POS EX

As filed with the Securities and Exchange Commission on March 3, 2022

Securities Act File No. 333-258916

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, DC 20549

FORM N-14

REGISTRATION STATEMENT

UNDER

THE SECURITIES ACT OF 1933
Pre-Effective Amendment No.	☐
Post-Effective Amendment No. 1	☒

COLUMBIA FUNDS SERIES TRUST I

(Exact Name of Registrant as Specified in Charter)

290 Congress Street, Boston, Massachusetts 02210

(Address of Principal Executive Offices) (Zip Code)

Registrant’s Telephone Number, Including Area Code: (800) 345-6611

Daniel J. Beckhan c/o Columbia Management Investment Advisers, LLC 225 Congress Street Boston, Massachusetts 02210 Ryan C. Larrenaga, Esq. c/o Columbia Management Investment Advisers, LLC 290 Congress Street Boston, Massachusetts 02210

(Name and Address of Agents for Service)

The Combined Proxy Statement/Prospectus and Statement of Additional Information, each in the form filed on October 6, 2021 pursuant to Rule 497 of the General Rules and Regulations under the Securities Act of 1933, as amended (File No. 333-258916), are incorporated herein by reference.

This Post-Effective Amendment relates solely to Class A and Class Advisor (“Class Adv”) shares of the Columbia Emerging Markets Fund; Class A, Class Adv and Class Institutional 3 (“Class Inst3”) shares of the Columbia Mid Cap Growth Fund; Class A and Class Adv shares of the Columbia Total Return Bond Fund; Class A and Class Adv shares of the Columbia Corporate Income Fund; Class A and Class Adv shares of the Columbia Intermediate Municipal Bond Fund; and Class A and Class Adv shares of the Columbia Strategic Income Fund; each, a series of the Registrant. This amendment is being filed for the sole purpose of adding to Part C of the Registration Statement the executed tax opinions of Vedder Price P.C. supporting the tax matters discussed in the Combined Proxy Statement/Prospectus.

COLUMBIA FUNDS SERIES TRUST I

PART C

OTHER INFORMATION

PART C. OTHER INFORMATION

Item 15. — Indemnification

Article Five of the Bylaws of Registrant provides that Registrant shall indemnify each of its trustees and officers (including persons who serve at Registrant’s request as directors, officers or trustees of another organization in which Registrant has any interest as a shareholder, creditor or otherwise) who are not employees or officers of any investment adviser to Registrant or any affiliated person thereof and its chief compliance officer, regardless of whether such person is an employee or officer of any investment adviser to Registrant or any affiliated person thereof, and each of its other trustees and officers (including persons who serve at Registrant’s request as directors, officers or trustees of another organization in which Registrant has any interest as a shareholder, creditor or otherwise) (i.e., those who are employees or officers of any investment adviser to Registrant or any affiliated person thereof) (Covered Persons) to the fullest extent authorized by applicable law against all liabilities and expenses in connection with the defense or disposition of any proceeding in which such Covered Person may be or may have been involved or with which such Covered Person may be or may have been threatened, while in office or thereafter, by reason of any alleged act or omission as a trustee or officer or by reason of his or her being or having been such a Covered Person, all as more fully set forth in the Registrant’s Bylaws, which have been filed as an exhibit to this registration statement.

Section 17(h) of the Investment Company Act of 1940 (1940 Act) provides that no instrument pursuant to which Registrant is organized or administered shall contain any provision which protects or purports to protect any trustee or officer of Registrant against any liability to Registrant or its shareholders to which he or she would otherwise be subject by reason of willful misfeasance, bad faith, gross negligence, or reckless disregard of the duties involved in the conduct of his or her office. In accordance with Section 17(h) of the 1940 Act, no Covered Person is indemnified under the Bylaws against any liability to Registrant or its shareholders by reason of willful misfeasance, bad faith, gross negligence, or reckless disregard of the duties involved in the conduct of the Covered Person’s office.

Pursuant to the Distribution Agreement, Columbia Management Investment Distributors, Inc. agrees to indemnify the Registrant, its officers and trustees against claims, demands, liabilities and expenses under specified circumstances, all as more fully set forth in the Registrant’s Distribution Agreement, which has been filed as an exhibit to the registration statement. The Registrant may be party to other contracts that include indemnification provisions for the benefit of the Registrant’s trustees and officers.

The trustees and officers of the Registrant and the personnel of the Registrant’s investment adviser and principal underwriter are insured under an errors and omissions liability insurance policy. Registrant’s investment adviser, Columbia Management Investment Advisers, LLC, maintains investment advisory professional liability insurance to insure it, for the benefit of Registrant and its non-interested trustees, against loss arising out of any effort, omission, or breach of any duty owed to Registrant or any series of Registrant by Columbia Management Investment Advisers, LLC.

Insofar as indemnification for liabilities arising under the Securities Act of 1933 may be permitted to trustees, officers and controlling persons of the Registrant by the Registrant pursuant to the Registrant’s organizational instruments or otherwise, the Registrant is aware that in the opinion of the Securities and Exchange Commission (SEC), such indemnification is against public policy as expressed in the Securities Act of 1933 and, therefore, is unenforceable. In the event that a claim for indemnification against such liabilities (other than the payment by the Registrant of expenses incurred or paid by a director, officer or controlling person of the Registrant in the successful defense of any action, suit or proceeding) is asserted by such director, officer or controlling person in connection with the securities being registered, the Registrant will, unless in the opinion of its counsel the matter has been settled by controlling precedent, submit to a court of appropriate jurisdiction the question whether such indemnification by it is against public policy as expressed in the Securities Act of 1933 and will be governed by the final adjudication of such issue.

Item 16. Exhibits

(1) (a)(i) Second Amended and Restated Agreement and Declaration of Trust, dated August 10, 2005, is incorporated by reference to Post-Effective Amendment No. 40 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (a)(1)), filed on September 16, 2005.

(1) (a)(ii) Amendment No. 1 to Second Amended and Restated Agreement and Declaration of Trust, effective September 19, 2005, is incorporated by reference to Post-Effective Amendment No. 40 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (a)(2)), filed on September 16, 2005.

(1) (a)(iii) Amendment No. 2 to Second Amended and Restated Agreement and Declaration of Trust, effective December 13, 2017, is incorporated by reference to Post-Effective Amendment No. 313 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (a)(3)), filed on January 16, 2018.

(1) (a)(iv) Amendment No. 3 to Second Amended and Restated Agreement and Declaration of Trust, effective March 7, 2018, is incorporated by reference to Post-Effective Amendment No. 318 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (a)(4)), filed on March 29, 2018.

(1) (a)(v) Amendment No. 4 to Second Amended and Restated Agreement and Declaration of Trust, effective December 13, 2018, is incorporated by reference to Post-Effective Amendment No. 342 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (a)(5)), filed on December 21, 2018.

(1) (a)(vi) Amendment No. 5 to Second Amended and Restated Agreement and Declaration of Trust, effective June 12, 2019, is incorporated by reference to Post-Effective Amendment No. 351 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (a)(6)), filed on June 21, 2019.

(1) (a)(vii) Amendment No. 6 to Second Amended and Restated Agreement and Declaration of Trust, effective December 11, 2019, is incorporated by reference to Post-Effective Amendment No. 369 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (a)(7)), filed on December 20, 2019.

(1) (a)(viii) Amendment No. 7 to Second Amended and Restated Agreement and Declaration of Trust, effective October 9, 2020, is incorporated by reference to Post-Effective Amendment No. 383 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (a)(8)), filed on December 23, 2020.

