schemaVersion:

N-CEN: Filer Information

Submission Contact Information

Name
 
Phone
 
E-Mail Address
 

Notification Information

Notify via Filing Website only?Checkbox not checked

N-CEN:Series/Class (Contract) Information

Series ID Record:1
Series ID
S000020974 
Class ID Record:1
Class ID
C000059518 
Class ID Record:2
Class ID
C000059517 
Class ID Record:3
Class ID
C000059519 
Series ID Record:2
Series ID
S000042247 
Class ID Record:1
Class ID
C000131120 
Class ID Record:2
Class ID
C000131122 
Class ID Record:3
Class ID
C000131121 
Series ID Record:3
Series ID
S000020975 
Class ID Record:1
Class ID
C000059520 
Class ID Record:2
Class ID
C000059522 
Class ID Record:3
Class ID
C000059521 
Series ID Record:4
Series ID
S000022888 
Class ID Record:1
Class ID
C000066378 
Class ID Record:2
Class ID
C000066379 
Class ID Record:3
Class ID
C000066380 
Series ID Record:5
Series ID
S000020972 
Class ID Record:1
Class ID
C000059513 
Class ID Record:2
Class ID
C000059512 
Class ID Record:3
Class ID
C000059511 
Series ID Record:6
Series ID
S000020973 
Class ID Record:1
Class ID
C000059516 
Class ID Record:2
Class ID
C000059515 
Class ID Record:3
Class ID
C000059514 
Series ID Record:7
Series ID
S000042248 
Class ID Record:1
Class ID
C000131124 
Class ID Record:2
Class ID
C000131123 
Class ID Record:3
Class ID
C000131125 
Series ID Record:8
Series ID
S000020978 
Class ID Record:1
Class ID
C000059529 
Class ID Record:2
Class ID
C000059530 
Class ID Record:3
Class ID
C000059531 
Series ID Record:9
Series ID
S000020979 
Class ID Record:1
Class ID
C000059532 
Class ID Record:2
Class ID
C000059534 
Class ID Record:3
Class ID
C000059533 
Series ID Record:10
Series ID
S000020971 
Class ID Record:1
Class ID
C000059509 
Class ID Record:2
Class ID
C000059510 
Class ID Record:3
Class ID
C000059508 
Series ID Record:11
Series ID
S000020977 
Class ID Record:1
Class ID
C000059527 
Class ID Record:2
Class ID
C000059528 
Class ID Record:3
Class ID
C000059526 
Series ID Record:12
Series ID
S000020976 
Class ID Record:1
Class ID
C000059525 
Class ID Record:2
Class ID
C000059523 
Class ID Record:3
Class ID
C000059524 
Series ID Record:13
Series ID
S000028743 
Class ID Record:1
Class ID
C000087895 
Class ID Record:2
Class ID
C000087897 
Class ID Record:3
Class ID
C000087896 
Series ID Record:14
Series ID
S000034854 
Class ID Record:1
Class ID
C000107185 
Class ID Record:2
Class ID
C000107187 
Class ID Record:3
Class ID
C000107186 

N-CEN:Part A: General Information

Item A.1. Reporting period covered.

a. Report for period ending:
2022-10-31 
b. Does this report cover a period of less than 12 months?Radio button not checked Yes Radio button checked No

N-CEN:Part B: Information About the Registrant


Item B.1. Background information.

a. Full name of Registrant
Dunham Funds 
b. Investment Company Act file number ( e.g., 811-)
811-22153 
c. CIK
0001420040 
d. LEI
549300FI2C3SP4YCHL80 

Item B.2. Address and telephone number of Registrant.

a. Street 1
6256 Greenwich Dr. 
Street 2
Suite 550 
b. City
San Diego 
c. State, if applicable
CALIFORNIA  
d. Foreign country, if applicable
UNITED STATES OF AMERICA  
e. Zip code and zip code extension, or foreign postal code
92122 
f. Telephone number (including country code if foreign)
858-964-0500 
g. Public Website, if any
https://www.dunham.com/ 

Item B.3. Location of books and records.

Instruction. Provide the requested information for each person maintaining physical possession of each account, book, or other document required to be maintained by section 31(a) of the Act (15 U.S.C. 80a-30(a)) and the rules under that section.
Location books Record: 1
a. Name of person (e.g., a custodian of records)
Ultimus Fund Solutions, LLC 
b. Street 1
225 Pictoria Drive, Suite 450 
Street 2
 
c. City
Cincinnati 
d. State, if applicable
OHIO  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Zip code and zip code extension, or foreign postal code
45246 
g. Telephone number (including country code if foreign)
855-891-0092 
h. Briefly describe the books and records kept at this location:
Records related to its function as administrator, transfer agent and accounting agent 

Item B.4. Initial of final filings.

Instruction. Respond "yes" to Item B.4.b only if the Registrant has filed an application to deregister or will file an application to deregister before its next required filing on this form.
a. Is this the first filing on this form by the Registrant? Radio button not checked Yes Radio button checked No
b. Is this the last filing on this form by the Registrant? Radio button not checked Yes Radio button checked No

Item B.5. Family of investment companies.

Instruction. "Family of investment companies" means, except for insurance company separate accounts, any two or more registered investment companies that (i) share the same investment adviser or principal underwriter; and (ii) hold themselves out to investors as related companies for purposes of investment and investor services.In responding to this item, all Registrants in the family of investment companies should report the name of the family of investment companies identically.
Insurance company separate accounts that may not hold themselves out to investors as related companies (products) for purposes of investment and investor services should consider themselves part of the same family if the operational or accounting or control systems under which these entities function are substantially similar.
a. Is the Registrant part of a family of investment companies? Radio button checked Yes Radio button not checked No
i. Full name of family of investment companies
Dunham Funds 

Item B.6. Organization.

Instruction. For Item B.6.a.i., the Registrant should include all Series that have been established by the Registrant and have shares outstanding (other than shares issued in connection with an initial investment to satisfy section 14(a) of the Act).
Indicate the classification of the Registrant by checking the applicable item below.
Checkbox checked  a. Open-end management investment company registered under the Act on Form N-1A 
Checkbox not checked  b. Closed-end management investment company registered under the Act on Form N-2  
Checkbox not checked  c. Separate account offering variable annuity contracts which is registered under the Act as a management investment company on Form N-3 
Checkbox not checked  d. Separate account offering variable annuity contracts which is registered under the Act as a unit investment trust on Form N-4 
Checkbox not checked  e. Small business investment company registered under the Act on Form N-5 
Checkbox not checked  f. Separate account offering variable insurance contracts which is registered under the Act as a unit investment trust on Form N-6 
Checkbox not checked  g. Unit investment trust registered under the Act on Form N-8B-2 
i. Total number of Series of the Registrant
14 

Item B.7. Securities Act registration.

Is the Registrant the issuer of a class of securities registered under the Securities Act of 1933 ("Securities Act")? Radio button checked Yes Radio button not checked No

Item B.8. Directors.

Provide the information requested below about each person serving as director of the Registrant (management investment companies only):
Director Record: 1
a. Full Name
Paul A. Rosinack 
b. CRD number, if any
N/A 
c. Is the person an "interested person" of the Registrant as that term is defined in section 2(a)(19) of the Act (15 U.S.C. 80a-2(a)(19))? Radio button not checked Yes Radio button checked No
d. Investment Company Act file number of any other registered investment company for which the person also serves as a director (e.g., 811-)
File Number Record: 1
File Number Record:
N/A 
Director Record: 2
a. Full Name
Michael J. Torvinen 
b. CRD number, if any
N/A 
c. Is the person an "interested person" of the Registrant as that term is defined in section 2(a)(19) of the Act (15 U.S.C. 80a-2(a)(19))? Radio button not checked Yes Radio button checked No
d. Investment Company Act file number of any other registered investment company for which the person also serves as a director (e.g., 811-)
File Number Record: 1
File Number Record:
N/A 
Director Record: 3
a. Full Name
Jeffrey A. Dunham 
b. CRD number, if any
N/A 
c. Is the person an "interested person" of the Registrant as that term is defined in section 2(a)(19) of the Act (15 U.S.C. 80a-2(a)(19))? Radio button checked Yes Radio button not checked No
d. Investment Company Act file number of any other registered investment company for which the person also serves as a director (e.g., 811-)
File Number Record: 1
File Number Record:
N/A 
Director Record: 4
a. Full Name
Henry R. Goldstein 
b. CRD number, if any
N/A 
c. Is the person an "interested person" of the Registrant as that term is defined in section 2(a)(19) of the Act (15 U.S.C. 80a-2(a)(19))? Radio button not checked Yes Radio button checked No
d. Investment Company Act file number of any other registered investment company for which the person also serves as a director (e.g., 811-)
File Number Record: 1
File Number Record:
N/A 

Item B.9. Chief compliance officer.

Provide the information requested below about each person serving as chief compliance officer of the Registrant for purposes of rule 38a-1 (17 CFR 270.38a- 1):
Chief compliance officer Record: 1
a. Full Name
Viktoria Palermo 
b. CRD Number, if any
N/A 
c. Street Address 1
6256 Greenwich Dr. 
Street Address 2
Suite 550 
d. City
San Diego 
e. State, if applicable
CALIFORNIA  
f. Foreign country, if applicable
UNITED STATES OF AMERICA  
g. Zip code and zip code extension, or foreign postal code
92122 
h. Telephone number (including country code if foreign)
XXXXXX 
i. Has the chief compliance officer changed since the last filing? Radio button not checked Yes Radio button checked No
If the chief compliance officer is compensated or employed by any person other than the Registrant, or an affiliated person of the Registrant, for providing chief compliance officer services, provide:
CCO employer Record: 1
i. Name of the person
Dunham & Associates Investment Counsel, Inc. 
ii. Person's IRS Employer Identification Number
N/A 

Item B.10. Matters for security holder vote.

Instruction. Registrants registered on Forms N-3, N-4 or N-6, should respond "yes" to this Item only if security holder votes were solicited on contract-level matters.
Were any matters submitted by the Registrant for its security holders' vote during the reporting period? Radio button not checked Yes Radio button checked No

Item B.11. Legal proceeding.

Instruction. For purposes of this Item, the following proceedings should be described: (1) any bankruptcy, receivership or similar proceeding with respect to the Registrant or any of its significant subsidiaries; (2) any proceeding to which any director, officer or other affiliated person of the Registrant is a party adverse to the Registrant or any of its subsidiaries; and (3) any proceeding involving the revocation or suspension of the right of the Registrant to sell securities.
a. Have there been any material legal proceedings, other than routine litigation incidental to the business, to which the Registrant or any of its subsidiaries was a party or of which any of their property was the subject during the reporting period? Radio button not checked Yes Radio button checked No
b. Has any proceeding previously reported been terminated? Radio button not checked Yes Radio button checked No

Item B.12. Fidelity bond and insurance (management investment companies only).

a. Were any claims with respect to the Registrant filed under a fidelity bond (including, but not limited to, the fidelity insuring agreement of the bond) during the reporting period? Radio button not checked Yes Radio button checked No

Item B.13. Directors and officers/errors and omissions insurance (management investment companies only).

a. Are the Registrant's officers or directors covered in their capacities as officers or directors under any directors and officers/errors and omissions insurance policy owned by the Registrant or anyone else? Radio button checked Yes Radio button not checked No
i. If yes, were any claims filed under the policy during the reporting period with respect to the Registrant? Radio button not checked Yes Radio button checked No

Item B.14. Provision of financial support.

Instruction. For purposes of this Item, a provision of financial support includes any (1) capital contribution, (2) purchase of a security from a Money Market Fund in reliance on rule 17a-9 under the Act (17 CFR 270.17a-9), (3) purchase of any defaulted or devalued security at fair value reasonably intended to increase or stabilize the value or liquidity of the Registrant's portfolio, (4) execution of letter of credit or letter of indemnity, (5) capital support agreement (whether or not the Registrant ultimately received support), (6) performance guarantee, or (7) other similar action reasonably intended to increase or stabilize the value or liquidity of the Registrant's portfolio. Provision of financial support does not include any (1) routine waiver of fees or reimbursement of Registrant's expenses, (2) routine inter-fund lending, (3) routine inter-fund purchases of Registrant's shares, or (4) action that would qualify as financial support as defined above, that the board of directors has otherwise determined not to be reasonably intended to increase or stabilize the value or liquidity of the Registrant's portfolio.
Did an affiliated person, promoter, or principal underwriter of the Registrant, or an affiliated person of such a person, provide any form of financial support to the Registrant during the reporting period? Radio button not checked Yes Radio button checked No

Item B.15. Exemptive orders.

a. During the reporting period, did the Registrant rely on any orders from the Commission granting an exemption from one or more provisions of the Act, Securities Act or Exchange Act? Radio button checked Yes Radio button not checked No
Release number Record: 1
i. If yes, provide below the release number for each order
IC-27501 

Item B.16. Principal underwriters.

a. Provide the information requested below about each principal underwriter:
Principal underwriter Record: 1
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. SEC file number (e.g., 8-)
8-28527 
iii. CRD number
N/A 
iv. LEI, if any
N/A 
v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the principal underwriter an affiliated person of the Registrant, or its investment adviser(s) or depositor? Radio button checked Yes Radio button not checked No
b. Have any principal underwriters been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item B.17. Independent public accountant.

Provide the following information about eachthe independent public accountant:
Public accountant Record: 1
a. Full Name
BBD, LLP 
b. PCAOB Number
552 
c. LEI, if any
N/A 
d. State, if applicable
PENNSYLVANIA  
e. Foreign country, if applicable
UNITED STATES OF AMERICA  
f. Has the independent public accountant changed since the last filing?Radio button not checked Yes Radio button checked No

Item B.18. Report on internal control (management investment companies only).

Instruction. Small business investment companies are not required to respond to this item.
For the reporting period, did an independent public accountant's report on internal control note any material weaknesses? Radio button not checked Yes Radio button checked No

Item B.19. Audit opinion.

For the reporting period, did an independent public accountant issue an opinion other than an unqualified opinion with respect to its audit of the Registrant's financial statements? Radio button not checked Yes Radio button checked No

Item B.20. Change in valuation methods.

Instruction. Responses to this item need not include changes to valuation techniques used for individual securities (e.g., changing from market approach to income approach for a private equity security). In responding to Item B.20.c., provide the applicable "asset type" category specified in Item C.4.a. of Form N-PORT. In responding to Item B.20.d., provide a brief description of the type of investments involved. If the change in valuation methods applies only to certain sub-asset types included in the response to Item B.20.c., please provide the sub-asset types in the response to Item B.20.d. The responses to Item B.20.c. and Item B.20.d. should be identical only if the change in valuation methods applies to all assets within that category.
Have there been material changes in the method of valuation (e.g., change from use of bid price to mid price for fixed income securities or change in trigger threshold for use of fair value factors on international equity securities) of the Registrant's assets during the reporting period? Radio button not checked Yes Radio button checked No

Item B.21. Change in accounting principles and practices.

Have there been any changes in accounting principles or practices, or any change in the method of applying any such accounting principles or practices, which will materially affect the financial statements filed or to be filed for the current year with the Commission and which has not been previously reported? Radio button not checked Yes Radio button checked No

Item B.22. Net asset value error corrections (open-end management investment companies only).

a. During the reporting period, were any payments made to shareholders or shareholder accounts reprocessed as a result of an error in calculating the Registrant's net asset value (or net asset value per share)? Radio button not checked Yes Radio button checked No

Item B.23. Rule 19a-1 notice (management investment companies only).

During the reporting period, did the Registrant pay any dividend or make any distribution in the nature of a dividend payment, required to be accompanied by a written statement pursuant to section 19(a) of the Act (15 U.S.C. 80a-19(a)) and rule 19a-1 thereunder (17 CFR 270.19a-1)? Radio button checked Yes Radio button not checked No
Payment dividend series info Record: 1
a. If yes, and to the extent the response relates only to certain series of the Registrant, indicate the series involved:
i. Series name
Dunham Monthly Distribution Fund 
ii. Series identification number
S000022888 

N-CEN:Part C: Additional Questions for Management Investment Companies

General Instruction.

Management investment companies that offer multiple series must complete Part C as to each series separately, even if some information is the same for two or more series. To begin this section or add an additional series(s), click on the bar labeled "Add a New Series" below.
Management Investment Record: 1

Item C.1. Background information.

a. Full Name of the Fund

Dunham Small Cap Value Fund 

b. Series identication number, if any

S000020974 

c. LEI

549300FUKK5THH5JHD83 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Dunham Small Cap Value Fund Class C 
ii. Class identification number, if any

C000059518 

iii. Ticker symbol, if any

DCSVX 

Shares Outstanding Record: 2
i. Full name of Class
Dunham Small Cap Value Fund Class A 
ii. Class identification number, if any

C000059517 

iii. Ticker symbol, if any

DASVX 

Shares Outstanding Record: 3
i. Full name of Class
Dunham Small Cap Value Fund Class N 
ii. Class identification number, if any

C000059519 

iii. Ticker symbol, if any

DNSVX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any

8KUMV9EIJ75IBFMLFD23 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any:

8KUMV9EIJ75IBFMLFD23 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox checked  vi. Other  
Checkbox not checked   N/A  
If other, describe:

75% Funds/25% Securities Lending Agent 

f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

22,777,414.71999999 

g. Provide the net income from securities lending activities

22,866.00000000 


Item C.7. Reliance on certain statutory exemption and rules.

