USAA MUTUAL FUNDS
Interfund Lending N-CEN Certification
Period Ending July 31, 2021

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
Chief Compliance Officer
Victory Funds