Common use of Anti-Money Laundering Program Clause in Contracts

Anti-Money Laundering Program. The Trust acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering Program. The Trust acknowledges Broker/Dealer hereby certifies that: (i) it understands that pursuant to various U.S. regulations, it has had is required to establish an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program, are reasonably designed which satisfies the requirements of Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to prevent Intercept and Obstruct Terrorism Act of 2001 (the Fund from being used for “USA Patriot Act”); (ii) Broker/Dealer has developed, implemented, and will maintain such an anti-money laundering or the financing of terrorist activities and to achieve compliance program, including a customer identification program consistent with the applicable provisions rules under Section 326 of the USA Patriot Act of 2002 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 implementing regulations thereunder. Based on this determination, the Trust hereby instructs Distributor and directs USBFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time deliver information reasonably requested by the parties as additional regulations are adopted and/or regulatory guidance 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 provided relating to the Trust’s found, by its Compliance Officer, independent anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) Prompt written notification of any transaction or combination of transactions that USBFS believesauditor, based on the Procedures, evidence money laundering activity in connection with the Trust or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believesFederal, based upon the Proceduresstate, or self-regulatory agencies, to be engaged in money laundering activityviolation of the USA Patriot Act, provided that any regulation implementing the Trust agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency USA Patriot Act, or applicable industry self-regulatory organization pertaining to USBFS’s its anti-money laundering monitoring on behalf of program. Notwithstanding anything to the Trust; (d) Prompt written notification of any action taken in response contrary, if Broker/Dealer is exempt from the requirement to develop, implement, and maintain anti-money laundering violations 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 described in (a), (b) or (c); and (e) Certified annual nominee if Broker/Dealer has not adopted and quarterly reports of its monitoring does not implement anti-money laundering policies and customer identification activities on behalf of procedures as required by the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the TrustUSA Patriot Act.

Anti-Money Laundering Program. The Each of Distributor and the Trust acknowledges that it has had an opportunity is a financial institution subject to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 2001 and the implementing regulations thereunderBank Secrecy Act, as amended, which require among other things, that financial institutions adopt compliance programs to guard against money laundering. Based on this determination, Each of Distributor and the Trust hereby instructs agrees that it will take such further steps, and directs USBFS cooperate with the other to implement the Procedures on facilitate such compliance. The Distributor acknowledges that it is a “Covered Service Provider” as defined in the Trust’s behalfAnti-Money Laundering Program (“Trust AML Program”) and 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 represents and warrants that it has adopted policies and procedures reasonably designed to detect and prevent money laundering activities in compliance with applicable laws, as such may be amended regulations and regulatory interpretations. The Distributor undertakes that it shall (a) conduct its operations in accordance with the provisions of the Trust AML Program and applicable laws, regulations and regulatory interpretations; (b) provide access to its books, records and operations relating to its anti-money laundering compliance only with respect to the Funds, by appropriate regulatory authorities, the Funds, and the Trust’s anti-money laundering Compliance Officer (the Trust’s Compliance Officer shall have no access to any of Distributor’s anti-money laundering operations, books or revised from time records pertaining to time. It other clients of Distributor); (c) certify, in writing, no less frequently than annually, that it is contemplated that these Procedures will be amended from time in compliance with applicable anti-money laundering laws, rules, regulations and regulatory interpretations with respect to time by the parties as additional regulations are adopted and/or regulatory guidance is services provided relating 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 responsibilities. USBFS agrees to Compliance Officer; (e) provide periodic reports to the Trust: (a) Prompt written notification ’s Board of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s Trustees concerning anti-money laundering monitoring on behalf of activities and compliance exceptions, as the Trust; parties may agree from time to time; and (df) Prompt written notification of any action taken in response ensure that selling group agreements require selling group members to adopt, as applicable, reasonable anti-money laundering violations as described in (a), (b) or (c); and (e) Certified annual procedures and quarterly reports otherwise comply with applicable anti-money laundering regulations and regulatory interpretations with respect to the sale and redemption of its monitoring and customer identification activities on behalf of the TrustShares. The Trust hereby directs, represents and USBFS acknowledges, warrants that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation it will conduct its operations in accordance with the provisions of the ProceduresTrust AML Program and applicable laws, on behalf of the Trust, as they may request, regulations and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the Trustregulatory interpretations.

Anti-Money Laundering Program. The Trust acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) A. Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust or any shareholder of the Fund; (b) B. Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) C. Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the Trust; (d) D. Prompt written notification of any action taken in response to anti-money laundering violations as described in (aA), (bB) or (c)C) above; and (e) E. Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering Program. The Trust acknowledges that it has had an opportunity to reviewUSBFS, consider and comment upon as the written procedures provided by USBFS describing Funds’ registered transfer agent, will implement various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the “Monitoring Procedures”) as well as written procedures for verifying a customer’s identity (collectivelythe “Customer Identification Procedures”), together referred to as the “Procedures”). Further, the Trust has determined that the These Procedures, which shall be approved by the Board of Trustees as part of the Trust’s overall anti-money laundering program, are will be reasonably designed by USBFS to prevent the Fund Funds from being used for money laundering or the financing of terrorist activities and to achieve compliance with USA PATRIOT ACT of 2001, the applicable provisions provision of the USA Patriot Act of 2002 Bank Secrecy Act, and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs all other applicable law and directs USBFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to timeregulation. It is contemplated that these Procedures will be amended from time to time time, as approved by the parties Board of Trustees, as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s Funds’ anti-money laundering responsibilities. USBFS agrees to provide to the TrustFunds and/or the Adviser: (a) A. Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Funds or any shareholder of the a Fund; (b) B. Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Funds/Adviser agrees not to communicate this information to the customer; (c) C. Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the TrustFunds; (d) D. Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified E. An annual report of USBFS’ monitoring and quarterly customer identification activities, and USBFS shall provide such other reports of its on the monitoring and customer identification activities on behalf of as may be agreed to from time to time by USBFS and the TrustAdviser and/or the Funds. The Trust hereby directsTo the extent that federal regulators are legally allowed, and USBFS acknowledges, that USBFS shall (i) permit federal such regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf Procedures. 1. Duties and Responsibilities of USBFS A. Answer all prospective shareholder calls concerning the Funds; B. Send all available Fund material requested by a prospect within 24 hours from time of call; C. Receive and update all Fund fulfillment literature so that the most current information is sent and quoted; D. Provide 24 hour answering service to record prospect calls made after hours (7:00 p.m. to 8:00 a.m., Central Time); E. Maintain and store Fund fulfillment inventory; F. Send periodic fulfillment reports to the Funds as agreed upon between the parties; and G. Supply sufficient inventory of fulfillment materials as required to meet the requests of prospective shareholders of the TrustFunds. H. Supply quarterly adviser update to existing and prospective adviser clients (up to a maximum of 2,500 ) 2. Duties and Responsibilities of the Adviser I. Provide Fund data updates to USBFS as necessary; J. Provide USBFS with any sundry information about the Funds that is necessary to answer prospect questions.

Anti-Money Laundering Program. The Trust Fund acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust Fund has determined that the Procedures, as part of the TrustFund’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Fund hereby instructs and directs USBFS to implement the Procedures on the TrustFund’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustFund’s anti-money laundering responsibilities. USBFS agrees to provide to the TrustFund: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Fund or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Fund agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the TrustFund; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the TrustFund. The Trust Fund hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the TrustFund, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the TrustFund.