Did the Fund rely on the following statutory exemption or any of the rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  k. Rule 6c-11 (17 CFR 270.6c-11) 
Checkbox not checked  l. Rule 12d1-4 (17 CFR 270.12d1-4) 
Checkbox not checked  m. Section 12(d)(1)(G) of the Act (15 USC 80a-12(d)(1)(G)) 
Checkbox not checked  n. Rule 18f-4 (17 CFR 270.18f-4) 
Checkbox not checked  i. Is the Fund excepted from the rule 18f-4 (17 CFR 270.18f-4) program requirement and limit on fund leverage risk under rule 18f-4(c)(4) (17CFR 270.18f-4(c)(4))? 
Checkbox not checked  ii. Is the Fund a leveraged/inverse fund that, under rule 18f-4(c)(5) (17 CFR 270.18f-4(c)(5)), is excepted from the requirement to comply with the limit on fund leverage risk described in rule 18f-4(c)(2) (17 CFR 270.18f-4(c)(2))? 
Checkbox not checked  iii. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(i) (17 CFR 270.18f-4(d)(i))? 
Checkbox not checked  iv. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(ii) (17 CFR 270.18f-4(d)(ii))? 
Checkbox not checked  v. Did the Fund enter into any unfunded commitment agreements under rule 18f-4(e) (17 CFR 270.18f-4(e))? 
Checkbox not checked  vi. Did the Fund invest in a security on a when-issued or forward-settling basis, or with a non-standard settlement cycle, in reliance on rule 18f-4(f) (17 CFR 270.18f-4(f))? 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button not checked Yes Radio button checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button not checked Yes Radio button checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. SEC file number ( e.g., 801- )

801-25803 

iii.CRD number
000013162 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
Ziegler Capital Management Inc. 
ii. SEC file number ( e.g., 801- ), if applicable

801-111813 

iii. CRD number
000309195 
iv. LEI, if any

J6FZKP08Z2X6Q8KQ7U12 

v. State, if applicable
NEVADA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii.SEC file number ( e.g., 84- or 85- )

84-05829 

iii. LEI, if any

N/A 

iv. State, if applicable
NEBRASKA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
ICE Data Services 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US Bank 
ii. LEI, if any

N1GZ7BBF3NP8GI976H15 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or provide and describe other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 2
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. LEI, if any, or provide and describe other identifying number

000013162 

Description of other identifying number

CRD Number 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
a. Full name
b. SEC file number

c. CRD number
d. LEI, if any

e. State, if applicable
f. Foreign country, if applicable
g. Total commissions paid to the affiliated broker-dealer for the reporting period:


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
MORGAN STANLEY SMITH BARNEY 
ii. SEC file number

8-68191 

iii. CRD number
000149777 
iv. LEI, if any

7PDDXEMZ0ZV0CEDU4D16 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

4,124.43999999 

Brokers Record: 2
i. Full name of broker
CAPITAL INSTITUTIONAL SERVICES, INC. 
ii. SEC file number

8-22273 

iii. CRD number
000007551 
iv. LEI, if any

54930061X8RDWFDJIS05 

v. State, if applicable
TEXAS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

53,325.68000000 

Brokers Record: 3
i. Full name of broker
ROYAL BANK OF CANADA CAPITAL MARKETS 
ii. SEC file number

8-39947 

iii. CRD number
000022698 
iv. LEI, if any

ES7IP3U3RHIGC71XBU11 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

32,267.72000000 

Brokers Record: 4
i. Full name of broker
KEYBANC CAPITAL MARKETS INC. 
ii. SEC file number

8-30177 

iii. CRD number
000000566 
iv. LEI, if any

2EQWV0180Z211YVAD813 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

2,370.60000000 

Brokers Record: 5
i. Full name of broker
ALEX.BROWN 
ii. SEC file number

8-10999 

iii. CRD number
000000705 
iv. LEI, if any

U4ONQX15J3RO8XCKE979 

v. State, if applicable
FLORIDA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

3,430.28000000 

Brokers Record: 6
i. Full name of broker
JPMORGAN CHASE 
ii. SEC file number

8-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

83,028.28000000 

Brokers Record: 7
i. Full name of broker
DEUTSCHE BANK 
ii. SEC file number

8-17822 

iii. CRD number
000002525 
iv. LEI, if any

9J6MBOOO7BECTDTUZW19 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

7,562.00000000 

Brokers Record: 8
i. Full name of broker
PIPER SANDLER 
ii. SEC file number

8-15204 

iii. CRD number
000000665 
iv. LEI, if any

549300GRQCWQ3XGH0H10 

v. State, if applicable
MINNESOTA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

2,694.24000000 

Brokers Record: 9
i. Full name of broker
SANFORD FINANCIAL SERVICES 
ii. SEC file number

8-52942 

iii. CRD number
000151388 
iv. LEI, if any

549300I7JYZHT7D5CO04 

v. State, if applicable
MICHIGAN  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

3,907.72000000 

Brokers Record: 10
i. Full name of broker
WILLIAM BLAIR & CO 
ii. SEC file number

8-02698 

iii. CRD number
000001252 
iv. LEI, if any

549300J0P7XYE8BMZ775 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

6,825.68000000 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

199,536.64000000 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
KEYBANC CAPITAL MARKETS INC. 
ii. SEC file number

8-30177 

iii. CRD number
000000566 
iv. LEI, if any

2EQWV0180Z211YVAD813 

v. State, if applicable
OHIO  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

5,967,090.25000000 

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

0 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

81,108,937.28000000 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button checked Yes Radio button not checked No
If yes, for each line of credit, provide the information requested below:
Line of Credit details Record: 1
i. Is the line of credit a committed or uncommitted line of credit? Radio button not checked Committed Radio button checked Uncommitted
ii. What size is the line of credit?

50,000,000.00000000 

iii. With which institution(s) is the line of credit?
Line Institutions Record: 1
Name of institution
U.S Bank National Association 
iv. Is the line of credit just for the Fund, or is it shared among multiple funds? Radio button not checked Sole Radio button checked Shared
1. If shared, list the names of other funds that may use the line of credit.
Shared Credit Users Record: 1
Name of fund
Dunham Monthly Distribution Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 2
Name of fund
Dunham Dynamic Macro Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 3
Name of fund
Dunham Focused Large Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 4
Name of fund
Dunham Real Estate Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 5
Name of fund
Dunham Corporate/Government Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 6
Name of fund
Dunham Large Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 7
Name of fund
Dunham Floating Rate Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 8
Name of fund
Dunham Emerging Markets Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 9
Name of fund
Dunham International Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 10
Name of fund
Dunham Long/Short Credit 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 11
Name of fund
Dunham High-Yield Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 12
Name of fund
Dunham Small Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 13
Name of fund
Dunham International Opportunity Bond Fund 
SEC File number( e.g., 811- )
811-22153 
v. Did the Fund draw on the line of credit this period?Radio button checked Yes Radio button not checked No vi. If the fund drew on the line of credit during this period, what was the average amount outstanding when the line of credit was in use?
1,468,278.00000000 
vii. If the fund drew on the line of credit during this period, what was the number of days that the line of credit was in use?
18 



b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 2

Item C.1. Background information.

a. Full Name of the Fund

Dunham International Opportunity Bond Fund 

b. Series identication number, if any

S000042247 

c. LEI

549300CZHQ4VN7TRVE44 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Dunham International Opportunity Bond Fund Class A 
ii. Class identification number, if any

C000131120 

iii. Ticker symbol, if any

DAIOX 

Shares Outstanding Record: 2
i. Full name of Class
Dunham International Opportunity Bond Fund Class N 
ii. Class identification number, if any

C000131122 

iii. Ticker symbol, if any

DNIOX 

Shares Outstanding Record: 3
i. Full name of Class
Dunham International Opportunity Bond Fund Class C 
ii. Class identification number, if any

C000131121 

iii. Ticker symbol, if any

DCIOX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button checked Yes Radio button not checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any

8KUMV9EIJ75IBFMLFD23 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any:

8KUMV9EIJ75IBFMLFD23 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox checked  vi. Other  
Checkbox not checked   N/A  
If other, describe:

75% Funds/25% Securities Lending Agent 

f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

1,809,572.69000000 

g. Provide the net income from securities lending activities

10,720.00000000 


Item C.7. Reliance on certain statutory exemption and rules.

Did the Fund rely on the following statutory exemption or any of the rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  k. Rule 6c-11 (17 CFR 270.6c-11) 
Checkbox not checked  l. Rule 12d1-4 (17 CFR 270.12d1-4) 
Checkbox not checked  m. Section 12(d)(1)(G) of the Act (15 USC 80a-12(d)(1)(G)) 
Checkbox not checked  n. Rule 18f-4 (17 CFR 270.18f-4) 
Checkbox not checked  i. Is the Fund excepted from the rule 18f-4 (17 CFR 270.18f-4) program requirement and limit on fund leverage risk under rule 18f-4(c)(4) (17CFR 270.18f-4(c)(4))? 
Checkbox not checked  ii. Is the Fund a leveraged/inverse fund that, under rule 18f-4(c)(5) (17 CFR 270.18f-4(c)(5)), is excepted from the requirement to comply with the limit on fund leverage risk described in rule 18f-4(c)(2) (17 CFR 270.18f-4(c)(2))? 
Checkbox not checked  iii. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(i) (17 CFR 270.18f-4(d)(i))? 
Checkbox not checked  iv. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(ii) (17 CFR 270.18f-4(d)(ii))? 
Checkbox not checked  v. Did the Fund enter into any unfunded commitment agreements under rule 18f-4(e) (17 CFR 270.18f-4(e))? 
Checkbox not checked  vi. Did the Fund invest in a security on a when-issued or forward-settling basis, or with a non-standard settlement cycle, in reliance on rule 18f-4(f) (17 CFR 270.18f-4(f))? 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button not checked Yes Radio button checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button not checked Yes Radio button checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. SEC file number ( e.g., 801- )

801-25803 

iii.CRD number
000013162 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
Virtus Fixed Income Advisers, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-68743 

iii. CRD number
000136029 
iv. LEI, if any

549300L7I4W19C7JV575 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii.SEC file number ( e.g., 84- or 85- )

84-05829 

iii. LEI, if any

N/A 

iv. State, if applicable
NEBRASKA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
ICE Data Services 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US Bank 
ii. LEI, if any

N1GZ7BBF3NP8GI976H15 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or provide and describe other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 2
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. LEI, if any, or provide and describe other identifying number

000013162 

Description of other identifying number

CRD Number 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
a. Full name
b. SEC file number

c. CRD number
d. LEI, if any

e. State, if applicable
f. Foreign country, if applicable
g. Total commissions paid to the affiliated broker-dealer for the reporting period:


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
BARCLAYS 
ii. SEC file number

8-41342 

iii. CRD number
000019714 
iv. LEI, if any

AC28XWWI3WIBK2824319 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

5,222.07000000 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

5,222.07000000 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
JPMORGAN CHASE 
ii. SEC file number

8-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

8,042,464.49000000 

Principal Transactions Record: 2
i. Full name of dealer
U.S. BANCORP INVESTMENTS, INC. 
ii. SEC file number

8-35359 

iii. CRD number
000017868 
iv. LEI, if any

H85Z6XZP8B10ES0M2G89 

v. State, if applicable
DELAWARE  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

24,816,000.00000000 

Principal Transactions Record: 3
i. Full name of dealer
HSBC SECURITIES 
ii. SEC file number

8-41562 

iii. CRD number
000019585 
iv. LEI, if any

MP6I5ZYZBEU3UXPYFY54 

v. State, if applicable
 
vi. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

9,332,160.46000000 

Principal Transactions Record: 4
i. Full name of dealer
JEFFERIES GROUP 
ii. SEC file number

8-15074 

iii. CRD number
000002347 
iv. LEI, if any

58PU97L1C0WSRCWADL48 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

7,862,578.56000000 

Principal Transactions Record: 5
i. Full name of dealer
MORGAN STANLEY SMITH BARNEY 
ii. SEC file number

8-68191 

iii. CRD number
000149777 
iv. LEI, if any

7PDDXEMZ0ZV0CEDU4D16 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

4,594,256.47000000 

Principal Transactions Record: 6
i. Full name of dealer
BANK OF AMERICA MERRILL LYNCH 
ii. SEC file number

8-7221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

6,496,630.25000000 

Principal Transactions Record: 7
i. Full name of dealer
BARRINGTON RESEARCH 
ii. SEC file number

8-29831 

iii. CRD number
000013820 
iv. LEI, if any

549300EAYDU2H358PB45 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

84,769,413.41000000 

Principal Transactions Record: 8
i. Full name of dealer
CAPSTONE GLOBAL MARKETS 
ii. SEC file number

8-67583 

iii. CRD number
000143612 
iv. LEI, if any

9845002A4C51D9EF8B27 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

7,936,205.33000000 

Principal Transactions Record: 9
i. Full name of dealer
Goldman Sachs 
ii. SEC file number

8-129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

5,199,579.50000000 

Principal Transactions Record: 10
i. Full name of dealer
BARCLAYS 
ii. SEC file number

8-41342 

iii. CRD number
000019714 
iv. LEI, if any

AC28XWWI3WIBK2824319 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

237,073,198.35000000 

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

423,253,502.33000000 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

57,827,925.10000000 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button checked Yes Radio button not checked No
If yes, for each line of credit, provide the information requested below:
Line of Credit details Record: 1
i. Is the line of credit a committed or uncommitted line of credit? Radio button not checked Committed Radio button checked Uncommitted
ii. What size is the line of credit?

50,000,000.00000000 

iii. With which institution(s) is the line of credit?
Line Institutions Record: 1
Name of institution
U.S Bank National Association 
iv. Is the line of credit just for the Fund, or is it shared among multiple funds? Radio button not checked Sole Radio button checked Shared
1. If shared, list the names of other funds that may use the line of credit.
Shared Credit Users Record: 1
Name of fund
Dunham Small Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 2
Name of fund
Dunham Floating Rate Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 3
Name of fund
Dunham Corporate/Government Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 4
Name of fund
Dunham Monthly Distribution Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 5
Name of fund
Dunham Dynamic Macro Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 6
Name of fund
Dunham High-Yield Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 7
Name of fund
Dunham Long/Short Credit 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 8
Name of fund
Dunham Large Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 9
Name of fund
Dunham Focused Large Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 10
Name of fund
Dunham International Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 11
Name of fund
Dunham Real Estate Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 12
Name of fund
Dunham Small Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 13
Name of fund
Dunham Emerging Markets Stock Fund 
SEC File number( e.g., 811- )
811-22153 
v. Did the Fund draw on the line of credit this period?Radio button checked Yes Radio button not checked No vi. If the fund drew on the line of credit during this period, what was the average amount outstanding when the line of credit was in use?
1,053,056.00000000 
vii. If the fund drew on the line of credit during this period, what was the number of days that the line of credit was in use?
18 



b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 3

Item C.1. Background information.

a. Full Name of the Fund

Dunham Long/Short Credit Fund 

b. Series identication number, if any

S000020975 

c. LEI

549300HNTJP4LP1J7Y67 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Dunham Long/Short Credit Fund Class A 
ii. Class identification number, if any

C000059520 

iii. Ticker symbol, if any

DAAIX 

Shares Outstanding Record: 2
i. Full name of Class
Dunham Long/Short Credit Fund Class N 
ii. Class identification number, if any

C000059522 

iii. Ticker symbol, if any

DNAIX 

Shares Outstanding Record: 3
i. Full name of Class
Dunham Long/Short Credit Fund Class C 
ii. Class identification number, if any

C000059521 

iii. Ticker symbol, if any

DCAIX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any

8KUMV9EIJ75IBFMLFD23 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any:

8KUMV9EIJ75IBFMLFD23 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox checked  vi. Other  
Checkbox not checked   N/A  
If other, describe:

75% Funds/25% Securites Lending Agent 

f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

15,699,063.18999999 

g. Provide the net income from securities lending activities

32,903.10000000 


Item C.7. Reliance on certain statutory exemption and rules.

Did the Fund rely on the following statutory exemption or any of the rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  k. Rule 6c-11 (17 CFR 270.6c-11) 
Checkbox not checked  l. Rule 12d1-4 (17 CFR 270.12d1-4) 
Checkbox not checked  m. Section 12(d)(1)(G) of the Act (15 USC 80a-12(d)(1)(G)) 
Checkbox not checked  n. Rule 18f-4 (17 CFR 270.18f-4) 
Checkbox not checked  i. Is the Fund excepted from the rule 18f-4 (17 CFR 270.18f-4) program requirement and limit on fund leverage risk under rule 18f-4(c)(4) (17CFR 270.18f-4(c)(4))? 
Checkbox not checked  ii. Is the Fund a leveraged/inverse fund that, under rule 18f-4(c)(5) (17 CFR 270.18f-4(c)(5)), is excepted from the requirement to comply with the limit on fund leverage risk described in rule 18f-4(c)(2) (17 CFR 270.18f-4(c)(2))? 
Checkbox not checked  iii. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(i) (17 CFR 270.18f-4(d)(i))? 
Checkbox not checked  iv. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(ii) (17 CFR 270.18f-4(d)(ii))? 
Checkbox not checked  v. Did the Fund enter into any unfunded commitment agreements under rule 18f-4(e) (17 CFR 270.18f-4(e))? 
Checkbox not checked  vi. Did the Fund invest in a security on a when-issued or forward-settling basis, or with a non-standard settlement cycle, in reliance on rule 18f-4(f) (17 CFR 270.18f-4(f))? 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button not checked Yes Radio button checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button not checked Yes Radio button checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. SEC file number ( e.g., 801- )

801-25803 

iii.CRD number
000013162 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
Metlife Investment Advisors LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-67314 

iii. CRD number
000285684 
iv. LEI, if any

EAUO72Q8FCR1S0XGYJ21 

v. State, if applicable
NEW JERSEY  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii.SEC file number ( e.g., 84- or 85- )

84-05829 

iii. LEI, if any

N/A 

iv. State, if applicable
NEBRASKA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
ICE Data Services 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US Bank 
ii. LEI, if any

N1GZ7BBF3NP8GI976H15 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. LEI, if any, or provide and describe other identifying number

000013162 

Description of other identifying number

CRD Number 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 2
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or provide and describe other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
OHIO  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
a. Full name
b. SEC file number

c. CRD number
d. LEI, if any

e. State, if applicable
f. Foreign country, if applicable
g. Total commissions paid to the affiliated broker-dealer for the reporting period:


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
i. Full name of broker
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Gross commissions paid by the Fund for the reporting period

b. Aggregate brokerage commissions paid by Fund during the reporting period:

0 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
Morgan Stanley Smith Barney 
ii. SEC file number

8-68191 

iii. CRD number
000149777 
iv. LEI, if any

7PDDXEMZ0ZV0CEDU4D16 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

142,060,510.61000000 

Principal Transactions Record: 2
i. Full name of dealer
Barclays 
ii. SEC file number

8-41342 

iii. CRD number
000019714 
iv. LEI, if any

AC28XWWI3WIBK2824319 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

74,701,946.96000000 

Principal Transactions Record: 3
i. Full name of dealer
JPMorgan Chase 
ii. SEC file number

8-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

32,689,946.46000000 

Principal Transactions Record: 4
i. Full name of dealer
CITADEL SECURITIES 
ii. SEC file number

8-53574 

iii. CRD number
000116797 
iv. LEI, if any

12UUJYTN7D3SW8KCSG25 

v. State, if applicable
FLORIDA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

110,959,167.83000000 

Principal Transactions Record: 5
i. Full name of dealer
Goldman Sachs 
ii. SEC file number

8-129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

43,291,311.36999999 

Principal Transactions Record: 6
i. Full name of dealer
RELIGARE CAPITAL MARKETS 
ii. SEC file number

8-48591 

iii. CRD number
000039142 
iv. LEI, if any

549300EE5KQ1LFZMHQ89 

v. State, if applicable
FLORIDA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

58,688,382.49000000 

Principal Transactions Record: 7
i. Full name of dealer
PIERPONT CAPITAL 
ii. SEC file number

8-68282 

iii. CRD number
000150696 
iv. LEI, if any

549300LGG2RLWD21SU97 

v. State, if applicable
DELAWARE  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

31,633,215.35999999 

Principal Transactions Record: 8
i. Full name of dealer
Bank of America Merrill Lynch 
ii. SEC file number

8-7221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
NORTH CAROLINA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

116,441,557.17000000 

Principal Transactions Record: 9
i. Full name of dealer
HSBC Securities 
ii. SEC file number

8-41562 

iii. CRD number
000019585 
iv. LEI, if any

MP6I5ZYZBEU3UXPYFY54 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

441,753,148.09350002 

Principal Transactions Record: 10
i. Full name of dealer
BNP PARIBAS 
ii. SEC file number

8-40490 

iii. CRD number
000024962 
iv. LEI, if any

549300K202RXT0NG9L40 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

36,637,127.07999999 

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

1,329,822,282.45337700 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

238,720,284.00000000 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button checked Yes Radio button not checked No
If yes, for each line of credit, provide the information requested below:
Line of Credit details Record: 1
i. Is the line of credit a committed or uncommitted line of credit? Radio button not checked Committed Radio button checked Uncommitted
ii. What size is the line of credit?

