notify us immediately if you come to have reason to believe that any of your customers holding Fund shares through you are engaged in money laundering activities or are associated with any terrorist or terrorist organization; (iv) have financial transaction surveillance procedures for FinCEN reporting purposes; (v) have a protocol to facilitate appropriate federal regulatory examiners’ inspections; and (vi) have established policies and controls that prohibit the sale of Fund shares to: (a) any investor listed on the various OFAC lists of prohibited persons, entities, and countries, and for which any Fund shares transaction is prohibited under the various economic sanctions laws and regulations administered by the USA Patriot ActOFAC, or (b) a foreign “shell bank” (i.e., a bank that (a) does not maintain a physical presence in any jurisdiction; and is not an affiliate of a bank that maintains a physical presence; or is not subject to regulation by relevant local governmental authority).

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands The Distributor and the Company each acknowledge that pursuant to various U.S. regulations, it is required a financial institution subject to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism USA Patriot Act of 2001 (and the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Bank Secrecy Act, and will comply with all applicable laws and regulations designed which require among other things, that financial institutions adopt compliance programs to guard against money laundering activities set out in laundering. Each of Distributor and the Company agrees that it will take such program; (iii) Broker/Dealer will further steps, and cooperate with the other to facilitate such compliance. The Distributor acknowledges that it is a “Covered Service Provider” as defined in the Company’s Anti-Money Laundering Program (“AML Program”) and deliver information shall assume responsibility for the implementation of the requirements of the AML Program with respect to the services provided under this Agreement. The Distributor represents and warrants that it has adopted policies and procedures reasonably requested by designed to detect and prevent money laundering activities in compliance with applicable laws, regulations and regulatory interpretations. The Distributor undertakes that it shall (a) conduct its operations in accordance with the provisions of the AML Program and applicable laws, regulations and regulatory interpretations, provided that the Distributor concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary for the Distributor or the Company shall not be required to comply with any changes, amendment or supplements to the USA Patriot ActAML Program without its prior written consent; (b) provide access to its books, records and (iv) Broker/Dealer will notify the Distributor, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, operations relating to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything compliance only with respect to the contraryFunds, if Broker/Dealer is exempt from by appropriate regulatory authorities, the requirement to develop, implementFunds, and maintain the Company’s anti-money laundering policies that comply with USA Patriot Act in which case Broker/Dealer agrees Compliance Officer (the Company’s Compliance Officer shall have no access to cooperate with the Distributor or the Company and deliver information reasonably requested by the Distributor or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor and the Company to comply with eitherany of Distributor’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering policies operations, books or records pertaining to other clients of Distributor); (c) certify, in writing, no less frequently than annually, that it is in compliance with applicable anti-money laundering laws, rules, regulations and regulatory interpretations with respect to the services provided under this Agreement; (d) upon request, provide a copy of its anti-money laundering program (or a summary of its program) to the Company’s anti-money laundering Compliance Officer; (e) provide periodic reports to the Company’s Board of Directors concerning anti-money laundering activities and compliance exceptions, as the parties may agree from time to time; and (f) ensure that Selling Agreements entered into after the date of this Agreement require selected dealers and agents to adopt, as applicable, reasonable anti-money laundering procedures as required by and otherwise comply with applicable anti-money laundering regulations and regulatory interpretations with respect to the USA Patriot Actsale and redemption of Fund shares. The Company represents and warrants that it will conduct its operations in accordance with the provisions of the AML Program and applicable laws, regulations and regulatory interpretations.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands Each of Distributor and the Trust acknowledges that pursuant to various U.S. regulations, it is required a financial institution subject to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism USA Patriot Act of 2001 (and the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Bank Secrecy Act, and will comply with all applicable laws and regulations designed which require among other things, that financial institutions adopt compliance programs to guard against money laundering activities set out in laundering. Each of Distributor and the Trust agrees that it will take such program; (iii) Broker/Dealer will further steps, and cooperate with the other to facilitate such compliance. The Distributor acknowledges that it is a "Covered Service Provider" as defined in the Trust's Anti-Money Laundering Program ("Trust AML Program") and deliver information reasonably requested by the Distributor concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary shall assume responsibility for the implementation of the requirements of the Trust AML Program with respect to the services provided under this Agreement. The Distributor or the Company represents and warrants that it has adopted policies and procedures reasonably designed to comply detect and prevent money laundering activities in compliance with applicable laws, regulations and regulatory interpretations. The Distributor undertakes that it shall (a) conduct its operations in accordance with the USA Patriot Act; and (iv) Broker/Dealer will notify the Distributor, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation provisions of the USA Patriot ActTrust AML Program and applicable laws, any regulation implementing the USA Patriot Actregulations and regulatory interpretations; (b) provide access to its books, or records and operations relating to its anti-money laundering program. Notwithstanding anything compliance only with respect to the contraryFunds, if Broker/Dealer is exempt from by appropriate regulatory authorities, the requirement to develop, implementFunds, and maintain the Trust's anti-money laundering policies that comply with USA Patriot Act in which case Broker/Dealer agrees Compliance Officer (the Trust's Compliance Officer shall have no access to cooperate with the Distributor or the Company and deliver information reasonably requested by the Distributor or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor or the Company may reject or refuse orders for the sale any of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement Distributor's anti-money laundering policies operations, books or records pertaining to other clients of Distributor); (c) certify, in writing, no less frequently than annually, that it is in compliance with applicable anti-money laundering laws, rules, regulations and regulatory interpretations with respect to the services provided under this Agreement; (d) upon request, provide a copy of its anti-money laundering program (or a summary of its program) to the Trust's anti-money laundering Compliance Officer; (e) provide periodic reports to the Trust's Board of Trustees concerning anti-money laundering activities and compliance exceptions, as the parties may agree from time to time; and (f) ensure that selling group agreements require selling group members to adopt, as applicable, reasonable anti-money laundering procedures as required by and otherwise comply with applicable anti-money laundering regulations and regulatory interpretations with respect to the USA Patriot Actsale and redemption of Shares. The Trust represents and warrants that it will conduct its operations in accordance with the provisions of the Trust AML Program and applicable laws, regulations and regulatory interpretations.

