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EXHIBIT (P)
THE VANTAGEPOINT FUNDS
VANTAGEPOINT INVESTMENT ADVISERS, LLC
ICMA-RC SERVICES, LLC
VANTAGEPOINT TRANSFER AGENTS, LLC
INSIDER TRADING POLICY UNDER RULE 17j-1 OF THE
INVESTMENT COMPANY ACT OF 1940
I. GENERAL POLICY
The Vantagepoint Funds (the "Funds") is an open-end investment company
that is registered under the Investment Company Act of 1940 (the "1940 Act").
Vantagepoint Advisers LLC ("VIA") serves as investment adviser to the Funds and
ICMA-RC Services LLC ("RC Services") serves as distributor to the Funds.
Vantagepoint Transfer Agents ("VTA") serves as transfer agent to the Funds.
VIA, VTA and RC Services are subsidiaries of the ICMA Retirement Corporation
("RC"). RC also serves as investment adviser to the ICMA Retirement Trust.
VIA, as a manager of managers, does not directly manage the
investments of the Funds, but rather hires various subadvisers to manage the
day-to-day portfolio selections of a Fund. As such, it is unlikely that an
access person, investment personnel, and associates, as defined in this policy,
would possess or have access to the knowledge that would lead to a violation of
this Insider Trading Policy.
This policy has been adopted and is intended to meet the requirements
of Rule 17j-1 of the 1940 Act, and it is based on the principle that all
persons associated with the Funds, its adviser, and principal
underwriter/distributor owe a fiduciary duty to the shareholders of the Funds
to conduct their affairs, including their personal securities transactions, in
such a manner as to avoid: (i) serving their own personal interests ahead of
the interests of the Funds' shareholders; (ii) taking advantage of their
position; and (iii) any actual or potential conflicts of interest. The rule
further requires that each investment company, its adviser(s) and its
underwriter(s) use responsible due diligence and institute procedures
reasonably expected to prevent violations of such policy.
Federal law prohibits the knowing or reckless purchase or sale of a
security by an individual based on material, non-public information. It is also
illegal to communicate such information to anyone in connection with a purchase
or sale of a security. It is the policy of the Funds that all associates (as
defined below), as well as members of the Board of Directors of the Funds and
the Board of Directors of RC, must comply with laws and regulations relating to
the use of material non-public information. If an associate or a director
acquires information as a
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result of a special or a confidential relationship with an issuer, that person
shall not communicate the information or take investment action based on such
information.
EACH PERSON SUBJECT TO THIS POLICY HEREBY AGREES TO ABIDE BY ITS TERMS.
This policy extends to all affiliates of The Vantagepoint Funds, VIA,
RC Services, and to the Trustees of the ICMA Retirement Trust to the extent that
such Trustees may, from time to time, be in a position to qualify as an Special
Purpose Investment Personnel, as defined below. The effective date of this
policy is May 20, 2000. Please direct any questions to Paul Gallagher, Vice
President and General Counsel of RC.
II. DEFINITIONS
1. FUND. Any series of The Vantagepoint Funds, collectively
referred to as the "Funds."
2. BOARD OF DIRECTORS. The Board of Directors of The
Vantagepoint Funds, individually, "Directors." The Board of
Directors of the ICMA Retirement Corporation is referred to
herein as the "RC Board." The Board of Trustees of the ICMA
Retirement Trust is referred to herein as the "Trust Board".
3. ASSOCIATE. Any employee of the ICMA Retirement Corporation
("RC") and its subsidiaries.
4. ACCESS PERSON. Any officer, director or Associate of the
Fund, VIA, VTA, RC or RC Services LLC, and any natural person
in a control relationship to the Fund who obtains information
concerning recommendations about the purchase or sale of a
security by a Fund.
5. INVESTMENT PERSONNEL. All Associates in RC's Investments
Division or Financial Operations group and/or any Access
Person who makes decisions regarding the purchase or sale of
securities for the Funds, or obtains prior or contemporaneous
information regarding the purchase or sale of securities for
the Funds through interaction with a Subadviser or otherwise.
6. SPECIAL PURPOSE INVESTMENT PERSONNEL. Any Associate or member
of the Board of Directors of either the Funds or RC or other
person who, by virtue of his or her position, may to be in a
position from time to time to obtain prior or contemporaneous
information regarding the purchase or sale of securities for
the Funds. A person is Special Purpose Investment Personnel
only with respect to securities as to which he or she has a
prior or contemporaneous information.