50,000,000.00000000 

iii. With which institution(s) is the line of credit?
Line Institutions Record: 1
Name of institution
U.S Bank National Association 
iv. Is the line of credit just for the Fund, or is it shared among multiple funds? Radio button not checked Sole Radio button checked Shared
1. If shared, list the names of other funds that may use the line of credit.
Shared Credit Users Record: 1
Name of fund
Dunham Small Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 2
Name of fund
Dunham Corporate/Government Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 3
Name of fund
Dunham International Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 4
Name of fund
Dunham Emerging Markets Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 5
Name of fund
Dunham Large Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 6
Name of fund
Dunham International Opportunity Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 7
Name of fund
Dunham Floating Rate Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 8
Name of fund
Dunham Small Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 9
Name of fund
Dunham Real Estate Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 10
Name of fund
Dunham Monthly Distribution Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 11
Name of fund
Dunham High-Yield Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 12
Name of fund
Dunham Dynamic Macro Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 13
Name of fund
Dunham Focused Large Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
v. Did the Fund draw on the line of credit this period?Radio button not checked Yes Radio button checked No


b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 4

Item C.1. Background information.

a. Full Name of the Fund

Dunham Monthly Distribution Fund 

b. Series identication number, if any

S000022888 

c. LEI

549300BJH1DPTJHNON75 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Dunham Monthly Distribution Fund Class A 
ii. Class identification number, if any

C000066378 

iii. Ticker symbol, if any

DAMDX 

Shares Outstanding Record: 2
i. Full name of Class
Dunham Monthly Distribution Fund Class C 
ii. Class identification number, if any

C000066379 

iii. Ticker symbol, if any

DCMDX 

Shares Outstanding Record: 3
i. Full name of Class
Dunham Monthly Distribution Fund Class N 
ii. Class identification number, if any

C000066380 

iii. Ticker symbol, if any

DNMDX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any

8KUMV9EIJ75IBFMLFD23 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any:

8KUMV9EIJ75IBFMLFD23 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox checked  vi. Other  
Checkbox not checked   N/A  
If other, describe:

75% Funds/25% Securities Lending Agent 

f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

15,049,239.50000000 

g. Provide the net income from securities lending activities

22,789.03000000 


Item C.7. Reliance on certain statutory exemption and rules.

Did the Fund rely on the following statutory exemption or any of the rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  k. Rule 6c-11 (17 CFR 270.6c-11) 
Checkbox not checked  l. Rule 12d1-4 (17 CFR 270.12d1-4) 
Checkbox not checked  m. Section 12(d)(1)(G) of the Act (15 USC 80a-12(d)(1)(G)) 
Checkbox not checked  n. Rule 18f-4 (17 CFR 270.18f-4) 
Checkbox not checked  i. Is the Fund excepted from the rule 18f-4 (17 CFR 270.18f-4) program requirement and limit on fund leverage risk under rule 18f-4(c)(4) (17CFR 270.18f-4(c)(4))? 
Checkbox not checked  ii. Is the Fund a leveraged/inverse fund that, under rule 18f-4(c)(5) (17 CFR 270.18f-4(c)(5)), is excepted from the requirement to comply with the limit on fund leverage risk described in rule 18f-4(c)(2) (17 CFR 270.18f-4(c)(2))? 
Checkbox not checked  iii. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(i) (17 CFR 270.18f-4(d)(i))? 
Checkbox not checked  iv. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(ii) (17 CFR 270.18f-4(d)(ii))? 
Checkbox not checked  v. Did the Fund enter into any unfunded commitment agreements under rule 18f-4(e) (17 CFR 270.18f-4(e))? 
Checkbox not checked  vi. Did the Fund invest in a security on a when-issued or forward-settling basis, or with a non-standard settlement cycle, in reliance on rule 18f-4(f) (17 CFR 270.18f-4(f))? 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button not checked Yes Radio button checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button not checked Yes Radio button checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. SEC file number ( e.g., 801- )

801-25803 

iii.CRD number
000013162 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
Grantham, Mayo, Van Otterloo & Co., LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-15028 

iii. CRD number
000106220 
iv. LEI, if any

KG0ECHUB6SFORDPJZK65 

v. State, if applicable
MASSACHUSETTS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii.SEC file number ( e.g., 84- or 85- )

84-05829 

iii. LEI, if any

N/A 

iv. State, if applicable
NEBRASKA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
ICE Data Services 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US Bank 
ii. LEI, if any

N1GZ7BBF3NP8GI976H15 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or provide and describe other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 2
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. LEI, if any, or provide and describe other identifying number

000013162 

Description of other identifying number

CRD Number 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
a. Full name
b. SEC file number

c. CRD number
d. LEI, if any

e. State, if applicable
f. Foreign country, if applicable
g. Total commissions paid to the affiliated broker-dealer for the reporting period:


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
LIQUIDNET 
ii. SEC file number

8-52461 

iii. CRD number
000103987 
iv. LEI, if any

213800HSKBBO1GCVRG79 

v. State, if applicable
DELAWARE  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

11,751.09000000 

Brokers Record: 2
i. Full name of broker
UBS AG 
ii. SEC file number

8-22651 

iii. CRD number
000007654 
iv. LEI, if any

T6FIZBDPKLYJKFCRVK44 

v. State, if applicable
 
vi. Foreign country, if applicable
SWITZERLAND  
vii. Gross commissions paid by the Fund for the reporting period

43,730.62000000 

Brokers Record: 3
i. Full name of broker
JEFFERIES GROUP 
ii. SEC file number

8-15074 

iii. CRD number
000002347 
iv. LEI, if any

NY9Q8VBNB6D1L6YV0J84 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

125,217.63000000 

Brokers Record: 4
i. Full name of broker
COWEN GROUP 
ii. SEC file number

8-22522 

iii. CRD number
000007616 
iv. LEI, if any

549300WR155U7DVMIW58 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

94,477.71000000 

Brokers Record: 5
i. Full name of broker
JPMORGAN CHASE 
ii. SEC file number

8-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

36,400.94999999 

Brokers Record: 6
i. Full name of broker
MORGAN STANLEY SMITH BARNEY 
ii. SEC file number

8-68191 

iii. CRD number
000149777 
iv. LEI, if any

7PDDXEMZ0ZV0CEDU4D16 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

41,712.19000000 

Brokers Record: 7
i. Full name of broker
CITIBANK 
ii. SEC file number

8-8177 

iii. CRD number
000007059 
iv. LEI, if any

CYSD4L2598RQ9BPPCB72 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

21,357.63000000 

Brokers Record: 8
i. Full name of broker
INSTINET INC 
ii. SEC file number

8-23669 

iii. CRD number
000007897 
iv. LEI, if any

549300MGMN3RKMU8FT57 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

99,905.64000000 

Brokers Record: 9
i. Full name of broker
GOLDMAN SACHS 
ii. SEC file number

8-129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

8,412.41000000 

Brokers Record: 10
i. Full name of broker
UNITED FIRST PARTNERS 
ii. SEC file number

8-68718 

iii. CRD number
000155456 
iv. LEI, if any

254900WD45SOCZ7IKM52 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

18,691.38000000 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

530,762.66000000 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
MORGAN STANLEY SMITH BARNEY 
ii. SEC file number

8-68191 

iii. CRD number
000149777 
iv. LEI, if any

7PDDXEMZ0ZV0CEDU4D16 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

342,466.98964799 

Principal Transactions Record: 2
i. Full name of dealer
US BANCORP 
ii. SEC file number

8-35359 

iii. CRD number
000017868 
iv. LEI, if any

H85Z6XZP8B10ES0M2G89 

v. State, if applicable
MINNESOTA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

6,276,000.00000000 

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

336,954,059.55653387 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

249,159,224.58339715 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button checked Yes Radio button not checked No
If yes, for each line of credit, provide the information requested below:
Line of Credit details Record: 1
i. Is the line of credit a committed or uncommitted line of credit? Radio button not checked Committed Radio button checked Uncommitted
ii. What size is the line of credit?

50,000,000.00000000 

iii. With which institution(s) is the line of credit?
Line Institutions Record: 1
Name of institution
U.S Bank National Association 
iv. Is the line of credit just for the Fund, or is it shared among multiple funds? Radio button not checked Sole Radio button checked Shared
1. If shared, list the names of other funds that may use the line of credit.
Shared Credit Users Record: 1
Name of fund
Dunham Long/Short Credit 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 2
Name of fund
Dunham Dynamic Macro Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 3
Name of fund
Dunham International Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 4
Name of fund
Dunham Small Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 5
Name of fund
Dunham Emerging Markets Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 6
Name of fund
Dunham Real Estate Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 7
Name of fund
Dunham High-Yield Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 8
Name of fund
Dunham Corporate/Government Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 9
Name of fund
Dunham Small Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 10
Name of fund
Dunham International Opportunity Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 11
Name of fund
Dunham Focused Large Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 12
Name of fund
Dunham Floating Rate Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 13
Name of fund
Dunham Large Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
v. Did the Fund draw on the line of credit this period?Radio button checked Yes Radio button not checked No vi. If the fund drew on the line of credit during this period, what was the average amount outstanding when the line of credit was in use?
1,699,167.00000000 
vii. If the fund drew on the line of credit during this period, what was the number of days that the line of credit was in use?
6 



b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 5

Item C.1. Background information.

a. Full Name of the Fund

Dunham Large Cap Value Fund 

b. Series identication number, if any

S000020972 

c. LEI

5493001VLJXYGHEP4K98 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Dunham Large Cap Value Fund Class N 
ii. Class identification number, if any

C000059513 

iii. Ticker symbol, if any

DNLVX 

Shares Outstanding Record: 2
i. Full name of Class
Dunham Large Cap Value Fund Class C 
ii. Class identification number, if any

C000059512 

iii. Ticker symbol, if any

DCLVX 

Shares Outstanding Record: 3
i. Full name of Class
Dunham Large Cap Value Fund Class A 
ii. Class identification number, if any

C000059511 

iii. Ticker symbol, if any

DALVX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any

8KUMV9EIJ75IBFMLFD23 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any:

8KUMV9EIJ75IBFMLFD23 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox checked  vi. Other  
Checkbox not checked   N/A  
If other, describe:

75% Funds/25% Securities Lending Agent 

f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

15,053,010.60000000 

g. Provide the net income from securities lending activities

15,341.00000000 


Item C.7. Reliance on certain statutory exemption and rules.

Did the Fund rely on the following statutory exemption or any of the rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  k. Rule 6c-11 (17 CFR 270.6c-11) 
Checkbox not checked  l. Rule 12d1-4 (17 CFR 270.12d1-4) 
Checkbox not checked  m. Section 12(d)(1)(G) of the Act (15 USC 80a-12(d)(1)(G)) 
Checkbox not checked  n. Rule 18f-4 (17 CFR 270.18f-4) 
Checkbox not checked  i. Is the Fund excepted from the rule 18f-4 (17 CFR 270.18f-4) program requirement and limit on fund leverage risk under rule 18f-4(c)(4) (17CFR 270.18f-4(c)(4))? 
Checkbox not checked  ii. Is the Fund a leveraged/inverse fund that, under rule 18f-4(c)(5) (17 CFR 270.18f-4(c)(5)), is excepted from the requirement to comply with the limit on fund leverage risk described in rule 18f-4(c)(2) (17 CFR 270.18f-4(c)(2))? 
Checkbox not checked  iii. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(i) (17 CFR 270.18f-4(d)(i))? 
Checkbox not checked  iv. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(ii) (17 CFR 270.18f-4(d)(ii))? 
Checkbox not checked  v. Did the Fund enter into any unfunded commitment agreements under rule 18f-4(e) (17 CFR 270.18f-4(e))? 
Checkbox not checked  vi. Did the Fund invest in a security on a when-issued or forward-settling basis, or with a non-standard settlement cycle, in reliance on rule 18f-4(f) (17 CFR 270.18f-4(f))? 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button not checked Yes Radio button checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button not checked Yes Radio button checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. SEC file number ( e.g., 801- )

801-25803 

iii.CRD number
000013162 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
Rothschild & Co Asset Management, Inc. 
ii. SEC file number ( e.g., 801- ), if applicable

801-5875 

iii. CRD number
000110349 
iv. LEI, if any

9845007HYL5B8ED63A37 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii.SEC file number ( e.g., 84- or 85- )

84-05829 

iii. LEI, if any

N/A 

iv. State, if applicable
NEBRASKA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
ICE Data Services 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US Bank 
ii. LEI, if any

N1GZ7BBF3NP8GI976H15 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. LEI, if any, or provide and describe other identifying number

000013162 

Description of other identifying number

CRD Number 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 2
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or provide and describe other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
a. Full name
b. SEC file number

c. CRD number
d. LEI, if any

e. State, if applicable
f. Foreign country, if applicable
g. Total commissions paid to the affiliated broker-dealer for the reporting period:


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
Goldman Sachs 
ii. SEC file number

8-129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

474.75000000 

Brokers Record: 2
i. Full name of broker
TRUIST SECURITIES 
ii. SEC file number

8-17212 

iii. CRD number
000006271 
iv. LEI, if any

CSVTK36R0PNGXEM7NS14 

v. State, if applicable
TENNESSEE  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

732.00000000 

Brokers Record: 3
i. Full name of broker
FERRETTI GROUP 
ii. SEC file number

8-51895 

iii. CRD number
000047768 
iv. LEI, if any

254900CIWUSRGAPET478 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

1,737.29000000 

Brokers Record: 4
i. Full name of broker
RAYMOND JAMES 
ii. SEC file number

8-10999 

iii. CRD number
000000705 
iv. LEI, if any

U4ONQX15J3RO8XCKE979 

v. State, if applicable
FLORIDA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

651.70000000 

Brokers Record: 5
i. Full name of broker
COWEN & COMPANY 
ii. SEC file number

8-22522 

iii. CRD number
000007616 
iv. LEI, if any

549300WR155U7DVMIW58 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

412.79000000 

Brokers Record: 6
i. Full name of broker
BANK OF AMERICA MERRILL LYNCH 
ii. SEC file number

8-7221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
DELAWARE  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

357.35000000 

Brokers Record: 7
i. Full name of broker
CAPITAL INSTITUTIONAL SERVICES, INC. 
ii. SEC file number

8-22273 

iii. CRD number
000007551 
iv. LEI, if any

54930061X8RDWFDJIS05 

v. State, if applicable
TEXAS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

3,463.18000000 

Brokers Record: 8
i. Full name of broker
STIFEL NICOLAUS 
ii. SEC file number

008-01447 

iii. CRD number
000000793 
iv. LEI, if any

5WUVMA08EYG4KEUPW589 

v. State, if applicable
MISSOURI  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

3,548.44000000 

Brokers Record: 9
i. Full name of broker
JPMorgan Chase 
ii. SEC file number

8-129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

1,736.10000000 

Brokers Record: 10
i. Full name of broker
KEEFE, BRUYETTE & WOODS 
ii. SEC file number

8-10888 

iii. CRD number
000000481 
iv. LEI, if any

549300OM47DQV01G4854 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

567.00000000 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

14,698.69000000 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
i. Full name of dealer
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

0 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

157,932,427.96000000 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button checked Yes Radio button not checked No
If yes, for each line of credit, provide the information requested below:
Line of Credit details Record: 1
i. Is the line of credit a committed or uncommitted line of credit? Radio button not checked Committed Radio button checked Uncommitted
ii. What size is the line of credit?