Anti-Money Laundering Program. Broker/Dealer hereby certifies thatNotwithstanding any thing to the contrary in this Selling Agreement, you represent that you: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer has have developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer will cooperate with the Distributor and deliver information reasonably requested by the Distributor concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary for the Distributor or the Company to comply with the USA Patriot Act; and (iv) Broker/Dealer will notify the Distributor, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer is exempt from the requirement to develop, implement, implemented and maintain anti-money laundering policies that comply with the USA Patriot PATRIOT Act in which case Broker/Dealer agrees of 2001, as amended and applicable Federal anti-money laundering regulations, including steps to verify prospective shareholder identity ("AML Laws, Regulations and Policies"); (ii) comply with AML Laws, Regulations and Policies; (iii) will promptly deliver to the Distributor or Accessor Funds' designated Money Laundering Reporting Officer any AML Laws, Regulations and Policy violation, suspicious activity, suspicious activity investigation or filed Suspicious Activity Report that relates to any prospective shareholder of the Accessor Funds, and (iii) will cooperate with the Distributor or the Company and Accessor Funds and deliver information reasonably requested by the Distributor or the Company Accessor Funds concerning shareholders that purchased Accessor Funds shares sold by Broker/Dealer you necessary for the Distributor and the Company Accessor Funds to comply with either’s internal policiesAML Laws, Regulations and Policies. You agree to furnish the USA Patriot Act Distributor or Accessor Funds with the following information, as applicable: (1) a copy of the policies and relevant rules procedures governing your AML Program as in effect on the date hereof, and regulationsany material amendment thereto promptly after the adoption of any such amendment; (2) a copy of any deficiency letter sent by any federal examination authorities concerning your AML Program; (3) a copy of the certifications necessary for you to share suspicious activity or transaction information with us; (4) no less frequently than annually, a copy of any audit prepared with respect to your AML Program; and (5) any information reasonably requested by the Distributor or Accessor Funds to assist with compliance with applicable anti-money laundering requirements. Broker/Dealer acknowledges You acknowledge that the Distributor or the Company Accessor Funds may reject or refuse orders for the sale of Accessor Funds shares with respect to customers for which Broker/Dealer serves you serve as nominee if Broker/Dealer has you have not adopted and does do not implement anti-money laundering policies and procedures as required by the USA Patriot ActAML Rules and Regulations.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “"USA Patriot Act”"); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section sec. 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer will cooperate with the Distributor ADI and deliver information reasonably requested by the Distributor ADI concerning shareholders that purchased a Fund’s 's shares sold by Broker/Dealer necessary for the Distributor ADI or the Company to comply with the USA Patriot Act; and (iv) Broker/Dealer will notify the DistributorADI, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with USA Patriot Act in which case Broker/Dealer agrees to cooperate with the Distributor ADI or the Company and deliver information reasonably requested by the Distributor ADI or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor ADI and the Company to comply with either’s 's internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor ADI or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act.

Anti-Money Laundering Program. Broker/Dealer Servicer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “"USA Patriot Act”"); (ii) Broker/Dealer Servicer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section sec. 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer Servicer will cooperate with the Distributor ADI and deliver information reasonably requested by the Distributor ADI concerning shareholders that purchased a Fund’s 's shares sold by Broker/Dealer Servicer necessary for the Distributor ADI or the Company to comply with the USA Patriot Act; and (iv) Broker/Dealer Servicer will notify the DistributorADI, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer Servicer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with the USA Patriot Act in which case Broker/Dealer Servicer agrees to cooperate with the Distributor ADI or the Company and deliver information reasonably requested by the Distributor ADI or the Company concerning shareholders that purchased shares sold by Broker/Dealer Servicer necessary for the Distributor ADI and the Company to comply with either’s 's internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer Servicer acknowledges that the Distributor ADI or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer Servicer serves as nominee if Broker/Dealer Servicer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act.

