VICTORY FUNDS
Interfund Lending N-CEN Certification
Period Ending June 30, 2022

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/Sean Fox
9/12/22   DATE
Chief Compliance Officer
Victory Funds