50,000,000.00000000 

iii. With which institution(s) is the line of credit?
Line Institutions Record: 1
Name of institution
U.S Bank National Association 
iv. Is the line of credit just for the Fund, or is it shared among multiple funds? Radio button not checked Sole Radio button checked Shared
1. If shared, list the names of other funds that may use the line of credit.
Shared Credit Users Record: 1
Name of fund
Dunham Small Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 2
Name of fund
Dunham Corporate/Government Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 3
Name of fund
Dunham Real Estate Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 4
Name of fund
Dunham Small Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 5
Name of fund
Dunham International Opportunity Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 6
Name of fund
Dunham High-Yield Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 7
Name of fund
Dunham Focused Large Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 8
Name of fund
Dunham Long/Short Credit 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 9
Name of fund
Dunham Monthly Distribution Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 10
Name of fund
Dunham International Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 11
Name of fund
Dunham Floating Rate Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 12
Name of fund
Dunham Emerging Markets Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 13
Name of fund
Dunham Dynamic Macro Fund 
SEC File number( e.g., 811- )
811-22153 
v. Did the Fund draw on the line of credit this period?Radio button not checked Yes Radio button checked No


b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 6

Item C.1. Background information.

a. Full Name of the Fund

Dunham Small Cap Growth Fund 

b. Series identication number, if any

S000020973 

c. LEI

54930051EXOQ52YVED02 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Dunham Small Cap Growth Fund Class N 
ii. Class identification number, if any

C000059516 

iii. Ticker symbol, if any

DNDGX 

Shares Outstanding Record: 2
i. Full name of Class
Dunham Small Cap Growth Fund Class C 
ii. Class identification number, if any

C000059515 

iii. Ticker symbol, if any

DCDGX 

Shares Outstanding Record: 3
i. Full name of Class
Dunham Small Cap Growth Fund Class A 
ii. Class identification number, if any

C000059514 

iii. Ticker symbol, if any

DADGX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any

8KUMV9EIJ75IBFMLFD23 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any:

8KUMV9EIJ75IBFMLFD23 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox checked  vi. Other  
Checkbox not checked   N/A  
If other, describe:

75% Funds/25% Securities Lending Agent 

f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

15,753,765.03999999 

g. Provide the net income from securities lending activities

59,023.41000000 


Item C.7. Reliance on certain statutory exemption and rules.

Did the Fund rely on the following statutory exemption or any of the rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  k. Rule 6c-11 (17 CFR 270.6c-11) 
Checkbox not checked  l. Rule 12d1-4 (17 CFR 270.12d1-4) 
Checkbox not checked  m. Section 12(d)(1)(G) of the Act (15 USC 80a-12(d)(1)(G)) 
Checkbox not checked  n. Rule 18f-4 (17 CFR 270.18f-4) 
Checkbox not checked  i. Is the Fund excepted from the rule 18f-4 (17 CFR 270.18f-4) program requirement and limit on fund leverage risk under rule 18f-4(c)(4) (17CFR 270.18f-4(c)(4))? 
Checkbox not checked  ii. Is the Fund a leveraged/inverse fund that, under rule 18f-4(c)(5) (17 CFR 270.18f-4(c)(5)), is excepted from the requirement to comply with the limit on fund leverage risk described in rule 18f-4(c)(2) (17 CFR 270.18f-4(c)(2))? 
Checkbox not checked  iii. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(i) (17 CFR 270.18f-4(d)(i))? 
Checkbox not checked  iv. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(ii) (17 CFR 270.18f-4(d)(ii))? 
Checkbox not checked  v. Did the Fund enter into any unfunded commitment agreements under rule 18f-4(e) (17 CFR 270.18f-4(e))? 
Checkbox not checked  vi. Did the Fund invest in a security on a when-issued or forward-settling basis, or with a non-standard settlement cycle, in reliance on rule 18f-4(f) (17 CFR 270.18f-4(f))? 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button not checked Yes Radio button checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button not checked Yes Radio button checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. SEC file number ( e.g., 801- )

801-25803 

iii.CRD number
000013162 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
Pier Capital, LLC. 
ii. SEC file number ( e.g., 801- ), if applicable

801-63390 

iii. CRD number
000131212 
iv. LEI, if any

2549001TJTQYPPNJBU40 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii.SEC file number ( e.g., 84- or 85- )

84-05829 

iii. LEI, if any

N/A 

iv. State, if applicable
NEBRASKA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
ICE Data Services 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US Bank 
ii. LEI, if any

N1GZ7BBF3NP8GI976H15 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or provide and describe other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 2
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. LEI, if any, or provide and describe other identifying number

000013162 

Description of other identifying number

CRD Number 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
a. Full name
b. SEC file number

c. CRD number
d. LEI, if any

e. State, if applicable
f. Foreign country, if applicable
g. Total commissions paid to the affiliated broker-dealer for the reporting period:


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
CAPITAL INSTITUTIONAL SERVICES (CAPIS) 
ii. SEC file number

8-22273 

iii. CRD number
000007551 
iv. LEI, if any

54930061X8RDWFDJIS05 

v. State, if applicable
TEXAS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

23,430.42000000 

Brokers Record: 2
i. Full name of broker
STIFEL NICOLAUS 
ii. SEC file number

008-01447 

iii. CRD number
000000793 
iv. LEI, if any

5WUVMA08EYG4KEUPW589 

v. State, if applicable
MISSOURI  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

12,004.83000000 

Brokers Record: 3
i. Full name of broker
JPMORGAN CHASE 
ii. SEC file number

8-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

6,744.02000000 

Brokers Record: 4
i. Full name of broker
PIPER SANDLER 
ii. SEC file number

008-15204 

iii. CRD number
000000665 
iv. LEI, if any

549300GRQCWQ3XGH0H10 

v. State, if applicable
MISSOURI  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

9,179.49000000 

Brokers Record: 5
i. Full name of broker
OPPENHEIMER & CO 
ii. SEC file number

8-4077 

iii. CRD number
000000249 
iv. LEI, if any

254900VH02JQR2L8XD64 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

7,145.80000000 

Brokers Record: 6
i. Full name of broker
ROBERT W. BAIRD & CO. 
ii. SEC file number

008-00497 

iii. CRD number
000008158 
iv. LEI, if any

549300772UJAHRD6LO53 

v. State, if applicable
WISCONSIN  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

8,224.87999999 

Brokers Record: 7
i. Full name of broker
WILLIAM BLAIR & CO 
ii. SEC file number

008-02698 

iii. CRD number
000001252 
iv. LEI, if any

549300J0P7XYE8BMZ775 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

10,855.31000000 

Brokers Record: 8
i. Full name of broker
COWEN GROUP 
ii. SEC file number

8-22522 

iii. CRD number
000007616 
iv. LEI, if any

549300WR155U7DVMIW58 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

9,008.84000000 

Brokers Record: 9
i. Full name of broker
RAYMOND JAMES 
ii. SEC file number

008-10999 

iii. CRD number
000000705 
iv. LEI, if any

U4ONQX15J3RO8XCKE979 

v. State, if applicable
FLORIDA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

8,982.37999999 

Brokers Record: 10
i. Full name of broker
JEFFERIES GROUP 
ii. SEC file number

8-15074 

iii. CRD number
000002347 
iv. LEI, if any

NY9Q8VBNB6D1L6YV0J84 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

8,812.43000000 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

166,265.64000000 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
US Bancorp. 
ii. SEC file number

8-35359 

iii. CRD number
000017868 
iv. LEI, if any

H85Z6XZP8B10ES0M2G89 

v. State, if applicable
MINNESOTA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

404,000.00000000 

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

7,090,000.00000000 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

77,385,698.55802735 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button checked Yes Radio button not checked No
If yes, for each line of credit, provide the information requested below:
Line of Credit details Record: 1
i. Is the line of credit a committed or uncommitted line of credit? Radio button not checked Committed Radio button checked Uncommitted
ii. What size is the line of credit?

50,000,000.00000000 

iii. With which institution(s) is the line of credit?
Line Institutions Record: 1
Name of institution
U.S Bank National Association 
iv. Is the line of credit just for the Fund, or is it shared among multiple funds? Radio button not checked Sole Radio button checked Shared
1. If shared, list the names of other funds that may use the line of credit.
Shared Credit Users Record: 1
Name of fund
Dunham Focused Large Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 2
Name of fund
Dunham Emerging Markets Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 3
Name of fund
Dunham Monthly Distribution Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 4
Name of fund
Dunham Dynamic Macro Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 5
Name of fund
Dunham Corporate/Government Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 6
Name of fund
Dunham Floating Rate Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 7
Name of fund
Dunham Long/Short Credit 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 8
Name of fund
Dunham Real Estate Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 9
Name of fund
Dunham International Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 10
Name of fund
Dunham Small Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 11
Name of fund
Dunham International Opportunity Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 12
Name of fund
Dunham High-Yield Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 13
Name of fund
Dunham Large Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
v. Did the Fund draw on the line of credit this period?Radio button checked Yes Radio button not checked No vi. If the fund drew on the line of credit during this period, what was the average amount outstanding when the line of credit was in use?
1,066,714.00000000 
vii. If the fund drew on the line of credit during this period, what was the number of days that the line of credit was in use?
6 



b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 7

Item C.1. Background information.

a. Full Name of the Fund

Dunham Floating Rate Bond Fund 

b. Series identication number, if any

S000042248 

c. LEI

549300UGWNBB21ENNS29 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Dunham Floating Rate Bond Fund Class C 
ii. Class identification number, if any

C000131124 

iii. Ticker symbol, if any

DCFRX 

Shares Outstanding Record: 2
i. Full name of Class
Dunham Floating Rate Bond Fund Class A 
ii. Class identification number, if any

C000131123 

iii. Ticker symbol, if any

DAFRX 

Shares Outstanding Record: 3
i. Full name of Class
Dunham Floating Rate Bond Fund Class N 
ii. Class identification number, if any

C000131125 

iii. Ticker symbol, if any

DNFRX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any

8KUMV9EIJ75IBFMLFD23 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any:

8KUMV9EIJ75IBFMLFD23 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox checked  vi. Other  
Checkbox not checked   N/A  
If other, describe:

75% Funds/25% Securities Lending Agent 

f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

4,953,066.47000000 

g. Provide the net income from securities lending activities

21,391.75999999 


Item C.7. Reliance on certain statutory exemption and rules.

Did the Fund rely on the following statutory exemption or any of the rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  k. Rule 6c-11 (17 CFR 270.6c-11) 
Checkbox not checked  l. Rule 12d1-4 (17 CFR 270.12d1-4) 
Checkbox not checked  m. Section 12(d)(1)(G) of the Act (15 USC 80a-12(d)(1)(G)) 
Checkbox not checked  n. Rule 18f-4 (17 CFR 270.18f-4) 
Checkbox not checked  i. Is the Fund excepted from the rule 18f-4 (17 CFR 270.18f-4) program requirement and limit on fund leverage risk under rule 18f-4(c)(4) (17CFR 270.18f-4(c)(4))? 
Checkbox not checked  ii. Is the Fund a leveraged/inverse fund that, under rule 18f-4(c)(5) (17 CFR 270.18f-4(c)(5)), is excepted from the requirement to comply with the limit on fund leverage risk described in rule 18f-4(c)(2) (17 CFR 270.18f-4(c)(2))? 
Checkbox not checked  iii. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(i) (17 CFR 270.18f-4(d)(i))? 
Checkbox not checked  iv. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(ii) (17 CFR 270.18f-4(d)(ii))? 
Checkbox not checked  v. Did the Fund enter into any unfunded commitment agreements under rule 18f-4(e) (17 CFR 270.18f-4(e))? 
Checkbox not checked  vi. Did the Fund invest in a security on a when-issued or forward-settling basis, or with a non-standard settlement cycle, in reliance on rule 18f-4(f) (17 CFR 270.18f-4(f))? 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button not checked Yes Radio button checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button not checked Yes Radio button checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. SEC file number ( e.g., 801- )

801-25803 

iii.CRD number
000013162 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
Pinebridge Investments, LLC. 
ii. SEC file number ( e.g., 801- ), if applicable

801-18759 

iii. CRD number
000105926 
iv. LEI, if any

CLDVY8VY4GNT81Q4VM57 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii.SEC file number ( e.g., 84- or 85- )

84-05829 

iii. LEI, if any

N/A 

iv. State, if applicable
NEBRASKA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
ICE Data Services 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US Bank 
ii. LEI, if any

N1GZ7BBF3NP8GI976H15 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or provide and describe other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 2
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. LEI, if any, or provide and describe other identifying number

000013162 

Description of other identifying number

CRD Number 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
a. Full name
b. SEC file number

c. CRD number
d. LEI, if any

e. State, if applicable
f. Foreign country, if applicable
g. Total commissions paid to the affiliated broker-dealer for the reporting period:


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
Bloomberg 
ii. SEC file number

8-49219 

iii. CRD number
000040881 
iv. LEI, if any

549300B56MD0ZC402L06 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

4,000 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

4,000 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
Credit Suisse 
ii. SEC file number

8-422 

iii. CRD number
000000816 
iv. LEI, if any

549300506SI9CRFV9Z86 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

23,466,079.08830300 

Principal Transactions Record: 2
i. Full name of dealer
Goldman Sachs 
ii. SEC file number

8-129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

35,542,007.19651820 

Principal Transactions Record: 3
i. Full name of dealer
Bank of America Merrill Lynch 
ii. SEC file number

8-7221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
NORTH CAROLINA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

56,829,065.77444270 

Principal Transactions Record: 4
i. Full name of dealer
Barclays 
ii. SEC file number

8-41342 

iii. CRD number
000019714 
iv. LEI, if any

AC28XWWI3WIBK2824319 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

30,159,330.37252080 

Principal Transactions Record: 5
i. Full name of dealer
Citibank 
ii. SEC file number

8-8177 

iii. CRD number
000007059 
iv. LEI, if any

CYSD4L2598RQ9BPPCB72 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

14,448,434.07055710 

Principal Transactions Record: 6
i. Full name of dealer
JP Morgan Chase 
ii. SEC file number

8-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

58,073,438.66000000 

Principal Transactions Record: 7
i. Full name of dealer
US Bancorp 
ii. SEC file number

8-35359 

iii. CRD number
000017868 
iv. LEI, if any

H85Z6XZP8B10ES0M2G89 

v. State, if applicable
DELAWARE  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

42,340,908.53980000 

Principal Transactions Record: 8
i. Full name of dealer
ROYAL BANK OF CANADA CAPITAL MARKETS 
ii. SEC file number

8-39947 

iii. CRD number
000022698 
iv. LEI, if any

ES7IP3U3RHIGC71XBU11 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

12,288,634.69787420 

Principal Transactions Record: 9
i. Full name of dealer
Wells Fargo bank 
ii. SEC file number

8-65876 

iii. CRD number
000126292 
iv. LEI, if any

VYVVCKR63DVZZN70PB21 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

13,620,568.07851980 

Principal Transactions Record: 10
i. Full name of dealer
Deutsche Bank 
ii. SEC file number

8-17822 

iii. CRD number
000002525 
iv. LEI, if any

9J6MBOOO7BECTDTUZW19 

v. State, if applicable
DELAWARE  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

11,864,332.11427499 

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

413,158,392.24117600 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

196,198,056.01279458 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button checked Yes Radio button not checked No
If yes, for each line of credit, provide the information requested below:
Line of Credit details Record: 1
i. Is the line of credit a committed or uncommitted line of credit? Radio button not checked Committed Radio button checked Uncommitted
ii. What size is the line of credit?

50,000,000.00000000 

iii. With which institution(s) is the line of credit?
Line Institutions Record: 1
Name of institution
U.S Bank National Association 
iv. Is the line of credit just for the Fund, or is it shared among multiple funds? Radio button not checked Sole Radio button checked Shared
1. If shared, list the names of other funds that may use the line of credit.
Shared Credit Users Record: 1
Name of fund
Dunham Large Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 2
Name of fund
Dunham Corporate/Government Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 3
Name of fund
Dunham International Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 4
Name of fund
Dunham International Opportunity Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 5
Name of fund
Dunham Real Estate Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 6
Name of fund
Dunham Dynamic Macro Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 7
Name of fund
Dunham Small Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 8
Name of fund
Dunham Monthly Distribution Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 9
Name of fund
Dunham Long/Short Credit 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 10
Name of fund
Dunham Focused Large Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 11
Name of fund
Dunham Emerging Markets Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 12
Name of fund
Dunham Small Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 13
Name of fund
Dunham High-Yield Bond Fund 
SEC File number( e.g., 811- )
811-22153 
v. Did the Fund draw on the line of credit this period?Radio button checked Yes Radio button not checked No vi. If the fund drew on the line of credit during this period, what was the average amount outstanding when the line of credit was in use?
3,105,524.00000000 
vii. If the fund drew on the line of credit during this period, what was the number of days that the line of credit was in use?
21 



b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 8

Item C.1. Background information.

a. Full Name of the Fund

Dunham High Yield Bond 

b. Series identication number, if any

S000020978 

c. LEI

549300EMO57TQ4UQFX73 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Dunham High Yield Bond Fund Class A 
ii. Class identification number, if any

C000059529 

iii. Ticker symbol, if any

DAHYX 

Shares Outstanding Record: 2
i. Full name of Class
Dunham High Yield Bond Fund Class C 
ii. Class identification number, if any

C000059530 

iii. Ticker symbol, if any

DCHYX 

Shares Outstanding Record: 3
i. Full name of Class
Dunham High Yield Bond Fund Class N 
ii. Class identification number, if any

C000059531 

iii. Ticker symbol, if any

DNHYX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any

8KUMV9EIJ75IBFMLFD23 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any:

8KUMV9EIJ75IBFMLFD23 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox checked  vi. Other  
Checkbox not checked   N/A  
If other, describe:

75% Funds/25% Securities Lending Agent 

f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

8,798,856.43000000 

g. Provide the net income from securities lending activities

40,639.67000000 


Item C.7. Reliance on certain statutory exemption and rules.