Anti-Money Laundering Program. Broker/Dealer hereby certifies thatNotwithstanding any thing to the contrary in this Selling Agreement, you represent that you have: (i) it understands that pursuant to various U.S. regulationsdeveloped, it is required to establish an implemented and maintain anti-money laundering program, which satisfies policies that comply with the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism USA PATRIOT Act of 2001 2001, as amended and applicable Federal anti-money laundering regulations, including steps to verify prospective shareholder identity (the “USA Patriot Act”"AML Laws, Regulations and Policies"); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Act, and will comply with all applicable laws AML Laws, Regulations and regulations designed to guard against money laundering activities set out in such programPolicies; (iii) Broker/Dealer will promptly deliver to the Distributor or Accessor Funds' designated Money Laundering Reporting Officer any AML Laws, Regulations and Policy violation, suspicious activity, suspicious activity investigation or filed Suspicious Activity Report that relates to any prospective shareholder of the Accessor Funds, and (iv) will cooperate with the Distributor and deliver information reasonably requested by the Distributor concerning shareholders that purchased a Fund’s Accessor Funds shares sold by Broker/Dealer you necessary for the Distributor or and the Company Accessor Funds to comply with the USA Patriot ActAML Laws, Regulations and Policies; and OR (ivv) Broker/Dealer will notify the Distributor, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer is are exempt from the requirement to develop, implement, implement and maintain anti-money laundering policies that comply with USA Patriot Act AML Laws, Regulations and Policies in which case Broker/Dealer agrees you agree to cooperate with the Distributor or the Company Accessor Funds and deliver information reasonably requested by the Distributor or the Company Accessor Funds concerning shareholders that purchased Accessor Funds shares sold by Broker/Dealer you necessary for the Distributor and the Company Accessor Funds to comply with either’s internal policiesAML Laws, Regulations and Policies. If you maintain AML policies and procedures, you agree to furnish the USA Patriot Act Distributor or Accessor Funds with the following information, as applicable: (1) a copy of the policies and relevant rules procedures governing your AML Program as in effect on the date hereof, and regulationsany material amendment thereto promptly after the adoption of any such amendment; (2) a copy of any deficiency letter sent by any federal examination authorities concerning your AML Program; (3) a copy of the certifications necessary for you to share suspicious activity or transaction information with us; (4) no less frequently than annually, a copy of any audit prepared with respect to your AML Program; and (5) any information reasonably requested by the Distributor or Accessor Funds to assist with compliance with applicable anti-money laundering requirements. Broker/Dealer acknowledges You acknowledge that the Distributor or the Company Accessor Funds may reject or refuse orders for the sale of Accessor Funds shares with respect to customers for which Broker/Dealer serves you serve as nominee if Broker/Dealer has you have not adopted and does do not implement anti-money laundering policies and procedures as required by the USA Patriot ActAML Rules and Regulations.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section sec. 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer will cooperate with the Distributor ADI and deliver information reasonably requested by the Distributor ADI concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary for the Distributor ADI or the Company to comply with the USA Patriot Act; and (iv) Broker/Dealer will notify the DistributorADI, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Broker/Dealer agrees that accounts in the Funds held in the name of, or beneficially owned by, Broker/Dealer’s customers shall be accounts of Broker/Dealer, and that Broker/Dealer’s customers will be customers of Broker/Dealer, for all purposes under Broker/Dealer’s anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with the USA Patriot Act in which case Act, Broker/Dealer agrees to cooperate with the Distributor or ADI and the Company and deliver information reasonably requested by the Distributor ADI or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor ADI and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor ADI or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act. Upon ADI’s request, Broker/Dealer shall promptly certify to having implemented anti-money laundering policies and procedures and complying with all aspects of the USA Patriot Act and applicable regulations.

Anti-Money Laundering Program. Broker/Dealer Servicer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer Servicer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer Servicer will cooperate with the Distributor ADI and deliver information reasonably requested by the Distributor ADI concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer Servicer necessary for the Distributor ADI or the Company to comply with the USA Patriot Act; and (iv) Broker/Dealer Servicer will notify the DistributorADI, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Servicer agrees that accounts in the Funds held in the name of, or beneficially owned by, Servicer’s customers shall be accounts of Servicer, and that Servicer’s customers will be customers of Servicer, for all purposes under Servicer’s anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer Servicer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with the USA Patriot Act in which case Broker/Dealer Act, then Servicer agrees to cooperate with the Distributor or ADI and the Company and deliver information reasonably requested by the Distributor ADI or the Company concerning shareholders that purchased shares sold by Broker/Dealer Servicer necessary for the Distributor ADI and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer Servicer acknowledges that the Distributor ADI or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer Servicer serves as nominee if Broker/Dealer Servicer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act. Upon ADI’s request, Servicer shall promptly certify to having implemented anti-money laundering policies and procedures and complying with all aspects of the USA Patriot Act and applicable regulations.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer will cooperate with the Distributor and deliver information reasonably requested by the Distributor concerning shareholders that purchased a the Fund’s shares sold by Broker/Dealer necessary for the Distributor or the Company Fund to comply with the USA Patriot Act; and (iv) Broker/Dealer will notify the Distributor, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with USA Patriot Act in which case Broker/Dealer agrees to cooperate with the Distributor or the Company Fund and deliver information reasonably requested by the Distributor or the Company Fund concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor and the Company Fund to comply with either’s internal policies, the USA Patriot Act and relevant any other applicable anti-money laundering rules and regulations. Broker/Dealer acknowledges that the Distributor or the Company Fund may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot ActAct or other applicable anti-money laundering rules and regulations.

Anti-Money Laundering Program. Broker/Dealer Servicer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer Servicer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer Servicer will cooperate with the Distributor and deliver information reasonably requested by the Distributor concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer Servicer necessary for the Distributor or the Company to comply with the USA Patriot Act; and (iv) Broker/Dealer Servicer will notify the Distributor, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer Servicer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with the USA Patriot Act in which case Broker/Dealer Servicer agrees to cooperate with the Distributor or the Company and deliver information reasonably requested by the Distributor or the Company concerning shareholders that purchased shares sold by Broker/Dealer Servicer necessary for the Distributor and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer Servicer acknowledges that the Distributor or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer Servicer serves as nominee if Broker/Dealer Servicer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act.