Anti-Money Laundering Program. The Trust acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the "Monitoring Procedures") as well as written procedures for verifying a customer’s 's identity (collectivelythe "Customer Identification Procedures"), together referred to as the “"Procedures”). Further, ," and the Trust has determined that the Procedures, as part of the Trust’s 's overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBFS to implement the Procedures on the Trust’s 's behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s 's anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s 's anti-money laundering monitoring on behalf of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified An annual and quarterly reports report of its monitoring and customer identification activities on behalf of the Trust. USBFS shall provide such other reports on the monitoring and customer identification activities conducted at the direction of the Trust as may be agreed to from time to time by USBFS and the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s 's implementation of the Procedures, Procedures on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s 's implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering Program. The Trust Fund acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the “Monitoring Procedures”) as well as written procedures for verifying a customer’s identity (collectivelythe “Customer Identification Procedures”), together referred to as the “Procedures”). Further, ,” and the Trust Fund has determined that the Procedures, as part of the TrustFund’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Fund hereby instructs and directs USBFS to implement the Procedures on the TrustFund’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustFund’s anti-money laundering responsibilities. USBFS agrees to provide to the TrustFund: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Fund or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Fund agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the TrustFund; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified An annual and quarterly reports report of its monitoring and customer identification activities on behalf of the TrustFund. USBFS shall provide such other reports on the monitoring and customer identification activities conducted at the direction of the Fund as may be agreed to from time to time by USBFS and the Fund. The Trust Fund hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, Procedures on behalf of the TrustFund, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the TrustFund.

Anti-Money Laundering Program. The Trust acknowledges that it has had an opportunity to reviewUSBFS, consider and comment upon as the written procedures provided by USBFS describing Funds’ registered transfer agent, will implement various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the “Monitoring Procedures”) as well as written procedures for verifying a customer’s identity (collectivelythe “Customer Identification Procedures”), together referred to as the “Procedures”). Further, the Trust has determined that the These Procedures, which shall be approved by the Board of Trustees as part of the Trust’s overall anti-money laundering program, are will be reasonably designed by USBFS to prevent the Fund Funds from being used for money laundering or the financing of terrorist activities and to achieve compliance with USA PATRIOT ACT of 2001, the applicable provisions provision of the USA Patriot Act of 2002 Bank Secrecy Act, and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs all other applicable law and directs USBFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to timeregulation. It is contemplated that these Procedures will be amended from time to time time, as approved by the parties Board of Trustees, as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s Funds’ anti-money laundering responsibilities. USBFS agrees to provide to the TrustFunds and/or the Adviser: (a) A. Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Funds or any shareholder of the a Fund; (b) B. Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Funds/Adviser agrees not to communicate this information to the customer; (c) C. Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the TrustFunds; (d) D. Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified E. An annual report of USBFS’ monitoring and quarterly customer identification activities, and USBFS shall provide such other reports of its on the monitoring and customer identification activities on behalf of as may be agreed to from time to time by USBFS and the TrustAdviser and/or the Funds. The Trust hereby directsTo the extent that federal regulators are legally allowed, and USBFS acknowledges, that USBFS shall (i) permit federal such regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf Procedures. 1. Duties and Responsibilities of USBFS A. Answer all prospective shareholder calls concerning the Funds; B. Send all available Fund material requested by a prospect within 24 hours from time of call; C. Receive and update all Fund fulfillment literature so that the most current information is sent and quoted; D. Provide 24 hour answering service to record prospect calls made after hours (7:00 p.m. to 8:00 a.m., Central Time); E. Maintain and store Fund fulfillment inventory; F. Send periodic fulfillment reports to the Funds as agreed upon between the parties; and G. Supply sufficient inventory of fulfillment materials as required to meet the requests of prospective shareholders of the TrustFunds.

Anti-Money Laundering Program. The Trust acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s 's identity (collectively, the “"Procedures”"). Further, the Trust has determined that the Procedures, as part of the Trust’s 's overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBFS to implement the Procedures on the Trust’s 's behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s 's anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s 's anti-money laundering monitoring on behalf of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s 's implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s 's implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering Program. The Trust acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the “Monitoring Procedures”) as well as written procedures for verifying a customer’s identity (collectivelythe “Customer Identification Procedures”), together referred to as the “Procedures”). Further, ,” and the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) A. Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust or any shareholder of the Fund; (b) B. Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) C. Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering Program. The Trust acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the "Monitoring Procedures") as well as written procedures for verifying a customer’s 's identity (collectivelythe "Customer Identification Procedures"), together referred to as the “"Procedures”). Further, ," and the Trust has determined that the Procedures, as part of the Trust’s 's overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBFS to implement the Procedures on the Trust’s 's behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s 's anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s 's anti-money laundering monitoring on behalf of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified A certified annual and quarterly reports report of its monitoring and customer identification activities on behalf of the Trust. USBFS shall provide such other reports on the monitoring and customer identification activities conducted at the direction of the Trust as may be agreed to from time to time by USBFS and the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s 's implementation of the Procedures, Procedures on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s 's implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering Program. The Trust Company acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the “Monitoring Procedures”) as well as written procedures for verifying a customer’s identity (collectivelythe “Customer Identification Procedures”), together referred to as the “Procedures”). Further, ,” and the Trust Company has determined that the Procedures, as part of the TrustCompany’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Company hereby instructs and directs USBFS to implement the Procedures on the TrustCompany’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustCompany’s anti-money laundering responsibilities. USBFS agrees to provide to the TrustCompany: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Company or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Company agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the TrustCompany; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified An annual and quarterly reports report of its monitoring and customer identification activities on behalf of the TrustCompany. USBFS shall provide such other reports on the monitoring and customer identification activities conducted at the direction of the Company as may be agreed to from time to time by USBFS and the Company. The Trust Company hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, Procedures on behalf of the TrustCompany, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the TrustCompany.

Anti-Money Laundering Program. The Trust Company acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust Company has determined that the Procedures, as part of the TrustCompany’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 2001 and the implementing regulations thereunder. Based on this determination, the Trust Company hereby instructs and directs USBFS to implement the Procedures on the TrustCompany’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustCompany’s anti-money laundering responsibilities. USBFS agrees to provide to the TrustCompany: (a) A. Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Company or any shareholder of the Fund; (b) B. Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Company agrees not to communicate this information to the customer; (c) C. Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the TrustCompany; (d) D. Prompt written notification of any action taken in response to anti-money laundering violations as described in (aA), (bB) or (c)C) above; and (e) E. Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the TrustCompany. The Trust Company hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the TrustCompany, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the TrustCompany.

Anti-Money Laundering Program. The Trust Company acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the “Monitoring Procedures”) as well as written procedures for verifying a customer’s identity (collectivelythe “Customer Identification Procedures”), together referred to as the “Procedures”). Further, ,” and the Trust Company has determined that the Procedures, as part of the TrustCompany’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Company hereby instructs and directs USBFS and USBFS hereby agrees to implement the Procedures on the TrustCompany’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustCompany’s anti-money laundering responsibilities. USBFS agrees to provide to the TrustCompany: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Company or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Company agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the TrustCompany; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified An annual and quarterly reports report of its monitoring and customer identification activities on behalf of the TrustCompany. USBFS shall provide such other reports on the monitoring and customer identification activities conducted at the direction of the Company as may be agreed to from time to time by USBFS and the Company. The Trust Company hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, Procedures on behalf of the TrustCompany, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the TrustCompany.

