EX-99.77O RULE 10F-3 2 ex77o.txt Sun Capital Advisers Trust Rule 10f-3 Reporting Form For Quarter Ended: 3/31/2012 Subadviser Name: Goldman Sachs Asset Management, L.P. List below or attach a report showing all transactions during the quarter for which an affiliate was a member of the selling syndicate. Of attaching a separate report, please make sure that the following requested information is included. 1. Name of Purchasing Fund: SunCapital Short Duration Fund 2. Issuer: COMMONWEALTH BK AUSTR NY 3. Date of purchase: 3/5/2012 4. Underwriter from whom purchased: SAL 5. Name of affiliated underwriter managing or participating in syndicate (attach list of all members of syndicate): Goldman, Sachs & Co. 6. Aggregate principal amount of offering: 2,000,000,000 7. Aggregate principal amount of purchase: 6,150,000 by the Fund 8. Purchase price (net of fees and expenses): 99.962 9. Date offering commenced: 3/5/2012 10. Offering price at close of first day on which any sales are made: 99.962 11. Commission, spread or profit: 0.150 % $ Yes No 1. Have the following conditions been satisfied? a. The securities are either part of an issue registered under the Securities Act of 1933 which is being offered to the public or "Eligible Municipal Securities" (as defined in Rule 10f-3) or securities sold in either an Eligible Foreign Offering or Eligible Rule 144A Offering (as defined in Rule 10f-3)? ___X____ _______ b. The securities were purchased prior to the end of the first day on which any sales were made? ____X___ _______ c. The purchase price paid did not exceed the price paid by each other purchaser of securities in the offering or in any concurrent offering of the securities (except, in the case of an Eligible Foreign Offering (as defined in Rule 10f-3), for any rights to purchase that are required by law to be granted to existing security holders of the issuer) and, if the securities are offered for subscription upon exercise of rights, the securities were purchased on or before the fourth day preceding the day on which the rights offering terminated? ___X____ _______ d. The underwriting was a firm commitment underwriting? ___X____ _______ e. The commission, spread or profit was reasonable and fair in relation to that being received by others for underwriting similar securities during the same period? ___X____ _______ f. If the securities are part of an issue registered under the Securities Act of 1933 that is being offered to the public or are purchased pursuant to an Eligible Foreign Offering or an Eligible Rule 144A Offering, has the issuer of the securities been in continuous operation for not less than three years, including the operations of any predecessors? ____X___ _______ g. If the offering is other than an Eligible Rule 144A Offering, did the amount of such securities purchased by all of the investment companies advised by the Advisor and its affiliates exceed 25% of the principal amount of the offering? _______ ___X____ h. If the offering was an Eligible Rule 144A Offering, did the amount of such securities purchased by all of the investment companies advised by the Adviser exceed 25% of the total of (x) the principal amount of the offering of such class sold by members of the selling syndicate to Qualified Institutional Buyers, as defined in the Rule 144A(a)(1) under the Securities Act of 1933, plus (y) the principal amount of the offering of such class in any concurrent public offering? _______ _____X__ i. Was an affiliated underwriter, a direct or indirect participant in the sale? ____ ___ _____X__ I hereby attest that the information provided is accurate and complete to the best of my knowledge as of the date below. I will promptly report in writing to Sun Capital Advisers Trust if I become aware that any of the foregoing answers are no longer accurate. Signature: _____________________________ Date: ______________________ CCO or Designated Signor Name: _____________________________ Position: ______________________ Sun Capital Advisers Trust Rule 10f-3 Reporting Form For Quarter Ended: 3/31/2012 Subadviser Name: Goldman Sachs Asset Management, L.P. List below or attach a report showing all transactions during the quarter for which an affiliate was a member of the selling syndicate. Of attaching a separate report, please make sure that the following requested information is included. 