In regards to the InterFund Lending Program, I certify that the Adviser on
behalf of the Funds has implemented procedures reasonably designed to
achieve compliance with the terms and conditions of the InterFund Lending
Order which includes the following objectives (a) that the InterFund Loan
rate will be higher than the Repo Rate, but lower than the Bank Loan Rate
(b) compliance with the collateral requirements as set forth in the
Application (c) Compliance with the percentage limitations on interfund
borrowing and lending (d) Allocation of the interfund borrowing and
lending demand in an equitable manner and in accordance with procedures
established by the Trustees and (e) that the InterFund Loan Rate does
not exceed the interest rate on any third-party borrowings of a borrowing
Fund at the time of the InterFund Loan.


/s/ Colin Kinney

Colin Kinney
Chief Compliance Officer
Victory Funds


February 28, 2019
Date