(1) (a)(ix) Amendment No. 8 to Second Amended and Restated Agreement and Declaration of Trust, effective July 19, 2021, is incorporated by reference to Post-Effective Amendment No. 386 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (a)(9)), filed on July 28, 2021.

(2) By-Laws as amended November 2020, are incorporated by reference to Post-Effective Amendment No. 383 to Registration Statement No.  2-99356 of the Registrant on Form N-1A (Exhibit (b)), filed on December 23, 2020.

(3) Not applicable.

(4) Agreement and Plan of Reorganization is incorporated by reference to Pre-Effective Amendment No. 1 to Registration Statement No. 333-258916 of the Registrant on Form N-14, filed on October 1, 2021.

(5) Articles III and V of the Registrant’s Second Amended and Restated Declaration of Trust dated August 10, 2005 define the rights of holders of securities being registered.

(6) (a)(i) Amended and Restated Management Agreement, as of April 25, 2016, between Columbia Management Investment Advisers, LLC, Columbia Funds Variable Insurance Trust and the Registrant, is incorporated by reference to Post-Effective Amendment No. 257 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(1)), filed on April 27, 2016.

(6) (a)(ii) Schedule  A and Schedule B, effective June 15, 2021, to the Management Agreement (amended and restated), dated April 25, 2016, between Columbia Management Investment Advisers, LLC, the Registrant, and Columbia Funds Variable Insurance Trust, are incorporated by reference to Post-Effective Amendment No. 386 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(1)(i)), filed on July 28, 2021.

(6) (b)(i) Amended and Restated Management Agreement, as of October 25, 2016, between Columbia Management Investment Advisers, LLC, Columbia Funds Variable Insurance Trust and the Registrant, effective June 16, 2015, is incorporated by reference to Post-Effective Amendment No. 68 to Registration Statement No. 033-14954 of Columbia Funds Variable Insurance Trust on Form N-1A (Exhibit (d)(2)), filed on October 31, 2016.

(6) (b)(ii) Schedule  A and Schedule B, as of August 7, 2019, to the Management Agreement between Columbia Management Investment Advisers, LLC, Columbia Funds Variable Insurance Trust and the Registrant, as of October 25, 2016, are incorporated by reference to Post-Effective Amendment No. 357 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (d)(2)(i)), filed on September 3, 2019.

(7) (a)(i) Distribution Agreement by and between the Registrant, Columbia Funds Series Trust, Columbia Funds Series Trust II and Columbia Management Investment Distributors, Inc., dated June 15, 2021, is incorporated by reference to Post-Effective Amendment No. 386 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (e)(1)), filed on July 28, 2021.

(7) (a)(ii) Schedule  I, effective June 15, 2021, and Schedule II to Distribution Agreement by and between the Registrant, Columbia Funds Series Trust, Columbia Funds Series Trust II and Columbia Management Investment Distributors, Inc., dated June 15, 2021, is incorporated by reference to Post-Effective Amendment No. 386 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (e)(1)(i)), filed on July 28, 2021.

(7) (b) Form of Mutual Fund Sales Agreement is incorporated by reference to Post-Effective Amendment No. 196 to Registration Statement No. 333-131683 of Columbia Funds Series Trust II on Form N-1A (Exhibit (e)(2)) filed on June 27, 2019.

(8) Deferred Compensation Plan adopted as of December 31, 2020, is incorporated by reference to Post-Effective Amendment No. 384 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (f)), filed on February 25, 2021.

(9) (a)(i) Second Amended and Restated Master Global Custody Agreement between certain Funds and JP Morgan Chase Bank, N.A., dated March 7, 2011, is incorporated by reference to Post-Effective Amendment No. 124 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (g)(2)), filed on April 29, 2011.

(9) (a)(ii) Addendum to Master Global Custody Agreement (related to Multi-Manager Alternative Strategies Fund, Multi-Manager Total Return Bond Strategies Fund, Multi-Manager Small Cap Equity Strategies Fund and Multi-Manager Growth Strategies Fund), dated March 9, 2012 and Addendum to Master Global Custody Agreement (related to Columbia Adaptive Risk Allocation Fund), dated June 11, 2012, are incorporated by reference to Post-Effective Amendment No. 196 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (g)(2)), filed on May 30, 2014.

(9) (a)(iii) Addendum to Master Global Custody Agreement (related to Columbia Multi Strategy Alternatives Fund), dated January 15, 2015, is incorporated by reference to Post-Effective Amendment No. 221 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (g)(3)), filed on February 27, 2015.

(9) (a)(iv) Addendum to Master Global Custody Agreement (related to Columbia Multi-Asset Income Fund and Columbia U.S. Social Bond Fund), dated March 18, 2015, is incorporated by reference to Post-Effective Amendment No. 223 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (g)(4)), filed on March 24, 2015.

(9) (a)(v) Side letter (related to the China Connect Service on behalf of Columbia Emerging Markets Fund, Columbia Greater China Fund and Columbia Pacific/Asia Fund), dated March 6, 2018, to the Second Amended and Restated Master Global Custody Agreement with JP Morgan Chase Bank, N.A., dated March 7, 2011, is incorporated by reference to Post-Effective Amendment No. 318 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (g)(5)), filed on March 29, 2018.

(9) (a)(vi) Addendum to Master Global Custody Agreement (related to Multi-Manager Directional Alternative Strategies Fund), is incorporated by reference to Post-Effective Amendment No. 276 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (g)(6)), filed on September 30, 2016.

(9) (a)(vii) Addendum to Master Global Custody Agreement (related to Columbia Adaptive Retirement 2020 Fund, Columbia Adaptive Retirement 2030 Fund, Columbia Adaptive Retirement 2040 Fund, Columbia Adaptive Retirement 2050 Fund, Columbia Adaptive Retirement 2060 Fund, Columbia Solutions Aggressive Portfolio and Columbia Solutions Conservative Portfolio) is incorporated by reference to Post-Effective Amendment No. 308 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (g)(7)), filed on October 20, 2017.

(9) (a)(viii) Addendum to Master Global Custody Agreement (related to Columbia Adaptive Retirement 2025 Fund, Columbia Adaptive Retirement 2035 Fund, Columbia Adaptive Retirement 2045 Fund and Columbia Adaptive Retirement 2055 Fund) is incorporated by reference to Post-Effective Amendment No. 318 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (g)(8)), filed on March 29, 2018.

(9) (a)(ix) Addendum to Master Global Custody Agreement (related to Multi-Manager International Equity Strategies Fund) is incorporated by reference to Post-Effective Amendment No. 324 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (g)(9)), filed on May 4, 2018.

(9) (a)(x) Addendum to Master Global Custody Agreement (related to Overseas SMA Completion Portfolio) is incorporated by reference to Post-Effective Amendment No. 357 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (g)(10)), filed on September 3, 2019.

(9) (a)(xi) Addendum to Master Global Custody Agreement (related to Multisector Bond SMA Completion Portfolio), is incorporated by reference to Post-Effective Amendment No. 364 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (g)(11)), filed on October 25, 2019.

(9) (a)(xii) Addendum, effective April 1, 2016, to the Second Amended and Restated Master Global Custody Agreement with JP Morgan Chase Bank, N.A., dated March 7, 2011, is incorporated by reference to Post-Effective Amendment No. 297 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (g)(7)), filed on May 30, 2017.

(10) (a)(i) Amended and Restated Distribution Plan, as of June 15, 2021, is incorporated by reference to Post-Effective Amendment No. 386 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (m)(1)), filed on July 28, 2021.