1. Name of Purchasing Fund: SunCapital Short Duration Fund 2. Issuer: FREEPORT-MCMORAN C & G 3. Date of purchase: 2/8/12 4. Underwriter from whom purchased: BOA 5. Name of affiliated underwriter managing or participating in syndicate (attach list of all members of syndicate): Goldman, Sachs & Co. 6. Aggregate principal amount of offering: 500,000,000 7. Aggregate principal amount of purchase: 2,825,000 by the Fund 8. Purchase price (net of fees and expenses): 99.85700 9. Date offering commenced: 2/8/12 10. Offering price at close of first day on which any sales are made: 99.85700 11. Commission, spread or profit: 0.450 % $ Yes No 1. Have the following conditions been satisfied? a. The securities are either part of an issue registered under the Securities Act of 1933 which is being offered to the public or "Eligible Municipal Securities" (as defined in Rule 10f-3) or securities sold in either an Eligible Foreign Offering or Eligible Rule 144A Offering (as defined in Rule 10f-3)? ___X____ _______ b. The securities were purchased prior to the end of the first day on which any sales were made? ____X___ _______ c. The purchase price paid did not exceed the price paid by each other purchaser of securities in the offering or in any concurrent offering of the securities (except, in the case of an Eligible Foreign Offering (as defined in Rule 10f-3), for any rights to purchase that are required by law to be granted to existing security holders of the issuer) and, if the securities are offered for subscription upon exercise of rights, the securities were purchased on or before the fourth day preceding the day on which the rights offering terminated? ___X____ _______ d. The underwriting was a firm commitment underwriting? ___X____ _______ e. The commission, spread or profit was reasonable and fair in relation to that being received by others for underwriting similar securities during the same period? ___X____ _______ f. If the securities are part of an issue registered under the Securities Act of 1933 that is being offered to the public or are purchased pursuant to an Eligible Foreign Offering or an Eligible Rule 144A Offering, has the issuer of the securities been in continuous operation for not less than three years, including the operations of any predecessors? ____X___ _______ g. If the offering is other than an Eligible Rule 144A Offering, did the amount of such securities purchased by all of the investment companies advised by the Advisor and its affiliates exceed 25% of the principal amount of the offering? _______ ___X____ h. If the offering was an Eligible Rule 144A Offering, did the amount of such securities purchased by all of the investment companies advised by the Adviser exceed 25% of the total of (x) the principal amount of the offering of such class sold by members of the selling syndicate to Qualified Institutional Buyers, as defined in the Rule 144A(a)(1) under the Securities Act of 1933, plus (y) the principal amount of the offering of such class in any concurrent public offering? _______ _____X__ i. Was an affiliated underwriter, a direct or indirect participant in the sale? ____ ___ _____X__ I hereby attest that the information provided is accurate and complete to the best of my knowledge as of the date below. I will promptly report in writing to Sun Capital Advisers Trust if I become aware that any of the foregoing answers are no longer accurate. Signature: _____________________________ Date: ______________________ CCO or Designated Signor Name: _____________________________ Position: ______________________ Sun Capital Advisers Trust Rule 10f-3 Reporting Form For Quarter Ended: 3/31/2012 Subadviser Name: Goldman Sachs Asset Management, L.P. List below or attach a report showing all transactions during the quarter for which an affiliate was a member of the selling syndicate. Of attaching a separate report, please make sure that the following requested information is included. 1. Name of Purchasing Fund: SunCapital Short Duration Fund 2. Issuer: GENERAL ELEC CAP CORP 3. Date of purchase: 1/4/12 4. Underwriter from whom purchased: SAL 5. Name of affiliated underwriter managing or participating in syndicate (attach list of all members of syndicate): Goldman, Sachs & Co. 6. Aggregate principal amount of offering: 2,000,000,000 7. Aggregate principal amount of purchase: 11,775,000 by the Fund 8. Purchase price (net of fees and expenses): 99.89600 9. Date offering commenced: 1/4/12 10. Offering price at close of first day on which any sales are made: 99.89600 11. Commission, spread or profit: 0.200 % $ Yes No 1. Have the following conditions been satisfied? a. The securities are either part of an issue registered under the Securities Act of 1933 which is being offered to the public or "Eligible Municipal Securities" (as defined in Rule 10f-3) or securities sold in either an Eligible Foreign Offering or Eligible Rule 144A Offering (as defined in Rule 10f-3)? ___X____ _______ b. The securities were purchased prior to the end of the first day on which any sales were made? ____X___ _______ c. The purchase price paid did not exceed the price paid by each other purchaser of securities in the offering or in any concurrent offering of the securities (except, in the case of an Eligible Foreign Offering (as defined in Rule 10f-3), for any rights to purchase that are required by law to be granted to existing security holders of the issuer) and, if the securities are offered for subscription upon exercise of rights, the securities were purchased on or before the fourth day preceding the day on which the rights offering terminated? ___X____ _______ d. The underwriting was a firm commitment underwriting? ___X____ _______ e. The commission, spread or profit was reasonable and fair in relation to that being received by others for underwriting