Anti-Money Laundering Program. The Trust Adviser acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the "Monitoring Procedures") as well as written procedures for verifying a customer’s 's identity (collectivelythe "Customer Identification Procedures"), together referred to as the “"Procedures”). Further, ," and the Trust Adviser has determined that the Procedures, as part of the Trust’s Funds' overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Adviser hereby instructs and directs USBFS to implement the Procedures on the Trust’s Funds' behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s Funds' anti-money laundering responsibilities. USBFS agrees to provide to the TrustFunds: (a) A. Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Funds or any shareholder of the Fund; (b) B. Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Funds agrees not to communicate this information to the customer; (c) C. Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s 's anti-money laundering monitoring on behalf of the TrustFunds; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering Program. The Trust acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the “Monitoring Procedures”) as well as written procedures for verifying a customer’s identity (collectivelythe “Customer Identification Procedures”), together referred to as the “Procedures”). Further, ,” and the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified A certified annual and quarterly reports report of its monitoring and customer identification activities on behalf of the Trust. USBFS shall provide such other reports on the monitoring and customer identification activities conducted at the direction of the Trust as may be agreed to from time to time by USBFS and the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, Procedures on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering Program. The Each of Distributor and the Trust acknowledges that it has had an opportunity is a financial institution subject to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 2001 and the implementing regulations thereunderBank Secrecy Act, as amended, which require among other things, that financial institutions adopt compliance programs to guard against money laundering. Based on this determination, Each of Distributor and the Trust hereby instructs agrees that it will take such further steps, and directs USBFS cooperate with the other to implement the Procedures on facilitate such compliance. The Distributor acknowledges that it is a “Covered Service Provider” as defined in the Trust’s behalfAnti- Money Laundering Program (“Trust AML Program”) and 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 represents and warrants that it has adopted policies and procedures reasonably designed to detect and prevent money laundering activities in compliance with applicable laws, as such may be amended regulations and regulatory interpretations. The Distributor undertakes that it shall (a) conduct its operations in accordance with the provisions of the Trust AML Program and applicable laws, regulations and regulatory interpretations; (b) provide access to its books, records and operations relating to its anti-money laundering compliance only with respect to the Funds, by appropriate regulatory authorities, the Funds, and the Trust’s anti-money laundering Compliance Officer (the Trust’s Compliance Officer shall have no access to any of Distributor’s anti-money laundering operations, books or revised from time records pertaining to time. It other clients of Distributor); (c) certify, in writing, no less frequently than annually, that it is contemplated that these Procedures will be amended from time in compliance with applicable anti-money laundering laws, rules, regulations and regulatory interpretations with respect to time by the parties as additional regulations are adopted and/or regulatory guidance is services provided relating 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 responsibilities. USBFS agrees to Compliance Officer; (e) provide periodic reports to the Trust: (a) Prompt written notification ’s Board of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence Trustees concerning anti- money laundering activity in connection with activities and compliance exceptions, as the Trust or any shareholder of the Fund; parties may agree from time to time; and (bf) Prompt written notification of any customer(s) ensure that USBFS reasonably believesselling group agreements require selling group members to adopt, based upon the Proceduresas applicable, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s reasonable anti-money laundering monitoring on behalf of the Trust; (d) Prompt written notification of any action taken in response to procedures and otherwise comply with applicable anti-money laundering violations as described in (a), (b) or (c); and (e) Certified annual regulations and quarterly reports regulatory interpretations with respect to the sale and redemption of its monitoring and customer identification activities on behalf of the TrustShares. The Trust hereby directs, represents and USBFS acknowledges, warrants that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation it will conduct its operations in accordance with the provisions of the ProceduresTrust AML Program and applicable laws, on behalf of the Trust, as they may request, regulations and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the Trustregulatory interpretations.

Anti-Money Laundering Program. (a) The Trust acknowledges that hereby delegates to the Administrator, and the Administrator hereby accepts, responsibility to perform certain services in connection with the Trust’s Anti-Money Laundering Program (the “Trust AML Program”), as further set out in the Trust AML Program, including provisions relating to: (i) customer identification program, (ii) suspicious activity monitoring and reporting; (iii) cash transaction reporting; (iv) recordkeeping; and (v) employee training (as it has had an opportunity relates to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity Administrator employees) (collectively, the “ProceduresAML Services”). Further, the Trust has determined that the Procedures, as part of The Administrator further agrees to cooperate with the Trust’s overall AML Compliance Officer in the performance of the AML Services as set forth in the Trust AML Program. (b) The Administrator represents and warrants that: (i) The Administrator undertakes to perform all delegated responsibilities under the Trust AML Program; and (ii) The Administrator has adopted and will maintain a written anti-money laundering program, are reasonably designed program (“Administrator AML Program”) that includes policies and procedures that enable it to prevent perform its responsibilities under the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBFS to implement the Procedures on the Trust’s behalfAgreement, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer;hereby. (c) Any reports received by USBFS from The Trust represents and warrants that the Trust will promptly provide the Administrator any government agency or applicable industry self-regulatory organization pertaining amendment(s) to USBFS’s anti-money laundering monitoring on behalf the Trust AML Program, which will be subject to the terms of the Trust;Agreement, as amended hereby, upon delivery to the Administrator. (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); andThe Administrator hereby: (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit agrees to provide, upon request by federal regulators access to such examiners, information and records maintained by USBFS and the Administrator relating to USBFS’s implementation the Trust AML Program for purposes of the ProceduresTrust AML Program; (ii) agrees to provide, on behalf of upon request by the Trust, information and records maintained by the Administrator relating to the AML Services and the Administrator AML Program as they may requestit applies to the AML Services; (iii) agrees to cooperate with the Trust’s AML Compliance Officer with respect to any request for information by the Financial Crimes Enforcement Network pursuant to the Bank Secrecy Act, as amended by the USA PATRIOT Act and the regulations thereunder; and (iv) consents to the inspection of the Administrator by federal examiners for purposes of the Trust AML Program. (e) The Administrator agrees to furnish to the Trust the following: (i) a copy of the Administrator AML Program as in effect on the date hereof, and any material amendment thereto promptly after the adoption of any such amendment; (ii) permit such federal regulators no less frequently than annually, a report on the Administrator AML Program that includes a certification to inspect USBFSthe Trust concerning the Administrator’s implementation of, and ongoing compliance with, the Administrator AML Program and a summary of any audit report prepared with respect to the Procedures on behalf of Administrator AML Program as its pertains to the TrustAML Services; (iii) interim reports with respect to any material issues that arise with respect to the AML Services or the Administrator AML Program; and (iv) periodic reports concerning Administrator’s compliance with the Administrator AML Program and/or the AML Services at such times as may be reasonably requested by the Board or AML Compliance Officer.

Anti-Money Laundering Program. The Trust Company acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust Company has determined that the Procedures, as part of the TrustCompany’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Company hereby instructs and directs USBFS to implement the Procedures on the TrustCompany’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustCompany’s anti-money laundering responsibilities. USBFS agrees to provide to the TrustCompany: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Company or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Company agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the TrustCompany; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the TrustCompany. The Trust Company hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the TrustCompany, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the TrustCompany.

Anti-Money Laundering Program. The Each of Distributor and the Trust acknowledges that it has had an opportunity is a financial institution subject to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 2001 and the implementing Bank Secrecy Act, which require among other things, that financial institutions adopt compliance programs to guard against money laundering. Each of Distributor and the Trust agrees that it will take such 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 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 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 thereunderand regulatory interpretations. Based on this determinationThe Distributor undertakes that it shall (a) conduct its operations in accordance with the provisions of the Trust AML Program and applicable laws, regulations and regulatory interpretations; (b) provide access to its books, records and operations relating to its anti-money laundering compliance only with respect to the Funds, by appropriate regulatory authorities, the Trust hereby instructs Funds, and directs USBFS to implement the Procedures on the Trust’s behalf's anti-money laundering Compliance Officer (the Trust's Compliance Officer shall have no access to any of Distributor's anti-money laundering 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 such the parties may be amended or revised agree from time to time. It is contemplated ; and (f) ensure that these Procedures will be amended from time selling group agreements require selling group members to time by the parties adopt, as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s applicable, reasonable anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection procedures and otherwise comply with the Trust or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf regulations and regulatory interpretations with respect to the sale and redemption of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the TrustShares. The Trust hereby directs, represents and USBFS acknowledges, warrants that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation it will conduct its operations in accordance with the provisions of the ProceduresTrust AML Program and applicable laws, on behalf of the Trust, as they may request, regulations and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the Trustregulatory interpretations.