Did the Fund rely on the following statutory exemption or any of the rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  k. Rule 6c-11 (17 CFR 270.6c-11) 
Checkbox not checked  l. Rule 12d1-4 (17 CFR 270.12d1-4) 
Checkbox not checked  m. Section 12(d)(1)(G) of the Act (15 USC 80a-12(d)(1)(G)) 
Checkbox not checked  n. Rule 18f-4 (17 CFR 270.18f-4) 
Checkbox not checked  i. Is the Fund excepted from the rule 18f-4 (17 CFR 270.18f-4) program requirement and limit on fund leverage risk under rule 18f-4(c)(4) (17CFR 270.18f-4(c)(4))? 
Checkbox not checked  ii. Is the Fund a leveraged/inverse fund that, under rule 18f-4(c)(5) (17 CFR 270.18f-4(c)(5)), is excepted from the requirement to comply with the limit on fund leverage risk described in rule 18f-4(c)(2) (17 CFR 270.18f-4(c)(2))? 
Checkbox not checked  iii. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(i) (17 CFR 270.18f-4(d)(i))? 
Checkbox not checked  iv. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(ii) (17 CFR 270.18f-4(d)(ii))? 
Checkbox not checked  v. Did the Fund enter into any unfunded commitment agreements under rule 18f-4(e) (17 CFR 270.18f-4(e))? 
Checkbox not checked  vi. Did the Fund invest in a security on a when-issued or forward-settling basis, or with a non-standard settlement cycle, in reliance on rule 18f-4(f) (17 CFR 270.18f-4(f))? 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button not checked Yes Radio button checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button not checked Yes Radio button checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. SEC file number ( e.g., 801- )

801-25803 

iii.CRD number
000013162 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
Pinebridge Investments, LLC. 
ii. SEC file number ( e.g., 801- ), if applicable

801-18759 

iii. CRD number
000105926 
iv. LEI, if any

CLDVY8VY4GNT81Q4VM57 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii.SEC file number ( e.g., 84- or 85- )

84-05829 

iii. LEI, if any

N/A 

iv. State, if applicable
NEBRASKA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
ICE Data Services 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US Bank 
ii. LEI, if any

N1GZ7BBF3NP8GI976H15 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. LEI, if any, or provide and describe other identifying number

000013162 

Description of other identifying number

CRD Number 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 2
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or provide and describe other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
a. Full name
b. SEC file number

c. CRD number
d. LEI, if any

e. State, if applicable
f. Foreign country, if applicable
g. Total commissions paid to the affiliated broker-dealer for the reporting period:


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
i. Full name of broker
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Gross commissions paid by the Fund for the reporting period

b. Aggregate brokerage commissions paid by Fund during the reporting period:

0 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
GOLDMAN SACHS 
ii. SEC file number

8-129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

10,268,618.20085230 

Principal Transactions Record: 2
i. Full name of dealer
RAYMOND JAMES 
ii. SEC file number

008-10999 

iii. CRD number
000000705 
iv. LEI, if any

U4ONQX15J3RO8XCKE979 

v. State, if applicable
FLORIDA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

8,345,400.00000000 

Principal Transactions Record: 3
i. Full name of dealer
BANK OF AMERICA MERRILL LYNCH 
ii. SEC file number

8-7221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
NORTH CAROLINA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

11,573,716.42999870 

Principal Transactions Record: 4
i. Full name of dealer
CREDIT SUISSE FIRST BOSTON 
ii. SEC file number

8-422 

iii. CRD number
000000816 
iv. LEI, if any

549300506SI9CRFV9Z86 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

4,505,757.00000000 

Principal Transactions Record: 5
i. Full name of dealer
JEFFERIES GROUP 
ii. SEC file number

8-15074 

iii. CRD number
000002347 
iv. LEI, if any

NY9Q8VBNB6D1L6YV0J84 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

5,419,983.59999999 

Principal Transactions Record: 6
i. Full name of dealer
CITIGROUP 
ii. SEC file number

8-8177 

iii. CRD number
000007059 
iv. LEI, if any

MBNUM2BPBDO7JBLYG310 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

9,936,605.86000000 

Principal Transactions Record: 7
i. Full name of dealer
MORGAN STANLEY SMITH BARNEY 
ii. SEC file number

8-68191 

iii. CRD number
000149777 
iv. LEI, if any

7PDDXEMZ0ZV0CEDU4D16 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

4,843,306.84000000 

Principal Transactions Record: 8
i. Full name of dealer
JPMORGAN CHASE 
ii. SEC file number

8-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

8,310,408.68035578 

Principal Transactions Record: 9
i. Full name of dealer
BARCLAYS 
ii. SEC file number

8-41342 

iii. CRD number
000019714 
iv. LEI, if any

AC28XWWI3WIBK2824319 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

5,598,196.50000000 

Principal Transactions Record: 10
i. Full name of dealer
WELLS FARGO BANK 
ii. SEC file number

8-65876 

iii. CRD number
000126292 
iv. LEI, if any

VYVVCKR63DVZZN70PB21 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

4,493,950.00000000 

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

90,062,784.66014950 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

107,302,371.60723288 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button checked Yes Radio button not checked No
If yes, for each line of credit, provide the information requested below:
Line of Credit details Record: 1
i. Is the line of credit a committed or uncommitted line of credit? Radio button not checked Committed Radio button checked Uncommitted
ii. What size is the line of credit?

50,000,000.00000000 

iii. With which institution(s) is the line of credit?
Line Institutions Record: 1
Name of institution
U.S Bank National Association 
iv. Is the line of credit just for the Fund, or is it shared among multiple funds? Radio button not checked Sole Radio button checked Shared
1. If shared, list the names of other funds that may use the line of credit.
Shared Credit Users Record: 1
Name of fund
Dunham Small Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 2
Name of fund
Dunham International Opportunity Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 3
Name of fund
Dunham Corporate/Government Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 4
Name of fund
Dunham Focused Large Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 5
Name of fund
Dunham Emerging Markets Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 6
Name of fund
Dunham Long/Short Credit 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 7
Name of fund
Dunham Floating Rate Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 8
Name of fund
Dunham Dynamic Macro Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 9
Name of fund
Dunham Small Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 10
Name of fund
Dunham Monthly Distribution Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 11
Name of fund
Dunham Real Estate Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 12
Name of fund
Dunham International Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 13
Name of fund
Dunham Large Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
v. Did the Fund draw on the line of credit this period?Radio button not checked Yes Radio button checked No


b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 9

Item C.1. Background information.

a. Full Name of the Fund

Dunham International Stock Fund 

b. Series identication number, if any

S000020979 

c. LEI

549300HN7WF948JOOR53 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Dunham International Stock Fund Class A 
ii. Class identification number, if any

C000059532 

iii. Ticker symbol, if any

DAINX 

Shares Outstanding Record: 2
i. Full name of Class
Dunham International Stock Fund Class N 
ii. Class identification number, if any

C000059534 

iii. Ticker symbol, if any

DNINX 

Shares Outstanding Record: 3
i. Full name of Class
Dunham International Stock Fund Class C 
ii. Class identification number, if any

C000059533 

iii. Ticker symbol, if any

DCINX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any

8KUMV9EIJ75IBFMLFD23 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any:

8KUMV9EIJ75IBFMLFD23 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox checked  vi. Other  
Checkbox not checked   N/A  
If other, describe:

75% Funds/25% Securities Lending Agent 

f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

10,838,452.61999999 

g. Provide the net income from securities lending activities

43,683.00000000 


Item C.7. Reliance on certain statutory exemption and rules.

Did the Fund rely on the following statutory exemption or any of the rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  k. Rule 6c-11 (17 CFR 270.6c-11) 
Checkbox not checked  l. Rule 12d1-4 (17 CFR 270.12d1-4) 
Checkbox not checked  m. Section 12(d)(1)(G) of the Act (15 USC 80a-12(d)(1)(G)) 
Checkbox not checked  n. Rule 18f-4 (17 CFR 270.18f-4) 
Checkbox not checked  i. Is the Fund excepted from the rule 18f-4 (17 CFR 270.18f-4) program requirement and limit on fund leverage risk under rule 18f-4(c)(4) (17CFR 270.18f-4(c)(4))? 
Checkbox not checked  ii. Is the Fund a leveraged/inverse fund that, under rule 18f-4(c)(5) (17 CFR 270.18f-4(c)(5)), is excepted from the requirement to comply with the limit on fund leverage risk described in rule 18f-4(c)(2) (17 CFR 270.18f-4(c)(2))? 
Checkbox not checked  iii. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(i) (17 CFR 270.18f-4(d)(i))? 
Checkbox not checked  iv. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(ii) (17 CFR 270.18f-4(d)(ii))? 
Checkbox not checked  v. Did the Fund enter into any unfunded commitment agreements under rule 18f-4(e) (17 CFR 270.18f-4(e))? 
Checkbox not checked  vi. Did the Fund invest in a security on a when-issued or forward-settling basis, or with a non-standard settlement cycle, in reliance on rule 18f-4(f) (17 CFR 270.18f-4(f))? 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button not checked Yes Radio button checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button not checked Yes Radio button checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. SEC file number ( e.g., 801- )

801-25803 

iii.CRD number
000013162 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
Arrowstreet Capital Limited Partnership 
ii. SEC file number ( e.g., 801- ), if applicable

801-56633 

iii. CRD number
000111298 
iv. LEI, if any

LO3UDTZUG0RICVPFGQ53 

v. State, if applicable
MASSACHUSETTS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii.SEC file number ( e.g., 84- or 85- )

84-05829 

iii. LEI, if any

N/A 

iv. State, if applicable
NEBRASKA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
ICE Data Services 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US Bank 
ii. LEI, if any

N1GZ7BBF3NP8GI976H15 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. LEI, if any, or provide and describe other identifying number

000013162 

Description of other identifying number

CRD Number 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 2
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or provide and describe other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
a. Full name
b. SEC file number

c. CRD number
d. LEI, if any

e. State, if applicable
f. Foreign country, if applicable
g. Total commissions paid to the affiliated broker-dealer for the reporting period:


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
BANK OF MONTREAL 
ii. SEC file number

8-67064 

iii. CRD number
000137115 
iv. LEI, if any

3Y4U8VZURTYWI1W2K376 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

3,215.38000000 

Brokers Record: 2
i. Full name of broker
MORGAN STANLEY SMITH BARNEY 
ii. SEC file number

8-68191 

iii. CRD number
000149777 
iv. LEI, if any

7PDDXEMZ0ZV0CEDU4D16 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

3,484.24000000 

Brokers Record: 3
i. Full name of broker
BARCLAYS 
ii. SEC file number

8-41342 

iii. CRD number
000019714 
iv. LEI, if any

AC28XWWI3WIBK2824319 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

3,481.34000000 

Brokers Record: 4
i. Full name of broker
BANK OF AMERICA MERRILL LYNCH 
ii. SEC file number

8-7221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
DELAWARE  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

3,956.08000000 

Brokers Record: 5
i. Full name of broker
CITIGROUP 
ii. SEC file number

8-8177 

iii. CRD number
000007059 
iv. LEI, if any

MBNUM2BPBDO7JBLYG310 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

4,296.17000000 

Brokers Record: 6
i. Full name of broker
JPMORGAN CHASE 
ii. SEC file number

8-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

5,006.10000000 

Brokers Record: 7
i. Full name of broker
ROYAL BANK OF CANADA CAPITAL MARKETS 
ii. SEC file number

8-39947 

iii. CRD number
000022698 
iv. LEI, if any

ES7IP3U3RHIGC71XBU11 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

2,788.37000000 

Brokers Record: 8
i. Full name of broker
UBS 
ii. SEC file number

8-22651 

iii. CRD number
000007654 
iv. LEI, if any

T6FIZBDPKLYJKFCRVK44 

v. State, if applicable
 
vi. Foreign country, if applicable
CENTRAL AFRICAN REPUBLIC  
vii. Gross commissions paid by the Fund for the reporting period

2,739.72000000 

Brokers Record: 9
i. Full name of broker
JEFFERIES GROUP 
ii. SEC file number

8-15074 

iii. CRD number
000002347 
iv. LEI, if any

58PU97L1C0WSRCWADL48 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

2,924.87000000 

Brokers Record: 10
i. Full name of broker
PENSERRA SECURITIES 
ii. SEC file number

8-67773 

iii. CRD number
000145994 
iv. LEI, if any

549300WY8ZBI168Y6Z05 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

4,030.63000000 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

59,174.44000000 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
US BANCORP 
ii. SEC file number

8-35359 

iii. CRD number
000017868 
iv. LEI, if any

H85Z6XZP8B10ES0M2G89 

v. State, if applicable
DELAWARE  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

14,528,000.00000000 

Principal Transactions Record: 2
i. Full name of dealer
UBS 
ii. SEC file number

8-22651 

iii. CRD number
000007654 
iv. LEI, if any

T6FIZBDPKLYJKFCRVK44 

v. State, if applicable
 
vi. Foreign country, if applicable
CENTRAL AFRICAN REPUBLIC  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

5,331.38000000 

Principal Transactions Record: 3
i. Full name of dealer
JPMORGAN CHASE 
ii. SEC file number

8-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

5.91000000 

Principal Transactions Record: 4
i. Full name of dealer
COWEN & COMPANY 
ii. SEC file number

8-22522 

iii. CRD number
000007616 
iv. LEI, if any

549300WR155U7DVMIW58 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

337,328.56000000 

Principal Transactions Record: 5
i. Full name of dealer
HSBC SECURITIES 
ii. SEC file number

8-41562 

iii. CRD number
000019585 
iv. LEI, if any

CYYGQCGNHMHPSMRL3R97 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

27,269.46000000 

Principal Transactions Record: 6
i. Full name of dealer
UBS 
ii. SEC file number

8-22651 

iii. CRD number
000007654 
iv. LEI, if any

T6FIZBDPKLYJKFCRVK44 

v. State, if applicable
 
vi. Foreign country, if applicable
CENTRAL AFRICAN REPUBLIC  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

4,617,468.24000000 

Principal Transactions Record: 7
i. Full name of dealer
NOMURA GROUP 
ii. SEC file number

8-15255 

iii. CRD number
000004297 
iv. LEI, if any

OXTKY6Q8X53C9ILVV871 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

7.98000000 

Principal Transactions Record: 8
i. Full name of dealer
MORGAN STANLEY SMITH BARNEY 
ii. SEC file number

8-68191 

iii. CRD number
000149777 
iv. LEI, if any

7PDDXEMZ0ZV0CEDU4D16 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

396,277.09000000 

Principal Transactions Record: 9
i. Full name of dealer
BANK OF AMERICA MERRILL LYNCH 
ii. SEC file number

8-7221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
DELAWARE  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

230,018.12000000 

Principal Transactions Record: 10
i. Full name of dealer
BARCLAYS 
ii. SEC file number

8-41342 

iii. CRD number
000019714 
iv. LEI, if any

AC28XWWI3WIBK2824319 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

168,832.43000000 

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

19,145,476.22000000 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

161,836,223.52000000 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button checked Yes Radio button not checked No
If yes, for each line of credit, provide the information requested below:
Line of Credit details Record: 1
i. Is the line of credit a committed or uncommitted line of credit? Radio button not checked Committed Radio button checked Uncommitted
ii. What size is the line of credit?

50,000,000.00000000 

iii. With which institution(s) is the line of credit?
Line Institutions Record: 1
Name of institution
U.S Bank National Association 
iv. Is the line of credit just for the Fund, or is it shared among multiple funds? Radio button not checked Sole Radio button checked Shared
1. If shared, list the names of other funds that may use the line of credit.
Shared Credit Users Record: 1
Name of fund
Dunham Floating Rate Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 2
Name of fund
Dunham Corporate/Government Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 3
Name of fund
Dunham Monthly Distribution Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 4
Name of fund
Dunham Dynamic Macro Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 5
Name of fund
Dunham Small Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 6
Name of fund
Dunham High-Yield Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 7
Name of fund
Dunham International Opportunity Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 8
Name of fund
Dunham Long/Short Credit 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 9
Name of fund
Dunham Large Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 10
Name of fund
Dunham Focused Large Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 11
Name of fund
Dunham Real Estate Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 12
Name of fund
Dunham Small Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 13
Name of fund
Dunham Emerging Markets Stock Fund 
SEC File number( e.g., 811- )
811-22153 
v. Did the Fund draw on the line of credit this period?Radio button checked Yes Radio button not checked No vi. If the fund drew on the line of credit during this period, what was the average amount outstanding when the line of credit was in use?
475,521.00000000 
vii. If the fund drew on the line of credit during this period, what was the number of days that the line of credit was in use?
48 



b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 10

Item C.1. Background information.

a. Full Name of the Fund

Dunham Real Estate Stock Fund 

b. Series identication number, if any

S000020971 

c. LEI

549300NHRSYVLPC3PQ36 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Dunham Real Estate Stock Fund Class C 
ii. Class identification number, if any

C000059509 

iii. Ticker symbol, if any

DCREX 

Shares Outstanding Record: 2
i. Full name of Class
Dunham Real Estate Stock Fund Class N 
ii. Class identification number, if any

C000059510 

iii. Ticker symbol, if any

DNREX 

Shares Outstanding Record: 3
i. Full name of Class
Dunham Real Estate Stock Fund Class A 
ii. Class identification number, if any

C000059508 

iii. Ticker symbol, if any

DAREX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button checked Yes Radio button not checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any

8KUMV9EIJ75IBFMLFD23 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any:

8KUMV9EIJ75IBFMLFD23 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox checked  vi. Other  
Checkbox not checked   N/A  
If other, describe:

75% Funds/25% Securities Lending Agent 

f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

21,423,632.94999999 

g. Provide the net income from securities lending activities

119,626.70000000 


Item C.7. Reliance on certain statutory exemption and rules.

