X0405TA-1/A0001562770XXXXXXXX084-06485trueLIVESECVirtus Fund Services, LLC030197c/o Virtus Partners Inc101 Munson Street Suite 104GreenfieldMA01301YOne Financial Plaza Floor 26HartfordCT06103800-248-7971NNYBNY Mellon Investment Servicing (US) Inc084-01761118 Flanders RdWestboroughMA01581NOtherVirtus Partners, Inc11/27/2012Sole MemberSole Member of Limited Liability CompanyHeidi Griswold11/30/2012Vice President Mutual Fund ServicesControl AffiliateMike Angerthal11/30/2012TreasurerControl AffiliateDavid Martin11/30/2012Vice President Chief Compliance OfficerControl Affiliate05/01/2025George Aylward11/30/2012PresidentControl AffiliateDiana Perlman05/01/2025Vice President Chief Compliance OfficerControl AffiliateLimited Liability CorporationYVirtus Investment Partners, IncVirtus Investment Partners, Inc is the parent company of Virtus Partners, IncYVirtus Investment Partners, IncVirtus Investment Partners, Inc is the parent company of Virtus Partners, IncNNNNYDuff & Phelps Investment Management CoSEC Admin Proceeding 3-1060609/28/2001SEC, 450 5th St. Washington DC 20001-2739On 9-28-01 control affiliate Duff & Phelps violated Sections 204, 206(1), and 207 of the Inv. Adv. Act and Section 17(3) of the Inv. Co. Act$100,000 fine paid 10-18-01; $754,161 disgorgement paid in full by 10-26-01Virtus Investment Advisers, IncAdministrative Proceeding File No. 3-1695911/16/2015Securities and Exchange Commission, Washington DCOn November 16, 2015, without admitting or denying the SEC's findings, VIA consented to the entry of an order providing that it cease and desist from committing or causing any violations and future violations of sections 204, 206(2) and 206(4) of the Investment Advisers Act of 1940, as amended and Rules 204-2, 206(4)-1, 206(4)-7 and 206(4)-8 thereunder, and section 34(B) of the Investment Company Act of 1940, as amended; agreed to a censure; and paid $16.5 million, which included a civil money penalty of $2 million, disgorgement of $13.4 million and prejudgment interest of $1.1 millionVIA agreed to a censure; and paid $16.5 million, which included a civil money penalty of $2 million, disgorgement of $13.4 million and prejudgment interest of $1.1 million.YPhoenix Investment Counsel now known as Virtus Investment AdvisersInvestment Advisors Act Release No. 44903/28/1975SEC, 450 5th St. Washington DC 20001-2739Allegations made by the SEC in Admin. Proceeding File 3-4635No formal findings were issued as a result of the consent to sanctions by Phoenix Investment Counsel and Chase Investment Services of Boston.Virtus Investment Advisers, IncAdministrative Proceeding File No. 3-1695911/16/2015Securities and Exchange Commission, Washington DCOn November 16, 2015, without admitting or denying the SEC's findings, VIA consented to the entry of an order providing that it cease and desist from committing or causing any violations and future violations of sections 204, 206(2) and 206(4) of the Investment Advisers Act of 1940, as amended and Rules 204-2, 206(4)-1, 206(4)-7 and 206(4)-8 thereunder, and section 34(B) of the Investment Company Act of 1940, as amended; agreed to a censure; and paid $16.5 million, which included a civil penalty of $2 million, disgorgement of $13.4 million and prejudgment interest of $1.1 millionVIA agreed to a censure; and paid $16.5 million, which included a civil money penalty of $2 million, disgorgement of $13.4 million and prejudgment interest of $1.1 million.NYDuff & Phelps Investment Management CoSEC Admin Proceeding 3-1060609/28/2001SEC, 450 5th St. Washington DC 20001-2739On 9-28-01 control affiliate Duff & Phelps violated Sections 204, 206(1), and 207 of the Inv. Adv. Act and Section 17(e) of the Inv. Co. Act.$100,000 fine was paid 10-18-01; $754,161 disgorgement paid in full by 10-26-01NNNNNNNYPhoenix Equity Planning CorporationC1196003703/07/1997NASD 1735 K St. Washington DC 20006Failed to register at least 3 individuals who were functioning in principal capacity.Acceptance, Waiver and Consent; $100,000 fine paid 03/12/1997NNYKayne Anderson Rudnick Investment Management LLCFINANSTILSYNET Case 17/1116607/16/2018The Financial Supervisory Authority of NorwayOn July 16, 2018, Kayne Anderson Rudnick Investment Management, LLC ("KAR") received notice from the Financial Supervisory Authority of Norway ("FINANSTILSYNET") that FINANSTILSYNET had levied a penalty against KAR equivalent to approximately 19,092 USD based on a finding that two notifications of large share ownership in a Norwegian company were not made in a timely manner under Norwegian law.The fine imposed was 150,000 NOK which ended up being $19,092 USD with the exchange rate. The total amount of the fine was paid by Kayne Anderson Rudnick Investment Management LLC on October 3, 2018.Kayne Anderson Rudnick Investment Management LLCFINANSTILSYNET Case 21/295506/18/2021The Financial Supervisory Authority of NorwayOn June 18, 2021, Kayne Anderson Rudnick Investment Management, LLC ("KAR") received notice from Norway's financial regulatory, The Financial Supervisory Authority of Norway ("FINANSTILSYNET"), that the regulator had levied a penalty against KAR equivalent to approximately $23,000 USD based on a finding that a notification of large share ownership in a Norwegian company was not made in a timely manner under Norwegian law.Disposition is final.NYPhoenix Equity Planning CorporationFidelity Bond Claim03/05/1992St. Paul Fire & Marine Insurance Company 385 Washington St. St. Paul MN 55102Fidelity bond claim filed by registrant as a result of fraudulent activities of a former registered representative who offered bogus securities to the public.Claim less deductible paid by carrier; restitution made to clients in July 1993.Phoenix Equity Planning CorporationFidelity Bond Claim02/20/1991St. Paul Fire & Marine Insurance Company 385 Washington St, St. Paul MN 55102Fidelity bond claim filed by registrant as a result of fraudulent activities of a former registered representative who offered bogus securities to the public.Claim less deductible paid by carrier; restitution made to clients in September 1991.Phoenix Equity Planning CorporationFidelity Bond Claim02/27/1996National Union Fire Insurance Co. 175 Water St. NY, NY 10038Registrant suffered $221,568 loss due to stolen check fraud scheme. FBI and US Postal inspector notified by registrant.Claim paid in full by carrier. Restitution made to clients in December 1996.NHeidi Griswold413-775-6020VP, Mutual Fund Services05/13/2025