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7. SUBADVISER. Any individual or firm that contracts with the
Funds or with VIA to manage any portion of the Funds' assets
for compensation. Each Subadviser shall adopt an insider
trading policy pursuant to Rule 17j-1. Access Persons of each
Subadviser shall file their reports under the insider trading
policy adopted by such Subadvisers.
8. COMPLIANCE OFFICER. Such person or persons who may be
designated from time to time by the President of the Funds to
administer the provisions of this policy.
9. SECURITY. Shall have the same meaning as set forth in Section
2(a)(36) of the 1940 Act, including any stock or bond, but
does not include securities issued by the government of the
United States or any government agency, bankers' acceptances,
bank certificates of deposit, commercial paper, high quality
short-term debt instruments (including repurchase
agreements), such other money market instruments as may be
designated by the Board of Directors, and shares of open-end
investment companies. A security is "being purchased or
sold" from the time when a purchase or sale on behalf of the
Funds has been recommended, or communicated to the person who
places buy and sell orders on behalf of the Fund, by a
subadviser to the time that such transaction has been
completed or terminated.
10. BENEFICIAL OWNERSHIP. Shall be interpreted in the same manner
as it would be in determining whether a person is subject to
the provisions of Section 16 of the Securities Exchange Act
of 1934 and the rules and regulations thereunder, except that
the determination of direct or indirect beneficial ownership
shall apply to all securities (as defined herein) which a
person owns or acquires.
"Beneficial ownership" is generally understood to include
those securities from which a person enjoys some economic
benefits, which are substantially equivalent to ownership
regardless of who is the registered owner. This would
include:
(i) securities which a person holds for his or her own
benefit in bearer form, registered in his or her own
name or otherwise, regardless of whether the
securities are owned individually or jointly;
(ii) securities held in the name of his or her spouse or
minor children;
(iii) ultimate ownership rights to securities held by a
trustee, executor or administrator or by custodians,
brokers or relatives;
(iv) securities owned by a partnership or limited
liability company of which the person is a general
partner or managing member;
(v) a person's proportionate share of securities owned
through an investment club or similar organization;
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(vi) securities held by a corporation which can be
regarded as a personal holding company;
(vii) Securities recently purchased by a person and
awaiting transfer to his or her name.
11. AFFILIATES. Affiliates include the ICMA Retirement
Corporation; Vantagepoint Investment Advisers, LLC;
Vantagepoint Transfer Agents, LLC; ICMA-RC Services, LLC;
and, any subsidiaries of such companies that may be organized
in the future.
12. INITIAL PUBLIC OFFERING. An Initial Public Offering means an
offering of securities registered under the Securities and
Exchange Act of 1933, the issuer of which, immediately before
registration, was not subject to the reporting requirements
of Section 13 or Section 15(d) of the Securities Exchange Act
of 1934.
13. LIMITED OFFERINGS. A Limited Offering means an offering that
is exempt from registration under the Securities Act of 1933
pursuant to Section 4(2), Section 4(6), Rule 504, Rule 505 or
Rule 506 (e.g., private placements).
III. RESTRICTIONS ON PERSONAL SECURITIES TRANSACTIONS
When buying or selling securities Access Persons may not:
- Employ any device, scheme, or artifice to defraud the Fund
- Make to the Fund any untrue statement of a material fact or
omit to state to the Fund a material fact necessary in order
to make the statements made, in light of the circumstances
under which they are made, not misleading
- Engage in any act, practice or course of business that
operates or would operate as a fraud or deceit upon the Fund
- Engage in any manipulative practice with respect to the Fund.
A. THE FOLLOWING RESTRICTIONS SHALL APPLY SPECIFICALLY TO
INVESTMENT PERSONNEL:
1. BLACKOUT PERIODS. Investment Personnel may not
purchase or sell, directly or indirectly, any
security within 5 days before or after the time that
the same security is purchased or sold by the Funds
(subject to the exception set forth in Section IV
for index funds).
2. SHORT-TERM TRADING. Investment Personnel may not
generally realize a profit from the purchase and
sale of the same security within a period of sixty
days. It is recognized that short-term trading is
not dispositive of whether an individual is trading
on inside information. Accordingly, Investment
Personnel may apply to
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the Compliance Officer for an exception from this
provision, which will be granted if the Compliance
Officer reasonably believes that the trade is not
based on inside information and has no potential to
harm the Funds or their shareholders.
