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 oneday 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.

Chief Compliance Officer
January 14, 2022