October 19, 2020Nationwide Variable Insurance Trust • October 28th, 2020
You have requested our opinion as to certain federal income tax consequences of the reorganization (hereinafter referred to as the “Reorganization”), which will consist of: (i) the acquisition by the Acquiring Fund of substantially all of the property, assets and goodwill (“Assets”) of the Target Fund in exchange solely for shares of beneficial interest, without par value, of the corresponding class of shares of the Acquiring Fund listed in Exhibit A below; (ii) the assumption by the Acquiring Fund of all of the Target Fund’s Liabilities; (iii) the distribution of each class of the Acquiring Fund’s shares to the shareholders of its corresponding class of shares of the Target Fund, according to their respective interests, in complete liquidation of the Target Fund; and (iv) the liquidation and dissolution of the Target Fund as soon as practicable after the Closing, all upon and subject to the terms and conditions of the Plan. Capitalized terms not otherwise defined herein shall have the
AMENDMENT TO GLOBAL CUSTODY AGREEMENTGlobal Custody Agreement • October 28th, 2020 • Nationwide Variable Insurance Trust
This instrument, dated December 2, 2009, is between NATIONWIDE VARIABLE INSURANCE TRUST, successor in interest to GARTMORE VARIABLE INSURANCE TRUST (the "Customer"), and JPMORGAN CHASE BANK, NATIONAL ASSOCIATION (the "Bank"). It amends the Global Custody Agreement dated April 4, 2003, as supplemented, amended and restated from time to time, (the "Custody Agreement") between the Customer and the Bank. Capitalized terms in this amendment that are not defined herein have the meaning set forth in the Custody Agreement.
