X0405 TA-1/A 0001562770 XXXXXXXX 084-06485 true LIVE SEC Virtus Fund Services, LLC 030197 c/o Virtus Partners Inc 101 Munson Street Suite 104 Greenfield MA 01301 Y One Financial Plaza Floor 26 Hartford CT 06103 800-248-7971 N N Y BNY Mellon Investment Servicing (US) Inc 084-01761 118 Flanders Rd Westborough MA 01581 N Other Virtus Partners, Inc 11/27/2012 Sole Member Sole Member of Limited Liability Company Heidi Griswold 11/30/2012 Vice President Mutual Fund Services Control Affiliate Mike Angerthal 11/30/2012 Treasurer Control Affiliate David Martin 11/30/2012 Vice President Chief Compliance Officer Control Affiliate 05/01/2025 George Aylward 11/30/2012 President Control Affiliate Diana Perlman 05/01/2025 Vice President Chief Compliance Officer Control Affiliate Limited Liability Corporation Y Virtus Investment Partners, Inc Virtus Investment Partners, Inc is the parent company of Virtus Partners, Inc Y Virtus Investment Partners, Inc Virtus Investment Partners, Inc is the parent company of Virtus Partners, Inc N N N N Y Duff & Phelps Investment Management Co SEC Admin Proceeding 3-10606 09/28/2001 SEC, 450 5th St. Washington DC 20001-2739 On 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 10-26-01 Virtus Investment Advisers, Inc Administrative Proceeding File No. 3-16959 11/16/2015 Securities and Exchange Commission, Washington DC On 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 million VIA 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. Y Phoenix Investment Counsel now known as Virtus Investment Advisers Investment Advisors Act Release No. 449 03/28/1975 SEC, 450 5th St. Washington DC 20001-2739 Allegations made by the SEC in Admin. Proceeding File 3-4635 No 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, Inc Administrative Proceeding File No. 3-16959 11/16/2015 Securities and Exchange Commission, Washington DC On 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 million VIA 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. N Y Duff & Phelps Investment Management Co SEC Admin Proceeding 3-10606 09/28/2001 SEC, 450 5th St. Washington DC 20001-2739 On 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 10-26-01 N N N N N N N Y Phoenix Equity Planning Corporation C11960037 03/07/1997 NASD 1735 K St. Washington DC 20006 Failed to register at least 3 individuals who were functioning in principal capacity. Acceptance, Waiver and Consent; $100,000 fine paid 03/12/1997 N N Y Kayne Anderson Rudnick Investment Management LLC FINANSTILSYNET Case 17/11166 07/16/2018 The Financial Supervisory Authority of Norway On 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 LLC FINANSTILSYNET Case 21/2955 06/18/2021 The Financial Supervisory Authority of Norway On 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. N Y Phoenix Equity Planning Corporation Fidelity Bond Claim 03/05/1992 St. Paul Fire & Marine Insurance Company 385 Washington St. St. Paul MN 55102 Fidelity 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 Corporation Fidelity Bond Claim 02/20/1991 St. Paul Fire & Marine Insurance Company 385 Washington St, St. Paul MN 55102 Fidelity 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 Corporation Fidelity Bond Claim 02/27/1996 National Union Fire Insurance Co. 175 Water St. NY, NY 10038 Registrant 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. N Heidi Griswold 413-775-6020 VP, Mutual Fund Services 05/13/2025