Anti-Money Laundering Program. The Trust acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the “Monitoring Procedures”) as well as written procedures for verifying a customer’s identity (collectivelythe “Customer Identification Procedures”), together referred to as the “Procedures”). Further, ,” and the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBFS and USBFS hereby agrees to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified An annual and quarterly reports report of its monitoring and customer identification activities on behalf of the Trust. USBFS shall provide such other reports on the monitoring and customer identification activities conducted at the direction of the Trust as may be agreed to from time to time by USBFS and the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, Procedures on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering Program. The Trust acknowledges that it has had an opportunity to reviewUSBFS, consider and comment upon as the written procedures provided by USBFS describing Funds’ registered transfer agent, will implement various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the “Monitoring Procedures”) as well as written procedures for verifying a customer’s identity (collectivelythe “Customer Identification Procedures”), together referred to as the “Procedures”). Further, the Trust has determined that the These Procedures, which shall be approved by the Board of Trustees as part of the Trust’s overall anti-money laundering program, are will be reasonably designed by USBFS to prevent the Fund Funds from being used for money laundering or the financing of terrorist activities and to achieve compliance with USA PATRIOT ACT of 2001, the applicable provisions provision of the USA Patriot Act of 2002 Bank Secrecy Act, and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs all other applicable law and directs USBFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to timeregulation. It is contemplated that these Procedures will be amended from time to time time, as approved by the parties Board of Trustees, as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s Funds’ anti-money laundering responsibilities. USBFS agrees to provide to the TrustFunds and/or the Adviser: (a) A. Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Funds or any shareholder of the a Fund; (b) B. Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Funds/Adviser agrees not to communicate this information to the customer; (c) C. Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the TrustFunds; (d) D. Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified E. An annual report of USBFS’ monitoring and quarterly customer identification activities, and USBFS shall provide such other reports of its on the monitoring and customer identification activities on behalf of as may be agreed to from time to time by USBFS and the TrustAdviser and/or the Funds. The Trust hereby directsTo the extent that federal regulators are legally allowed, and USBFS acknowledges, that USBFS shall (i) permit federal such regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf Procedures. 1. Duties and Responsibilities of USBFS A. Answer all prospective shareholder calls concerning the Funds; B. Send all available Fund material requested by a prospect within 24 hours from time of call; C. Receive and update all Fund fulfillment literature so that the most current information is sent and quoted; D. Provide 24 hour answering service to record prospect calls made after hours (7:00 p.m. to 8:00 a.m., Central Time); E. Maintain and store Fund fulfillment inventory; F. Send periodic fulfillment reports to the Funds as agreed upon between the parties; and G. Supply sufficient inventory of fulfillment materials as required to meet the requests of prospective shareholders of the TrustFunds. H. Supply quarterly adviser update to existing and prospective adviser clients (up to a maximum of 2,500 )

Anti-Money Laundering Program. The Trust Company acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust Company has determined that the Procedures, as part of the TrustCompany’s overall anti-money laundering program, are reasonably designed to prevent the Fund Funds from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Company hereby instructs and directs USBFS to implement the Procedures on the TrustCompany’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustCompany’s anti-money laundering responsibilities. USBFS agrees to provide to the TrustCompany: (a) A. Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Company or any shareholder of the FundFunds; (b) B. Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Company agrees not to communicate this information to the customer; (c) C. Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the TrustCompany; (d) D. Prompt written notification of any action taken in response to anti-money laundering violations as described in (aA), (bB) or (c)C) above; and (e) E. Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the TrustCompany. The Trust Company hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the TrustCompany, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the TrustCompany.

Anti-Money Laundering Program. The Trust acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the “Monitoring Procedures”) as well as written procedures for verifying a customer’s identity (collectivelythe “Customer Identification Procedures”), together referred to as the “Procedures”). Further, ,” and the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified An annual and quarterly reports report of its monitoring and customer identification activities on behalf of the Trust. USBFS shall provide such other reports on the monitoring and customer identification activities conducted at the direction of the Trust as may be agreed to from time to time by USBFS and the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, Procedures on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering Program. The Trust Madison acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the "Monitoring Procedures") as well as written procedures for verifying a customer’s identity (collectivelythe "Customer Identification Procedures"), together referred to as the “"Procedures”). Further, the Trust ," and Madison has determined that the Procedures, as part of the Trust’s Trusts’ overall anti-money laundering program, are reasonably designed to prevent the Fund Funds from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Madison hereby instructs and directs USBFS to implement the Procedures on the Trust’s Trusts’ behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s Trusts’ anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) Madison: Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Trusts or any shareholder of the Fund; (b) Funds; Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Madison agrees not to communicate this information to the customer; (c) ; Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the Trust; (d) Trusts; Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified and An annual and quarterly reports report of its monitoring and customer identification activities on behalf of Madison. USBFS shall provide such other reports on the Trustmonitoring and customer identification activities conducted at the direction of Madison as may be agreed to from time to time by USBFS and Madison. The Trust Madison hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, Procedures on behalf of the TrustMadison, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the TrustTrusts.

Anti-Money Laundering Program. The Trust Corporation acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the “Monitoring Procedures”) as well as written procedures for verifying a customer’s identity (collectivelythe “Customer Identification Procedures”), together referred to as the “Procedures”). Further, ,” and the Trust has Corporation have determined that the Procedures, as part of the TrustCorporation’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Corporation hereby instructs instruct and directs direct USBFS to implement the Procedures on the TrustCorporation’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustCorporation’s anti-money laundering responsibilities. USBFS agrees to provide to the TrustCorporation: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Corporation or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees Corporation agree not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the TrustCorporation; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified A certified annual and quarterly reports report of its monitoring and customer identification activities on behalf of the TrustCorporation. USBFS shall provide such other reports on the monitoring and customer identification activities conducted at the direction of the Corporation as may be agreed to from time to time by USBFS and the Corporation. The Trust Corporation hereby directsdirect, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, Procedures on behalf of the TrustCorporation, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the TrustCorporation.

Anti-Money Laundering Program. The Trust acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) A. Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust or any shareholder of the FundFunds; (b) B. Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) C. Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the Trust; (d) D. Prompt written notification of any action taken in response to anti-money laundering violations as described in (aA), (bB) or (c)C) above; and (e) E. Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering Program. The Each of Distributor and the Trust acknowledges that it has had an opportunity is a financial institution subject to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 2001 and the implementing Bank Secrecy Act, which require among other things, that financial institutions adopt compliance programs to guard against money laundering. Each of Distributor and the Trust agrees that it will take such 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 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 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 thereunderand regulatory interpretations. Based on this determinationThe Distributor undertakes that it shall (a) conduct its operations in accordance with the provisions of the Trust AML Program and applicable laws, regulations and regulatory interpretations; (b) provide access to its books, records and operations relating to its anti-money laundering compliance only with respect to the Funds, by appropriate regulatory authorities, the Trust hereby instructs Funds, and directs USBFS to implement the Procedures on the Trust’s behalf's anti-money laundering Compliance Officer (the Trust's Compliance Officer shall have no access to any of Distributor's anti-money laundering 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 such the parties may be amended or revised agree from time to time. It is contemplated ; and (f) ensure that these Procedures will be amended from time selling group agreements require selling group members to time by the parties adopt, as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s applicable, reasonable anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection procedures and otherwise comply with the Trust or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf regulations and regulatory interpretations with respect to the sale and redemption of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the TrustShares. The Trust hereby directs, represents and USBFS acknowledges, warrants that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation it will conduct its operations in accordance with the provisions of the ProceduresTrust AML Program and applicable laws, on behalf of the Trust, as they may request, regulations and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the Trustregulatory interpretations.

Anti-Money Laundering Program. The Trust Company acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust Company has determined that the Procedures, as part of the TrustCompany’s overall anti-money laundering program, are reasonably designed to prevent the Fund Funds from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Company hereby instructs and directs USBFS to implement the Procedures on the TrustCompany’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustCompany’s anti-money laundering responsibilities. USBFS agrees to provide to the TrustCompany: (a) A. Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Company or any shareholder of the any Fund; (b) B. Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Company agrees not to communicate this information to the customer; (c) C. Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the TrustCompany; (d) D. Prompt written notification of any action taken in response to anti-money laundering violations as described in (aA), (bB) or (c)C) above; and (e) E. Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the TrustCompany. The Trust Company hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the TrustCompany, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the TrustCompany.