Anti-Money Laundering Program. Broker/Dealer Servicer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer Servicer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section sec. 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer Servicer will cooperate with the Distributor APSD and deliver information reasonably requested by the Distributor APSD concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer Servicer necessary for the Distributor APSD or the Company to comply with the USA Patriot Act; and (iv) Broker/Dealer Servicer will notify the DistributorAPSD, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. 2015-07-AAI-Cxxxxx 10 Notwithstanding anything to the contrary, if Broker/Dealer Servicer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with the USA Patriot Act in which case Broker/Dealer Servicer agrees to cooperate with the Distributor APSD or the Company and deliver information reasonably requested by the Distributor APSD or the Company concerning shareholders that purchased shares sold by Broker/Dealer Servicer necessary for the Distributor APSD and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer Servicer acknowledges that the Distributor APSD or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer Servicer serves as nominee if Broker/Dealer Servicer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section sec. 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer will cooperate with the Distributor and deliver information reasonably requested by the Distributor concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary for the Distributor or the Company to comply with the USA Patriot Act; and (iv) Broker/Dealer will notify the Distributor, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with USA Patriot Act in which case Broker/Dealer agrees to cooperate with the Distributor or the Company and deliver information reasonably requested by the Distributor or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section sec. 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer will cooperate with the Distributor ADI and deliver information reasonably requested by the Distributor ADI concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary for the Distributor ADI or the Company to comply with the USA Patriot Act; and (iv) Broker/Dealer will notify the DistributorADI, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Broker/Dealer agrees that accounts in the Funds held in the name of, or beneficially owned by, Broker/Dealer’s customers shall be accounts of Broker/Dealer, and that Broker/Dealer’s customers will be customers of Broker/Dealer, for all purposes under Broker/Dealer’s anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with USA Patriot Act in which case Broker/Dealer agrees to cooperate with the Distributor ADI or the Company and deliver information reasonably requested by the Distributor ADI or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor ADI and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor ADI or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer will cooperate with the Distributor ADI and deliver information reasonably requested by the Distributor ADI concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary for the Distributor ADI or the each Company to comply with the USA Patriot Act; and (iv) Broker/Dealer will notify the DistributorADI, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with the USA Patriot Act in which case , then Broker/Dealer agrees to cooperate with the Distributor ADI or the Company and deliver information reasonably requested by the Distributor ADI or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor ADI and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor ADI or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section sec. 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer will cooperate with the Distributor ADI and deliver information reasonably requested by the Distributor ADI concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary for the Distributor ADI or the Company to comply with the USA Exhibit (e)(4) Patriot Act; and (iv) Broker/Dealer will notify the DistributorADI, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with USA Patriot Act in which case Broker/Dealer agrees to cooperate with the Distributor ADI or the Company and deliver information reasonably requested by the Distributor ADI or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor ADI and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor ADI or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section sec. 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer will cooperate with the Distributor APSD and deliver information reasonably requested by the Distributor APSD concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary for the Distributor APSD or the Company to comply with the USA Patriot Act; and (iv) Broker/Dealer will notify the DistributorAPSD, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with USA Patriot Act in which case Broker/Dealer agrees to cooperate with the Distributor APSD or the Company and deliver information reasonably requested by the Distributor APSD or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor APSD and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor APSD or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “"USA Patriot Act”"); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section sec. 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer will cooperate with the Distributor ADI and deliver information reasonably requested by the Distributor ADI concerning shareholders that purchased a Fund’s 's shares sold by Broker/Dealer necessary for the Distributor ADI or the Company to comply with the USA Patriot Act; and (iv) Broker/Dealer will notify the DistributorADI, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with USA Patriot Act in which case Broker/Dealer agrees to cooperate with the Distributor ADI or the Company and deliver information reasonably requested by the Distributor ADI or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor ADI and the Company to comply with either’s 's internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor ADI or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands Each party acknowledges that pursuant to various U.S. regulations, it is required a financial institution subject to establish an the USA PATRIOT Act of 2001 and the Bank Secrecy Act, which require among other things, that financial institutions adopt anti-money laundering program(“AML”) compliance programs. Each party agrees that it will take such further steps, which satisfies and cooperate with the other to facilitate such compliance. TORS acknowledges that it is a “Covered Service Provider” as defined in the Fund’s Anti-Money Laundering Program (the “Fund AML Program”) and shall assume responsibility for the implementation of the requirements of Title III the Fund AML Program with respect to the services provided under this Agreement. TORS represents and warrants that it has adopted policies and procedures reasonably designed to detect and prevent money laundering activities in compliance with applicable laws, regulations and regulatory interpretations. TORS undertakes that it shall (a) conduct its operations in accordance with the provisions of the Uniting Fund AML Program and Strengthening America applicable laws, regulations and regulatory interpretations; (b) provide access to its books, records and operations relating to its AML compliance only with respect to the Funds, by Providing Appropriate Tools Required to Intercept appropriate regulatory authorities, the Funds, and Obstruct Terrorism Act of 2001 the Fund’s AML Compliance Officer (the “USA Patriot Act”Fund’s Compliance Officer shall have no access to any of Distributor’s AML operations, books or records pertaining to other clients of Distributor); (iic) Broker/Dealer has developedcertify, implementedin writing, no less frequently than annually, that it is in compliance with applicable AML laws, rules, regulations and will maintain such an regulatory interpretations with respect to the services provided under this Agreement; (d) upon request, provide a copy of its AML program (or a summary