similar securities during the same period? ___X____ _______ f. If the securities are part of an issue registered under the Securities Act of 1933 that is being offered to the public or are purchased pursuant to an Eligible Foreign Offering or an Eligible Rule 144A Offering, has the issuer of the securities been in continuous operation for not less than three years, including the operations of any predecessors? ____X___ _______ g. If the offering is other than an Eligible Rule 144A Offering, did the amount of such securities purchased by all of the investment companies advised by the Advisor and its affiliates exceed 25% of the principal amount of the offering? _______ ___X____ h. If the offering was an Eligible Rule 144A Offering, did the amount of such securities purchased by all of the investment companies advised by the Adviser exceed 25% of the total of (x) the principal amount of the offering of such class sold by members of the selling syndicate to Qualified Institutional Buyers, as defined in the Rule 144A(a)(1) under the Securities Act of 1933, plus (y) the principal amount of the offering of such class in any concurrent public offering? _______ _____X__ i. Was an affiliated underwriter, a direct or indirect participant in the sale? ____ ___ _____X__ I hereby attest that the information provided is accurate and complete to the best of my knowledge as of the date below. I will promptly report in writing to Sun Capital Advisers Trust if I become aware that any of the foregoing answers are no longer accurate. Signature: _____________________________ Date: ______________________ CCO or Designated Signor Name: _____________________________ Position: ______________________ Sun Capital Advisers Trust Rule 10f-3 Reporting Form For Quarter Ended: 6/30/2012 Subadviser Name: Goldman Sachs Asset Management, L.P. List below or attach a report showing all transactions during the quarter for which an affiliate was a member of the selling syndicate. Of attaching a separate report, please make sure that the following requested information is included. 1. Name of Purchasing Fund: SunCapital Short Duration Fund 2. Issuer: GLAXOSMITHKLINE CAPITAL 3. Date of purchase: 5/2/2012 4. Underwriter from whom purchased: SAL 5. Name of affiliated underwriter managing or participating in syndicate (attach list of all members of syndicate): Goldman, Sachs & Co. 6. Aggregate principal amount of offering: 1,000,000,000 7. Aggregate principal amount of purchase: 3,525,000 by the Fund 8. Purchase price (net of fees and expenses): 99.746 9. Date offering commenced: 5/2/2012 10. Offering price at close of first day on which any sales are made: 99.746 11. Commission, spread or profit: 0.250 % $ Yes No 1. Have the following conditions been satisfied? a. The securities are either part of an issue registered under the Securities Act of 1933 which is being offered to the public or "Eligible Municipal Securities" (as defined in Rule 10f-3) or securities sold in either an Eligible Foreign Offering or Eligible Rule 144A Offering (as defined in Rule 10f-3)? ___X____ _______ b. The securities were purchased prior to the end of the first day on which any sales were made? ____X___ _______ c. The purchase price paid did not exceed the price paid by each other purchaser of securities in the offering or in any concurrent offering of the securities (except, in the case of an Eligible Foreign Offering (as defined in Rule 10f-3), for any rights to purchase that are required by law to be granted to existing security holders of the issuer) and, if the securities are offered for subscription upon exercise of rights, the securities were purchased on or before the fourth day preceding the day on which the rights offering terminated? ___X____ _______ d. The underwriting was a firm commitment underwriting? ___X____ _______ e. The commission, spread or profit was reasonable and fair in relation to that being received by others for underwriting similar securities during the same period? ___X____ _______ f. If the securities are part of an issue registered under the Securities Act of 1933 that is being offered to the public or are purchased pursuant to an Eligible Foreign Offering or an Eligible Rule 144A Offering, has the issuer of the securities been in continuous operation for not less than three years, including the operations of any predecessors? ____X___ _______ g. If the offering is other than an Eligible Rule 144A Offering, did the amount of such securities purchased by all of the investment companies advised by the Advisor and its affiliates exceed 25% of the principal amount of the offering? _______ ___X____ h. If the offering was an Eligible Rule 144A Offering, did the amount of such securities purchased by all of the investment companies advised by the Adviser exceed 25% of the total of (x) the principal amount of the offering of such class sold by members of the selling syndicate to Qualified Institutional Buyers, as defined in the Rule 144A(a)(1) under the Securities Act of 1933, plus (y) the principal amount of the offering of such class in any