Anti-Money Laundering Program. The Trust acknowledges Tocqueville Funds acknowledge that it has they have had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the "Monitoring Procedures") as well as written procedures for verifying a customer’s 's identity (collectivelythe "Customer Identification Procedures"), together referred to as the “"Procedures”). Further, ," and the Trust has Tocqueville Funds have determined that the Procedures, as part of the Trust’s Tocqueville Funds' overall anti-money laundering program, are reasonably designed to prevent the any Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Tocqueville Funds hereby instructs instruct and directs direct USBFS to implement the Procedures on the Trust’s Tocqueville Funds' behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s Tocqueville Funds' anti-money laundering responsibilities. USBFS agrees to provide to the TrustTocqueville Funds: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Tocqueville Funds or any shareholder of the each Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees Tocqueville Funds agree not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s 's anti-money laundering monitoring on behalf of the TrustTocqueville Funds; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified A certified annual and quarterly reports report of its monitoring and customer identification activities on behalf of the TrustTocqueville Funds. USBFS shall provide such other reports on the monitoring and customer identification activities conducted at the direction of the Tocqueville Funds as may be agreed to from time to time by USBFS and the Tocqueville Funds. The Trust Tocqueville Funds hereby directsdirect, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s 's implementation of the Procedures, Procedures on behalf of the TrustTocqueville Funds, as they may request, and (ii) permit such federal regulators to inspect USBFS’s 's implementation of the Procedures on behalf of the TrustTocqueville Funds.

Anti-Money Laundering Program. USBFS acknowledges and represents that (1) it is a financial institution subject to the law entitled Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism ("USA Patriot") Act of 2001 and the Bank Secrecy Act (collectively the "AML Acts") and shall comply with the AML Acts and applicable regulations adopted thereunder (collectively, the "Applicable AML Laws") in all relevant respects; and (2) it is subject to a rule implementing 31 U.S.C. 5318(h) (the anti-money laundering program provision of the USA Patriot Act) and is regulated by a federal functional regulator such as a federal banking regulator or the SEC. The Trust acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s 's identity (collectively, the “"Procedures”"). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 and the implementing regulations thereunder. Based on this determination, the The Trust hereby instructs and directs USBFS to implement the Procedures on the Trust’s 's behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s 's anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) A. Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust or any shareholder of the Fund; (b) B. Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) C. Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s ' anti-money laundering monitoring on behalf of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering Program. The Trust Company acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the "Monitoring Procedures") as well as written procedures for verifying a customer’s 's identity (collectivelythe "Customer Identification Procedures"), together referred to as the “"Procedures”). Further, ," and the Trust Company has determined that the Procedures, as part of the Trust’s Company's overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Company hereby instructs and directs USBFS to implement the Procedures on the Trust’s Company's behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s Company's anti-money laundering responsibilities. USBFS agrees to provide to the TrustCompany: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Company or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Company agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s 's anti-money laundering monitoring on behalf of the TrustCompany; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified An annual and quarterly reports report of its monitoring and customer identification activities on behalf of the TrustCompany. USBFS shall provide such other reports on the monitoring and customer identification activities conducted at the direction of the Company as may be agreed to from time to time by USBFS and the Company. The Trust Company hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s 's implementation of the Procedures, Procedures on behalf of the TrustCompany, as they may request, and (ii) permit such federal regulators to inspect USBFS’s 's implementation of the Procedures on behalf of the TrustCompany.

Anti-Money Laundering Program. The Trust acknowledges Company delegates to USBFS the performance of the services set forth below (the “AML Services”) with respect to shareholder accounts maintained by USBFS pursuant to this Agreement; and subject to the terms and conditions of this Agreement, USBFS accepts this delegation and agrees to perform the AML Services in accordance with the Company’s and USBFS’ AML Program. Notwithstanding this delegation, the Company shall maintain full responsibility for ensuring that it has had an opportunity its AML Program is and continues to reviewbe reasonable designed ensure compliance with applicable AML Laws.. a. Verify shareholder identity upon opening new accounts in accordance with Section 326 of the USA PATRIOT Act (the “Patriot Act”) and any regulations thereunder, consider as required under applicable law; b. Monitor shareholder transactions and comment upon identify and report suspicious activities that are required to be so identified and reported, in each case consistent with the AML programs of the Company and USBFS; c. Submit all accounts through the Office of Foreign Asset Control (“OFAC”) database and FinCEN’s Control List; d. Follow the Company’s third party check policies; provided, however, that under no circumstance will USBFS accept a corporate third party check; e. Place holds on transactions in shareholder accounts or freeze assets in shareholder accounts, as provided in the AML programs of the Company and USBFS and in accordance with the Patriot Act and OFAC; and f. Maintain policies, procedures and internal controls that are consistent with the Company’s AML program USBFS agrees to provide to the Company: A. Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Company or any shareholder of the Fund; (b) B. Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Company agrees not to communicate this information to the customer; (c) C. Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the TrustCompany; (d) D. Prompt written notification of any action taken in response to anti-money laundering violations as described in (aA), (bB) or (c)C) above; and (e) E. Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the TrustCompany. The Trust Company hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the TrustCompany, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the TrustCompany.

Anti-Money Laundering Program. The Trust acknowledges that it USBFS has had an opportunity to review, consider developed and comment upon the implements written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures a program for verifying a customer’s identity identity, including beneficial owners for certain legal entity customers (collectively, the “Procedures”). The Procedures have been established and implemented in accordance with the USA PATRIOT Act, the Bank Secrecy Act, and the rules and regulations thereunder. Further, the Trust Company has reviewed and considered the Procedures and determined that the Procedures, as part of the TrustCompany’s overall anti-money laundering program, are reasonably designed to prevent the Fund Funds from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 PATRIOT Act, the Bank Secrecy Act, and the implementing regulations thereunder. Based on this determination, the Trust Company hereby instructs and directs USBFS to implement the Procedures on the TrustCompany’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustCompany’s anti-money laundering responsibilities. USBFS agrees to provide to the TrustCompany: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Company or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Company agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the TrustCompany; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the TrustCompany. The Trust Company hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the TrustCompany, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the TrustCompany.

Anti-Money Laundering Program. The Trust acknowledges that it has had an opportunity to reviewUSBFS, consider and comment upon as the written procedures provided by USBFS describing Funds’ registered transfer agent, will implement various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the “Monitoring Procedures”) as well as written procedures for verifying a customer’s identity (collectivelythe “Customer Identification Procedures”), together referred to as the “Procedures”). Further, the Trust has determined that the These Procedures, which shall be approved by the Funds’ Directors/Trustees as part of the Trust’s Funds’ overall anti-money laundering program, are will be reasonably designed by USBFS to prevent the Fund Funds from being used for money laundering or the financing of terrorist activities and to achieve compliance with USA PATRIOT ACT of 2001, the applicable provisions provision of the USA Patriot Act of 2002 Bank Secrecy Act, and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs all other applicable law and directs USBFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to timeregulation. It is contemplated that these Procedures will be amended from time to time time, as approved by the parties Funds’ Directors/Trustees, as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s Funds’ anti-money laundering responsibilities. USBFS agrees to provide to the TrustFunds and/or the Adviser: (a) A. Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Funds or any shareholder of the a Fund; (b) B. Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Funds/Adviser agrees not to communicate this information to the customer; (c) C. Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the TrustFunds; (d) D. Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering Program. The Trust acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Company hereby instructs and directs USBFS to implement the Anti-Money Laundering Policies and Procedures on (“Policies”) of the Trust’s behalfCompany, as such may be amended or revised from time to time. It is contemplated that these Procedures Policies will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustCompany’s anti-money laundering responsibilitiesresponsibilities or as reasonably requested by the Company. USBFS agrees to provide to the TrustCompany: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the ProceduresPolicies, evidence indicates money laundering activity in connection with the Trust Company or any shareholder of the a Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the ProceduresPolicies, to be engaged in money laundering activity, provided that the Trust Company agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the TrustCompany; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the TrustCompany. USBFS shall provide such other reports on the monitoring and customer identification activities conducted at the direction of the Company as may be agreed to from time to time by USBFS and the Company. The Trust Company hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators or agents or representatives of the Company access to such information and records maintained by USBFS and relating to USBFS’s implementation of the ProceduresPolicies, on behalf of the TrustCompany, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures Policies on behalf of the TrustCompany. USBFS understands this may involve inspection and sampling of data.