of its program) to the Fund’s AML Compliance Officer; (e) provide periodic reports to the Board concerning anti-money laundering programactivities and compliance exceptions, including a customer identification program consistent with as the rules under Section 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed parties may agree from time to guard against money laundering activities set out in such program; (iii) Broker/Dealer will cooperate with the Distributor and deliver information reasonably requested by the Distributor concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary for the Distributor or the Company to comply with the USA Patriot Acttime; and (ivf) Broker/Dealer will notify the Distributorensure that selling group agreements require selling group members to adopt, in writingas applicable, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer is exempt from the requirement to develop, implement, reasonable AML procedures and maintain anti-money laundering policies that otherwise comply with USA Patriot Act in which case Broker/Dealer agrees to cooperate with the Distributor or the Company applicable AML regulations and deliver information reasonably requested by the Distributor or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor or the Company may reject or refuse orders for the sale of shares regulatory interpretations with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted the sale and does not implement anti-money laundering policies redemption of Shares. The Fund represents and procedures as required by warrants that it will conduct its operations in accordance with the USA Patriot Actprovisions of the Fund AML Program and applicable laws, regulations and regulatory interpretations.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands Each of Distributor and the Trust acknowledges that pursuant to various U.S. regulations, it is required a financial institution subject to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism USA Patriot Act of 2001 (and the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Bank Secrecy Act, and will comply with all applicable laws and regulations designed which require among other things, that financial institutions adopt compliance programs to guard against money laundering activities set out in laundering. Each of Distributor and the Trust agrees that it will take such program; (iii) Broker/Dealer will further steps, and cooperate with the other to facilitate such compliance. The Distributor acknowledges that it is a "Covered Service Provider" as defined in the Fund's Anti-Money Laundering Program (Fund AML Program) and deliver information reasonably requested by the Distributor concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary shall assume responsibility for the implementation of the requirements of the Fund AML Program with respect to the services provided under this Agreement. The Distributor or the Company represents and warrants that it has adopted policies and procedures reasonably designed to comply detect and prevent money laundering activities in compliance with applicable laws, regulations and regulatory interpretations. The Distributor undertakes that it shall (a) conduct its operations in accordance with the USA Patriot Act; and (iv) Broker/Dealer will notify the Distributor, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation provisions of the USA Patriot ActFund AML Program and applicable laws, any regulation implementing the USA Patriot Actregulations and regulatory interpretations; (b) provide access to its books, or records and operations relating to its anti-money laundering program. Notwithstanding anything compliance only with respect to the contraryFunds, if Broker/Dealer is exempt from by appropriate regulatory authorities, the requirement to develop, implementFunds, and maintain the Fund's anti-money laundering policies that comply with USA Patriot Act in which case Broker/Dealer agrees Compliance Officer (the Trust's Compliance Officer shall have no access to cooperate with the Distributor or the Company and deliver information reasonably requested by the Distributor or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor or the Company may reject or refuse orders for the sale any of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement Distributor's anti-money laundering policies operations, books or records pertaining to other clients of Distributor); (c) certify, in writing, no less frequently than annually, that it is in compliance with applicable anti-money laundering laws, rules, regulations and regulatory interpretations with respect to the services provided under this Agreement; (d) upon request, provide a copy of its anti-money laundering program (or a summary of its program) to the Fund's anti-money laundering Compliance Officer; (e) provide periodic reports to the Fund's Board of Trustees concerning anti-money laundering activities and compliance exceptions, as the parties may agree from time to time; and (f) ensure that selling group agreements require selling group members to adopt, as applicable, reasonable anti-money laundering procedures as required by and otherwise comply with applicable anti-money laundering regulations and regulatory interpretations with respect to the USA Patriot Actsale and redemption of Fund shares. The Trust represents and warrants that it will conduct its operations in accordance with the provisions of the Fund AML Program and applicable laws, regulations and regulatory interpretations.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer will cooperate with the Distributor and deliver information reasonably requested by the Distributor concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary for the Distributor or the Company Trust to comply with the USA Patriot Act; and (iv) Broker/Dealer will notify the Distributor, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with USA Patriot Act in which case Broker/Dealer agrees to cooperate with the Distributor or the Company Trust and deliver information reasonably requested by the Distributor or the Company Trust concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor and the Company Trust to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor or the Company Trust may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer will cooperate with the Distributor and deliver information reasonably requested by the Distributor concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary for the Distributor or the Company to comply with the USA Patriot Act; and (iv) Broker/Dealer will promptly notify the Distributor, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program; and (v) Broker/Dealer is not, as of the date of this Agreement, aware of any material violations of the USA Patriot Act at Broker/Dealer. Notwithstanding anything to the contrary, if Broker/Dealer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with the USA Patriot Act in which case Broker/Dealer agrees to cooperate with the Distributor or the Company and deliver information reasonably requested by the Distributor or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands Each of Distributor and the Trust acknowledges that pursuant to various U.S. regulations, it is required a financial institution subject to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism USA Patriot Act of 2001 (and the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Bank Secrecy Act, and will comply with all applicable laws and regulations designed as amended, which require among other things, that financial institutions adopt compliance programs to guard against money laundering activities set out in laundering. Each of Distributor and the Trust agrees that it will take such program; (iii) Broker/Dealer will further steps, and cooperate with the other to facilitate such compliance. The Distributor acknowledges that it is a “Covered Service Provider” as defined in the Trust’s Anti-Money Laundering Program (“Trust AML Program”) and deliver information reasonably requested by the Distributor concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary shall assume responsibility for the implementation of the requirements of the Trust AML Program with respect to the services