(10) (a)(ii) Amended and Restated Shareholder Servicing Plan, as of June 15, 2021, for certain Fund share classes of the Registrant, is incorporated by reference to Post-Effective Amendment No. 386 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (m)(2)), filed on July 28, 2021.

(10) (a)(iii) Amended and Restated Shareholder Services Plan, as of July 10, 2020, for Registrant’s Class V (formerly known as Class T), is incorporated by reference to Post-Effective Amendment No. 376 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (m)(3)), filed on July 28, 2020.

(10) (b)(i) Shareholder Servicing Plan Implementation Agreement, amended and restated as of June 14, 2017, for Registrant’s Class V (formerly known as Class T) shares between the Registrant and Columbia Management Investment Distributors, Inc., is incorporated by reference to Post-Effective Amendment No. 299 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (m)(4)), filed on July 28, 2017.

(10) (b)(ii) Restated Schedule  I, effective June 15, 2021, to Shareholder Servicing Plan Implementation Agreement for Registrant’s Class V (formerly known as Class T) shares between the Registrant and Columbia Management Investment Distributors, Inc, is incorporated by reference to Post-Effective Amendment No. 386 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (m)(4)(i)), filed on July 28, 2021.

(10) (c)(i) Shareholder Servicing Plan Implementation Agreement between Registrant and Columbia Management Investment Distributors, Inc., is incorporated by reference to Post-Effective Amendment No. 82 to Registration Statement No. 333-89661 of Columbia Funds Series Trust on Form N-1A (Exhibit (m)(4)), filed on May 28, 2010.

(10) (c)(ii) Restated Schedule  I, dated June 15, 2021, to Shareholder Servicing Plan Implementation Agreement, between the Registrant, Columbia Funds Series Trust and Columbia Management Investment Distributors, Inc., is incorporated by reference to Post-Effective Amendment No. 386 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (m)(5)(i)), filed on July 28, 2021.

(10) (d) Rule 18f – 3 Multi-Class Plan, amended and restated as of June 17, 2020, is incorporated by reference to Post-Effective Amendment No. 376 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (n)), filed on July 28, 2020.

(11) Opinion and consent of Ropes & Gray LLP as to the legality of the securities being registered is incorporated by reference to Pre-Effective Amendment No. 1 to Registration Statement No. 333-258916 of the Registrant on Form N-14, filed on October 1, 2021.

(12) (a)(i) Opinion and consent of Vedder Price P.C. supporting the tax matters discussed in the Combined Proxy Statement/Prospectus, dated December 10, 2021 is filed electronically herewith.

(12) (a)(ii) Opinion and consent of Vedder Price P.C. supporting the tax matters discussed in the Combined Proxy Statement/Prospectus, dated January 21, 2022 is filed electronically herewith.

(13) (a)(i) Transfer and Dividend Disbursing Agent Agreement by and between Columbia Management Investment Services Corp., Columbia Funds Series Trust, Columbia Funds Series Trust II and the Registrant, dated June 15, 2021, is incorporated by reference to Post-Effective Amendment No. 386 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (h)(1)), filed on July 28, 2021.

(13) (a)(ii) Schedule  A and Schedule B, effective July 1, 2021, to the Transfer and Dividend Disbursing Agent Agreement by and between Columbia Management Investment Services Corp., the Registrant, Columbia Funds Series Trust and Columbia Funds Series Trust II, dated June 15, 2021, are incorporated by reference to Post-Effective Amendment No. 386 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (h)(1)(i)), filed on July 28, 2021.

(13) (b) Form of Indemnification Agreement is incorporated by reference to Post-Effective Amendment No. 46 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (h)(6)), filed on March 24, 2006.

(13) (c)(i) Fee Waiver and Expense Cap Agreement, effective June 15, 2021, between Columbia Management Investment Advisers, LLC, Columbia Management Investment Distributors, Inc., Columbia Management Investment Services Corp., the Registrant, Columbia Funds Series Trust, Columbia Funds Series Trust II, Columbia Funds Variable Insurance Trust and Columbia Funds Variable Series Trust II, is incorporated by reference to Post-Effective Amendment No. 386 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (h)(3)), filed on July 28, 2021.

(13) (c)(ii) Schedule  A, as of June 15, 2021, to the Fee Waiver and Expense Cap Agreement, effective June 15, 2021, between Columbia Management Investment Advisers, LLC, Columbia Management Investment Distributors, Inc., Columbia Management Investment Services Corp., the Registrant, Columbia Funds Series Trust, Columbia Funds Series Trust II, Columbia Funds Variable Insurance Trust and Columbia Funds Variable Series Trust II, is incorporated by reference to Post-Effective Amendment No. 386 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (h)(3)(i)), filed on July 28, 2021.

(13) (d) Agreement and Plan of Reorganization, dated October 9, 2012, is incorporated by reference to Post-Effective Amendment No. 175 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (h)(8)), filed on May 30, 2013.

(13) (e) Agreement and Plan of Reorganization, dated December 20, 2010, is incorporated by reference to Post-Effective Amendment No. 15 to Registration Statement No. 333-146374 of Columbia Funds Variable Series Trust II on Form N-1A (Exhibit (h)(9)), filed on April 29, 2011.

(13) (f) Agreement and Plan of Reorganization, dated December 17, 2015, is incorporated by reference to Registration Statement No. 333-208706 of Columbia Funds Series Trust on Form N-14 (Exhibit (4)), filed on December 22, 2015.

(13) (g) Agreement and Plan of Reorganization, dated February 20, 2020, is incorporated by reference to Registration Statement No. 333-236646 of Columbia Funds Series Trust II on Form N-14 (Exhibit (4)), filed on February 26, 2020.

(13) (h) Amended and Restated Credit Agreement, as of December 1, 2020, is incorporated by reference to Post-Effective Amendment No. 383 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (h)(8)), filed on December 23, 2020.

(13) (i)(i) Master Inter-Fund Lending Agreement, dated May 1, 2018, is incorporated by reference to Post-Effective Amendment No. 179 to Registration Statement No. 333-131683 of Columbia Funds Series Trust II on Form N-1A (Exhibit (h)(11)), filed on May 25, 2018.

(13) (i)(ii) Schedule  A and Schedule B, effective June 15, 2021, to the Master Inter-Fund Lending Agreement dated May 1, 2018, are incorporated by reference to Post-Effective Amendment No. 386 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (h)(9)(i)), filed on July 28, 2021.

(13) (j)(i) Code of Ethics of Columbia Atlantic Board Funds adopted under Rule 17j-1, effective March 2019, is incorporated by reference to Post-Effective Amendment No. 349 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (p)(1)), filed on April 25, 2019.

(13) (j)(ii) Columbia Threadneedle Investments Global Personal Account Dealing and Code of Ethics, effective December 2020, is incorporated by reference to Post-Effective Amendment No. 384 to Registration Statement No. 2-99356 of the Registrant on Form N-1A (Exhibit (p)(2)), filed on February 25, 2021.

(14) (a) Consent of Independent Registered Public Accounting Firm of Acquiring Fund (PricewaterhouseCoopers LLP) is incorporated by reference to Pre-Effective Amendment No. 1 to Registration Statement No. 333-258916 of the Registrant on Form N-14, filed on October 1, 2021.

(14) (b) Consent of Independent Registered Public Accounting Firm of Target Fund (KPMG LLP) is incorporated by reference to Pre-Effective Amendment No. 1 to Registration Statement No. 333-258916 of the Registrant on Form N-14, filed on October 1, 2021.