3. INITIAL PUBLIC OFFERINGS AND LIMITED OFFERINGS.
Investment Personnel shall not acquire a security in
an initial public offering or limited offering.
4. BOARDS OF DIRECTORS. Investment Personnel may not
serve on the Board of Directors of any publicly
traded company unless such service has been
previously approved by the President of RC and the
President of the Funds.
5. SHORT SALES. Investment Personnel shall not engage
in short sales of securities.
B. THE FOLLOWING RESTRICTION SHALL APPLY TO SPECIAL PURPOSE
INVESTMENT PERSONNEL:
If any such person gains actual prior or contemporaneous
knowledge of a current Fund trade, such person shall not
trade in the security or securities that are the subject of
such trade for a period of 5 days from the later of the date
such knowledge is gained and the date of the trade.
C. THE FOLLOWING RESTRICTION SHALL APPLY TO ALL ASSOCIATES WITH
RESPECT TO ANY SECURITY IN WHICH THEY HOLD RIGHTS OF
BENEFICIAL OWNERSHIP AS DEFINED HEREIN:
Associates may not purchase or sell the securities of any
company that has a substantial business relationship with the
Funds, RC, or any of their affiliates.
IV. EXEMPTED TRANSACTIONS.
The prohibitions and reporting requirements contained in this policy
shall not apply to:
1. Purchases or sales effected in any account over which the
person has no direct or indirect influence or control.
2. Purchases or sales of any open-end investment company shares.
3. Purchases or sales which are non-volitional.
4. Purchases which are part of an automatic dividend
reinvestment plan.
5. Purchases effected upon the exercise of rights issued by an
issuer pro rata to all holders of a class of securities, to
the extent that such rights were acquired from such issuer,
and sales of such rights so acquired.
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6. Purchases and sales of securities corresponding with
purchases and sales of the same securities by a Vantagepoint
index fund.
7. Any purchase or sale of securities which has been determined,
upon investigation by the Compliance Officer, to present no
reasonable likelihood or potential for harm to the Funds or
their shareholders.
8. Any purchase or sale involving $1,000 or less.
V. PRIOR APPROVAL AND REPORTING
This policy recognizes the fact that The Vantagepoint Funds employ a
subadvisory structure in which all investment decisions are made by
non-affiliated subadvisers, and that Associates are not responsible for placing
buy and sell orders on behalf of the Funds.
In addition to the specific requirements set forth above, the
following requirements shall apply to securities transactions by Access
Persons, Associates, Investment Personnel and Special Purpose Investment
Personnel, as noted:
1. PRIOR APPROVAL. Investment Personnel shall receive prior
approval from the Compliance Officer before purchasing or
selling securities.
2. REPORTING.
(i) Access Persons and Investment Personnel shall report
all personal securities holdings and any securities
accounts they maintain or is maintained on their
behalf to the Compliance Officer as of the effective
date of this policy and, thereafter, on an annual
basis as of December 31.
(ii) Every person covered by this policy shall certify
annually that they have read and understand this
policy; that they have complied with its
requirements; and that they have reported all
securities transactions required to be reported
pursuant to this policy.
(iii) Access Persons and Investment Personnel shall file a
report with the Compliance Officer within 10 days of
the end of each calendar quarter. Such report shall
include the following: name of the Security; the
number of shares or principal amount, maturity date
and interest rate, if applicable; the date of the
transaction; the nature of the transaction
(i.e.purchase or sale); the price at which the
transaction was effected; and the name of the broker
or dealer with or through whom the transaction was
effected. Access Persons and Investment Personnel
will also report any securities accounts established
by them or on their behalf during the past calendar
quarter.
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(iv) Independent Directors of the Funds, as that term is
defined in the 1940 Act, and members of the RC Board
and Trust Board who are not also employees of RC,
shall report transactions under this Policy on a
quarterly basis only if they knew at the time of the
transaction or should have known that during the 15
day period immediately preceding or following the
date of the transaction the same security was
purchased or sold or was being considered for
purchase or sale by a Fund. The "should have known"
standard does not imply: a duty of inquiry; presume
that an independent director can deduce or
extrapolate from presentations or discussions about
Fund strategies; or impute knowledge from awareness
of a Fund's holdings, policies, objectives, and
restrictions.
VI. BOARD REVIEW
1. The President of the Funds shall report all violations of
this policy to the Board of Directors, the RC Board and to
the Trust Board at the board meeting following such
violation.