Did the Fund rely on the following statutory exemption or any of the rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  k. Rule 6c-11 (17 CFR 270.6c-11) 
Checkbox not checked  l. Rule 12d1-4 (17 CFR 270.12d1-4) 
Checkbox not checked  m. Section 12(d)(1)(G) of the Act (15 USC 80a-12(d)(1)(G)) 
Checkbox not checked  n. Rule 18f-4 (17 CFR 270.18f-4) 
Checkbox not checked  i. Is the Fund excepted from the rule 18f-4 (17 CFR 270.18f-4) program requirement and limit on fund leverage risk under rule 18f-4(c)(4) (17CFR 270.18f-4(c)(4))? 
Checkbox not checked  ii. Is the Fund a leveraged/inverse fund that, under rule 18f-4(c)(5) (17 CFR 270.18f-4(c)(5)), is excepted from the requirement to comply with the limit on fund leverage risk described in rule 18f-4(c)(2) (17 CFR 270.18f-4(c)(2))? 
Checkbox not checked  iii. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(i) (17 CFR 270.18f-4(d)(i))? 
Checkbox not checked  iv. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(ii) (17 CFR 270.18f-4(d)(ii))? 
Checkbox not checked  v. Did the Fund enter into any unfunded commitment agreements under rule 18f-4(e) (17 CFR 270.18f-4(e))? 
Checkbox not checked  vi. Did the Fund invest in a security on a when-issued or forward-settling basis, or with a non-standard settlement cycle, in reliance on rule 18f-4(f) (17 CFR 270.18f-4(f))? 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button not checked Yes Radio button checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button not checked Yes Radio button checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. SEC file number ( e.g., 801- )

801-25803 

iii.CRD number
000013162 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
American Assets Capital Advisers, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-80101 

iii. CRD number
000168805 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii.SEC file number ( e.g., 84- or 85- )

84-05829 

iii. LEI, if any

N/A 

iv. State, if applicable
NEBRASKA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
ICE Data Services 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US Bank 
ii. LEI, if any

N1GZ7BBF3NP8GI976H15 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or provide and describe other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 2
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. LEI, if any, or provide and describe other identifying number

000013162 

Description of other identifying number

CRD Number 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
a. Full name
b. SEC file number

c. CRD number
d. LEI, if any

e. State, if applicable
f. Foreign country, if applicable
g. Total commissions paid to the affiliated broker-dealer for the reporting period:


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
STIFEL NICOLAUS 
ii. SEC file number

008-01447 

iii. CRD number
000000793 
iv. LEI, if any

5WUVMA08EYG4KEUPW589 

v. State, if applicable
MISSOURI  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

16,682.88000000 

Brokers Record: 2
i. Full name of broker
ALEX.BROWN 
ii. SEC file number

008-10999 

iii. CRD number
000000705 
iv. LEI, if any

U4ONQX15J3RO8XCKE979 

v. State, if applicable
MARYLAND  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

11,764.70000000 

Brokers Record: 3
i. Full name of broker
MORGAN STANLEY SMITH BARNEY 
ii. SEC file number

8-68191 

iii. CRD number
000149777 
iv. LEI, if any

7PDDXEMZ0ZV0CEDU4D16 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

16,419.18000000 

Brokers Record: 4
i. Full name of broker
WELLS FARGO BANK 
ii. SEC file number

8-65876 

iii. CRD number
000126292 
iv. LEI, if any

VYVVCKR63DVZZN70PB21 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

10,450.23000000 

Brokers Record: 5
i. Full name of broker
JPMORGAN CHASE 
ii. SEC file number

8-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

28,612.83000000 

Brokers Record: 6
i. Full name of broker
COMPASS POINT 
ii. SEC file number

8-65866 

iii. CRD number
000126258 
iv. LEI, if any

254900VW04UOPUJ5PX70 

v. State, if applicable
MARYLAND  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

8,463.50000000 

Brokers Record: 7
i. Full name of broker
RAYMOND JAMES 
ii. SEC file number

008-10999 

iii. CRD number
000000705 
iv. LEI, if any

U4ONQX15J3RO8XCKE979 

v. State, if applicable
FLORIDA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

18,979.84000000 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

117,874.98000000 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
US Bancorp. 
ii. SEC file number

8-35359 

iii. CRD number
000017868 
iv. LEI, if any

H85Z6XZP8B10ES0M2G89 

v. State, if applicable
MINNESOTA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

971,000.00000000 

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

10,494,014.88999974 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

92,356,460.92432874 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button checked Yes Radio button not checked No
If yes, for each line of credit, provide the information requested below:
Line of Credit details Record: 1
i. Is the line of credit a committed or uncommitted line of credit? Radio button not checked Committed Radio button checked Uncommitted
ii. What size is the line of credit?

50,000,000.00000000 

iii. With which institution(s) is the line of credit?
Line Institutions Record: 1
Name of institution
U.S Bank National Association 
iv. Is the line of credit just for the Fund, or is it shared among multiple funds? Radio button not checked Sole Radio button checked Shared
1. If shared, list the names of other funds that may use the line of credit.
Shared Credit Users Record: 1
Name of fund
Dunham Focused Large Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 2
Name of fund
Dunham Emerging Markets Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 3
Name of fund
Dunham Large Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 4
Name of fund
Dunham Long/Short Credit 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 5
Name of fund
Dunham Small Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 6
Name of fund
Dunham Dynamic Macro Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 7
Name of fund
Dunham Corporate/Government Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 8
Name of fund
Dunham Monthly Distribution Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 9
Name of fund
Dunham International Opportunity Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 10
Name of fund
Dunham High-Yield Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 11
Name of fund
Dunham Small Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 12
Name of fund
Dunham Floating Rate Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 13
Name of fund
Dunham International Stock Fund 
SEC File number( e.g., 811- )
811-22153 
v. Did the Fund draw on the line of credit this period?Radio button checked Yes Radio button not checked No vi. If the fund drew on the line of credit during this period, what was the average amount outstanding when the line of credit was in use?
560,949.00000000 
vii. If the fund drew on the line of credit during this period, what was the number of days that the line of credit was in use?
39 



b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 11

Item C.1. Background information.

a. Full Name of the Fund

Dunham Emerging Markets Stock Fund 

b. Series identication number, if any

S000020977 

c. LEI

549300H44PWNDVV6MH44 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Dunham Emerging Markets Stock Fund Class C 
ii. Class identification number, if any

C000059527 

iii. Ticker symbol, if any

DCEMX 

Shares Outstanding Record: 2
i. Full name of Class
Dunham Emerging Markets Stock Fund Class N 
ii. Class identification number, if any

C000059528 

iii. Ticker symbol, if any

DNEMX 

Shares Outstanding Record: 3
i. Full name of Class
Dunham Emerging Markets Stock Fund Class A 
ii. Class identification number, if any

C000059526 

iii. Ticker symbol, if any

DAEMX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any

8KUMV9EIJ75IBFMLFD23 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any:

8KUMV9EIJ75IBFMLFD23 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox checked  vi. Other  
Checkbox not checked   N/A  
If other, describe:

75% Funds/25% Securities Lending Agent 

f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

1,590,940.23000000 

g. Provide the net income from securities lending activities

2,489.00000000 


Item C.7. Reliance on certain statutory exemption and rules.

Did the Fund rely on the following statutory exemption or any of the rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  k. Rule 6c-11 (17 CFR 270.6c-11) 
Checkbox not checked  l. Rule 12d1-4 (17 CFR 270.12d1-4) 
Checkbox not checked  m. Section 12(d)(1)(G) of the Act (15 USC 80a-12(d)(1)(G)) 
Checkbox not checked  n. Rule 18f-4 (17 CFR 270.18f-4) 
Checkbox not checked  i. Is the Fund excepted from the rule 18f-4 (17 CFR 270.18f-4) program requirement and limit on fund leverage risk under rule 18f-4(c)(4) (17CFR 270.18f-4(c)(4))? 
Checkbox not checked  ii. Is the Fund a leveraged/inverse fund that, under rule 18f-4(c)(5) (17 CFR 270.18f-4(c)(5)), is excepted from the requirement to comply with the limit on fund leverage risk described in rule 18f-4(c)(2) (17 CFR 270.18f-4(c)(2))? 
Checkbox not checked  iii. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(i) (17 CFR 270.18f-4(d)(i))? 
Checkbox not checked  iv. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(ii) (17 CFR 270.18f-4(d)(ii))? 
Checkbox not checked  v. Did the Fund enter into any unfunded commitment agreements under rule 18f-4(e) (17 CFR 270.18f-4(e))? 
Checkbox not checked  vi. Did the Fund invest in a security on a when-issued or forward-settling basis, or with a non-standard settlement cycle, in reliance on rule 18f-4(f) (17 CFR 270.18f-4(f))? 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button not checked Yes Radio button checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button not checked Yes Radio button checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. SEC file number ( e.g., 801- )

801-25803 

iii.CRD number
000013162 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
NS Partners Ltd. 
ii. SEC file number ( e.g., 801- ), if applicable

801-26315 

iii. CRD number
000110625 
iv. LEI, if any

5493007WB278T7U8VH86 

v. State, if applicable
 
vi. Foreign country, if applicable
UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii.SEC file number ( e.g., 84- or 85- )

84-05829 

iii. LEI, if any

N/A 

iv. State, if applicable
NEBRASKA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
ICE Data Services 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US Bank 
ii. LEI, if any

N1GZ7BBF3NP8GI976H15 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. LEI, if any, or provide and describe other identifying number

000013162 

Description of other identifying number

CRD Number 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 2
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or provide and describe other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
a. Full name
b. SEC file number

c. CRD number
d. LEI, if any

e. State, if applicable
f. Foreign country, if applicable
g. Total commissions paid to the affiliated broker-dealer for the reporting period:


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
CICC US SECURITIES, INC. 
ii. SEC file number

8-67544 

iii. CRD number
000143221 
iv. LEI, if any

2549000DUR72WYLKY616 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

8,749.86000000 

Brokers Record: 2
i. Full name of broker
CLSA 
ii. SEC file number

8-69166 

iii. CRD number
000165533 
iv. LEI, if any

213800M2DXATWY7JMS07 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

45,971.49000000 

Brokers Record: 3
i. Full name of broker
JEFFERIES GROUP 
ii. SEC file number

8-15074 

iii. CRD number
000002347 
iv. LEI, if any

58PU97L1C0WSRCWADL48 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

49,514.57000000 

Brokers Record: 4
i. Full name of broker
SANFORD FINANCIAL SERVICES 
ii. SEC file number

8-52942 

iii. CRD number
000151388 
iv. LEI, if any

549300I7JYZHT7D5CO04 

v. State, if applicable
MICHIGAN  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

6,495.19000000 

Brokers Record: 5
i. Full name of broker
BANK OF AMERICA MERRILL LYNCH 
ii. SEC file number

8-7221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

14,067.70000000 

Brokers Record: 6
i. Full name of broker
MAYBANK 
ii. SEC file number

8-43264 

iii. CRD number
000027861 
iv. LEI, if any

2549009H2HEH6G0DLU87 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

1,423.57000000 

Brokers Record: 7
i. Full name of broker
WOOD & COMPANY 
ii. SEC file number

8-3368 

iii. CRD number
000003798 
iv. LEI, if any

N/A 

v. State, if applicable
MASSACHUSETTS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

272.69000000 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

126,495.07000000 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
JEFFERIES GROUP 
ii. SEC file number

8-15074 

iii. CRD number
000002347 
iv. LEI, if any

58PU97L1C0WSRCWADL48 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

889,236.74000000 

Principal Transactions Record: 2
i. Full name of dealer
CLSA 
ii. SEC file number

8-69166 

iii. CRD number
000165533 
iv. LEI, if any

213800M2DXATWY7JMS07 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

32,226.20000000 

Principal Transactions Record: 3
i. Full name of dealer
U.S. BANCORP INVESTMENTS, INC. 
ii. SEC file number

8-35359 

iii. CRD number
000017868 
iv. LEI, if any

H85Z6XZP8B10ES0M2G89 

v. State, if applicable
DELAWARE  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

704,500.00000000 

Principal Transactions Record: 4
i. Full name of dealer
CLSA 
ii. SEC file number

8-69166 

iii. CRD number
000165533 
iv. LEI, if any

213800M2DXATWY7JMS07 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

45,971.49 

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

7,934,236.74000000 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

122,243,021.56000000 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button checked Yes Radio button not checked No
If yes, for each line of credit, provide the information requested below:
Line of Credit details Record: 1
i. Is the line of credit a committed or uncommitted line of credit? Radio button not checked Committed Radio button checked Uncommitted
ii. What size is the line of credit?

50,000,000.00000000 

iii. With which institution(s) is the line of credit?
Line Institutions Record: 1
Name of institution
U.S Bank National Association 
iv. Is the line of credit just for the Fund, or is it shared among multiple funds? Radio button not checked Sole Radio button checked Shared
1. If shared, list the names of other funds that may use the line of credit.
Shared Credit Users Record: 1
Name of fund
Dunham Corporate/Government Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 2
Name of fund
Dunham Monthly Distribution Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 3
Name of fund
Dunham Dynamic Macro Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 4
Name of fund
Dunham High-Yield Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 5
Name of fund
Dunham International Opportunity Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 6
Name of fund
Dunham Long/Short Credit 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 7
Name of fund
Dunham Large Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 8
Name of fund
Dunham Focused Large Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 9
Name of fund
Dunham International Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 10
Name of fund
Dunham Real Estate Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 11
Name of fund
Dunham Small Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 12
Name of fund
Dunham Floating Rate Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 13
Name of fund
Dunham Small Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
v. Did the Fund draw on the line of credit this period?Radio button checked Yes Radio button not checked No vi. If the fund drew on the line of credit during this period, what was the average amount outstanding when the line of credit was in use?
577,545.00000000 
vii. If the fund drew on the line of credit during this period, what was the number of days that the line of credit was in use?
22 



b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 12

Item C.1. Background information.

a. Full Name of the Fund

Dunham Corporate/Government Bond Fund 

b. Series identication number, if any

S000020976 

c. LEI

549300TMDJ8PGJIEKS74 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Dunham Corporate/Government Bond Fund Class N 
ii. Class identification number, if any

C000059525 

iii. Ticker symbol, if any

DNCGX 

Shares Outstanding Record: 2
i. Full name of Class
Dunham Corporate/Government Bond Fund Class A 
ii. Class identification number, if any

C000059523 

iii. Ticker symbol, if any

DACGX 

Shares Outstanding Record: 3
i. Full name of Class
Dunham Corporate/Government Bond Fund Class C 
ii. Class identification number, if any

C000059524 

iii. Ticker symbol, if any

DCCGX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any

8KUMV9EIJ75IBFMLFD23 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any:

8KUMV9EIJ75IBFMLFD23 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox checked  vi. Other  
Checkbox not checked   N/A  
If other, describe:

75% Funds/25% Securities Lending Agent 

f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

4,178,300.43000000 

g. Provide the net income from securities lending activities

5,591.00000000 


Item C.7. Reliance on certain statutory exemption and rules.

Did the Fund rely on the following statutory exemption or any of the rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  k. Rule 6c-11 (17 CFR 270.6c-11) 
Checkbox not checked  l. Rule 12d1-4 (17 CFR 270.12d1-4) 
Checkbox not checked  m. Section 12(d)(1)(G) of the Act (15 USC 80a-12(d)(1)(G)) 
Checkbox not checked  n. Rule 18f-4 (17 CFR 270.18f-4) 
Checkbox not checked  i. Is the Fund excepted from the rule 18f-4 (17 CFR 270.18f-4) program requirement and limit on fund leverage risk under rule 18f-4(c)(4) (17CFR 270.18f-4(c)(4))? 
Checkbox not checked  ii. Is the Fund a leveraged/inverse fund that, under rule 18f-4(c)(5) (17 CFR 270.18f-4(c)(5)), is excepted from the requirement to comply with the limit on fund leverage risk described in rule 18f-4(c)(2) (17 CFR 270.18f-4(c)(2))? 
Checkbox not checked  iii. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(i) (17 CFR 270.18f-4(d)(i))? 
Checkbox not checked  iv. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(ii) (17 CFR 270.18f-4(d)(ii))? 
Checkbox not checked  v. Did the Fund enter into any unfunded commitment agreements under rule 18f-4(e) (17 CFR 270.18f-4(e))? 
Checkbox not checked  vi. Did the Fund invest in a security on a when-issued or forward-settling basis, or with a non-standard settlement cycle, in reliance on rule 18f-4(f) (17 CFR 270.18f-4(f))? 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button not checked Yes Radio button checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button not checked Yes Radio button checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. SEC file number ( e.g., 801- )

801-25803 

iii.CRD number
000013162 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
Virtus Fixed Income Advisers, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-68743 

iii. CRD number
000136029 
iv. LEI, if any

549300L7I4W19C7JV575 

v. State, if applicable
CONNECTICUT  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii.SEC file number ( e.g., 84- or 85- )

84-05829 

iii. LEI, if any

N/A 

iv. State, if applicable
NEBRASKA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
Pricing Direct 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

 

iii. State, if applicable
NEVADA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 2
i. Full name
Markit 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
Pricing Services Record: 3
i. Full name
ICE Data Services 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US Bank 
ii. LEI, if any

N1GZ7BBF3NP8GI976H15 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or provide and describe other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 2
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. LEI, if any, or provide and describe other identifying number

000013162 

Description of other identifying number

CRD Number 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
a. Full name
b. SEC file number

c. CRD number
d. LEI, if any

e. State, if applicable
f. Foreign country, if applicable
g. Total commissions paid to the affiliated broker-dealer for the reporting period:


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
Jane Street 
ii. SEC file number

8-69254 

iii. CRD number
000167280 
iv. LEI, if any

549300HXJLXCPDWAH070 

v. State, if applicable
DELAWARE  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

110.37000000 

Brokers Record: 2
i. Full name of broker
Jane Street 
ii. SEC file number

8-69254 

iii. CRD number
000167280 
iv. LEI, if any

549300HXJLXCPDWAH070 

v. State, if applicable
DELAWARE  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

109.22000000 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

110.37000000 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
CREDIT SUISSE 
ii. SEC file number

8-422 

iii. CRD number
000000816 
iv. LEI, if any

549300506SI9CRFV9Z86 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

5,715,380.50162616 

Principal Transactions Record: 2
i. Full name of dealer
GOLDMAN SACHS 
ii. SEC file number

8-129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

5,906,619.87886012 

Principal Transactions Record: 3
i. Full name of dealer
BANK OF AMERICA MERRILL LYNCH 
ii. SEC file number

8-7221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
DELAWARE  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

7,573,093.69450209 

Principal Transactions Record: 4
i. Full name of dealer
BARCLAYS 
ii. SEC file number

8-41342 

iii. CRD number
000019714 
iv. LEI, if any

AC28XWWI3WIBK2824319 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

5,531,814.17068598 

Principal Transactions Record: 5
i. Full name of dealer
SIEBERT BRANDFORD SHANK & CO 
ii. SEC file number

8-49877 

iii. CRD number
000042568 
iv. LEI, if any

254900VTARX8RAY9QK77 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

2,391,596.29999999 

Principal Transactions Record: 6
i. Full name of dealer
WELLS FARGO BANK 
ii. SEC file number

8-65876 

iii. CRD number
000126292 
iv. LEI, if any

VYVVCKR63DVZZN70PB21 

v. State, if applicable
DELAWARE  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

6,032,846.23198172 

Principal Transactions Record: 7
i. Full name of dealer
MORGAN STANLEY SMITH BARNEY 
ii. SEC file number

8-68191 

iii. CRD number
000149777 
iv. LEI, if any

7PDDXEMZ0ZV0CEDU4D16 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

5,956,955.43571309 

Principal Transactions Record: 8
i. Full name of dealer
US BANCORP 
ii. SEC file number

8-35359 

iii. CRD number
000017868 
iv. LEI, if any

H85Z6XZP8B10ES0M2G89 

v. State, if applicable
DELAWARE  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

9,649,656.32000000 

Principal Transactions Record: 9
i. Full name of dealer
JPMORGAN CHASE 
ii. SEC file number

8-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

8,189,051.19614257 

Principal Transactions Record: 10
i. Full name of dealer
CITIGROUP 
ii. SEC file number

8-8177 

iii. CRD number
000007059 
iv. LEI, if any

MBNUM2BPBDO7JBLYG310 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

4,440,656.93268568 

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

78,185,126.25000000 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

75,312,037.84000000 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button checked Yes Radio button not checked No
If yes, for each line of credit, provide the information requested below:
Line of Credit details Record: 1
i. Is the line of credit a committed or uncommitted line of credit? Radio button not checked Committed Radio button checked Uncommitted
ii. What size is the line of credit?