(15) Not applicable.

(16) Trustees’ Power of Attorney to sign this Registration Statement and all amendments hereto is incorporated by reference to Registration Statement No. 333-258916 of the Registrant on Form N-14 (Exhibit (16)) filed on August 19, 2021.

(17) Not applicable.

Item 17. Undertakings

(1) The undersigned registrant agrees that prior to any public reoffering of the securities registered through the use of a prospectus which is a part of this registration statement by any person or party who is deemed to be an underwriter within the meaning of Rule 145(c) of the Securities Act, the reoffering prospectus will contain the information called for by the applicable registration form for reofferings by persons who may be deemed underwriters, in addition to the information called for by the other items of the applicable form.

(2) The undersigned registrant agrees that every prospectus that is filed under paragraph (1) above will be filed as a part of an amendment to the registration statement and will not be used until the amendment is effective, and that, in determining any liability under the 1933 Act, each post-effective amendment shall be deemed to be a new registration statement for the securities offered therein, and the offering of the securities at that time shall be deemed to be the initial bona fide offering of them.

SIGNATURES

As required by the Securities Act of 1933, this Amendment to the Registration Statement has been signed on behalf of the Registrant, Columbia Funds Series Trust I, by the undersigned, duly authorized, in the City of Boston, and The Commonwealth of Massachusetts on the 3rd day of March, 2022.

COLUMBIA FUNDS SERIES TRUST I
By:	/s/ Daniel J. Beckman
Name: Daniel J. Beckman
Title: Trustee and President

Pursuant to the requirements of the Securities Act of 1933, this Amendment No. 1 to the Registration Statement has been signed below by the following persons in the capacities indicated on the 3rd day of March, 2022.

Signature	Capacity	Signature	Capacity
/s/ Daniel J. Beckman Daniel J. Beckman	Trustee and President (Principal Executive Officer)	/s/ Olive M. Darragh* Olive M. Darragh	Trustee
/s/ Michael G. Clarke Michael G. Clarke	Chief Financial Officer, (Principal Financial Officer) and Senior Vice President	/s/ Patricia M. Flynn* Patricia M. Flynn	Trustee
/s/ Joseph Beranek Joseph Beranek	Treasurer, Chief Accounting Officer (Principal Accounting Officer) and Principal Financial Officer	/s/ Brian J. Gallagher* Brian J. Gallagher	Trustee
/s/ Catherine James Paglia* Catherine James Paglia	Co-Chair of the Board	s/ Nancy T. Lukitsh* Nancy T. Lukitsh	Trustee
/s/ Douglas A. Hacker* Douglas A. Hacker	Co-Chair of the Board	/s/ David M. Moffett* David M. Moffett	Trustee
/s/ George S. Batejan* George S. Batejan	Trustee	/s/ Minor M. Shaw* Minor M. Shaw	Trustee
/s/ Kathleen A. Blatz* Kathleen A. Blatz	Trustee	/s/ Natalie A. Trunow* Natalie A. Trunow	Trustee
/s/ Pamela G. Carlton* Pamela G. Carlton	Trustee	/s/ Sandra Yeager* Sandra Yeager	Trustee
/s/ Janet Langford Carrig* Janet Langford Carrig	Trustee
/s/ J. Kevin Connaughton* J. Kevin Connaughton	Trustee

*  By:/s/Michael G. Clarke                        

    Name: Michael G. Clarke**
            Attorney-in-fact

** Executed by Michael G. Clarke on behalf of each of the Trustees pursuant to a Power of Attorney incorporated by reference to the Registration Statement of the Registrant on Form N-14, filed with the Commission on August 19, 2021.

EXHIBIT INDEX

Exhibit No.	Description
(12)(a)(i)	Opinion and consent of Vedder Price P.C. supporting the tax matters discussed in the Combined Proxy Statement/Prospectus, dated December 10, 2021.
(12)(a)(ii)	Opinion and consent of Vedder Price P.C. supporting the tax matters discussed in the Combined Proxy Statement/Prospectus, dated January 21, 2022.

EX-99.(12)(A)(I)

Chicago New York Washington, DC London San Francisco Los Angeles Singapore Dallas vedderprice.com

December 10, 2021

Columbia Funds Series Trust I

290 Congress Street

Boston, Massachusetts 02210

BMO Funds, Inc.

790 North Water Street, Suite 1100

Milwaukee, Wisconsin 53202

Ladies and Gentlemen:

Columbia Funds Series Trust I, a Massachusetts business trust (the “Acquiring Company”), on behalf of each of its series listed on Schedule A attached hereto and incorporated herein by reference,¹ and BMO Funds, Inc., a Wisconsin corporation (the “Target Company” and together with the Acquiring Company, each a “Company” and collectively, the “Companies”), on behalf of each of its series listed on Schedule A, have requested our opinion regarding certain federal income tax consequences of the reorganization (each a “Reorganization” and collectively, the “Reorganizations”) of each Target Fund listed on Schedule A into the Acquiring Fund listed on Schedule A opposite such Target Fund’s name.

The Reorganizations will be accomplished pursuant to an Agreement and Plan of Reorganization, dated as of October 5, 2021, entered into by the Acquiring Company, on behalf of the Acquiring Funds, and the Target Company, on behalf of the Target Funds, and for purposes of paragraphs 6.8, 10.2, 12.2 and 15 thereof only, BMO Asset Management Corp. and for purposes of paragraphs 10.2, 12.2 and 15 thereof only, Columbia Management Investment Advisers, LLC (the “Plan”). Each Reorganization contemplates the transfer of all the assets of the Target Fund to its corresponding Acquiring Fund as set forth on Schedule A solely in exchange for voting common shares of beneficial interest (“Acquisition Shares”) of the corresponding Acquiring Fund and the assumption by the corresponding Acquiring Fund of all the Obligations (as defined in the Plan) of the Target Fund. As part of each Reorganization, the Target Fund will immediately thereafter distribute pro rata, by class, to its shareholders of record all the Acquisition Shares so received in complete liquidation of the Target Fund, and the Target Fund as soon as practicable thereafter will be dissolved and terminated under applicable state law.

In rendering this opinion, we have examined the Plan and have reviewed and relied upon representations made to us by duly authorized officers of each Company, on behalf of itself and its respective Funds, in letters dated December 10, 2021 (collectively, the “Representation Letters”). We have also examined such other agreements, documents, corporate records and other materials as we have deemed necessary in order for us to render the opinions set forth in this letter. In such review and examination, we have assumed the genuineness of all signatures, the legal capacity and authority of the parties who executed such documents, the authenticity of all documents submitted to us as originals, the conformity to originals of all documents submitted to us as copies and the authenticity of the originals of such latter documents.

¹  Each series listed under the heading “Target Fund” on Schedule A is referred to herein as a “Target Fund,” each series listed under the heading “Acquiring Fund” on Schedule A is referred to herein as an “Acquiring Fund” and each Target Fund and each Acquiring Fund is referred to herein as a “Fund” and collectively, as the “Funds.”

222 North LaSalle Street | Chicago, Illinois 60601 | T +1 312 609 7500 | F +1 312 609 5005

Vedder Price P.C. is affiliated with Vedder Price LLP, which operates in England and Wales, Vedder Price (CA), LLP, which operates in California, and Vedder Price Pte. Ltd., which operates in Singapore.

Columbia Funds Series Trust I

BMO Funds, Inc.