2. An annual report relating to this policy shall be presented
to the Board of Directors, the RC Board, and the Trust Board,
and such report shall:
(i) summarize existing procedures concerning
personal investing and any changes in the
procedures made during the year. Identify
any violations requiring significant
remedial action during the past year; and
(ii) identify any recommended changes in
existing restrictions or procedures based
on the Funds' experience under this policy,
evolving industry practices, or
developments in applicable laws or
regulations.
3. VIA and RC shall certify annually to the Directors of the
Funds that each has adopted procedures reasonably necessary
to prevent its investment personnel from violating the
provisions of this policy.
4. Each subadviser shall submit a copy of its insider trading
policy for the Directors' approval. Each subadviser shall
also furnish to the Directors of the Funds a written report
of any issues arising under its policy, including any
material violations and any sanctions imposed in response to
these violations. Each subadviser will also certify annually
that it has adopted procedures reasonably necessary to
prevent its access persons from violating the provisions of
its insider trading policy.
VIII. SANCTIONS
Upon discovering a violation of this policy, the President of the
Funds, VIA or RC may impose such sanctions as they deem appropriate, including
but not limited to, forfeiture of profits, a letter of censure, or suspension
or termination from employment.
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IX. RETENTION OF RECORDS
This policy, a copy of each required report filed, any written report
relating to the interpretation of this policy, or violations hereunder, shall
be preserved with the records of the Funds for the period required by Rule
17j-1, as amended.
Dated: May 20, 2000
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EXHIBIT A
ICMA RETIREMENT CORPORATION
THE VANTAGEPOINT FUNDS
INSIDER TRADING POLICY
I. INTRODUCTION
The Vantagepoint Funds ("Funds"), its adviser, Vantagepoint Investment
Advisers, LLC ("VIA"), and its underwriter, ICMA-RC Services, LLC ("RC
Services"), its transfer agent, Vantagepoint Transfer Agents, LLC ("VTA") and
the ICMA Retirement Corporation ("RC") are confident that its officers,
directors, and other persons involved with the Fund's business act with
integrity and good faith. The Insider Trading Policy (the "Policy") that has
been adopted by the Board of Directors of each of these entities is designed to
address situations in which personal interests may conflict with the Fund's
interests where officers, directors, and certain other persons: know about the
Fund's present or future portfolio transactions; or have the power to influence
the Fund's portfolio transactions; and engage in securities transactions in
their personal account(s).
In an effort to prevent conflicts of interest from arising, and in
accordance with Rule 17j-1 under the Investment Company of 1940, the Fund, VIA,
VTA, RC and RC-Services have adopted the Policy to address transactions and
conduct that may create conflicts of interest, establish reporting
requirements, and create enforcement procedures.
II. IDENTIFICATION OF ACCESS PERSONS & INVESTMENT PERSONNEL
MAINTENANCE OF LIST OF ACCESS PERSONS AND INVESTMENT PERSONNEL
BROKERAGE STATEMENTS AND TRANSACTION CONFIRMS
1. WHO IS AN ASSOCIATE?
An Associate is any employee of RC and its subsidiaries.
2. WHO IS AN ACCESS PERSON?
An Access Person is any Officer, Director or Associate (see
above) of the Fund, VIA, VTA, RC or RC Services and any
natural person in a control relationship to the Fund who
obtains prior or contemporaneous information concerning
recommendations about the purchase or sale of a security by a
Fund.
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3. WHO ARE INVESTMENT PERSONNEL?
Investment Personnel (referred to individually as "Investment
Persons") are all Associates in RC's Investment Division or
Financial Operations group. Investment Personnel also include
any Access Person who makes decisions regarding the purchase
or sale of securities for the Funds, or obtains prior or
contemporaneous information regarding the purchase or sale of
securities for the Funds.
4. WHAT IS THE LIST OF ACCESS PERSONS AND INVESTMENT PERSONNEL?
A list of all Access Persons and Investment Personnel will be
maintained and updated by the Review Officer. This list will
include the name, position, department, date the person
became an Access Person and/or Investment Person and the date
the person was no longer required to report under the Policy
(if applicable).
5. WHO IS RESPONSIBLE FOR THIS LIST?
The Review Officer or designee will maintain this list at all
times. A representative of RC's Human Resources department
will contact the Review Officer immediately when action is
taken that would cause an Associate to become an Access
Person and/or Investment Personnel.