Anti-Money Laundering Program. The Trust Fund acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the "Monitoring Procedures") as well as written procedures for verifying a customer’s 's identity (collectivelythe "Customer Identification Procedures"), together referred to as the “"Procedures”). Further, ," and the Trust Fund has determined that the Procedures, as part of the Trust’s Fund's overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Fund hereby instructs and directs USBFS to implement the Procedures on the Trust’s Fund's behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s Fund's anti-money laundering responsibilities. USBFS agrees to provide to the TrustFund: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Fund or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Fund agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s 's anti-money laundering monitoring on behalf of the TrustFund; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified A certified annual and quarterly reports report of its monitoring and customer identification activities on behalf of the TrustFund. USBFS shall provide such other reports on the monitoring and customer identification activities conducted at the direction of the Fund as may be agreed to from time to time by USBFS and the Fund. The Trust Fund hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s 's implementation of the Procedures, Procedures on behalf of the TrustFund, as they may request, and (ii) permit such federal regulators to inspect USBFS’s 's implementation of the Procedures on behalf of the TrustFund.

Anti-Money Laundering Program. The Trust Fund acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the "Monitoring Procedures") as well as written procedures for verifying a customer’s 's identity (collectivelythe "Customer Identification Procedures"), together referred to as the “"Procedures”). Further, ," and the Trust Fund has determined that the Procedures, as part of the Trust’s Fund's overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Fund hereby instructs and directs USBFS to implement the Procedures on the Trust’s Fund's behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s Fund's anti-money laundering responsibilities. USBFS agrees to provide to the TrustFund: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Fund or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Fund agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s 's anti-money laundering monitoring on behalf of the TrustFund; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified An annual and quarterly reports report of its monitoring and customer identification activities on behalf of the TrustFund. USBFS shall provide such other reports on the monitoring and customer identification activities conducted at the direction of the Fund as may be agreed to from time to time by USBFS and the Fund. The Trust Fund hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s 's implementation of the Procedures, Procedures on behalf of the TrustFund, as they may request, and (ii) permit such federal regulators to inspect USBFS’s 's implementation of the Procedures on behalf of the TrustFund.

Anti-Money Laundering Program. The Trust acknowledges Anti-Money Laundering. USBFS represents and warrants that it it: (i) has had adopted an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering programcompliance program (“AML Program”) that satisfies the requirements of all applicable laws and regulations; (ii) undertakes to carry out its AML Program to the best of its ability; (iii) will promptly notify the Trust and MDT Advisers, are reasonably designed to prevent the Fund from being used for money laundering or Funds’ investment advisor, if an inspection by the financing appropriate regulatory authorities of terrorist activities its AML Program identifies any material deficiency; and to achieve compliance with the applicable provisions (iv) will promptly remedy any material deficiency of the USA Patriot Act of 2002 and the implementing regulations thereunderwhich it has notice. Based on this determinationrepresentation, the Trust hereby instructs and directs USBFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering Program. The Trust Corporation acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the “Monitoring Procedures”) as well as written procedures for verifying a customer’s identity (collectivelythe “Customer Identification Procedures”), together referred to as the “Procedures”). Further, ,” and the Trust Corporation has determined that the Procedures, as part of the TrustCorporation’s overall anti-money laundering program, are reasonably designed to prevent the each Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Corporation hereby instructs and directs USBFS to implement the Procedures on the TrustCorporation’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustCorporation’s anti-money laundering responsibilities. USBFS agrees to provide to the TrustCorporation: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Corporation or any shareholder of the a Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Corporation agrees not to communicate this information to the customercustomer unless otherwise required by applicable law; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s ’ anti-money laundering monitoring on behalf of the TrustCorporation; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); (e) A certified annual report of its Monitoring Procedures and Customer Identification Procedures on behalf of the Corporation. USBFS shall provide such other reports on the Monitoring Procedures and Customer Identification Procedures conducted at the direction of the Corporation as may be agreed to from time to time by USBFS and the Corporation; and (ef) Certified annual Such other certifications and quarterly reports of its monitoring representations regarding USBFS’ Monitoring Procedures and customer identification activities on behalf of Customer Identification Procedures as the TrustCorporation may reasonably request. The Trust Corporation hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s ’ implementation of the Procedures, Procedures on behalf of the TrustCorporation, as they may request, and (ii) permit such federal regulators to inspect USBFS’s ’ implementation of the Procedures on behalf of the TrustCorporation.

Anti-Money Laundering Program. The Trust Corporation acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the "Monitoring Procedures") as well as written procedures for verifying a customer’s 's identity (collectivelythe "Customer Identification Procedures"), together referred to as the “"Procedures”). Further, ," and the Trust Corporation has determined that the Procedures, as part of the Trust’s Corporation's overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Corporation hereby instructs and directs USBFS to implement the Procedures on the Trust’s Corporation's behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s Corporation's anti-money laundering responsibilities. USBFS agrees to provide to the TrustCorporation: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Corporation or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Corporation agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s 's anti-money laundering monitoring on behalf of the TrustCorporation; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified An annual and quarterly reports report of its monitoring and customer identification activities on behalf of the TrustCorporation. USBFS shall provide such other reports on the monitoring and customer identification activities conducted at the direction of the Corporation as may be agreed to from time to time by USBFS and the Corporation. The Trust Corporation hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s 's implementation of the Procedures, Procedures on behalf of the TrustCorporation, as they may request, and (ii) permit such federal regulators to inspect USBFS’s 's implementation of the Procedures on behalf of the TrustCorporation.

Anti-Money Laundering Program. The Trust Company acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust Company has determined that the Procedures, as part of the TrustCompany’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Company hereby instructs and directs USBFS to implement the Procedures on the TrustCompany’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustCompany’s anti-money laundering responsibilities. USBFS agrees to provide to the TrustCompany: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Company or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Company agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s ’ anti-money laundering monitoring on behalf of the TrustCompany; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the TrustCompany. The Trust Company hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s ’ implementation of the Procedures, on behalf of the TrustCompany, as they may request, and (ii) permit such federal regulators to inspect USBFS’s ’ implementation of the Procedures on behalf of the TrustCompany.

Anti-Money Laundering Program. The Trust acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program and the Red Flag Identity Theft Prevention program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the Fair and Accurate Credit Transactions Act of 2003 and the USA Patriot Act of 2002 2001 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering and identity theft responsibilities. USBFS agrees to provide to the Trust: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity or identity theft activities in connection with the Trust or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activityor identity theft activities, provided that the Trust agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring or the Red Flag Identity Theft Prevention Program on behalf of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations or identity theft activity as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the Trust. 2. Except to the extent amended hereby, the Transfer Agent Agreement, the First Amendment the Second Amendment shall remain in full force and effect.

Anti-Money Laundering Program. The Trust acknowledges that it has had an opportunity to review, . consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) A. Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust or any shareholder of the Fund; (b) B. Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer;: (c) C. Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the Trust; (d) D. Prompt written notification of any action taken in response to anti-money laundering violations as .is described in (aA), . (bB) or (c); C) above: and (e) E. Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the Trust, as they may request, . and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering Program. The Each of Distributor and the Trust acknowledges that it has had an opportunity is a financial institution subject to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 2001 and the implementing regulations thereunderBank Secrecy Act, as amended, which require among other things, that financial institutions adopt compliance programs to guard against money laundering. Based on this determination, Each of Distributor and the Trust hereby instructs agrees that it will take such further steps, and directs USBFS cooperate with the other to implement the Procedures on facilitate such compliance. The Distributor acknowledges that it is a “Covered Service Provider” as defined in the Trust’s behalfAnti-Money Laundering Program (“Trust AML Program”) and 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 represents and warrants that it has adopted policies and procedures reasonably designed to detect and prevent money laundering activities in compliance with applicable laws, as such may be amended regulations and regulatory interpretations. The Distributor undertakes that it shall (a) conduct its operations in accordance with the provisions of the Trust AML Program and applicable laws, regulations and regulatory interpretations; (b) provide access to its books, records and operations relating to its anti-money laundering compliance only with respect to the Funds, by appropriate regulatory authorities, the Funds, and the Trust’s anti-money laundering Compliance Officer (the Trust’s Compliance Officer shall have no access to any of Distributor’s anti-money laundering operations, books or revised from time records pertaining to time. It other clients of Distributor); (c) certify, in writing, no less frequently than annually, that it is contemplated that these Procedures will be amended from time in compliance with applicable anti-money laundering laws, rules, regulations and regulatory interpretations with respect to time by the parties as additional regulations are adopted and/or regulatory guidance is services provided relating 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 responsibilities. USBFS agrees to Compliance Officer; (e) provide periodic reports to the Trust: (a) Prompt written notification ’s Board of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s Trustees concerning anti-money laundering monitoring on behalf of activities and compliance exceptions, as the Trust; parties may agree from time to time; and (df) Prompt written notification of any action taken in response ensure that selling group agreements require selling group members to adopt, as applicable, reasonable anti-money laundering violations as described in (a), (b) or (c); and (e) Certified annual procedures and quarterly reports otherwise comply with applicable anti-money laundering regulations and regulatory interpretations with respect to the sale and redemption of its monitoring and customer identification activities on behalf of the TrustShares. The Trust hereby directs, represents and USBFS acknowledges, warrants that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation it will conduct its operations in accordance with the provisions of the ProceduresTrust AML Program and applicable laws, on behalf of the Trustregulations and regulatory interpretations.5. Counterparts. This Agreement may be executed in counterparts, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the Trust.each of