December 10, 2021

Page 2

Our opinions are based, in part, on the assumptions that (i) each Reorganization described herein will occur in accordance with the terms of the Plan (without the waiver or modification of any terms or conditions thereof and without taking into account any amendment thereof that we have not approved) and the facts and representations set forth or referred to in this letter, and that such facts and representations, as well as the facts and representations set forth in the Plan, are true, correct and complete as of the date hereof and will be true, correct and complete as of the date and time of the Closing (as defined in the Plan) (the “Effective Time”) and (ii) any representation set forth in the Representation Letters qualified by knowledge, intention, belief, disclaimer of responsibility or any similar qualification is, and will be as of the Effective Time, true, correct and complete without such qualification. You have not requested that we undertake, and we have not undertaken, any independent investigation of the accuracy of the facts, representations and assumptions set forth or referred to herein.

For the purposes indicated above, and based upon the facts, assumptions and representations set forth or referred to herein, it is our opinion, with respect to each Reorganization, that for federal income tax purposes:

1. The transfer by the Target Fund of all its assets to its corresponding Acquiring Fund solely in exchange for Acquisition Shares of the corresponding Acquiring Fund and the assumption by the corresponding Acquiring Fund of all the Obligations of the Target Fund, immediately followed by the pro rata, by class, distribution of all the Acquisition Shares so received by the Target Fund to the Target Fund’s shareholders of record in complete liquidation of the Target Fund and the termination and dissolution of the Target Fund as soon as practicable thereafter, will constitute a “reorganization” within the meaning of section 368(a)(1) of the Internal Revenue Code of 1986, as amended (the “Code”), and the Acquiring Fund and the Target Fund will each be a “party to a reorganization,” within the meaning of section 368(b) of the Code, with respect to such Reorganization.

2. No gain or loss will be recognized by the Acquiring Fund upon the receipt of all the assets of its corresponding Target Fund solely in exchange for Acquisition Shares of such Acquiring Fund and the assumption by such Acquiring Fund of all the Obligations of the corresponding Target Fund. (Section 1032(a) of the Code).

3. No gain or loss will be recognized by the Target Fund upon the transfer of all its assets to its corresponding Acquiring Fund solely in exchange for Acquisition Shares of the corresponding Acquiring Fund and the assumption by the corresponding Acquiring Fund of all the Obligations of such Target Fund or upon the distribution (whether actual or constructive) of the Acquisition Shares so received to the Target Fund’s shareholders solely in exchange for such shareholders’ shares of the Target Fund in complete liquidation of the Target Fund. (Sections 361(a) and (c) and 357(a) of the Code).

4. No gain or loss will be recognized by the Target Fund’s shareholders upon the exchange, pursuant to the Plan, of all their shares of the Target Fund solely for Acquisition Shares of the corresponding Acquiring Fund. (Section 354(a) of the Code).

Columbia Funds Series Trust I

BMO Funds, Inc.

December 10, 2021

Page 3

5. The aggregate basis of the Acquisition Shares received by each Target Fund shareholder pursuant to the Reorganization will be the same as the aggregate basis of the Target Fund shares exchanged therefor by such shareholder. (Section 358(a)(1) of the Code).

6. The holding period of the Acquisition Shares received by each Target Fund shareholder in the Reorganization will include the period during which the shares of the Target Fund exchanged therefor were held by such shareholder, provided such Target Fund shares were held as capital assets at the Effective Time. (Section 1223(1) of the Code).

7. The basis of the assets of the Target Fund received by its corresponding Acquiring Fund will be the same as the basis of such assets in the hands of such Target Fund immediately before the Effective Time. (Section 362(b) of the Code).

8. The holding period of the assets of the Target Fund received by the corresponding Acquiring Fund will include the period during which such assets were held by such Target Fund. (Section 1223(2) of the Code).

9. The Acquiring Fund will succeed to and take into account the items of the corresponding Target Fund described in section 381(c) of the Code, subject to the conditions and limitations specified in sections 381, 382, 383 and 384 of the Code and the Income Tax Regulations thereunder. (Section 381(a) of the Code).

Notwithstanding anything to the contrary herein, we express no opinion as to the effect of the Reorganizations on a Target Fund, an Acquiring Fund or any Target Fund shareholder with respect to any asset (including without limitation any stock held in a passive foreign investment company as defined in section 1297(a) of the Code) as to which any gain or loss is required to be recognized under federal income tax principles (i) at the end of a taxable year or upon the termination thereof, or (ii) upon the transfer of such asset regardless of whether such transfer would otherwise be a non-taxable transaction under the Code.

FACTS

Our opinion is based upon the facts, representations and assumptions set forth or referred to above and the following facts and assumptions, any alteration of which could adversely affect our conclusions.

Each Company has been registered and operated, since it commenced operations, as an open-end management investment company under the Investment Company Act of 1940, as amended (the “1940 Act”). Each Fund is a separate series of its respective Company that is treated for federal income tax purposes as a separate corporation pursuant to section 851(g) of the Code. Each Fund has elected to be taxed as a regulated investment company under section 851 of the Code for all its taxable years, including without limitation the taxable year in which its respective Reorganization occurs, and has qualified and will continue to qualify for the tax treatment afforded regulated investment companies under the Code for each of its taxable years, including without limitation the taxable year in which its respective Reorganization occurs. All the outstanding shares of each Target Fund are treated as equity for federal income tax purposes. All the Acquisition Shares of each Acquiring Fund issued in a Reorganization will be treated as equity for federal income tax purposes.

Columbia Funds Series Trust I

BMO Funds, Inc.

December 10, 2021

Page 4

Upon satisfaction of certain terms and conditions set forth in the Plan on or before the Effective Time, each Acquiring Fund will acquire all the assets of its corresponding Target Fund solely in exchange for Acquisition Shares of such Acquiring Fund and the assumption by the Acquiring Fund of all the Obligations of the corresponding Target Fund. The Acquisition Shares issued to each Target Fund will have the same aggregate net asset value, as of the close of regular trading on the New York Stock Exchange on the Valuation Date (as defined in the Plan) (the “Valuation Time”), as the aggregate value of the net assets of such Target Fund transferred to its corresponding Acquiring Fund as of such time. Immediately thereafter, each Target Fund will distribute pro rata, by class, to its shareholders of record all the Acquisition Shares so received in complete liquidation of the Target Fund, and as soon as practicable thereafter, the Target Fund will be dissolved and terminated under applicable state law. The assets of each Target Fund to be acquired by its corresponding Acquiring Fund will consist of all its assets, including, without limitation, all portfolio securities and other assets that would be shown on its schedule of investments, cash, dividends and interest receivable, claims or rights of action, books and records, receivables for shares sold and all other tangible and intangible assets owned by such Target Fund, including any prepaid expenses shown as an asset on the books of such Target Fund as of the Effective Time. As set forth in the Representation Letters, in each Reorganization, the Acquiring Fund will acquire at least ninety percent (90%) of the fair market value of the corresponding Target Fund’s net assets and at least seventy percent (70%) of the fair market value of the corresponding Target Fund’s gross assets held immediately prior to the Reorganization.

As a result of each Reorganization, every shareholder of the Target Fund will own Acquisition Shares of the corresponding Acquiring Fund that will have an aggregate per share net asset value as of the Valuation Time equal to the aggregate per share net asset value of the Target Fund shares held by such shareholder as of the Valuation Time.

