Securities Law & Instruments

Headnote

MRRS -- relief granted from the investment prohibition in subsection 4.1(1) of NI 81-102 to permit purchases of equity securities under private placements where the issuer is a reporting issuer in one or more jurisdictions --relief conditional on funds complying with conditions under s. 4.1(4)(a), (c)(ii), and (d) which include approval by the funds' independent review committee.

Applicable Legislative Provisions

National Instrument 81-102 Mutual Funds, ss. 4.1(1), 19.1.

National Instrument 81-107 -- Independent Review Committees for Investment Funds, s. 5.2.

November 20, 2007

IN THE MATTER OF

THE SECURITIES LEGISLATION OF

BRITISH COLUMBIA, ALBERTA, SASKATCHEWAN,

MANITOBA, ONTARIO, QUEBEC, NEW BRUNSWICK,

NOVA SCOTIA, PRINCE EDWARD ISLAND,

NEWFOUNDLAND AND LABRADOR,

THE NORTHWEST TERRITORIES, NUNAVUT

AND THE YUKON

(the "Jurisdictions")

AND

IN THE MATTER OF

THE MUTUAL RELIANCE REVIEW SYSTEM

FOR EXEMPTIVE RELIEF APPLICATIONS

(the "MRRS")

AND

IN THE MATTER OF

CIBC ASSET MANAGEMENT INC. ("CAMI"),

CANADIAN IMPERIAL BANK OF COMMERCE

(collectively with CAMI, "CIBC"),

RBC ASSET MANAGEMENT INC. ("RBC"),

BMO INVESTMENTS INC. ("BMOI"),

BMO HARRIS INVESTMENT MANAGEMENT INC.

("BMOH"), BMO NESBITT BURNS INC. ("BMONB") AND

GUARDIAN GROUP OF FUNDS LTD. ("GUARDIAN",

and collectively with BMOI, BMOH AND BMONB, "BMO")

(collectively, the "Applicants")

 

MRRS DECISION DOCUMENT

Background

The local securities regulatory authority or regulator (the "Decision Maker") in each of the Jurisdictions has received an application (the "Application") from the Applicants (or "Dealer Managers") on behalf of the mutual funds listed in Appendix "A" hereto for which the Applicants currently act as manager or portfolio adviser or both (the "Existing Funds") and any other mutual fund subject to National Instrument 81-102 - Mutual Funds ("NI 81-102") which may be created in the future for which the Applicants or an affiliate thereof will act as manager or portfolio adviser or both (the "Future Funds", and together with the Existing Funds, the "Funds" or "Dealer Managed Funds"), for a decision under section 19.1 of NI 81-102 (the "Legislation") for:

    • an exemption from subsection 4.1(1) of NI 81-102 to enable the Dealer Managed Funds to purchase equity securities (the "Securities") of a reporting issuer during the period of distribution (the "Distribution") of the issuer's Securities pursuant to a private placement offering (a "Private Placement") and for the 60-day period (the "60-Day Period") following completion of the Distribution (the Distribution and the 60-Day Period together, the "Prohibition Period"), notwithstanding that the Dealer Managers or the associates or affiliates thereof act or have acted as underwriter in connection with the Distribution (each a "Relevant Offering"), such relief referred to as the "Requested Relief".

Under the MRRS:

(a) the Ontario Securities Commission is the principal regulator for this Application, and

(b) this MRRS decision document evidences the decision of each Decision Maker.

Interpretation

Defined terms contained in the Securities Act (Ontario) or National Instrument 14-101 - Definitions have the same meanings in this decision (the "Decision") unless they are defined in this Decision.

Representations

This Decision is based on the following facts represented by the Applicants:

1. Each of the Dealer Managed Funds is or will be an open-ended mutual fund trust or corporation established under the laws of the Province of Ontario. Other than the BMO Harris Private Portfolios which are not reporting issuers in the Northwest Territories, Nunavut and the Yukon, the securities of each of the Dealer Managed Funds are or will be qualified for distribution in the Jurisdictions pursuant to simplified prospectuses and annual information forms that have been prepared and filed in accordance with the securities legislation of the Jurisdictions.

