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Excessive Trading Policy

Capital One Investing℠ has adopted an Excessive Trading Policy to discourage market timing and excessive trading activity in our funds.

We monitor mutual fund trade activity and strive to prevent an individual from engaging in excessive trading. If it is determined that an individual has engaged in excessive trading, Capital One Investing will restrict the individual from future purchases with the impacted fund family. In general, we define excessive trading as more than six exchanges within a rolling 12-month period. However, Capital One Investing reserves the right to limit fund trading with respect to any individual, with or without prior notice, if we determine that the individual's trading activity is disruptive.

Additionally, Capital One Investing's policy may differ from a mutual fund's excessive/frequent trading policy as defined in the prospectus. In this situation, we will cooperate with the fund family to implement restrictions and/or block future purchases when their stated policy has been violated. All such restrictions will be done in accordance with the directions Capital One Investing receives from the fund or from our clearing agent, and may include a permanent purchase restriction in that fund family.