EX-99.28.H.5 3 fp0035962_ex9928h5.htm

Exhibit (h)(5)

January 27, 2018

 

Community Capital Management

2500 Weston Road

Suite 101

Weston, FL 33331

 

Attn:Alyssa Greenspan, CFA

President and Chief Operating Officer

 

Re: Amendment to Administration Agreement adding Investment Company Reporting Modernization Services

 

Dear Alyssa:

 

As referenced in our prior communications, SEI has spent considerable time and effort analyzing the SEC’s new investment company reporting modernization requirements for mutual funds and exchange traded funds registered under the Investment Company Act of 1940. Working with industry leading software and data vendors, SEI has developed a service offering designed to assist our clients with satisfying these new requirements in a cost effective manner and by applicable compliance dates.

 

With initial compliance deadlines approaching, it is necessary to amend the Administration Agreement (the “Administration Agreement”) by and among the Community Capital Trust (the “Trust”) and SEI Investments Global Funds Services (“SEI”) to include SEI’s Investment Company Reporting Modernization – N-PORT and N-CEN Services and associated fees within the scope of the Agreement. Accordingly, this letter amendment (“Letter Amendment”) shall serve to: (i) add the “Investment Company Reporting Modernization – N-PORT and N-CEN Support Services” set forth on Exhibit I of this Letter Amendment to the end of Schedule I (List of Services) of the Administration Agreement, and (ii) add the “Investment Company Reporting Modernization – N-PORT and N-CEN Support Services Fees” set forth on Exhibit II of this Letter Amendment, as additional fees payable by each Fund to SEI pursuant to the Administration Agreement.

 

Except to the extent specifically set forth herein, the terms and conditions of the Administration Agreement shall remain in full force and effect. Please acknowledge your agreement with the terms and conditions of this Letter Amendment by counter-signing in the space provided below.

 

  Best regards,  
       
  SEI Investments Global Funds Services  
       
  By: /s/ John Alshefski  
  Name: John Alshefski  
  Title: Senior Vice President  

 

AGREED TO AND ACCEPTED BY:

Community Capital Trust, by and on behalf of all Funds of the Trust

 

By: /s/ Alyssa D. Greenspan  
Name: Alyssa D. Greenspan  
Title: President/CCO  

 

 

 

EXHIBIT I

 

Investment Company Reporting Modernization – N-PORT and N-CEN Support Services

 

The below list of services applies to the SEC’s new Investment Company Reporting Modernization reporting requirements, as applicable to the following:

 

SEC Form N-PORT
SEC Form N-CEN

 

 

 

N-PORT and N-CEN Support Services

 

Administrator Responsibility

Trust Responsibility

Project Management Services

 

Establish key deliverables and timelines

Establish and maintain project plan

Communicate project status and escalate deadlines “at risk”

Coordinate the operations units between Administrator and the Trust

Participate in planning and coordination activities

Communicate key deliverables and timelines internally

Provide information requested per target dates established in the project plan

Implementation Services

Define regulatory reporting platform and operational support requirements

Complete implementation activities that support the established services

Coordinate Trust on-boarding with internal Administrator teams

Define and communicate N-PORT data feed requirements to Trust and to applicable third party firms

Establish and test automated file transmissions with the Trust and with applicable third party firms

Confirm business scope and notify Administrator of any opened or closed funds

Establish automated N-PORT data feeds per Administrator requirements

Notify Administrator prior to any contemplated changes in the N-PORT automated data file format, timing, delivery or content of information

Escalate data file issues with third party firms per Administrator’s request as required

Provide a daily operations contact person to whom Administrator should direct queries

On-boarding Services

Load all data files into regulatory reporting platform

Validate initial data feeds provided by Trust and by applicable third party firms.

Communicate required modifications to appropriate parties

Notify Administrator of any opened funds within 60 days of first required filing

Notify Administrator of any closed funds within 60 days of final required filing

Provide modified/ additional data via automated file feeds as instructed by Administrator

Escalate data file issues with third party firms per Administrator’s request as required

Survey Management Services

Provide comprehensive N-CEN survey to Trust annually

Receive completed N-CEN survey from Trust

Load N-CEN survey data into regulatory reporting platform

Review and complete N-CEN survey based on current business scenarios

Return verified N-CEN survey to Administrator per agreed upon timeframe

 

Data Aggregation Services

Receive electronic N-PORT data files from Trust and from applicable third party firms in accordance with TBD monthly timelines

If files are not received per defined timeframes, contact Trust or applicable third party firms to investigate and resolve

Send holdings files to third party market data providers as required

Load all N-PORT data files into regulatory reporting platform

Research and resolve data file issues in a timely manner

Escalate data file issues with third party firms per Administrator’s request as required

 

 

 

Data Management Services

Review data loads for completion

Research and resolve data load exceptions

Populate Form N-PORT with data received via electronic data files

Populate Form N-CEN with data provided on N-CEN survey

Research and resolve data file issues in a timely manner

Escalate data file issues with third party firms per Administrator’s request as required

Processing Services

 

Execute N-PORT and N-CEN data validation checks to confirm completeness and reasonableness of form data

Research and resolve data exceptions

Prepare draft Forms N-PORT and N-CEN for submission to the SEC

Provide draft Forms to client for review and approval

Modify Forms as directed by Trust

File approved Form N-PORT with the SEC in structured data (XML) format within 30 days of previous month end

File approved Form N-CEN with the SEC in structured data (XML) format within 30 days of Fund’s fiscal year end

Upon request and in a timely manner, answer all questions related to Form N-PORT and Form N-CEN data exceptions

Review draft Forms N-PORT and N-CEN for accuracy

Instruct Administrator to modify Forms N-PORT and/or N-CEN as necessary

Approve Forms N-PORT and N-CEN for filing with SEC

 

Maintenance Services

Maintain core regulatory reporting platform

For static N-CEN data elements, ensure that values are carried over in the regulatory reporting platform from year to year

Update N-PORT data templates as required by Administrator

Update and validate N-CEN survey responses on an annual basis

 

 

EXHIBIT II

 

Investment Company Reporting Modernization – N-PORT and N-CEN Support Services Fees

 

Investment Company Reporting Modernization Services Implementation Fee (calculated and payable quarterly, with the first payment becoming due and owing after approval of this Letter Amendment by the Trust’s Board at its January, 26, 2018 Meeting):

 

$100 per month, per Fund, from October 1, 2017 through and until June 30, 2018

 

 

 

N-PORT & N-CEN Support Services Fees (calculated and payable quarterly):

 

N-PORT & N-CEN Support Services Fees are payable from and after July 1, 2018 with respect to each Fund within a group of related investment companies having aggregate net assets in excess of $1 billion; and from and after July 1, 2019 with respect to each Fund within a group of related investment companies having aggregate net assets of less than $1 billion.

 

Equity Funds - $7,500 per Fund per annum
Fixed Income Funds - $8,500 per Fund per annum
Funds holding non-exchange traded securities - $10,500 per Fund per annum