50,000,000.00000000 

iii. With which institution(s) is the line of credit?
Line Institutions Record: 1
Name of institution
U.S Bank National Association 
iv. Is the line of credit just for the Fund, or is it shared among multiple funds? Radio button not checked Sole Radio button checked Shared
1. If shared, list the names of other funds that may use the line of credit.
Shared Credit Users Record: 1
Name of fund
Dunham High-Yield Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 2
Name of fund
Dunham International Opportunity Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 3
Name of fund
Dunham Long/Short Credit 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 4
Name of fund
Dunham Large Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 5
Name of fund
Dunham Focused Large Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 6
Name of fund
Dunham Floating Rate Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 7
Name of fund
Dunham Monthly Distribution Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 8
Name of fund
Dunham International Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 9
Name of fund
Dunham Real Estate Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 10
Name of fund
Dunham Small Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 11
Name of fund
Dunham Dynamic Macro Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 12
Name of fund
Dunham Emerging Markets Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 13
Name of fund
Dunham Small Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
v. Did the Fund draw on the line of credit this period?Radio button checked Yes Radio button not checked No vi. If the fund drew on the line of credit during this period, what was the average amount outstanding when the line of credit was in use?
758,733.00000000 
vii. If the fund drew on the line of credit during this period, what was the number of days that the line of credit was in use?
45 



b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 13

Item C.1. Background information.

a. Full Name of the Fund

Dunham Dynamic Macro Fund 

b. Series identication number, if any

S000028743 

c. LEI

549300QCEJLNTIYU7A30 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Dunham Dynamic Macro Fund Class A 
ii. Class identification number, if any

C000087895 

iii. Ticker symbol, if any

DAAVX 

Shares Outstanding Record: 2
i. Full name of Class
Dunham Dynamic Macro Fund Class N 
ii. Class identification number, if any

C000087897 

iii. Ticker symbol, if any

DNAVX 

Shares Outstanding Record: 3
i. Full name of Class
Dunham Dynamic Macro Fund Class C 
ii. Class identification number, if any

C000087896 

iii. Ticker symbol, if any

DCAVX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button not checked Yes Radio button checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any

8KUMV9EIJ75IBFMLFD23 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any:

8KUMV9EIJ75IBFMLFD23 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox checked  vi. Other  
Checkbox not checked   N/A  
If other, describe:

75% Funds/25% Securities Lending Agent 

f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

4,189,481.66000000 

g. Provide the net income from securities lending activities

7,985.00000000 


Item C.7. Reliance on certain statutory exemption and rules.

Did the Fund rely on the following statutory exemption or any of the rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  k. Rule 6c-11 (17 CFR 270.6c-11) 
Checkbox not checked  l. Rule 12d1-4 (17 CFR 270.12d1-4) 
Checkbox not checked  m. Section 12(d)(1)(G) of the Act (15 USC 80a-12(d)(1)(G)) 
Checkbox not checked  n. Rule 18f-4 (17 CFR 270.18f-4) 
Checkbox not checked  i. Is the Fund excepted from the rule 18f-4 (17 CFR 270.18f-4) program requirement and limit on fund leverage risk under rule 18f-4(c)(4) (17CFR 270.18f-4(c)(4))? 
Checkbox not checked  ii. Is the Fund a leveraged/inverse fund that, under rule 18f-4(c)(5) (17 CFR 270.18f-4(c)(5)), is excepted from the requirement to comply with the limit on fund leverage risk described in rule 18f-4(c)(2) (17 CFR 270.18f-4(c)(2))? 
Checkbox not checked  iii. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(i) (17 CFR 270.18f-4(d)(i))? 
Checkbox not checked  iv. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(ii) (17 CFR 270.18f-4(d)(ii))? 
Checkbox not checked  v. Did the Fund enter into any unfunded commitment agreements under rule 18f-4(e) (17 CFR 270.18f-4(e))? 
Checkbox not checked  vi. Did the Fund invest in a security on a when-issued or forward-settling basis, or with a non-standard settlement cycle, in reliance on rule 18f-4(f) (17 CFR 270.18f-4(f))? 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button not checked Yes Radio button checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button not checked Yes Radio button checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. SEC file number ( e.g., 801- )

801-25803 

iii.CRD number
000013162 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
Newton Investment Management NA 
ii. SEC file number ( e.g., 801- ), if applicable

801-120501 

iii. CRD number
000312937 
iv. LEI, if any

549300USELNALQ9OYY51 

v. State, if applicable
MASSACHUSETTS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii.SEC file number ( e.g., 84- or 85- )

84-05829 

iii. LEI, if any

N/A 

iv. State, if applicable
NEBRASKA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
ICE Data Services 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US Bank 
ii. LEI, if any

N1GZ7BBF3NP8GI976H15 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. LEI, if any, or provide and describe other identifying number

000013162 

Description of other identifying number

CRD Number 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 2
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or provide and describe other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
a. Full name
b. SEC file number

c. CRD number
d. LEI, if any

e. State, if applicable
f. Foreign country, if applicable
g. Total commissions paid to the affiliated broker-dealer for the reporting period:


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
FLOW TRADERS 
ii. SEC file number

8-68300 

iii. CRD number
000150780 
iv. LEI, if any

549300K64LZQW7R9ST34 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

59.37000000 

Brokers Record: 2
i. Full name of broker
GOLDMAN SACHS 
ii. SEC file number

8-129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

11,799.71000000 

Brokers Record: 3
i. Full name of broker
JPMORGAN CHASE 
ii. SEC file number

8-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

170.62000000 

Brokers Record: 4
i. Full name of broker
CITIGROUP 
ii. SEC file number

8-8177 

iii. CRD number
000007059 
iv. LEI, if any

MBNUM2BPBDO7JBLYG310 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

24.51000000 

Brokers Record: 5
i. Full name of broker
SUSQUEHANNA CAPITAL GROUP 
ii. SEC file number

8-43174 

iii. CRD number
000029337 
iv. LEI, if any

549300RX9GZX8Y9IGJ81 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

2,197.60000000 

Brokers Record: 6
i. Full name of broker
SUSQUEHANNA CAPITAL GROUP 
ii. SEC file number

8-43174 

iii. CRD number
000029337 
iv. LEI, if any

549300RX9GZX8Y9IGJ81 

v. State, if applicable
PENNSYLVANIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

58.14000000 

Brokers Record: 7
i. Full name of broker
CANTOR FITZGERALD 
ii. SEC file number

8-00201 

iii. CRD number
000159296 
iv. LEI, if any

549300DWZ3YOKJO5X179 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

102.58000000 

Brokers Record: 8
i. Full name of broker
Jane Street 
ii. SEC file number

8-69254 

iii. CRD number
000167280 
iv. LEI, if any

549300HXJLXCPDWAH070 

v. State, if applicable
DELAWARE  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

86.29000000 

Brokers Record: 9
i. Full name of broker
CITADEL SECURITIES 
ii. SEC file number

8-53574 

iii. CRD number
000116797 
iv. LEI, if any

12UUJYTN7D3SW8KCSG25 

v. State, if applicable
ILLINOIS  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

11.93000000 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

14,167.93000000 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
Principal Transactions Record: 1
i. Full name of dealer
Goldman Sachs 
ii. SEC file number

8-129 

iii. CRD number
000000361 
iv. LEI, if any

FOR8UP27PHTHYVLBNG30 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

520,685,099.94805998 

Principal Transactions Record: 2
i. Full name of dealer
CITIGROUP 
ii. SEC file number

8-8177 

iii. CRD number
000007059 
iv. LEI, if any

MBNUM2BPBDO7JBLYG310 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

11,498,279.63409000 

Principal Transactions Record: 3
i. Full name of dealer
MORGAN STANLEY SMITH BARNEY 
ii. SEC file number

8-68191 

iii. CRD number
000149777 
iv. LEI, if any

7PDDXEMZ0ZV0CEDU4D16 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

24,069,517.95074899 

Principal Transactions Record: 4
i. Full name of dealer
CAPSTONE GLOBAL MARKETS 
ii. SEC file number

8-67583 

iii. CRD number
000143612 
iv. LEI, if any

N/A 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

3,643,152.66494800 

Principal Transactions Record: 5
i. Full name of dealer
JPMORGAN CHASE 
ii. SEC file number

8-35008 

iii. CRD number
000000079 
iv. LEI, if any

ZBUT11V806EZRVTWT807 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

1,367,099.53250000 

Principal Transactions Record: 6
i. Full name of dealer
BANK OF AMERICA MERRILL LYNCH 
ii. SEC file number

8-7221 

iii. CRD number
000007691 
iv. LEI, if any

8NAV47T0Y26Q87Y0QP81 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

4,980,230.55470199 

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

557,619,997.06000000 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

25,267,128.07000000 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button checked Yes Radio button not checked No
If yes, for each line of credit, provide the information requested below:
Line of Credit details Record: 1
i. Is the line of credit a committed or uncommitted line of credit? Radio button not checked Committed Radio button checked Uncommitted
ii. What size is the line of credit?

50,000,000.00000000 

iii. With which institution(s) is the line of credit?
Line Institutions Record: 1
Name of institution
U.S Bank National Association 
iv. Is the line of credit just for the Fund, or is it shared among multiple funds? Radio button not checked Sole Radio button checked Shared
1. If shared, list the names of other funds that may use the line of credit.
Shared Credit Users Record: 1
Name of fund
Dunham Corporate/Government Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 2
Name of fund
Dunham Monthly Distribution Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 3
Name of fund
Dunham High-Yield Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 4
Name of fund
Dunham International Opportunity Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 5
Name of fund
Dunham Long/Short Credit 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 6
Name of fund
Dunham Large Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 7
Name of fund
Dunham Floating Rate Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 8
Name of fund
Dunham Focused Large Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 9
Name of fund
Dunham International Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 10
Name of fund
Dunham Real Estate Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 11
Name of fund
Dunham Small Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 12
Name of fund
Dunham Emerging Markets Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 13
Name of fund
Dunham Small Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
v. Did the Fund draw on the line of credit this period?Radio button not checked Yes Radio button checked No


b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No
Management Investment Record: 14

Item C.1. Background information.

a. Full Name of the Fund

Dunham Focused Large Cap Growth Fund 

b. Series identication number, if any

S000034854 

c. LEI

549300RBSK31DR791214 

d. Is this the first filing on this form by the Fund? Radio button not checked Yes Radio button checked No

Item C.2. Classes of open-end management investment companies.

a. How many Classes of shares of the Fund (if any) are authorized?

3 

b. How many new Classes of shares of the Fund were added during the reporting period?

0 

c. How many Classes of shares of the Fund were terminated during the reporting period?

0 

d. For each Class with shares outstanding, provide the information requested below:
Shares Outstanding Record: 1
i. Full name of Class
Dunham Focused Large Cap Growth Fund Class A 
ii. Class identification number, if any

C000107185 

iii. Ticker symbol, if any

DAFGX 

Shares Outstanding Record: 2
i. Full name of Class
Dunham Focused Large Cap Growth Fund Class N 
ii. Class identification number, if any

C000107187 

iii. Ticker symbol, if any

DNFGX 

Shares Outstanding Record: 3
i. Full name of Class
Dunham Focused Large Cap Growth Fund Class C 
ii. Class identification number, if any

C000107186 

iii. Ticker symbol, if any

DCFGX 


Item C.3. Type of fund.

Instructions. 1. "Fund of Funds" means a fund that acquires securities issued by any other investment company in excess of the amounts permitted under paragraph (A) of section 12(d)(1) of the Act (15 U.S.C. 80a-12(d)(1)(A)), but, for purposes of this Item, does not include a fund that acquires securities issued by another company solely in reliance on rule 12d1-1 under the Act (CFR 270.12d1-1). 2. "Index Fund" means an investment company, including an Exchange-Traded Fund, that seeks to track the performance of a specified index. 3. "Interval Fund" means a closed-end management investment company that makes periodic repurchases of its shares pursuant to rule 23c-3 under the Act (17 CFR 270.23c-3). 4. "Master-Feeder Fund" means a two-tiered arrangement in which one or more funds (each a feeder fund) holds shares of a single Fund (the master fund) in accordance with section 12(d)(1)(E) of the Act (15 U.S.C. 80a-12(d)(1)(E)) or pursuant to exemptive relief granted by the Commission. 5. "Target Date Fund" means an investment company that has an investment objective or strategy of providing varying degrees of long-term appreciation and capital preservation through a mix of equity and fixed income exposures that changes over time based on an investor's age, target retirement date, or life expectancy.
Indicate if the Fund is any one of the types listed below. Check all that apply.
 a. Exchange-Traded Fund or Exchange-Traded Managed Fund or offers a Class that itself is an Exchange-Traded Fund or Exchange-Traded Managed Fund 
      i.   Checkbox not checked   Exchange-Traded Fund 
      ii.  Checkbox not checked   Exchange-Traded Managed Fund 
 b.  Checkbox not checked  Index Fund 

 c.  Checkbox not checked   Seeks to achieve performance results that are a multiple of a benchmark, the inverse of a benchmark, or a multiple of the inverse of a benchmark 
 d.  Checkbox not checked   Interval Fund 
 e.  Checkbox not checked   Fund of Funds 
 f.   Checkbox not checked   Master-Feeder Fund 
 g.  Checkbox not checked   Money Market Fund 
 h.  Checkbox not checked   Target Date Fund 
 i.   Checkbox not checked   Underlying fund to a variable annuity or variable life insurance contract 
      Checkbox checked   N/A 

Item C.4. Diversification.

Does the Fund seek to operate as a “non-diversified company” as such term is defined in section 5(b)(2) of the Act (15 U.S.C. 80a- 5(b) (2))? Radio button checked Yes Radio button not checked No

Item C.5. Investments in certain foreign corporations.

Instruction. "Controlled foreign corporation" has the meaning provided in section 957 of the Internal Revenue Code [26 U.S.C. 957].
a. Does the fund invest in a controlled foreign corporation for the purpose of investing in certain types of instruments such as, but not limited to, commodities? Radio button not checked Yes Radio button checked No

Item C.6. Securities lending.

Instruction. For purposes of this Item, other adverse impacts would include, for example, (1) a loss to the Fund if collateral and indemnification were not sufficient to replace the loaned securities or their value, (2) the Fund's ineligibility to vote shares in a proxy, or (3) the Fund's ineligibility to receive a direct distribution from the issuer.
a. Is the Fund authorized to engage in securities lending transactions? Radio button checked Yes Radio button not checked No
b. Did the Fund lend any of its securities during the reporting period? Radio button checked Yes Radio button not checked No
i. If yes, during the reporting period, did any borrower fail to return the loaned securities by the contractual deadline with the result that:
1. The Fund (or its securities lending agent) liquidated collateral pledged to secure the loaned securities? Radio button not checked Yes Radio button checked No
2. The Fund was otherwise adversely impacted? Radio button not checked Yes Radio button checked No
c. Provide the information requested below about each securities lending agent, if any, retained by the Fund:
Securities Lending Record: 1
i. Full name of securities lending agent
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any

8KUMV9EIJ75IBFMLFD23 

iii. Is the securities lending agent an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No
iv. Does the securities lending agent or any other entity indemnify the fund against borrower default on loans administered by this agent? Radio button checked Yes Radio button not checked No
v. If the entity providing the indemnification is not the securities lending agent, provide the following information:
Idemnity Providers Record: 1
1. Name of person providing indemnification
N/A 
2. LEI, if any, of person providing indemnification

N/A 

vi. Did the Fund exercise its indemnification rights during the reporting period? Radio button not checked Yes Radio button checked No
d. If a person providing cash collateral management services to the Fund in connection with the Fund's securities lending activities does not also serve as securities lending agent, provide the following information about each cash collateral manager:
Collateral Managers Record: 1
i. Full name of cash collateral manager:
U.S. Bancorp Asset Management, Inc. 
ii. LEI, if any:

8KUMV9EIJ75IBFMLFD23 

iii. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of a securities lending agent retained by the Fund? Radio button checked Yes Radio button not checked No
iv. Is the cash collateral manager an affiliated person, or an affiliated person of an affiliated person, of the Fund? Radio button not checked Yes Radio button checked No

e. Types of payments made to one or more securities lending agents and cash collateral managers (check all that apply): Checkbox not checked  i. Revenue sharing split 
Checkbox not checked  ii. Non-revenue sharing split (other than administrative fee)  
Checkbox not checked  iii. Administrative fee 
Checkbox not checked  iv. Cash collateral reinvestment fee 
Checkbox not checked  v. Indemnification fee 
Checkbox checked  vi. Other  
Checkbox not checked   N/A  
If other, describe:

75% Funds/25% Securities Lending Agent 

f. Provide the monthly average of the value of portfolio securities on loan during the reporting period

230,757,013.22000000 

g. Provide the net income from securities lending activities

24,205.08000000 


Item C.7. Reliance on certain statutory exemption and rules.