Following each Reorganization, the Acquiring Fund will continue its corresponding Target Fund’s historic business in that it will have a similar investment objective and similar investment strategies, policies, risks and restrictions as the Target Fund. In addition, each Acquiring Fund will use a significant portion of its corresponding Target Fund’s historic business assets in its business. Prior to the Effective Time, a portion of each Target Fund’s portfolio may have been repositioned solely due to differences in particular security selections by the portfolio managers of the Target Fund and corresponding Acquiring Fund from the securities available to the portfolio managers of both Funds consistent with the Target Fund’s investment objective, strategies, policies, risks and restrictions. At least thirty-four percent (34%) of the total fair market value of each Target Fund’s portfolio assets (i) will meet, as of the Effective Time, and (ii) met, at all times beginning two years prior to the date the Board of Directors of the Target Company approved the Reorganizations and at all times thereafter, the investment objective, strategies, policies, risks and restrictions of the corresponding Acquiring Fund (collectively, the “34% Test”). No Target Fund altered, or will alter, its portfolio in connection with its respective Reorganization to meet the 34% Test. No Fund modified any of its investment objective, strategies, policies, risks or restrictions to meet the 34% Test or in connection with its respective Reorganization. No Acquiring Fund has any plan or intention to change any of its investment objective, strategies, policies, risks or restrictions after its respective Reorganization, except as required by the 1940 Act and the rules and regulations thereunder.

The Board of Trustees of the Acquiring Company and the Board of Directors of the Target Company (each a “Board”) determined, with respect to each of its Funds participating in a Reorganization, that the Plan and the transactions contemplated thereunder are in the best interests of such Fund and that the interests of the shareholders of such Fund will not be diluted as a result of its Reorganization. In making such determination, each Board considered a number of factors as set forth under the heading “Section A-Proposals 1-6: Reorganization Proposals-Additional Information about the Reorganizations-Board. Considerations” in the Combined Proxy Statement/Prospectus dated October 5, 2021 relating to the Registration Statement (as defined below).

Columbia Funds Series Trust I

BMO Funds, Inc.

December 10, 2021

Page 5

CONCLUSION

Based on the foregoing, it is our opinion that the transfer of all the assets of a Target Fund, pursuant to the Plan, to its corresponding Acquiring Fund solely in exchange for Acquisition Shares of the corresponding Acquiring Fund and the assumption by the corresponding Acquiring Fund of all the Obligations of such Target Fund followed by the complete liquidation of such Target Fund immediately thereafter and the dissolution and termination of such Target Fund as soon as practicable thereafter will qualify as a reorganization under section 368(a)(1) of the Code.

The opinions set forth above (subject to the conditions and limitations set forth above) with respect to (i) the nonrecognition of gain or loss by a Target Fund and an Acquiring Fund, (ii) the basis and holding period of the assets received by an Acquiring Fund, (iii) the nonrecognition of gain or loss by a Target Fund’s shareholders upon the receipt of the Acquisition Shares, (iv) the basis and holding period of the Acquisition Shares received by a Target Fund’s shareholders and (v) an Acquiring Fund’s ability to succeed to and take into account the items of its corresponding Target Fund described in section 381(c) of the Code follow as a matter of law from the opinion that the transfers under the Plan will qualify as reorganizations under section 368(a)(1) of the Code.

The opinions expressed in this letter are based on the Code, the Income Tax Regulations promulgated by the Treasury Department thereunder and judicial authority reported as of the date hereof. We have also considered the positions of the Internal Revenue Service (the “Service”) reflected in published and private rulings. Although we are not aware of any pending changes to these authorities that would alter our opinions, there can be no assurances that future legislative or administrative changes, court decisions or Service interpretations will not significantly modify the statements or opinions expressed herein. We do not undertake to make any continuing analysis of the facts or relevant law following the date of this letter or to notify you of any changes to such facts or law.

Our opinions are limited to those federal income tax issues specifically considered herein. We do not express any opinion as to any other federal tax issues, or any state, local or foreign tax law issues, arising from or related to the transactions contemplated by the Plan. Although the discussion herein is based upon our best interpretation of existing sources of law and expresses what we believe a court would properly conclude if presented with these issues, no assurance can be given that such interpretations would be followed if they were to become the subject of judicial or administrative proceedings.

This opinion letter is furnished to each Fund solely for its benefit in connection with its respective Reorganization and is not to be relied upon, for any other purpose, in whole or in part, without our express prior written consent. Shareholders of each Fund may rely on this opinion letter with respect to the Reorganization involving their Fund, it being understood that we are not establishing any attorney-client relationship with any shareholder of any Fund. This opinion letter is not to be relied upon for the benefit of any other person.

Columbia Funds Series Trust I

BMO Funds, Inc.

December 10, 2021

Page 6

We hereby consent to (i) the filing of this opinion letter as an exhibit to the Registration Statement on Form N-14 (File No. 333-258916) relating to the Reorganizations with the Securities and Exchange Commission (the “Registration Statement”), (ii) to the discussion of this opinion letter in the Combined Proxy Statement/Prospectus dated October 5, 2021 relating to the Registration Statement and (iii) to the use of our name and to any reference to our firm in the Registration Statement. In giving such consent, we do not thereby admit that we are within the category of persons whose consent is required under section 7 of the Securities Act of 1933, as amended, or the rules and regulations of the Securities and Exchange Commission thereunder.

Very truly yours,

Vedder Price P.C.

SCHEDULE A

The Funds participating in each Reorganization are as follows:

Target Company	Target Fund	Acquiring Company	Acquiring Fund
BMO Funds, Inc.	BMO LGM Emerging Markets Equity Fund	Columbia Funds Series Trust I	Columbia Emerging Markets Fund
BMO Funds, Inc.	BMO Core Plus Bond Fund	Columbia Funds Series Trust I	Columbia Total Return Bond Fund
BMO Funds, Inc.	BMO Intermediate Tax-Free Fund	Columbia Funds Series Trust I	Columbia Intermediate Municipal Bond Fund
BMO Funds, Inc.	BMO Strategic Income Fund	Columbia Funds Series Trust I	Columbia Strategic Income Fund

EX-99.(12)(A)(II)

Chicago New York Washington, DC London San Francisco Los Angeles Singapore Dallas vedderprice.com

January 21, 2022

Columbia Funds Series Trust I

290 Congress Street

Boston, Massachusetts 02210

BMO Funds, Inc.

790 North Water Street, Suite 1100

Milwaukee, Wisconsin 53202

Ladies and Gentlemen:

Columbia Funds Series Trust I, a Massachusetts business trust (the “Acquiring Company”), on behalf of each of its series listed on Schedule A attached hereto and incorporated herein by reference,¹ and BMO Funds, Inc., a Wisconsin corporation (the “Target Company” and together with the Acquiring Company, each a “Company” and collectively, the “Companies”), on behalf of each of its series listed on Schedule A, have requested our opinion regarding certain federal income tax consequences of the reorganization (each a “Reorganization” and collectively, the “Reorganizations”) of each Target Fund listed on Schedule A into the Acquiring Fund listed on Schedule A opposite such Target Fund’s name.

The Reorganizations will be accomplished pursuant to an Agreement and Plan of Reorganization, dated as of October 5, 2021, entered into by the Acquiring Company, on behalf of the Acquiring Funds, and the Target Company, on behalf of the Target Funds, and for purposes of paragraphs 6.8, 10.2, 12.2 and 15 thereof only, BMO Asset Management Corp. and for purposes of paragraphs 10.2, 12.2 and 15 thereof only, Columbia Management Investment Advisers, LLC (the “Plan”). Each Reorganization contemplates the transfer of all the assets of the Target Fund to its corresponding Acquiring Fund as set forth on Schedule A solely in exchange for voting common shares of beneficial interest (“Acquisition Shares”) of the corresponding Acquiring Fund and the assumption by the corresponding Acquiring Fund of all the Obligations (as defined in the Plan) of the Target Fund. As part of each Reorganization, the Target Fund will immediately thereafter distribute pro rata, by class, to its shareholders of record all the Acquisition Shares so received in complete liquidation of the Target Fund, and the Target Fund as soon as practicable thereafter will be dissolved and terminated under applicable state law.