provided under this Agreement. The Distributor or the Company represents and warrants that it has adopted policies and procedures reasonably designed to comply detect and prevent money laundering activities in compliance with applicable laws, regulations and regulatory interpretations. The Distributor undertakes that it shall (a) conduct its operations in accordance with the USA Patriot Act; and (iv) Broker/Dealer will notify the Distributor, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation provisions of the USA Patriot ActTrust AML Program and applicable laws, any regulation implementing the USA Patriot Actregulations and regulatory interpretations; (b) provide access to its books, or records and operations relating to its anti-money laundering program. Notwithstanding anything compliance only with respect to the contraryFunds, if Broker/Dealer is exempt from by appropriate regulatory authorities, the requirement to develop, implementFunds, and maintain the Trust’s anti-money laundering policies that comply with USA Patriot Act in which case Broker/Dealer agrees Compliance Officer (the Trust’s Compliance Officer shall have no access to cooperate with the Distributor or the Company and deliver information reasonably requested by the Distributor or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor and the Company to comply with eitherany of Distributor’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering policies operations, books or records pertaining to other clients of Distributor); (c) certify, in writing, no less frequently than annually, that it is in compliance with applicable anti-money laundering laws, rules, regulations and regulatory interpretations with respect to the services provided under this Agreement; (d) upon request, provide a copy of its anti-money laundering program (or a summary of its program) to the Trust’s anti-money laundering Compliance Officer; (e) provide periodic reports to the Trust’s Board of Trustees concerning anti-money laundering activities and compliance exceptions, as the parties may agree from time to time; and (f) ensure that selling group agreements require selling group members to adopt, as applicable, reasonable anti-money laundering procedures as required by and otherwise comply with applicable anti-money laundering regulations and regulatory interpretations with respect to the USA Patriot Actsale and redemption of Shares. The Trust represents and warrants that it will conduct its operations in accordance with the provisions of the Trust AML Program and applicable laws, regulations and regulatory interpretations.5. Counterparts. This Agreement may be executed in counterparts, each of which shall be an original but all of which, taken together, shall constitute one and the same agreement.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section sec. 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer will cooperate with the Distributor ADI and deliver information reasonably requested by the Distributor ADI concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary for the Distributor ADI or the Company to comply with the USA Exhibit (e)(7) Patriot Act; and (iv) Broker/Dealer will notify the DistributorADI, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with USA Patriot Act in which case Broker/Dealer agrees to cooperate with the Distributor ADI or the Company and deliver information reasonably requested by the Distributor ADI or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor ADI and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor ADI or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer will cooperate with the Distributor and deliver information reasonably requested by the Distributor concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary for the Distributor or the Company to comply with the USA Patriot Act; and (iv) Broker/Dealer will notify the Distributor, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with USA Patriot Act in which case Act, Broker/Dealer agrees to cooperate with the Distributor or the Company and deliver information reasonably requested by the Distributor or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act.

Anti-Money Laundering Program. Broker/Dealer Servicer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer Servicer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section sec. 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer Servicer will cooperate with the Distributor ADI and deliver information reasonably requested by the Distributor ADI concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer Servicer necessary for the Distributor ADI or the Company to comply with the USA Patriot Act; and (iv) Broker/Dealer Servicer will notify the DistributorADI, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Servicer agrees that accounts in the Funds held in the name of, or beneficially owned by, Servicer’s customers shall be accounts of Servicer, and that Servicer’s customers will be customers of Servicer, for all purposes under Servicer’s anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer Servicer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with the USA Patriot Act in which case Broker/Dealer Servicer agrees to cooperate with the Distributor ADI or the Company and deliver information reasonably requested by the Distributor ADI or the Company concerning shareholders that purchased shares sold by Broker/Dealer Servicer necessary for the Distributor ADI and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer Servicer acknowledges that the Distributor ADI or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer Servicer serves as nominee if Broker/Dealer Servicer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act.

Anti-Money Laundering Program. Broker/Dealer Servicer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “USA Patriot Act”); (ii) Broker/Dealer Servicer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer Servicer will cooperate with the Distributor ADI and deliver information reasonably requested by the Distributor ADI concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer Servicer necessary for the Distributor ADI or the Company to comply with the USA Patriot Act; and (iv) Broker/Dealer Servicer will notify the DistributorADI, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer Servicer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with the USA Patriot Act in which case Broker/Dealer Act, then Servicer agrees to cooperate with the Distributor ADI or the Company and deliver information reasonably requested by the Distributor ADI or the Company concerning shareholders that purchased shares sold by Broker/Dealer Servicer necessary for the Distributor ADI and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer Servicer acknowledges that the Distributor ADI or the Company may reject or refuse orders for the sale of shares with respect to customers for which Broker/Dealer Servicer serves as nominee if Broker/Dealer Servicer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands Each of Distributor and the Trust acknowledges that pursuant to various U.S. regulations, it is required a financial institution subject to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism USA Patriot Act of 2001 (and the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Bank Secrecy Act, and will comply with all applicable laws and regulations designed which require among other things, that financial institutions adopt compliance programs to guard against money laundering activities set out in laundering. Each of Distributor and the Trust agrees that it will take such program; (iii) Broker/Dealer will further steps, and cooperate with the other to facilitate such compliance. The Distributor acknowledges that it is a "Covered Service Provider" as defined in the Trust's Anti-Money Laundering Program (Trust AML Program) and deliver information reasonably requested by the Distributor concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary shall assume responsibility for the implementation of the requirements of the Trust AML Program with respect to the services provided under this Agreement. The Distributor or the Company represents and warrants that it has adopted policies