concurrent public offering? _______ _____X__ i. Was an affiliated underwriter, a direct or indirect participant in the sale? ____ ___ _____X__ I hereby attest that the information provided is accurate and complete to the best of my knowledge as of the date below. I will promptly report in writing to Sun Capital Advisers Trust if I become aware that any of the foregoing answers are no longer accurate. Signature: _____________________________ Date: ______________________ CCO or Designated Signor Name: _____________________________ Position: ______________________ Sun Capital Advisers Trust Rule 10f-3 Reporting Form For Quarter Ended: 6/30/2012 Subadviser Name: Goldman Sachs Asset Management, L.P. List below or attach a report showing all transactions during the quarter for which an affiliate was a member of the selling syndicate. Of attaching a separate report, please make sure that the following requested information is included. 1. Name of Purchasing Fund: SunCapital Short Duration Fund 2. Issuer: KRAFT FOODS GROUP INC 3. Date of purchase: 05/30/2012 4. Underwriter from whom purchased: JPMSI 5. Name of affiliated underwriter managing or participating in syndicate (attach list of all members of syndicate): Goldman, Sachs & Co. 6. Aggregate principal amount of offering: 1,000,000,000 7. Aggregate principal amount of purchase: 2,750,000 by the Fund 8. Purchase price (net of fees and expenses): 99.741 9. Date offering commenced: 05/30/2012 10. Offering price at close of first day on which any sales are made: 99.741 11. Commission, spread or profit: 0.25% $ Yes No 1. Have the following conditions been satisfied? a. The securities are either part of an issue registered under the Securities Act of 1933 which is being offered to the public or "Eligible Municipal Securities" (as defined in Rule 10f-3) or securities sold in either an Eligible Foreign Offering or Eligible Rule 144A Offering (as defined in Rule 10f-3)? ___X____ _______ b. The securities were purchased prior to the end of the first day on which any sales were made? ____X___ _______ c. The purchase price paid did not exceed the price paid by each other purchaser of securities in the offering or in any concurrent offering of the securities (except, in the case of an Eligible Foreign Offering (as defined in Rule 10f-3), for any rights to purchase that are required by law to be granted to existing security holders of the issuer) and, if the securities are offered for subscription upon exercise of rights, the securities were purchased on or before the fourth day preceding the day on which the rights offering terminated? ___X____ _______ d. The underwriting was a firm commitment underwriting? ___X____ _______ e. The commission, spread or profit was reasonable and fair in relation to that being received by others for underwriting similar securities during the same period? ___X____ _______ f. If the securities are part of an issue registered under the Securities Act of 1933 that is being offered to the public or are purchased pursuant to an Eligible Foreign Offering or an Eligible Rule 144A Offering, has the issuer of the securities been in continuous operation for not less than three years, including the operations of any predecessors? ____X___ _______ g. If the offering is other than an Eligible Rule 144A Offering, did the amount of such securities purchased by all of the investment companies advised by the Advisor and its affiliates exceed 25% of the principal amount of the offering? _______ ___X____ h. If the offering was an Eligible Rule 144A Offering, did the amount of such securities purchased by all of the investment companies advised by the Adviser exceed 25% of the total of (x) the principal amount of the offering of such class sold by members of the selling syndicate to Qualified Institutional Buyers, as defined in the Rule 144A(a)(1) under the Securities Act of 1933, plus (y) the principal amount of the offering of such class in any concurrent public offering? _______ _____X__ i. Was an affiliated underwriter, a direct or indirect participant in the sale? ____ ___ _____X__ I hereby attest that the information provided is accurate and complete to the best of my knowledge as of the date below. I will promptly report in writing to Sun Capital Advisers Trust if I become aware that any of the foregoing answers are no longer accurate. Signature: _____________________________ Date: ______________________ CCO or Designated Signor Name: _____________________________ Position: ______________________ Sun Capital Advisers Trust Rule 10f-3 Reporting Form For Quarter Ended: 3/31/2012 Subadviser Name: Goldman Sachs Asset Management, L.P. List below or attach a report showing all transactions during the quarter for which an affiliate was a member of the selling syndicate. Of attaching a separate report, please make sure that the following requested information is included. 