Anti-money laundering

Unusual activities in fund shares

Excessive trading in fund shares

Misuse of non-public information

Market timing-violation of policy and detection

Timely and accurate transaction reconciliation, settlement and reporting

Corporate actions checking

Called and matured securities payments checking

Pricing/valuation instances of manual pricing, if applicable

Other factors as determined by the client

Pricing/valuation instances of manual pricing, if applicable

Pricing/valuation instances of manual pricing, if applicable

Proprietary trading of the Advisor and supervised personnel, and best execution analysis,

Misuse of non-public information,

Portfolio process checking for fair and timely allocation of trades,

Unlawful transactions with affiliates,

Portfolio process decision checking for fair and timely idea allocation (e.g. detection of favoritism and cherry picking among like portfolios), and

Portfolio process checking for adherence to
a. Client investment policy
b. Investment manager process and philosophy
c. ERISA and IRS requirements
d. SEC and Treasury Department guidelines
e. Federal securities laws