| Return Reference | Explanation |
|---|---|
| FORM 990, PART VI, SECTION B, LINE 11B | THE FORM 990 IS ON FILE AT THE FUND OFFICE TO BE REVIEWED BY THE BOARD OF TRUSTEES. |
| PART VI, SECTION B, LINES 12 - 14 | ALTHOUGH THE FUND HAS NO FORMAL WRITTEN POLICIES ON CONFLICT OF INTEREST, WHISTLEBLOWERS AND DOCUMENT RETENTION, THE FUND IS GOVERNED BY ERISA. ERISA CONTAINS PRUDENCE AND PROHIBITED TRANSACTIONS RULES THAT, IN PRACTICE, ACT AS THE FUND'S CONFLICT OF INTEREST POLICY, RECORD RETENTION REQUIREMENTS THAT ACT AS THE FUND'S RECORD RETENTION POLICY, AND CO-FIDUCIARY REPORTING OBLIGATIONS THAT ACT AS A WHISTLEBLOWER POLICY FOR THE FUND. |
| FORM 990, PART VI, SECTION C, LINE 19 | THE FUND IS ESTABLISHED AND MAINTAINED PURSUANT TO ERISA. IT OPERATES IN COMPLIANCE WITH REPORTING REQUIREMENTS OF ITS GOVERNING DOCUMENTS AND FINANCIAL INFORMATION. NO DOCUMENTS OR FINANCIAL INFORMATION IS AVAILABLE TO THE GENERAL PUBLIC OTHER THAN THOSE FINANCIAL STATEMENTS REQUIRED TO BE DISCLOSED AS PART OF GOVERNMENTAL FILINGS. |
| FORM 990, PART XII, LINE 2C: | THE PROCESS HAS NOT CHANGED FROM THE PRIOR YEAR. |
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