Anti-Money Laundering Program. The Trust Corporation acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust Corporation has determined that the Procedures, as part of the TrustCorporation’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Corporation hereby instructs and directs USBFS to implement the Procedures on the TrustCorporation’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustCorporation’s anti-money laundering responsibilities. USBFS agrees to provide to the TrustCorporation: (a) A. Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Corporation or any shareholder of the Fund; (b) B. Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Corporation agrees not to communicate this information to the customer; (c) C. Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the TrustCorporation; (d) D. Prompt written notification of any action taken in response to anti-money laundering violations as described in (aA), (bB) or (c)C) above; and (e) E. Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the TrustCorporation. The Trust Corporation hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the TrustCorporation, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the TrustCorporation.

Anti-Money Laundering Program. The Trust Company acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust Company has determined that the Procedures, as part of the TrustCompany’s overall anti-money laundering program, are reasonably designed to prevent the Fund Company from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Company hereby instructs and directs USBFS to implement the Procedures on the TrustCompany’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustCompany’s anti-money laundering responsibilities. USBFS agrees to provide to the TrustCompany: (a) A. Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Company or any shareholder of the Fund; (b) B. Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Company agrees not to communicate this information to the customer; (c) C. Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the TrustCompany; (d) D. Prompt written notification of any action taken in response to anti-money laundering violations as described in (aA), (bB) or (c)C) above; and (e) E. Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the TrustCompany. The Trust Company hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the TrustCompany, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the TrustCompany.

Anti-Money Laundering Program. The Trust acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s 's identity (collectively, the “"Procedures”"). Further, the Trust has determined that the Procedures, as part of the Trust’s 's overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBFS to implement the Procedures on the Trust’s 's behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s 's anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s 's anti-money laundering monitoring on behalf of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators to access to such information and records maintained by USBFS and relating to USBFS’s 's implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s 's implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering Program. The Trust Company acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the “Monitoring Procedures”) as well as written procedures for verifying a customer’s identity (collectivelythe “Customer Identification Procedures”), together referred to as the “Procedures”). Further, ,” and the Trust Company has determined that the Procedures, as part of the TrustCompany’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Company hereby instructs and directs USBFS to implement the Procedures on the TrustCompany’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustCompany’s anti-money laundering responsibilities. USBFS agrees to provide to the TrustCompany: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Company or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Company agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the TrustCompany; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified An annual and quarterly reports report of its monitoring and customer identification activities on un behalf of the TrustCompany. USBFS shall provide such other reports on the monitoring and customer identification activities conducted at the direction of the Company as may be agreed to from time to time by USBFS and the Company. The Trust Company hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, Procedures on behalf of the TrustCompany, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the TrustCompany.

Anti-Money Laundering Program. The Trust Company acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the “Monitoring Procedures”) as well as written procedures for verifying a customer’s identity (collectivelythe “Customer Identification Procedures”), together referred to as the “Procedures”). Further, ,” and the Trust Company has determined that the Procedures, as part of the TrustCompany’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Company hereby instructs and directs USBFS to implement the Procedures on the TrustCompany’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustCompany’s anti-money laundering responsibilities. USBFS agrees to provide to the TrustCompany: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Company or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Company agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the TrustCompany; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified An annual and quarterly reports report of its monitoring and customer identification activities on behalf of the TrustCompany. USBFS shall provide such other reports on the monitoring and customer identification activities conducted at the direction of the Company as may be agreed to from time to time by USBFS and the Company. The Trust Company hereby directs, and USBFS acknowledges, that USBFS shall shall: (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, Procedures on behalf of the TrustCompany, as they may request, ; and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the TrustCompany.

Anti-Money Laundering Program. The Trust acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the "Monitoring Procedures") as well as written procedures for verifying a customer’s 's identity (collectivelythe "Customer Identification Procedures"), together referred to as the “"Procedures”). Further, ," and the Trust has determined that the Procedures, as part of the Trust’s 's overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBFS and USBFS hereby agrees to implement the Procedures on the Trust’s 's behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s 's anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s 's anti-money laundering monitoring on behalf of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified An annual and quarterly reports report of its monitoring and customer identification activities on behalf of the Trust. USBFS shall provide such other reports on the monitoring and customer identification activities conducted at the direction of the Trust as may be agreed to from time to time by USBFS and the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s 's implementation of the Procedures, Procedures on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s 's implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering Program. The Trust acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). USBFS represents and warrants that all such tools are reasonably designed to satisfy all obligations of registered investment companies under the USA Patriot Act of 2002, related rules, and any revisions, supplements, or other changes thereto as may be promulgated from time to time. Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 and the implementing regulations thereunder. USBFS acknowledges that the Trust is relying on USBFS in making this determination. Based on this determination, the Trust hereby instructs and directs USBFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and; (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust; and (f) Annual summary letter regarding an independent audit of the Procedures. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the Trust.

Anti-Money Laundering Program. The Trust acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively's identity, the “Procedures”). Further, and the Trust has determined that the ProceduresUSBFS's procedures, as part of the Trust’s 's overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBFS to implement the Procedures its procedures on the Trust’s 's behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures USBFS's procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s 's anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Proceduresits procedures, evidence money laundering activity in connection with the Trust or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Proceduresits procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s 's anti-money laundering monitoring on behalf of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified An annual and quarterly reports report of its monitoring and customer identification activities on behalf of the Trust. USBFS shall provide such other reports on the monitoring and customer identification activities conducted at the direction of the Trust as may be agreed to from time to time by USBFS and the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s 's implementation of the Procedures, its procedures on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s 's implementation of the Procedures its procedures on behalf of the Trust.

Anti-Money Laundering Program. The Trust acknowledges that it USBFS has had an opportunity to review, consider developed and comment upon the implements written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures a program for verifying a customer’s identity (collectively, the “Procedures”). The Procedures have been established and implemented in accordance with the USA PATRIOT Act and the rules and regulations thereunder. Further, the Trust Company has reviewed and considered the Procedures and determined that the Procedures, as part of the TrustCompany’s overall anti-money laundering program, are reasonably designed to prevent the Fund Funds from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot PATRIOT Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Company hereby instructs and directs USBFS to implement the Procedures on the TrustCompany’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustCompany’s anti-money laundering responsibilities. USBFS agrees to provide to the TrustCompany: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Company or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Company agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s ’ anti-money laundering monitoring on behalf of the TrustCompany; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the TrustCompany. The Trust Company hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s ’ implementation of the Procedures, on behalf of the TrustCompany, as they may request, and (ii) permit such federal regulators to inspect USBFS’s ’ implementation of the Procedures on behalf of the TrustCompany.