1. Name of Purchasing Fund: SunCapital Short Duration Fund 2. Issuer: MIZUHO CORP BANK LTD 3. Date of purchase: 3/13/2012 4. Underwriter from whom purchased: MIZUHO 5. Name of affiliated underwriter managing or participating in syndicate (attach list of all members of syndicate): Goldman, Sachs & Co. 6. Aggregate principal amount of offering: 1,500,000,000 7. Aggregate principal amount of purchase: 3,900,000 by the Fund 8. Purchase price (net of fees and expenses): 99.837 9. Date offering commenced: 3/13/2012 10. Offering price at close of first day on which any sales are made: 99.837 11. Commission, spread or profit: 0.350 % $ Yes No 1. Have the following conditions been satisfied? a. The securities are either part of an issue registered under the Securities Act of 1933 which is being offered to the public or "Eligible Municipal Securities" (as defined in Rule 10f-3) or securities sold in either an Eligible Foreign Offering or Eligible Rule 144A Offering (as defined in Rule 10f-3)? ___X____ _______ b. The securities were purchased prior to the end of the first day on which any sales were made? ____X___ _______ c. The purchase price paid did not exceed the price paid by each other purchaser of securities in the offering or in any concurrent offering of the securities (except, in the case of an Eligible Foreign Offering (as defined in Rule 10f-3), for any rights to purchase that are required by law to be granted to existing security holders of the issuer) and, if the securities are offered for subscription upon exercise of rights, the securities were purchased on or before the fourth day preceding the day on which the rights offering terminated? ___X____ _______ d. The underwriting was a firm commitment underwriting? ___X____ _______ e. The commission, spread or profit was reasonable and fair in relation to that being received by others for underwriting similar securities during the same period? ___X____ _______ f. If the securities are part of an issue registered under the Securities Act of 1933 that is being offered to the public or are purchased pursuant to an Eligible Foreign Offering or an Eligible Rule 144A Offering, has the issuer of the securities been in continuous operation for not less than three years, including the operations of any predecessors? ____X___ _______ g. If the offering is other than an Eligible Rule 144A Offering, did the amount of such securities purchased by all of the investment companies advised by the Advisor and its affiliates exceed 25% of the principal amount of the offering? _______ ___X____ h. If the offering was an Eligible Rule 144A Offering, did the amount of such securities purchased by all of the investment companies advised by the Adviser exceed 25% of the total of (x) the principal amount of the offering of such class sold by members of the selling syndicate to Qualified Institutional Buyers, as defined in the Rule 144A(a)(1) under the Securities Act of 1933, plus (y) the principal amount of the offering of such class in any concurrent public offering? _______ _____X__ i. Was an affiliated underwriter, a direct or indirect participant in the sale? ____ ___ _____X__ I hereby attest that the information provided is accurate and complete to the best of my knowledge as of the date below. I will promptly report in writing to Sun Capital Advisers Trust if I become aware that any of the foregoing answers are no longer accurate. Signature: _____________________________ Date: ______________________ CCO or Designated Signor Name: _____________________________ Position: ______________________ Sun Capital Advisers Trust Rule 10f-3 Reporting Form For Quarter Ended: 6/30/2012 Subadviser Name: Goldman Sachs Asset Management, L.P. List below or attach a report showing all transactions during the quarter for which an affiliate was a member of the selling syndicate. Of attaching a separate report, please make sure that the following requested information is included. 1. Name of Purchasing Fund: SunCapital Short Duration Fund 2. Issuer: UNITED TECHNOLOGIES CORP 3. Date of purchase: 05/24/2012 4. Underwriter from whom purchased: JPMSI 5. Name of affiliated underwriter managing or participating in syndicate (attach list of all members of syndicate): Goldman, Sachs & Co. 6. Aggregate principal amount of offering: 1,000,000,000 7. Aggregate principal amount of purchase: 2,325,000 by the Fund 8. Purchase price (net of fees and expenses): 99.944 9. Date offering commenced: 05/24/2012 10. Offering price at close of first day on which any sales are made: 99.944 11. Commission, spread or profit: 0.300 % $ Yes No 1. Have the following conditions been satisfied? a. The securities are either part of an issue registered under the Securities Act of 1933 which is being offered to the public or "Eligible Municipal Securities" (as defined in Rule 10f-3) or securities sold in either an Eligible Foreign Offering or Eligible Rule 144A Offering (as defined in Rule 10f-3)? ___X____ _______ b. The securities were purchased prior to the end of the first day on which any sales were made? ____X___ _______ c. The purchase price paid did not exceed the price paid by each other purchaser of securities in the offering or in any concurrent offering of the securities (except, in the case of an Eligible Foreign Offering (as defined in Rule 10f-3), for any rights to purchase that are required by law to be granted to existing security holders of the issuer) and, if the securities are offered for subscription upon exercise of rights, the securities were purchased on or before the fourth day preceding the day on which the rights offering terminated? ___X____ _______ d. The underwriting was a firm commitment underwriting? ___X____ _______ e. The commission, spread or profit was reasonable and fair in relation to that being received by others for underwriting similar securities during the same period? ___X____ _______ f. If the securities are part of an issue registered under the Securities Act of 1933 that is being offered to the public or are purchased pursuant to an Eligible Foreign Offering or an Eligible Rule 144A Offering, has the issuer of the securities been in continuous operation for not less than three years, including the operations of any predecessors? ____X___ _______ g. If the offering is other than an Eligible Rule 144A Offering, did the amount of such securities purchased by all of the investment companies advised by the Advisor and its affiliates exceed 25% of the principal amount of the offering? _______ ___X____ h. If the offering was an Eligible Rule 144A Offering, did the amount of such securities purchased by all of the investment companies advised by the Adviser exceed 25% of the total of (x) the principal amount of the offering of such class sold by members of the selling syndicate to Qualified Institutional Buyers, as defined in the Rule 144A(a)(1) under the Securities Act of 1933, plus (y) the principal amount of the offering of such class in any concurrent public offering? _______ _____X__ i. Was an affiliated underwriter, a direct or indirect participant in the sale? ____ ___ _____X__ I hereby attest that the information provided is accurate and complete to the best of my knowledge as of the date below. I will promptly report in writing to Sun Capital Advisers Trust if I become aware that any of the foregoing answers are no longer accurate. Signature: _____________________________ Date: ______________________ CCO or Designated Signor Name: _____________________________ Position: ______________________ Sun Capital Advisers Trust Rule 10f-3 Reporting Form For Quarter Ended: 6/30/2012 Subadviser Name: Goldman Sachs Asset Management, L.P. List below or attach a report showing all transactions during the quarter for which an affiliate was a member of the selling syndicate. Of attaching a separate report, please make sure that the following requested information is included. 1. Name of Purchasing Fund: SunCapital Short Duration Fund 2. Issuer: WELLS FARGO & COMPANY 3. Date of purchase: 6/20/2012 4. Underwriter from whom purchased: WACH 5. Name of affiliated underwriter managing or participating in syndicate (attach list of all members of syndicate): Goldman, Sachs & Co. 6. Aggregate principal amount of offering: 2,000,000,000 7. Aggregate principal amount of purchase: 1,925,000 by the Fund 8. Purchase price (net of fees and expenses): 99.804 9. Date offering commenced: 6/20/2012 10. Offering price at close of first day on which any sales are made: 99.804 11. Commission, spread or profit: 0.250 % $ Yes No 1. Have the following conditions been satisfied? a. The securities are either part of an issue registered under the Securities Act of 1933 which is being offered to the public or "Eligible Municipal Securities" (as defined in Rule 10f-3) or securities sold in either an Eligible Foreign Offering or Eligible Rule 144A Offering (as defined in Rule 10f-3)? ___X____ _______ b. The securities were purchased prior to the end of the first day on which any sales were made? ____X___ _______ c. The purchase price paid did not exceed the price paid by each other purchaser of securities in the offering or in any concurrent offering of the securities (except, in the case of an Eligible Foreign Offering (as defined in Rule 10f-3), for any rights to purchase that are required by law to be granted to existing security holders of the issuer) and, if the securities are offered for subscription upon exercise of rights, the securities were purchased on or before the fourth day preceding the day on which the rights offering terminated? ___X____ _______ d. The underwriting was a firm commitment underwriting? ___X____ _______ e. The commission, spread or profit was reasonable and fair in relation to that being received by others for underwriting similar securities during the same period? ___X____ _______ f. If the securities are part of an issue registered under the Securities Act of 1933 that is being offered to the public or are purchased pursuant to an Eligible Foreign Offering or an Eligible Rule 144A Offering, has the issuer of the securities been in continuous operation for not less than three years, including the operations of any predecessors? ____X___ _______ g. If the offering is other than an Eligible Rule 144A Offering, did the amount of such securities purchased by all of the investment companies advised by the Advisor