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Short Term Trading and Market Timing

The Fund discourages short term trading and market timing. Market timing is an investment strategy using frequent purchases, redemptions, and/or exchanges in an attempt to profit from short term market movements. Market timing many result in dilution of the value of Fund shares held by long term shareholders, disrupt portfolio management, and increase Fund expenses to all shareholders. The Board of Trustees has adopted a policy directing the Fund to reject any purchase order with respect to one investor, a related group of investors or their agent(s), where it detects a pattern of purchases and sales of the Fund that indicates short term trading or market timing. This policy applies to all Fund shareholders.

While the Fund attempts to deter market timing, there is no assurance that it will be able to identify and eliminate all market timers. For example, certain accounts called "omnibus accounts" include multiple shareholders. Omnibus accounts typically provide the Fund with a net purchase or redemption request on any given day where purchasers of Fund shares and redeemers of Fund shares are netted against one another and the identity of individual purchasers and redeemers whose orders are aggregated are not known by the Fund. This netting effect often makes it more difficult for the Fund to detect short term trading, and there can be no assurance that the Fund will be able to do so.

Please refer to the Fund prospectus for additional information on how the Fund may be vulnerable to short term traders and market timers.

   

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