Did the Fund rely on the following statutory exemption or any of the rules under the Act during the reporting period? (check all that apply) Checkbox not checked  a. Rule 10f-3 (17 CFR 270.10f-3)  
Checkbox not checked  b. Rule 12d1-1 (17 CFR 270.12d1-1) 
Checkbox not checked  c. Rule 15a-4 (17 CFR 270.15a-4)  
Checkbox not checked  d. Rule 17a-6 (17 CFR 270.17a-6)  
Checkbox not checked  e. Rule 17a-7 (17 CFR 270.17a-7) 
Checkbox not checked  f. Rule 17a-8 (17 CFR 270.17a-8) 
Checkbox not checked  g. Rule 17e-1 (17 CFR 270.17e-1) 
Checkbox checked  h. Rule 22d-1 (17 CFR 270.22d-1) 
Checkbox not checked  i. Rule 23c-1 (17 CFR 270.23c-1)  
Checkbox checked  j. Rule 32a-4 (17 CFR 270.32a-4) 
Checkbox not checked  k. Rule 6c-11 (17 CFR 270.6c-11) 
Checkbox not checked  l. Rule 12d1-4 (17 CFR 270.12d1-4) 
Checkbox not checked  m. Section 12(d)(1)(G) of the Act (15 USC 80a-12(d)(1)(G)) 
Checkbox not checked  n. Rule 18f-4 (17 CFR 270.18f-4) 
Checkbox not checked  i. Is the Fund excepted from the rule 18f-4 (17 CFR 270.18f-4) program requirement and limit on fund leverage risk under rule 18f-4(c)(4) (17CFR 270.18f-4(c)(4))? 
Checkbox not checked  ii. Is the Fund a leveraged/inverse fund that, under rule 18f-4(c)(5) (17 CFR 270.18f-4(c)(5)), is excepted from the requirement to comply with the limit on fund leverage risk described in rule 18f-4(c)(2) (17 CFR 270.18f-4(c)(2))? 
Checkbox not checked  iii. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(i) (17 CFR 270.18f-4(d)(i))? 
Checkbox not checked  iv. Did the Fund enter into any reverse repurchase agreements or similar financing transactions under rule 18f-4(d)(ii) (17 CFR 270.18f-4(d)(ii))? 
Checkbox not checked  v. Did the Fund enter into any unfunded commitment agreements under rule 18f-4(e) (17 CFR 270.18f-4(e))? 
Checkbox not checked  vi. Did the Fund invest in a security on a when-issued or forward-settling basis, or with a non-standard settlement cycle, in reliance on rule 18f-4(f) (17 CFR 270.18f-4(f))? 
Checkbox not checked  N/A 

Item C.8. Expense limitations.

Instruction. Provide information concerning any direct or indirect limitations, waivers or reductions, on the level of expenses incurred by the fund during the reporting period. A limitation, for example, may be applied indirectly (such as when an adviser agrees to accept a reduced fee pursuant to a voluntary fee waiver) or it may apply only for a temporary period such as for a new fund in its start-up phase.
a. Did the Fund have an expense limitation arrangement in place during the reporting period? Radio button not checked Yes Radio button checked No
b. Were any expenses of the Fund reduced or waived pursuant to an expense limitation arrangement during the reporting period? Radio button not checked Yes Radio button checked No
c. Are the fees waived subject to recoupment? Radio button not checked Yes Radio button checked No
d. Were any expenses previously waived recouped during the period? Radio button not checked Yes Radio button checked No

Item C.9. Investment advisers.

a. Provide the following information about each investment adviser (other than a sub-adviser) of the Fund:
Investment Advisers Record: 1
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. SEC file number ( e.g., 801- )

801-25803 

iii.CRD number
000013162 
iv. LEI, if any

N/A 

v. State, if applicable
CALIFORNIA  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Was the investment adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
b. If an investment adviser (other than a sub- adviser) to the Fund was terminated during the reporting period, provide the following with respect to each investment adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 

c. For each sub-adviser to the Fund, provide the information requested:
Sub Advisors Record: 1
i. Full name
The Ithaka Group, LLC 
ii. SEC file number ( e.g., 801- ), if applicable

801-69086 

iii. CRD number
000146975 
iv. LEI, if any

N/A 

v. State, if applicable
MARYLAND  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Is the sub-adviser an affiliated person of the Fund's investment adviser(s)? Radio button not checked Yes Radio button checked No
viii. Was the sub-adviser hired during the reporting period? Radio button not checked Yes Radio button checked No
d. If a sub-adviser was terminated during the reporting period, provide the following with respect to such sub-adviser:
i. Full name
 
ii. SEC file number ( e.g., 801- )

 

iii. CRD number
 
iv. LEI, if any

 

v. State, if applicable
 
vi. Foreign country, if applicable
 
vii. Termination date

 


Item C.10. Transfer agents.

a. Provide the following information about each person providing transfer agency services to the Fund:
Transfer Agents Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii.SEC file number ( e.g., 84- or 85- )

84-05829 

iii. LEI, if any

N/A 

iv. State, if applicable
NEBRASKA  
v. Foreign country, if applicable
UNITED STATES OF AMERICA  
vi. Is the transfer agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vii. Is the transfer agent a sub-transfer agent? Radio button not checked Yes Radio button checked No
b. Has a transfer agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.11. Pricing services.

a. Provide the following information about each person that provided pricing services to the Fund during the reporting period:
Pricing Services Record: 1
i. Full name
ICE Data Services 
ii. LEI, if any, or provide and describe other identifying number

N/A 

Description of other identifying number

 

iii. State, if applicable
NEW YORK  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the pricing service an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
b. Was a pricing service hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.12. Custodians.

a. Provide the following information about each person that provided custodial services to the Fund during the reporting period:
Custodians Record: 1
i. Full name
US Bank 
ii. LEI, if any

N1GZ7BBF3NP8GI976H15 

iii. State, if applicable
MINNESOTA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the custodian an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the custodian a sub-custodian? Radio button not checked Yes Radio button checked No
vii. With respect to the custodian, check below to indicate the type of custody: Radio button checked 1.Bank - section 17(f)(1) (15 U.S.C. 80a-17(f)(1))
Radio button not checked 2.Member national securities exchange - rule 17f-1 (17 CFR 270.17f-1)
Radio button not checked 3.Self - rule 17f-2 (17 CFR 270.17f-2)
Radio button not checked 4.Securities depository - rule 17f-4 (17 CFR 270.17f-4)
Radio button not checked 5.Foreign custodian - rule 17f-5 (17 CFR 270.17f-5)
Radio button not checked 6.Futures commission merchants and commodity clearing organizations - rule 17f-6 (17 CFR 270.17f-6)
Radio button not checked 7.Foreign securities depository - rule 17f-7 (17 CFR 270.17f-7)
Radio button not checked 8.Insurance company sponsor - rule 26a-2 (17 CFR 270.26a-2)
Radio button not checked 9.Other

b. Has a custodian been hired or terminated during the reporting period?* Radio button not checked Yes Radio button checked No

Item C.13. Shareholder servicing agents.

a. Provide the following information about each shareholder servicing agent of the Fund:
Shareholder servicing agents Record: 1
i. Full name
Dunham & Associates Investment Counsel, Inc. 
ii. LEI, if any, or provide and describe other identifying number

000013162 

Description of other identifying number

CRD Number 

iii. State, if applicable
CALIFORNIA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button checked Yes Radio button not checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
Shareholder servicing agents Record: 2
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or provide and describe other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the shareholder servicing agent an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the shareholder servicing agent a sub-shareholder servicing agent? Radio button not checked Yes Radio button checked No
b. Has a shareholder servicing agent been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.14. Administrators.

a. Provide the following information about each administrator of the Fund:
Administrators Record: 1
i. Full name
Ultimus Fund Solutions, LLC 
ii. LEI, if any, or other identifying number

84-05829 

Description of other identifying number

Filing Number 

iii. State, if applicable
NEBRASKA  
iv. Foreign country, if applicable
UNITED STATES OF AMERICA  
v. Is the administrator an affiliated person of the Fund or its investment adviser(s)? Radio button not checked Yes Radio button checked No
vi. Is the administrator a sub-administrator? Radio button not checked Yes Radio button checked No
b.Has a third-party administrator been hired or terminated during the reporting period? Radio button not checked Yes Radio button checked No

Item C.15. Affiliated broker-dealers.

Provide the following information about each affiliated broker-dealer:
a. Full name
b. SEC file number

c. CRD number
d. LEI, if any

e. State, if applicable
f. Foreign country, if applicable
g. Total commissions paid to the affiliated broker-dealer for the reporting period:


Item C.16. Brokers.

Instructions to Item C.16 and Item C.17.
To help Registrants distinguish between agency and principal transactions, and to promote consistent reporting of the information required by these items, the following criteria should be used:
1. If a security is purchased or sold in a transaction for which the confirmation specifies the amount of the commission to be paid by the Registrant, the transaction should be considered an agency transaction and included in determining the answers to Item C.16.
2. If a security is purchased or sold in a transaction for which the confirmation specifies only the net amount to be paid or received by the Registrant and such net amount is equal to the market value of the security at the time of the transaction, the transaction should be considered a principal transaction and included in determining the amounts in Item C.17.
3. If a security is purchased by the Registrant in an underwritten offering, the acquisition should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the underwriters are receiving from the issuer.
4. If a security is sold by the Registrant in a tender offer, the sale should be considered a principal transaction and included in answering Item C.17 even though the Registrant has knowledge of the amount the offeror is paying to soliciting brokers or dealers.
5. If a security is purchased directly from the issuer (such as a bank CD), the purchase should be considered a principal transaction and included in answering Item C.17.
6. The value of called or maturing securities should not be counted in either agency or principal transactions and should not be included in determining the amounts shown in Item C.16 and Item C.17. This means that the acquisition of a security may be included, but it is possible that its disposition may not be included. Disposition of a repurchase agreement at its expiration date should not be included.
7. The purchase or sales of securities in transactions not described in paragraphs (1) through (6) above should be evaluated by the Fund based upon the guidelines established in those paragraphs and classified accordingly. The agents considered in Item C.16 may be persons or companies not registered under the Exchange Act as securities brokers. The persons or companies from whom the investment company purchased or to whom it sold portfolio instruments on a principal basis may be persons or entities not registered under the Exchange Act as securities dealers.
a. For each of the ten brokers that received the largest dollar amount of brokerage commissions (excluding dealer concessions in underwritings) by virtue of direct or indirect participation in the Fund’s portfolio transactions, provide the information below:
Brokers Record: 1
i. Full name of broker
Cowen Group 
ii. SEC file number

8-22522 

iii. CRD number
000007616 
iv. LEI, if any

549300WR155U7DVMIW58 

v. State, if applicable
NEW YORK  
vi. Foreign country, if applicable
UNITED STATES OF AMERICA  
vii. Gross commissions paid by the Fund for the reporting period

10,282.22 

b. Aggregate brokerage commissions paid by Fund during the reporting period:

10,282.22 


Item C.17. Principal transactions.

a. For each of the ten entities acting as principals with which the Fund did the largest dollar amount of principal transactions (include all short-term obligations, and U.S. government and tax-free securities) in both the secondary market and in underwritten offerings, provide the information below:
i. Full name of dealer
ii. SEC file number

iii. CRD number
iv. LEI, if any

v. State, if applicable
vi. Foreign country, if applicable
vii. Total value of purchases and sales (excluding maturing securities) with Fund:

b. Aggregate value of principal purchase/sale transactions of Fund during the reporting period:

0 


Item C.18. Payments for brokerage and research.

During the reporting period, did the Fund pay commissions to broker-dealers for "brokerage and research services" within the meaning of section 28(e) of the Exchange Act (15 U.S.C. 78bb)? Radio button not checked Yes Radio button checked No

Item C.19. Average net assets.

a. Provide the Fund's (other than a money market fund's) monthly average net assets during the reporting period

176,995,585.18115073 

b. Provide the money market fund's daily average net assets during the reporting period

 


Item C.20. Lines of credit, interfund lending and interfund borrowing.

For open-end management investment companies, respond to the following:
a. Does the Fund have available a line of credit?Radio button checked Yes Radio button not checked No
If yes, for each line of credit, provide the information requested below:
Line of Credit details Record: 1
i. Is the line of credit a committed or uncommitted line of credit? Radio button not checked Committed Radio button checked Uncommitted
ii. What size is the line of credit?

50,000,000.00000000 

iii. With which institution(s) is the line of credit?
Line Institutions Record: 1
Name of institution
U.S Bank National Association 
iv. Is the line of credit just for the Fund, or is it shared among multiple funds? Radio button not checked Sole Radio button checked Shared
1. If shared, list the names of other funds that may use the line of credit.
Shared Credit Users Record: 1
Name of fund
Dunham Monthly Distribution Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 2
Name of fund
Dunham Large Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 3
Name of fund
Dunham International Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 4
Name of fund
Dunham Small Cap Growth Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 5
Name of fund
Dunham Small Cap Value Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 6
Name of fund
Dunham International Opportunity Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 7
Name of fund
Dunham Emerging Markets Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 8
Name of fund
Dunham Corporate/Government Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 9
Name of fund
Dunham Floating Rate Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 10
Name of fund
Dunham High-Yield Bond Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 11
Name of fund
Dunham Real Estate Stock Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 12
Name of fund
Dunham Dynamic Macro Fund 
SEC File number( e.g., 811- )
811-22153 
Shared Credit Users Record: 13
Name of fund
Dunham Long/Short Credit 
SEC File number( e.g., 811- )
811-22153 
v. Did the Fund draw on the line of credit this period?Radio button checked Yes Radio button not checked No vi. If the fund drew on the line of credit during this period, what was the average amount outstanding when the line of credit was in use?
0.00000000 
vii. If the fund drew on the line of credit during this period, what was the number of days that the line of credit was in use?
0 



b. Did the Fund engage in interfund lending? Radio button not checked Yes Radio button checked No

c.Did the Fund engage in interfund borrowing? Radio button not checked Yes Radio button checked No

Item C.21. Swing pricing.

For open-end management investment companies, respond to the following:
a. Did the Fund (if not a Money Market Fund, Exchange-Traded Fund, or Exchange-Traded Managed Fund) engage in swing pricing? Radio button not checked Yes Radio button checked No

N-CEN:Part G: Attachments

Item G.1a. Attachments.

Attachments applicable to all Registrants. All Registrants shall file the following attachments, as applicable, with the current report. Indicate the attachments filed with the current report by checking the applicable items below: Checkbox not checked   i. Legal proceedings  
Checkbox not checked  ii. Provision of financial support  
Checkbox checked  iii. Independent public accountant's report on internal control (management investment companies other than small business investment companies only)  
Checkbox not checked  iv. Change in accounting principles and practices  
Checkbox not checked  v. Information required to be filed pursuant to exemptive orders  
Checkbox not checked  vi. Other information required to be included as an attachment pursuant to Commission rules and regulations 

Instructions.

1. Item G.1.a.i. Legal proceedings.

(a) If the Registrant responded "YES" to Item B.11.a., provide a brief description of the proceedings. As part of the description, provide the case or docket number (if any), and the full names of the principal parties to the proceeding.
(b) If the Registrant responded "YES" to Item B.11.b., identify the proceeding and give its date of termination.

2. Item G.1.a.ii. Provision of financial support. If the Registrant responded "YES" to Item B.14., provide the following information (unless the Registrant is a Money Market Fund): (a) Description of nature of support.

(b) Person providing support.

(c) Brief description of relationship between the person providing support and the Registrant.

(d) Date support provided.

(e) Amount of support.

(f) Security supported (if applicable). Disclose the full name of the issuer, the title of the issue (including coupon or yield, if applicable) and at least two identifiers, if available (e.g., CIK, CUSIP, ISIN, LEI).
(g) Value of security supported on date support was initiated (if applicable).

(h) Brief description of reason for support.

(i) Term of support.

(j) Brief description of any contractual restrictions relating to support.

3. Item G.1.a.iii. Independent public accountant's report on internal control (management investment companies other than small business investment companies only). Each management investment company shall furnish a report of its independent public accountant on the company's system of internal accounting controls. The accountant's report shall be based on the review, study and evaluation of the accounting system, internal accounting controls, and procedures for safeguarding securities made during the audit of the financial statements for the reporting period. The report should disclose any material weaknesses in: (a) the accounting system; (b) system of internal accounting control; or (c) procedures for safeguarding securities which exist as of the end of the Registrant's fiscal year.

The accountant's report shall be furnished as an exhibit to the form and shall: (1) be addressed to the Registrant's shareholders and board of directors; (2) be dated; (3) be signed manually; and (4) indicate the city and state where issued.

Attachments that include a report that discloses a material weakness should include an indication by the Registrant of any corrective action taken or proposed.

The fact that an accountant's report is attached to this form shall not be regarded as acknowledging any review of this form by the independent public accountant.

4. Item G.1.a.iv. Change in accounting principles and practices. If the Registrant responded "YES" to Item B.21, provide an attachment that describes the change in accounting principles or practices, or the change in the method of applying any such accounting principles or practices. State the date of the change and the reasons therefor. A letter from the Registrant's independent accountants, approving or otherwise commenting on the change, shall accompany the description.

5. Item G.1.a.v. Information required to be filed pursuant to exemptive orders. File as an attachment any information required to be reported on Form N-CEN or any predecessor form to Form N-CEN (e.g., Form N-SAR) pursuant to exemptive orders issued by the Commission and relied on by the Registrant.

6. Item G.1.a.vi. Other information required to be included as an attachment pursuant to Commission rules and regulations. File as an attachment any other information required to be included as an attachment pursuant to Commission rules and regulations.

N-CEN: Signature

Pursuant to the requirements of the Investment Company Act of 1940, the Registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.
Registrant
Dunham Funds 
Date
2023-01-06 
Signature
James Colantino 
Title
Assistant Treasurer