and its affiliates exceed 25% of the principal amount of the offering? _______ ___X____ h. If the offering was an Eligible Rule 144A Offering, did the amount of such securities purchased by all of the investment companies advised by the Adviser exceed 25% of the total of (x) the principal amount of the offering of such class sold by members of the selling syndicate to Qualified Institutional Buyers, as defined in the Rule 144A(a)(1) under the Securities Act of 1933, plus (y) the principal amount of the offering of such class in any concurrent public offering? _______ _____X__ i. Was an affiliated underwriter, a direct or indirect participant in the sale? ____ ___ _____X__ I hereby attest that the information provided is accurate and complete to the best of my knowledge as of the date below. I will promptly report in writing to Sun Capital Advisers Trust if I become aware that any of the foregoing answers are no longer accurate. Signature: _____________________________ Date: ______________________ CCO or Designated Signor Name: _____________________________ Position: ______________________ Sun Capital Advisers Trust Rule 10f-3 Reporting Form For Quarter Ended: 3/31/2012 Subadviser Name: Goldman Sachs Asset Management, L.P. List below or attach a report showing all transactions during the quarter for which an affiliate was a member of the selling syndicate. Of attaching a separate report, please make sure that the following requested information is included. 1. Name of Purchasing Fund: SunCapital Short Duration Fund 2. Issuer: WELLS FARGO & COMPANY 3. Date of purchase: 2/8/12 4. Underwriter from whom purchased: WACH 5. Name of affiliated underwriter managing or participating in syndicate (attach list of all members of syndicate): Goldman, Sachs & Co. 6. Aggregate principal amount of offering: 2,000,000,000 7. Aggregate principal amount of purchase: 10,125,000 by the Fund 8. Purchase price (net of fees and expenses): 99.716 9. Date offering commenced: 2/8/12 10. Offering price at close of first day on which any sales are made: 99.716 11. Commission, spread or profit: 0.250 % $ Yes No 1. Have the following conditions been satisfied? a. The securities are either part of an issue registered under the Securities Act of 1933 which is being offered to the public or "Eligible Municipal Securities" (as defined in Rule 10f-3) or securities sold in either an Eligible Foreign Offering or Eligible Rule 144A Offering (as defined in Rule 10f-3)? ___X____ _______ b. The securities were purchased prior to the end of the first day on which any sales were made? ____X___ _______ c. The purchase price paid did not exceed the price paid by each other purchaser of securities in the offering or in any concurrent offering of the securities (except, in the case of an Eligible Foreign Offering (as defined in Rule 10f-3), for any rights to purchase that are required by law to be granted to existing security holders of the issuer) and, if the securities are offered for subscription upon exercise of rights, the securities were purchased on or before the fourth day preceding the day on which the rights offering terminated? ___X____ _______ d. The underwriting was a firm commitment underwriting? ___X____ _______ e. The commission, spread or profit was reasonable and fair in relation to that being received by others for underwriting similar securities during the same period? ___X____ _______ f. If the securities are part of an issue registered under the Securities Act of 1933 that is being offered to the public or are purchased pursuant to an Eligible Foreign Offering or an Eligible Rule 144A Offering, has the issuer of the securities been in continuous operation for not less than three years, including the operations of any predecessors? ____X___ _______ g. If the offering is other than an Eligible Rule 144A Offering, did the amount of such securities purchased by all of the investment companies advised by the Advisor and its affiliates exceed 25% of the principal amount of the offering? _______ ___X____ h. If the offering was an Eligible Rule 144A Offering, did the amount of such securities purchased by all of the investment companies advised by the Adviser exceed 25% of the total of (x) the principal amount of the offering of such class sold by members of the selling syndicate to Qualified Institutional Buyers, as defined in the Rule 144A(a)(1) under the Securities Act of 1933, plus (y) the principal amount of the offering of such class in any concurrent public offering? _______ _____X__ i. Was an affiliated underwriter, a direct or indirect participant in the sale? ____ ___ _____X__ I hereby attest that the information provided is accurate and complete to the best of my knowledge as of the date below. I will promptly report in writing to Sun Capital Advisers Trust if I become aware that any of the foregoing answers are no longer accurate. Signature: _____________________________ Date: ______________________ CCO or Designated Signor Name: _____________________________ Position: ______________________ 8/24/2012 1 Rule 10f-3 Reporting Form