and procedures reasonably designed to comply detect and prevent money laundering activities in compliance with applicable laws, regulations and regulatory interpretations. The Distributor undertakes that it shall (a) conduct its operations in accordance with the USA Patriot Act; and (iv) Broker/Dealer will notify the Distributor, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation provisions of the USA Patriot ActTrust AML Program and applicable laws, any regulation implementing the USA Patriot Actregulations and regulatory interpretations; (b) provide access to its books, or records and operations relating to its anti-money laundering program. Notwithstanding anything compliance only with respect to the contraryFunds, if Broker/Dealer is exempt from by appropriate regulatory authorities, the requirement to develop, implementFunds, and maintain the Trust's anti-money laundering policies that comply with USA Patriot Act in which case Broker/Dealer agrees Compliance Officer (the Trust's Compliance Officer shall have no access to cooperate with the Distributor or the Company and deliver information reasonably requested by the Distributor or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor or the Company may reject or refuse orders for the sale any of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement Distributor's anti-money laundering policies operations, books or records pertaining to other clients of Distributor); (c) certify, in writing, no less frequently than annually, that it is in compliance with applicable anti-money laundering laws, rules, regulations and regulatory interpretations with respect to the services provided under this Agreement; (d) upon request, provide a copy of its anti-money laundering program (or a summary of its program) to the Trust's anti-money laundering Compliance Officer; (e) provide periodic reports to the Trust's Board of Trustees concerning anti-money laundering activities and compliance exceptions, as the parties may agree from time to time; and (f) ensure that selling group agreements require selling group members to adopt, as applicable, reasonable anti-money laundering procedures as required by and otherwise comply with applicable anti-money laundering regulations and regulatory interpretations with respect to the USA Patriot Actsale and redemption of Shares. The Trust represents and warrants that it will conduct its operations in accordance with the provisions of the Trust AML Program and applicable laws, regulations and regulatory interpretations.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it is required to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (the “"USA Patriot Act”"); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section sec. 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed to guard against money laundering activities set out in such program; (iii) Broker/Dealer will cooperate with the Distributor ADI and deliver information reasonably requested by the Distributor ADI concerning shareholders Shareholders that purchased a Fund’s shares Shares sold by Broker/Dealer necessary for the Distributor ADI or the Company Trust to comply with the USA Patriot Act; and (iv) Broker/Dealer will notify the DistributorADI, in writing, if it is found, found by its Compliance Officer, an independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering programprogram relating to this Agreement. Notwithstanding anything to the contrary, if Broker/Dealer is exempt from the requirement to develop, implement, and maintain anti-money laundering policies that comply with USA Patriot Act in which case Broker/Dealer agrees to cooperate with the Distributor ADI or the Company Trust and deliver information reasonably requested by the Distributor ADI or the Company Trust concerning shareholders Shareholders that purchased shares sold by Shares through Broker/Dealer necessary for the Distributor ADI and the Company Trust to comply with either’s 's internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor ADI or the Company Trust may reject or refuse orders for the sale of shares Shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement anti-money laundering policies and procedures as required by the USA Patriot Act.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands Each party acknowledges that pursuant to various U.S. regulations, it is required a financial institution subject to establish an the USA PATRIOT Act of 2001 and the Bank Secrecy Act, which require among other things, that financial institutions adopt anti-money laundering program("AML") compliance programs. Each party agrees that it will take such further steps, which satisfies and cooperate with the other to facilitate such compliance. TORS acknowledges that it is a "Covered Service Provider" as defined in the Trust's Anti-Money Laundering Program (the "Trust AML Program") and shall assume responsibility for the implementation of the requirements of Title III the Trust AML Program with respect to the services provided under this Agreement. TORS represents and warrants that it has adopted policies and procedures reasonably designed to detect and prevent money laundering activities in compliance with applicable laws, regulations and regulatory interpretations. TORS undertakes that it shall (a) conduct its operations in accordance with the provisions of the Uniting Trust AML Program and Strengthening America applicable laws, regulations and regulatory interpretations; (b) provide access to its books, records and operations relating to its AML compliance only with respect to the Funds, by Providing Appropriate Tools Required to Intercept appropriate regulatory authorities, the Funds, and Obstruct Terrorism Act of 2001 the Trust's AML Compliance Officer (the “USA Patriot Act”Trust's Compliance Officer shall have no access to any of Distributor's AML operations, books or records pertaining to other clients of Distributor); (iic) Broker/Dealer has developedcertify, implementedin writing, no less frequently than annually, that it is in compliance with applicable AML laws, rules, regulations and will maintain such an regulatory interpretations with respect to the services provided under this Agreement; (d) upon request, provide a copy of its AML program (or a summary of its program) to the Trust's AML Compliance Officer; (e) provide periodic reports to the Board concerning anti-money laundering programactivities and compliance exceptions, including a customer identification program consistent with as the rules under Section 326 of the USA Patriot Act, and will comply with all applicable laws and regulations designed parties may agree from time to guard against money laundering activities set out in such program; (iii) Broker/Dealer will cooperate with the Distributor and deliver information reasonably requested by the Distributor concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary for the Distributor or the Company to comply with the USA Patriot Acttime; and (ivf) Broker/Dealer will notify the Distributorensure that selling group agreements require selling group members to adopt, in writingas applicable, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything to the contrary, if Broker/Dealer is exempt from the requirement to develop, implement, reasonable AML procedures and maintain anti-money laundering policies that otherwise comply with USA Patriot Act in which case Broker/Dealer agrees to cooperate with the Distributor or the Company applicable AML regulations and deliver information reasonably requested by the Distributor or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor or the Company may reject or refuse orders for the sale of shares regulatory interpretations with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted the sale and does not implement anti-money laundering policies redemption of Shares. The Trust represents and procedures as required by warrants that it will conduct its operations in accordance with the USA Patriot Actprovisions of the Trust AML Program and applicable laws, regulations and regulatory interpretations.