FORM OF OPINION RE: TAX MATTERSDiamond Hill Funds • March 6th, 2019
Re: AGREEMENT AND PLAN OF REORGANIZATION, DATED AS OF _______________, 2019 (THE "AGREEMENT"), BY AND BETWEEN DIAMOND HILL FUNDS ("DIAMOND HILL") ON BEHALF OF ITS SERIES, DIAMOND HILL FINANCIAL LONG-SHORT FUND (THE "TRANSFERRING FUND") AND ITS SERIES, DIAMOND HILL RESEARCH OPPORTUNITIES FUND (THE "ACQUIRING FUND") AND, SOLELY FOR PURPOSES OF PARAGRAPH 5 THEREOF, DIAMOND HILL CAPITAL MANAGEMENT, INC. ("DHCM")
AGREEMENT AND PLAN OF REORGANIZATIONAgreement and Plan of Reorganization • March 6th, 2019 • Diamond Hill Funds • Ohio
THIS AGREEMENT AND PLAN OF REORGANIZATION (the “Agreement”) is made as of this fourteenth day of February, 2019 by and between Diamond Hill Funds, an Ohio business trust (the “Trust”), on behalf of Diamond Hill Financial Long-Short Fund, a series of the Trust (the “Target Fund”), and Diamond Hill Research Opportunities Fund, a series of the Trust (the “Acquiring Fund”). Diamond Hill Capital Management, Inc. (“DHCM”) joins this agreement solely for the purpose of agreeing to be bound by Paragraph 5.
