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.

________________________
/s/ Randy Olson
Chief Compliance Officer
January 14, 2022