VICTORY PORTFOLIOS
Interfund Lending N-CEN Certification
Period Ending December 31, 2023

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
March 12, 2024
Chief Compliance Officer
Victory Funds