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands Each of Distributor and the Trust acknowledges that pursuant to various U.S. regulations, it is required a financial institution subject to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism USA Patriot Act of 2001 (and the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Bank Secrecy Act, and will comply with all applicable laws and regulations designed as amended, which require among other things, that financial institutions adopt compliance programs to guard against money laundering activities set out in laundering. Each of Distributor and the Trust agrees that it will take such program; (iii) Broker/Dealer will further steps, and cooperate with the other to facilitate such compliance. The Distributor acknowledges that it is a "Covered Service Provider" as defined in the Trust's Anti-Money Laundering Program ("Trust AML Program") and deliver information reasonably requested by the Distributor concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary shall assume responsibility for the implementation of the requirements of the Trust AML Program with respect to the services provided under this Agreement. The Distributor or the Company represents and warrants that it has adopted policies and procedures reasonably designed to comply detect and prevent money laundering activities in compliance with applicable laws, regulations and regulatory interpretations. The Distributor undertakes that it shall (a) conduct its operations in accordance with the USA Patriot Act; and (iv) Broker/Dealer will notify the Distributor, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, to be in violation provisions of the USA Patriot ActTrust AML Program and applicable laws, any regulation implementing the USA Patriot Actregulations and regulatory interpretations; (b) provide access to its books, or records and operations relating to its anti-money laundering program. Notwithstanding anything compliance only with respect to the contraryFunds, if Broker/Dealer is exempt from by appropriate regulatory authorities, the requirement to develop, implementFunds, and maintain the Trust's anti-money laundering policies that comply with USA Patriot Act in which case Broker/Dealer agrees compliance officer (the Trust's compliance officer shall have no access to cooperate with the Distributor or the Company and deliver information reasonably requested by the Distributor or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor or the Company may reject or refuse orders for the sale any of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement Distributor's anti-money laundering policies operations, books or records pertaining to other clients of Distributor); (c) certify, in writing, no less frequently than annually, that it is in compliance with applicable anti-money laundering laws, rules, regulations and regulatory interpretations with respect to the services provided under this Agreement; (d) upon request, provide a copy of its anti-money laundering program (or a summary of its program) to the Trust's anti-money laundering compliance officer; (e) provide periodic reports to the Trust's Board of Trustees concerning anti-money laundering activities and compliance exceptions, as the parties may agree from time to time; and (f) ensure that selling group agreements require selling group members to adopt, as applicable, reasonable anti-money laundering procedures as required by and otherwise comply with applicable anti-money laundering regulations and regulatory interpretations with respect to the USA Patriot Actsale and redemption of Shares. The Trust represents and warrants that it will conduct its operations in accordance with the provisions of the Trust AML Program and applicable laws, regulations and regulatory interpretations.

Anti-Money Laundering Program. Broker/Dealer hereby certifies that: (i) it understands The Distributor and the Company each acknowledge that pursuant to various U.S. regulations, it is required a financial institution subject to establish an anti-money laundering program, which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism USA Patriot Act of 2001 (and the “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering program, including a customer identification program consistent with the rules under Section 326 of the USA Patriot Bank Secrecy Act, and will comply with all applicable laws and regulations designed which require among other things, that financial institutions adopt compliance programs to guard against money laundering activities set out in laundering. Each of Distributor and the Company agrees that it will take such program; (iii) Broker/Dealer will further steps, and cooperate with the other to facilitate such compliance. The Distributor acknowledges that it is a "Covered Service Provider" as defined in the Company's Anti-Money Laundering Program ("AML Program") and deliver information shall assume responsibility for the implementation of the requirements of the AML Program with respect to the services provided under this Agreement. The Distributor represents and warrants that it has adopted policies and procedures reasonably requested by designed to detect and prevent money laundering activities in compliance with applicable laws, regulations and regulatory interpretations. The Distributor undertakes that it shall (a) conduct its operations in accordance with the provisions of the AML Program and applicable laws, regulations and regulatory interpretations, provided that the Distributor concerning shareholders that purchased a Fund’s shares sold by Broker/Dealer necessary for the Distributor or the Company shall not be required to comply with any changes, amendment or supplements to the USA Patriot ActAML Program without its prior written consent; (b) provide access to its books, records and (iv) Broker/Dealer will notify the Distributor, in writing, if it is found, by its Compliance Officer, independent anti-money laundering auditor, or any Federal, state, or self-regulatory agencies, operations relating to be in violation of the USA Patriot Act, any regulation implementing the USA Patriot Act, or its anti-money laundering program. Notwithstanding anything compliance only with respect to the contraryFunds, if Broker/Dealer is exempt from by appropriate regulatory authorities, the requirement to develop, implementFunds, and maintain the Company's anti-money laundering policies that comply with USA Patriot Act in which case Broker/Dealer agrees Compliance Officer (the Company's Compliance Officer shall have no access to cooperate with the Distributor or the Company and deliver information reasonably requested by the Distributor or the Company concerning shareholders that purchased shares sold by Broker/Dealer necessary for the Distributor and the Company to comply with either’s internal policies, the USA Patriot Act and relevant rules and regulations. Broker/Dealer acknowledges that the Distributor or the Company may reject or refuse orders for the sale any of shares with respect to customers for which Broker/Dealer serves as nominee if Broker/Dealer has not adopted and does not implement Distributor's anti-money laundering policies operations, books or records pertaining to other clients of Distributor); (c) certify, in writing, no less frequently than annually, that it is in compliance with applicable anti-money laundering laws, rules, regulations and regulatory interpretations with respect to the services provided under this Agreement; (d) upon request, provide a copy of its anti-money laundering program (or a summary of its program) to the Company's anti-money laundering Compliance Officer; (e) provide periodic reports to the Company's Board of Directors concerning anti-money laundering activities and compliance exceptions, as the parties may agree from time to time; and (f) ensure that Selling Agreements entered into after the date of this Agreement require selected dealers and agents to adopt, as applicable, reasonable anti-money laundering procedures as required by and otherwise comply with applicable anti-money laundering regulations and regulatory interpretations with respect to the USA Patriot Actsale and redemption of Fund shares. The Company represents and warrants that it will conduct its operations in accordance with the provisions of the AML Program and applicable laws, regulations and regulatory interpretations.