(b)
Not
Applicable
Item 2 – Code of Ethics – The registrant has adopted a
code of ethics, as of the end of the period covered by this report, applicable
to the registrant’s principal executive officer, principal financial officer,
principal accounting officer or controller, or persons performing similar
functions. During the
period covered by this report, the registrant has not amended the code of ethics
and there have been no waivers granted under the code of ethics. The registrant undertakes to provide a
copy of the code of ethics to any person upon request, without charge, by
calling 1-800-474-2737.
Item 3 – Audit Committee
Financial Expert – The registrant’s board of directors (the “board of
directors”), has determined that (i) the registrant has the following audit
committee financial experts serving on its audit committee and (ii) each audit
committee financial expert is independent:
Richard L. Fagnani
Laura F.
Fergerson
Under applicable securities laws, a
person determined to be an audit committee financial expert will not be deemed
an “expert” for any purpose, including without limitation for the purposes of
Section 11 of the Securities Act of 1933, as a result of being designated or
identified as an audit committee financial expert. The designation or
identification of a person as an audit committee financial expert does not
impose on such person any duties, obligations, or liabilities greater than the
duties, obligations, and liabilities imposed on such person as a member of the
audit committee and board of directors in the absence of such designation or
identification. The designation or identification of a person as an audit
committee financial expert does not affect the duties, obligations, or liability
of any other member of the audit committee or board of directors.
Item 4 – Principal Accountant Fees and
Services
The principal accountant fees disclosed
in items 4(a), 4(b), 4(c), 4(d) and 4(g) are for the one series of the
registrant for which the fiscal year-end is March 31, 2026 (the “Fund”), and
whose annual financial statements are reported in Item 1.
(a) Audit Fees – The aggregate fees billed
for each of the last two fiscal years for professional services rendered by the
principal accountant for the audit of the Fund’s annual financial statements or
services that are normally provided by the accountant in connection with
statutory and regulatory filings or engagements for those fiscal years were
$16,200 for the fiscal year ended March 31, 2025 and $16,200 for the fiscal year
ended March 31, 2026.
(b) Audit-Related Fees – There were no
fees billed for the fiscal years ended March 31, 2025 and March 31, 2026 for
assurance and related services by the principal accountant that were reasonably
related to the performance of the audit of the Fund’s financial statements and
are not reported under (a) of this Item.
(c) Tax Fees – The aggregate fees billed
in each of the last two fiscal years for professional services rendered by the
principal accountant for tax compliance, tax advice and tax planning for the
Fund were $9,700 for the fiscal year ended March 31, 2025 and $9,700 for the
fiscal year ended March 31, 2026. These services related to the review of the
Fund’s tax returns and excise tax calculations.
(d) All Other Fees – There were no other
fees billed in each of the fiscal years ended March 31, 2025 and March 31, 2026
for products and services provided by the principal accountant, other than the
services reported in (a) through (c) of this Item.
(e)(1) Audit Committee Pre-Approval
Policies and Procedures:
The registrant’s audit committee
charter, as amended, provides that the audit committee is responsible for the
approval, prior to appointment, of the engagement of the principal accountant to
annually audit and provide their opinion on the registrant’s financial
statements. The audit committee must also approve, prior to appointment, the
engagement of the principal accountant to provide non-audit services to the
registrant or to any entity controlling, controlled by or under common control
with the registrant’s investment adviser (“Adviser Affiliate”) that provides
ongoing services to the registrant, if the engagement relates directly to the
operations and financial reporting of the registrant.
(e)(2) None of the services
described in each of Items 4(b) through (d) were approved by the audit committee
pursuant to paragraph (c)(7)(i)(C) of Rule 2-01 of Regulation S-X.
(f)
Not Applicable
(g) The aggregate non-audit fees billed by
the registrant’s principal accountant for services rendered to the Fund, and
rendered to the registrant’s investment adviser, and any Adviser Affiliate that
provides ongoing services to the registrant for the last two fiscal years were
$9,700 for the fiscal year ended March 31, 2025 and $9,700 for the fiscal year ended March 31, 2026.
(h) The registrant’s audit committee has considered whether the provision of
non-audit services rendered to the registrant’s investment adviser and
any Adviser Affiliate
that provides ongoing
services to the registrant that were not pre-approved pursuant to paragraph
(c)(7)(ii) of Rule 2-01 of Regulation S-X, if any, is compatible with
maintaining the principal accountant’s independence, and has determined that the
provision of these services, if any, does not compromise the principal
accountant’s independence.
(i) Not Applicable
(j) Not Applicable
Item 5 – Audit Committee of
Listed Registrant
(a)
The following
individuals are members of the registrant’s separately designated standing
Committee established in accordance with Section 3(a)(58)(A) of the Securities
Exchange Act of 1934 (15 U.S.C. 78c(a)(58)(A)):
Richard L.
Fagnani
Laura F. Fergerson
John E. Martinez
(b)
Not
Applicable
Item 6 – Investments
(a) The registrant’s Schedule of
Investments is included as part of the Financial Statements and Financial
Highlights for Open-End Management Investment Companies filed under Item 7 of
this Form.
(b) Not applicable due to no such
divestments during the semi-annual period covered since the previous Form N-CSR
filing.
Item 7 – Financial Statements and
Financial Highlights for Open-End Management Investment Companies
(a) The registrant’s Financial Statements are attached herewith.
(b) The registrant’s Financial
Highlights are attached herewith.