In rendering this opinion, we have examined the Plan and have reviewed and relied upon representations made to us by duly authorized officers of each Company, on behalf of itself and its respective Funds, in letters dated January 21, 2022 (collectively, the “Representation Letters”). We have also examined such other agreements, documents, corporate records and other materials as we have deemed necessary in order for us to render the opinions set forth in this letter. In such review and examination, we have assumed the genuineness of all signatures, the legal capacity and authority of the parties who executed such documents, the authenticity of all documents submitted to us as originals, the conformity to originals of all documents submitted to us as copies and the authenticity of the originals of such latter documents.

¹  Each series listed under the heading “Target Fund” on Schedule A is referred to herein as a “Target Fund,” each series listed under the heading “Acquiring Fund” on Schedule A is referred to herein as an “Acquiring Fund” and each Target Fund and each Acquiring Fund is referred to herein as a “Fund” and collectively, as the “Funds.”

222 North LaSalle Street | Chicago, Illinois 60601 | T +1 312 609 7500 | F +1 312 609 5005

Vedder Price P.C. is affiliated with Vedder Price LLP, which operates in England and Wales, Vedder Price (CA), LLP, which operates in California, and Vedder Price Pte. Ltd., which operates in Singapore.

Columbia Funds Series Trust I

BMO Funds, Inc.

January 21, 2022

Page 2

Our opinions are based, in part, on the assumptions that (i) each Reorganization described herein will occur in accordance with the terms of the Plan (without the waiver or modification of any terms or conditions thereof and without taking into account any amendment thereof that we have not approved) and the facts and representations set forth or referred to in this letter, and that such facts and representations, as well as the facts and representations set forth in the Plan, are true, correct and complete as of the date hereof and will be true, correct and complete as of the date and time of the Closing (as defined in the Plan) (the “Effective Time”) and (ii) any representation set forth in the Representation Letters qualified by knowledge, intention, belief, disclaimer of responsibility or any similar qualification is, and will be as of the Effective Time, true, correct and complete without such qualification. You have not requested that we undertake, and we have not undertaken, any independent investigation of the accuracy of the facts, representations and assumptions set forth or referred to herein.

For the purposes indicated above, and based upon the facts, assumptions and representations set forth or referred to herein, it is our opinion, with respect to each Reorganization, that for federal income tax purposes:

1. The transfer by the Target Fund of all its assets to its corresponding Acquiring Fund solely in exchange for Acquisition Shares of the corresponding Acquiring Fund and the assumption by the corresponding Acquiring Fund of all the Obligations of the Target Fund, immediately followed by the pro rata, by class, distribution of all the Acquisition Shares so received by the Target Fund to the Target Fund’s shareholders of record in complete liquidation of the Target Fund and the termination and dissolution of the Target Fund as soon as practicable thereafter, will constitute a “reorganization” within the meaning of section 368(a)(1) of the Internal Revenue Code of 1986, as amended (the “Code”), and the Acquiring Fund and the Target Fund will each be a “party to a reorganization,” within the meaning of section 368(b) of the Code, with respect to such Reorganization.

2. No gain or loss will be recognized by the Acquiring Fund upon the receipt of all the assets of its corresponding Target Fund solely in exchange for Acquisition Shares of such Acquiring Fund and the assumption by such Acquiring Fund of all the Obligations of the corresponding Target Fund. (Section 1032(a) of the Code).

3. No gain or loss will be recognized by the Target Fund upon the transfer of all its assets to its corresponding Acquiring Fund solely in exchange for Acquisition Shares of the corresponding Acquiring Fund and the assumption by the corresponding Acquiring Fund of all the Obligations of such Target Fund or upon the distribution (whether actual or constructive) of the Acquisition Shares so received to the Target Fund’s shareholders solely in exchange for such shareholders’ shares of the Target Fund in complete liquidation of the Target Fund. (Sections 361(a) and (c) and 357(a) of the Code).

4. No gain or loss will be recognized by the Target Fund’s shareholders upon the exchange, pursuant to the Plan, of all their shares of the Target Fund solely for Acquisition Shares of the corresponding Acquiring Fund. (Section 354(a) of the Code).

Columbia Funds Series Trust I

BMO Funds, Inc.

January 21, 2022

Page 3

5. The aggregate basis of the Acquisition Shares received by each Target Fund shareholder pursuant to the Reorganization will be the same as the aggregate basis of the Target Fund shares exchanged therefor by such shareholder. (Section 358(a)(1) of the Code).

6. The holding period of the Acquisition Shares received by each Target Fund shareholder in the Reorganization will include the period during which the shares of the Target Fund exchanged therefor were held by such shareholder, provided such Target Fund shares were held as capital assets at the Effective Time. (Section 1223(1) of the Code).

7. The basis of the assets of the Target Fund received by its corresponding Acquiring Fund will be the same as the basis of such assets in the hands of such Target Fund immediately before the Effective Time. (Section 362(b) of the Code).

8. The holding period of the assets of the Target Fund received by the corresponding Acquiring Fund will include the period during which such assets were held by such Target Fund. (Section 1223(2) of the Code).

9. The Acquiring Fund will succeed to and take into account the items of the corresponding Target Fund described in section 381(c) of the Code, subject to the conditions and limitations specified in sections 381, 382, 383 and 384 of the Code and the Income Tax Regulations thereunder. (Section 381(a) of the Code).

Notwithstanding anything to the contrary herein, we express no opinion as to the effect of the Reorganizations on a Target Fund, an Acquiring Fund or any Target Fund shareholder with respect to any asset (including without limitation any stock held in a passive foreign investment company as defined in section 1297(a) of the Code) as to which any gain or loss is required to be recognized under federal income tax principles (i) at the end of a taxable year or upon the termination thereof, or (ii) upon the transfer of such asset regardless of whether such transfer would otherwise be a non-taxable transaction under the Code.

FACTS

Our opinion is based upon the facts, representations and assumptions set forth or referred to above and the following facts and assumptions, any alteration of which could adversely affect our conclusions.

Each Company has been registered and operated, since it commenced operations, as an open-end management investment company under the Investment Company Act of 1940, as amended (the “1940 Act”). Each Fund is a separate series of its respective Company that is treated for federal income tax purposes as a separate corporation pursuant to section 851(g) of the Code. Each Fund has elected to be taxed as a regulated investment company under section 851 of the Code for all its taxable years, including without limitation the taxable year in which its respective Reorganization occurs, and has qualified and will continue to qualify for the tax treatment afforded regulated investment companies under the Code for each of its taxable years, including without limitation the taxable year in which its respective Reorganization occurs. All the outstanding shares of each Target Fund are treated as equity for federal income tax purposes. All the Acquisition Shares of each Acquiring Fund issued in a Reorganization will be treated as equity for federal income tax purposes.

Columbia Funds Series Trust I

BMO Funds, Inc.

