Certificate of Chief Compliance Officer
In regard to the Interfund Lending program, I certify that each
Portfolio and the Adviser have established procedures reasonably
designed to achieve compliance with the terms and conditions of
the exemptive order dated April 2, 2014, pursuant to certain
sections of the Investment Company Act of 1940. These procedures,
which have been previously approved by the Board of Directors/
Trustees of the Portfolios, include the following objectives:
(a) that the Interfund Loan Rate will be higher than the Repo
Rate, and, if applicable, the one-day yield on any money market
fund in which the lending Portfolio could otherwise invest, but
lower than the Bank Loan Rate;
(b) compliance with the collateral requirements as set forth in
the application for exemptive relief filed on September 5, 2013,
and amended on February 18, 2014;
(c) compliance with the percentage limitations on interfund
borrowing and lending;
(d) allocation of interfund borrowing and lending demand in an
equitable manner and in accordance with procedures established
by the Board; and
(e) that the Interfund Loan Rate does not exceed the interest rate
on any third-party borrowings of a borrowing Portfolio at the time
of the Interfund Loan.

________________________
Randy Olson
Chief Compliance Officer
January 3, 2023