Proposed change clause samples

There is also a risk that some Fund shareholders may not be in favor of a less diversified portfolio, which could result in possible investor outflows in response to the proposed change. Also, initial portfolio turnover is anticipated to be high as the Funds transition, which creates the potential for realizing capital gains (if they are not offset by capital losses). This risk may adversely impact taxable shareholders.

Response: As an initial matter, the Company hereby confirms that, prior to the change in the terms of the minimum offering requirement, no shares were sold in its offering and no subscriptions were accepted and placed in escrow. In addition, in advance of lowering the minimum offering amount, the Company reached out to each of the state securities administrators and advised them of the proposed change. To the extent states provided comments regarding the proposed change, such comments were incorporated prior to filing a supplement to the Prospectus to reflect such revised terms.