III. INITIAL AND ANNUAL HOLDINGS REPORTS
1. WHO HAS TO COMPLETE A REPORT?
Each Access Person and Investment Person to the Fund, VIA, RC
or RC Services as defined by the Policy, must complete a
report.
2. HOW DO I GET THE REPORT?
The Review Officer will forward an annual report form to all
Access and Investment Personnel prior to December 31st of
each year. (See Appendix for example)
You will also receive a holdings report form for completion
within 10 days following your identification as an Access
Person or Investment Person as a result of hire or department
transfer.
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3. WHAT DO I HAVE TO REPORT?
You must report all securities you beneficially own. This
annual disclosure of holdings should be calculated as of
December 31st.
You must also report all securities accounts you have opened
and maintained or that have been opened and are maintained on
your behalf since you became obligated to report under the
Policy. Account information must included the name of the
broker-dealers or banks at which the accounts are held and
the name of each owner of the accounts. Your report should
include information up to and including December 31st.
4. WHAT DON'T I HAVE TO REPORT?
Purchases or sales effected in any account over which you have no
direct or indirect influence or control.
Purchases or sales of any open-end investment company shares.
Purchases or sales which are non-volitional.
Purchases which are part of an automatic dividend reinvestment
plan.
Purchases effected upon the exercise of rights issued by an issuer
pro rata to all holders of a class of securities, to the extent
that such rights were acquired from such issuer, and sales of such
rights so acquired.
Any purchase or sale of securities which has been determined, upon
investigation by the General Counsel of RC or his designee, to
present no reasonable likelihood or potential for harm to the Funds
or their shareholders.
Any purchase or sale involving $1,000 or less.
5. WHEN IS THE REPORT DUE?
The report is due within 10 days after December 31st.
6. TO WHOM DO I RETURN THE REPORT?
The report should be returned to the Review Officer.
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IV. QUARTERLY REPORTS
1. WHO HAS TO COMPLETE A QUARTERLY REPORT?
Each Access Person and Investment Person to the Fund, VIA,
VTA, RC or RC Services, as defined by the Policy, must
complete a report.
2. HOW DO I GET A REPORT?
The Review Officer will send out a report form on the last
day of each calendar quarter. (See Appendix)
3. WHAT DO I HAVE TO REPORT?
You must report all securities you purchased or sold during
the past calendar quarter. You must also report any accounts
you established during the previous quarter in which
securities were held for your direct or indirect benefit.
Account information must include the broker-dealer or bank
where the account was opened and the name of each owner of
the account.
4. WHAT DON'T I HAVE TO REPORT?
Purchases or sales effected in any account over which you have no
direct or indirect influence or control.
Purchases or sales of any open-end investment company shares.
Purchases or sales which are non-volitional.
Purchases which are part of an automatic dividend reinvestment
plan.
Purchases effected upon the exercise of rights issued by an issuer
pro rata to all holders of a class of securities, to the extent
that such rights were acquired from such issuer, and sales of such
rights so acquired.
Any purchase or sale of securities which has been determined, upon
investigation by the General Counsel of RC, to present no
reasonable likelihood or potential for harm to the Funds or their
shareholders.
Any purchase or sale involving $1,000 or less.
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5. WHEN IS THE REPORT DUE?
All reports are due within 10 days after the end of the
calendar quarter.
6. TO WHOM DO I RETURN THE REPORT?
The report should be returned to the Review Officer.
V. PRIOR APPROVAL PROCEDURES
1. WHO IS REQUIRED TO OBTAIN PRIOR APPROVAL?
Investment Personnel are required to obtain prior approval
before they purchase or sell securities.
2. WHAT SECURITIES ARE NOT SUBJECT TO PRIOR APPROVAL?
Prior approval is not required before purchasing or selling
the following:
securities issued by the US government or its agencies
banker's acceptances
bank certificates or deposit
commercial paper
high quality short-term debt instruments
mutual fund shares
3. WHO DO I CONTACT FOR PRIOR APPROVAL?
You must contact the Review Officer with a request for prior
approval to purchase or sell a security. You may contact the
Review Officer by sending an e-mail to Katurah Harris(1) at
the Insider Trading address.
Your request for prior approval must include your name, the
date of the transaction, the name and ticker symbol of the
security and whether you intend to purchase or sell.
4. WHEN DO I HAVE TO RECEIVE PRIOR APPROVAL AND HOW LONG DOES IT
LAST?
You must receive prior approval before each securities
transaction. Prior approval is valid only on the date it is
received.