January 21, 2022

Page 4

Upon satisfaction of certain terms and conditions set forth in the Plan on or before the Effective Time, each Acquiring Fund will acquire all the assets of its corresponding Target Fund solely in exchange for Acquisition Shares of such Acquiring Fund and the assumption by the Acquiring Fund of all the Obligations of the corresponding Target Fund. The Acquisition Shares issued to each Target Fund will have the same aggregate net asset value, as of the close of regular trading on the New York Stock Exchange on the Valuation Date (as defined in the Plan) (the “Valuation Time”), as the aggregate value of the net assets of such Target Fund transferred to its corresponding Acquiring Fund as of such time. Immediately thereafter, each Target Fund will distribute pro rata, by class, to its shareholders of record all the Acquisition Shares so received in complete liquidation of the Target Fund, and as soon as practicable thereafter, the Target Fund will be dissolved and terminated under applicable state law. The assets of each Target Fund to be acquired by its corresponding Acquiring Fund will consist of all its assets, including, without limitation, all portfolio securities and other assets that would be shown on its schedule of investments, cash, dividends and interest receivable, claims or rights of action, books and records, receivables for shares sold and all other tangible and intangible assets owned by such Target Fund, including any prepaid expenses shown as an asset on the books of such Target Fund as of the Effective Time. As set forth in the Representation Letters, in each Reorganization, the Acquiring Fund will acquire at least ninety percent (90%) of the fair market value of the corresponding Target Fund’s net assets and at least seventy percent (70%) of the fair market value of the corresponding Target Fund’s gross assets held immediately prior to the Reorganization.

As a result of each Reorganization, every shareholder of the Target Fund will own Acquisition Shares of the corresponding Acquiring Fund that will have an aggregate per share net asset value as of the Valuation Time equal to the aggregate per share net asset value of the Target Fund shares held by such shareholder as of the Valuation Time.

Following each Reorganization, the Acquiring Fund will continue its corresponding Target Fund’s historic business in that it will have a similar investment objective and similar investment strategies, policies, risks and restrictions as the Target Fund. In addition, each Acquiring Fund will use a significant portion of its corresponding Target Fund’s historic business assets in its business. Prior to the Effective Time, a portion of each Target Fund’s portfolio may have been repositioned solely due to differences in particular security selections by the portfolio managers of the Target Fund and corresponding Acquiring Fund from the securities available to the portfolio managers of both Funds consistent with the Target Fund’s investment objective, strategies, policies, risks and restrictions. At least thirty-four percent (34%) of the total fair market value of each Target Fund’s portfolio assets are invested in securities that (i) will meet, as of the Effective Time, and (ii) met, at all times beginning two years prior to the date the Board of Directors of the Target Company approved the Reorganizations and at all times thereafter, the investment objective, strategies, policies, risks and restrictions of the corresponding Acquiring Fund (collectively, the “34% Test”). Neither Target Fund altered, or will alter, its portfolio in connection with its respective Reorganization to meet the 34% Test. No Fund modified any of its investment objective, strategies, policies, risks or restrictions to meet the 34% Test or in connection with its respective Reorganization. Neither Acquiring Fund has any plan or intention to change any of its investment objective, strategies, policies, risks or restrictions after its respective Reorganization, except as required by the 1940 Act and the rules and regulations thereunder.

Columbia Funds Series Trust I

BMO Funds, Inc.

January 21, 2022

Page 5

The Board of Trustees of the Acquiring Company and the Board of Directors of the Target Company (each a “Board”) determined, with respect to each of its Funds participating in a Reorganization, that the Plan and the transactions contemplated thereunder are in the best interests of such Fund and that the interests of the shareholders of such Fund will not be diluted as a result of its Reorganization. In making such determination, each Board considered a number of factors including without limitation those set forth under the heading “Section A – Proposals 1-6: Reorganization Proposals – Additional Information about the Reorganizations – Board Considerations” in the Combined Proxy Statement/Prospectus dated October 5, 2021 relating to the Registration Statement (as defined below).

CONCLUSION

Based on the foregoing, it is our opinion that the transfer of all the assets of a Target Fund, pursuant to the Plan, to its corresponding Acquiring Fund solely in exchange for Acquisition Shares of the corresponding Acquiring Fund and the assumption by the corresponding Acquiring Fund of all the Obligations of such Target Fund followed by the complete liquidation of such Target Fund immediately thereafter and the dissolution and termination of such Target Fund as soon as practicable thereafter will qualify as a reorganization under section 368(a)(1) of the Code.

The opinions set forth above (subject to the conditions and limitations set forth above) with respect to (i) the nonrecognition of gain or loss by a Target Fund and an Acquiring Fund, (ii) the basis and holding period of the assets received by an Acquiring Fund, (iii) the nonrecognition of gain or loss by a Target Fund’s shareholders upon the receipt of the Acquisition Shares, (iv) the basis and holding period of the Acquisition Shares received by a Target Fund’s shareholders and (v) an Acquiring Fund’s ability to succeed to and take into account the items of its corresponding Target Fund described in section 381(c) of the Code follow as a matter of law from the opinion that the transfers under the Plan will qualify as reorganizations under section 368(a)(1) of the Code.

The opinions expressed in this letter are based on the Code, the Income Tax Regulations promulgated by the Treasury Department thereunder and judicial authority reported as of the date hereof. We have also considered the positions of the Internal Revenue Service (the “Service”) reflected in published and private rulings. Although we are not aware of any pending changes to these authorities that would alter our opinions, there can be no assurances that future legislative or administrative changes, court decisions or Service interpretations will not significantly modify the statements or opinions expressed herein. We do not undertake to make any continuing analysis of the facts or relevant law following the date of this letter or to notify you of any changes to such facts or law.

Our opinions are limited to those federal income tax issues specifically considered herein. We do not express any opinion as to any other federal tax issues, or any state, local or foreign tax law issues, arising from or related to the transactions contemplated by the Plan. Although the discussion herein is based upon our best interpretation of existing sources of law and expresses what we believe a court would properly conclude if presented with these issues, no assurance can be given that such interpretations would be followed if they were to become the subject of judicial or administrative proceedings.

This opinion letter is furnished to each Fund solely for its benefit in connection with its respective Reorganization and is not to be relied upon, for any other purpose, in whole or in part, without our express prior written consent. Shareholders of each Fund may rely on this opinion letter with respect to the Reorganization involving their Fund, it being understood that we are not establishing any attorney-client relationship with any shareholder of any Fund. This opinion letter is not to be relied upon for the benefit of any other person.

Columbia Funds Series Trust I

BMO Funds, Inc.

January 21, 2022

Page 6

We hereby consent to (i) the filing of this opinion letter as an exhibit to the Registration Statement on Form N-14 (File No. 333-258916) relating to the Reorganizations with the Securities and Exchange Commission (the “Registration Statement”), (ii) to the discussion of this opinion letter in the Combined Proxy Statement/Prospectus dated October 5, 2021 relating to the Registration Statement and (iii) to the use of our name and to any reference to our firm in the Registration Statement. In giving such consent, we do not thereby admit that we are within the category of persons whose consent is required under section 7 of the Securities Act of 1933, as amended, or the rules and regulations of the Securities and Exchange Commission thereunder.

Very truly yours,

Vedder Price P.C.

SCHEDULE A

The Funds participating in each Reorganization are as follows:

Target Company	Target Fund	Acquiring Company	Acquiring Fund
BMO Funds, Inc.	BMO Mid-Cap Growth Fund	Columbia Funds Series Trust I	Columbia Mid Cap Growth Fund
BMO Funds, Inc.	BMO Corporate Income Fund	Columbia Funds Series Trust I	Columbia Corporate Income Fund