Anti-Money Laundering Program. The Trust Tocqueville Funds acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the "Monitoring Procedures") as well as written procedures for verifying a customer’s 's identity (collectivelythe "Customer Identification Procedures"), together referred to as the “"Procedures”). Further, ," and the Trust Tocqueville Funds has determined that the Procedures, as part of the Trust’s Tocqueville Funds' overall anti-money laundering program, are reasonably designed to prevent the any Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Tocqueville Funds hereby instructs and directs USBFS to implement the Procedures on the Trust’s Tocqueville Funds' behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s Tocqueville Funds' anti-money laundering responsibilities. USBFS agrees to provide to the TrustTocqueville Funds: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Tocqueville Funds or any shareholder of the each Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Tocqueville Funds agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s 's anti-money laundering monitoring on behalf of the TrustTocqueville Funds; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified A certified annual and quarterly reports report of its monitoring and customer identification activities on behalf of the TrustTocqueville Funds. USBFS shall provide such other reports on the monitoring and customer identification activities conducted at the direction of the Tocqueville Funds as may be agreed to from time to time by USBFS and the Tocqueville Funds. The Trust Tocqueville Funds hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s 's implementation of the Procedures, Procedures on behalf of the TrustTocqueville Funds, as they may request, and (ii) permit such federal regulators to inspect USBFS’s 's implementation of the Procedures on behalf of the TrustTocqueville Funds.

Anti-Money Laundering Program. The Trust Each party acknowledges that it has had an opportunity is a financial institution subject to reviewthe USA PATRIOT Act of 2001 and the Bank Secrecy Act, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectivelyrequire among other things, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall financial institutions adopt anti-money laundering program(“AML”) compliance programs. Each party agrees that it will take such further steps, are 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 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 the Fund from being used for money laundering or the financing of terrorist activities and to achieve in compliance with applicable laws, regulations and regulatory interpretations. TORS undertakes that it shall (a) conduct its operations in accordance with the applicable provisions of the USA Patriot Act of 2002 Fund AML Program and 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 appropriate regulatory authorities, the Funds, and the implementing Fund’s AML Compliance Officer (the Fund’s Compliance Officer shall have no access to any of Distributor’s AML 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 AML laws, rules, regulations thereunder. Based on and regulatory interpretations with respect to the services provided under this determinationAgreement; (d) upon request, provide a copy of its AML program (or a summary of its program) to the Trust hereby instructs Fund’s AML Compliance Officer; (e) provide periodic reports to the Board concerning anti-money laundering activities and directs USBFS to implement the Procedures on the Trust’s behalfcompliance exceptions, as such the parties may be amended or revised agree from time to time. It is contemplated ; and (f) ensure that these Procedures will be amended from time selling group agreements require selling group members to time by the parties adopt, as additional applicable, reasonable AML procedures and otherwise comply with applicable AML regulations are adopted and/or and regulatory guidance is provided relating interpretations with respect to the Trust’s anti-money laundering responsibilitiessale and redemption of Shares. USBFS agrees to provide to the Trust: (a) Prompt written notification of any transaction or combination of transactions The Fund represents and warrants that USBFS believes, based on the Procedures, evidence money laundering activity it will conduct its operations in connection accordance with the Trust or any shareholder provisions of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believesFund AML Program and applicable laws, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulations and regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the Trustinterpretations.

Anti-Money Laundering Program. The Each of Distributor and the Trust acknowledges that it has had an opportunity is a financial institution subject to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 2001 and the implementing regulations thereunderBank Secrecy Act, as amended, which require among other things, that financial institutions adopt compliance programs to guard against money laundering. Based on this determination, Each of Distributor and the Trust hereby instructs agrees that it will take such further steps, and directs USBFS cooperate with the other to implement the Procedures on facilitate such compliance. The Distributor acknowledges that it is a “Covered Service Provider” as defined in the Trust’s behalfAnti- Money Laundering Program (“Trust AML Program”) and 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 represents and warrants that it has adopted policies and procedures reasonably designed to detect and prevent money laundering activities in compliance with applicable laws, as such may be amended regulations and regulatory interpretations. The Distributor undertakes that it shall (a) conduct its operations in accordance with the provisions of the Trust AML Program and applicable laws, regulations and regulatory interpretations; (b) provide access to its books, records and operations relating to its anti-money laundering compliance only with respect to the Funds, by appropriate regulatory authorities, the Funds, and the Trust’s anti-money laundering Compliance Officer (the Trust’s Compliance Officer shall have no access to any of Distributor’s anti-money laundering operations, books or revised from time records pertaining to time. It other clients of Distributor); (c) certify, in writing, no less frequently than annually, that it is contemplated that these Procedures will be amended from time in compliance with applicable anti-money laundering laws, rules, regulations and regulatory interpretations with respect to time by the parties as additional regulations are adopted and/or regulatory guidance is services provided relating 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 responsibilities. USBFS agrees to Compliance Officer; (e) provide periodic reports to the Trust: (a) Prompt written notification ’s Board of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence Trustees concerning anti- money laundering activity in connection with activities and compliance exceptions, as the Trust or any shareholder of the Fund; parties may agree from time to time; and (bf) Prompt written notification of any customer(s) ensure that USBFS reasonably believesselling group agreements require selling group members to adopt, based upon the Proceduresas applicable, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s reasonable anti-money laundering monitoring on behalf of the Trust; (d) Prompt written notification of any action taken in response to procedures and otherwise comply with applicable anti-money laundering violations as described in (a), (b) or (c); and (e) Certified annual regulations and quarterly reports regulatory interpretations with respect to the sale and redemption of its monitoring and customer identification activities on behalf of the TrustShares. The Trust hereby directs, represents and USBFS acknowledges, warrants that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation it will conduct its operations in accordance with the provisions of the ProceduresTrust AML Program and applicable laws, on behalf of the Trust, as they may request, regulations and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the Trust.regulatory interpretations. 4865-8966-2205

Anti-Money Laundering Program. The Trust Corporation acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity (the “Monitoring Procedures”) as well as written procedures for verifying a customer’s identity (collectivelythe “Customer Identification Procedures”), together referred to as the “Procedures”). Further, ,” and the Trust Corporation has determined that the Procedures, as part of the TrustCorporation’s overall anti-money laundering program, are reasonably designed to prevent the Fund from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions provision of the USA Patriot Bank Secrecy Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust Corporation hereby instructs and directs USBFS to implement the Procedures on the TrustCorporation’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the TrustCorporation’s anti-money laundering responsibilities. USBFS agrees to provide to the TrustCorporation: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Corporation or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust Corporation agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the TrustCorporation; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified An annual and quarterly reports report of its monitoring and customer identification activities on behalf of the TrustCorporation. USBFS shall provide such other reports on the monitoring and customer identification activities conducted at the direction of the Corporation as may be agreed to from time to time by USBFS and the Corporation. The Trust Corporation hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, Procedures on behalf of the TrustCorporation, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the TrustCorporation.

Anti-Money Laundering Program. The Trust AGA acknowledges that it has AGA, the Fund and the Trust have had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are that USBFS designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, AGA acknowledges that AGA, the Fund and the Trust has have determined that the Procedures, as part of the Fund’s and the Trust’s overall anti-money laundering program, are reasonably designed to prevent the Fund or the Trust from being used for money laundering or the financing of terrorist activities and to achieve compliance with the applicable provisions of the USA Patriot Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust AGA hereby instructs and directs USBFS to implement the Procedures on in respect of the Fund and the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated The parties contemplate that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Fund’s and the Trust’s anti-money laundering responsibilities. USBFS agrees to provide to AGA, the Fund and the Trust: (a1) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust Fund or any shareholder of the Fund; (b2) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity; provided, provided however, that AGA shall not identify USBFS as the Trust agrees not to communicate source this information to the customershareholder of the Fund suspected of money laundering activity without reasonable prior written notice to USBFS and unless permitted by applicable laws; (c3) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf in respect of the Fund or the Trust; (d4) Prompt written notification of any action taken in response to anti-money laundering violations as described in clauses (a1), (b2) or (c)3) above; and (e5) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf in respect of the Fund and the Trust. The Trust AGA hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators having competent jurisdiction access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the TrustFund, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the TrustFund.