5. IF PRIOR APPROVAL IS DENIED, WHEN CAN I RESUBMIT MY REQUEST?
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(1) Alternate reviewers are Norma Richardson, Jan Feldman and Paul Gallagher
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You will be informed by the Review Officer of the earliest
date that you may reapply. You cannot transact in any security
that a Fund has purchased or sold within five days of your
request. However, purchases and sales of securities
corresponding with purchases and sales of the same securities
by a Vantagepoint Index Fund are not subject to this
restriction.
6. WHO KEEPS THE PRIOR APPROVAL RECORDS AND ARE THEY
CONFIDENTIAL?
Prior approval records are maintained by the Review Officer
and are confidential. Prior approval records will be reviewed
and compared to the Quarterly Transaction Reports required
under Section IV of these procedures. Failure to obtain prior
approval is considered a violation of the Policy and can
result in sanctions.
VI. TRAINING, CERTIFICATION AND ACKNOWLEDGEMENTS
1. NEW ASSOCIATE TRAINING
Each new Associate will receive a copy of the Policy and
these procedures within 10 days of their hire. Each new
Associate will be asked to certify and acknowledge the
receipt and understanding of the policy and these procedures.
2. ANNUAL TRAINING, ACKNOWLEDGEMENT AND CERTIFICATION
Each Access Person and Investment Person will be required to
attend a training session to be held annually during the
month of May. At this session the policy, procedures and any
amendments will be discussed. Each Access Person will be
required to sign an annual certification and acknowledgement
of the policy and these procedures.
3. DUPLICATE SECURITIES ACCOUNT STATEMENTS
Each person identified as an Access Person and/or Investment Personnel is
required to request that duplicate securities account statements and confirms
be forwarded by their broker-dealer to the attention of the Review Officer at
the address of the firm. (See Appendix)
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VII. VIOLATION & SANCTIONS
1. WHAT WOULD HAPPEN IF I VIOLATE THE POLICY?
Report forms are regularly reviewed to determine whether the
Policy has been violated. Upon discovery of a violation, THE
PRESIDENT of the Fund is notified and sanctions may be
imposed as deemed appropriate. You will be provided with an
opportunity to provide explanatory information relating to
any transaction that appears to be a violation of the Policy.
No one will be required to participate in a determination of
whether he or she has committed a violation or discuss the
imposition of any sanction against himself or herself.
2. WHAT SANCTIONS ARE AVAILABLE?
Sanctions may include, but are not limited to, forfeiture of
profits, a letter of censure, suspension or termination from
employment.
VIII. THE REVIEW OFFICER
1. WHO IS THE REVIEW OFFICER?
Katurah Harris has served as Review Officer since 1999.
2. WHAT ARE THE REVIEW OFFICER'S DUTIES:
Distributing and collecting Annual Holdings Reports
Distributing and collecting Quarterly Transaction Reports
Processing requests for prior approval of securities transactions
Reviewing transaction reports and reconciling these reports against
Fund records and prior approval records to determine whether a
violation has occurred
It shall be the responsibility of RC's General Counsel to report on a
quarterly basis to the President of the Fund and the Chief Executive
Officer of RC whether any violations have occurred.
IX. RECORDKEEPING REQUIREMENTS
The following records will be maintained at 777 North Capitol Street, NE,
Washington, DC 20002, the Fund's principal place of business.
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These records include:
A. A record of each Insider Trading Policy adopted under Rule
17j-1, that is currently in effect, or at any time within the
past five years was in effect.
B. A record of any violation of the Policy and any action taken
as a result of that violation for at least five years after
the end of the fiscal year in which the violation occurred.
C. A copy of each quarterly report submitted under the policy
will be maintained for at least five years after the end of
the fiscal year in which the report was made, the most recent
two years in an easily accessible place.
D. A copy of each initial and annual holdings report and
certifications submitted under the Policy will be maintained
for at least five years after the end of the fiscal year in
which the report was made, the most recent two years in a
readily accessible place.
E. A record of all Access Persons, currently or within the past
five years, who are or were required to submit reports under
the policy.
F. A record of the name of each Review Officer and the General
Counsel, currently or within the past five years, who are or
were responsible for reviewing reports submitted under the
policy.
G. A copy of each annual report and certification presented to
the Board of Directors of the Funds for a period of five
years, the most recent two years in a readily acceptable
place.
H. A record of all prior approval decisions approving the
acquisition by Access Persons of securities, including IPOs
and private placements, for the past five years.