2. The Applicants are or will be the manager or the portfolio adviser or both of the Dealer Managed Funds. The Applicants and/or their affiliates currently are, and will be in the future, "dealer managers" with respect to the Funds, and each Fund is or will be a "dealer managed fund", as such terms are defined in section 1.1 of NI 81-102.

3. CAMI is a corporation incorporated under the laws of Canada and holds a registration in the categories of "investment counsel" and "portfolio manager" in Ontario. It also holds a registration in the categories of "investment counsel" and "portfolio manager" or the equivalent in each of the other Jurisdictions. The head office of CAMI is located in Toronto, Ontario. CIBC is a Schedule 1 Canadian chartered bank governed by the Bank Act (Canada) and its head office is located in Toronto, Ontario.

4. RBC is a corporation incorporated under the laws of Ontario and holds a registration in the categories of "investment counsel" and "portfolio adviser" in Ontario. It also holds a registration in the categories of "investment counsel" and "portfolio manager" or the equivalent in each of the other Jurisdictions. The head office of RBC is located in Toronto, Ontario.

5. BMOI and BMONB are corporations incorporated under the laws of Canada and their head offices are located in Toronto, Ontario. BMOH is a corporation incorporated under the laws of Canada and holds a registration in the categories of "investment counsel" and "portfolio manager" in Ontario. It also holds a registration in the categories of "investment counsel" and "portfolio manager" or the equivalent in each of the other Jurisdictions except Quebec where it holds the registration of "unrestricted practice advisor". The head office of BMOH is located in Toronto, Ontario. Guardian is a corporation incorporated under the laws of Canada and holds a registration in the categories of "investment counsel" and "portfolio manager" in Ontario. The head office of Guardian is located in Toronto, Ontario.

6. In addition, affiliates of the Applicants, who are registered as advisers in the categories of "investment counsel" and "portfolio manager" or the equivalent in each of the Jurisdictions, may from time to time act as portfolio advisers of the Funds through advisory or sub-advisory agreements. Each such affiliate will be a "dealer manager" with respect to the Funds.

7. The Applicants have each appointed an independent review committee (the "IRC") under National Instrument 81-107 - Independent Review Committee for Investment Funds ("NI 81-107") for the Existing Funds and will appoint an IRC for the Future Funds. In compliance with NI 81-107, each IRC has assumed its roles and responsibilities. The investment objective of each Dealer Managed Fund permits it or will permit it to invest in the relevant Securities.

8. In the case of CIBC, CIBC World Markets ("CIBCWM") may be a party to the underwriting agreement with a reporting issuer of Securities in a Relevant Offering. In the case of RBC, RBC Dominion Securities Inc. ("RBC Dominion") may be a party to the underwriting agreement with a reporting issuer of Securities in a Relevant Offering. In the case of BMO, BMO Nesbitt Burns Inc. (together with CIBCWM and RBC Dominion, each a "Related Underwriter") may be a party to the underwriting agreement with a reporting issuer of Securities in a Relevant Offering. In respect of each Relevant Offering in which a Related Underwriter participates as an underwriter, the Dealer Managers may wish to cause the Dealer Managed Funds to invest in Securities during the Prohibition Period.

9. To the extent a Related Underwriter participates as an underwriter in a Relevant Offering, the investment prohibition contained in subsection 4.1(1) of NI 81-102 (the "Investment Prohibition") restricts the Dealer Managed Funds from making certain investments in the issuer's Securities during the relevant Prohibition Period and can result in the portfolio adviser incurring extra costs, which are ultimately borne by the relevant Fund, to substitute investments for those that it is prohibited from buying.

10. Subsection 4.1(1) provides an exemption if the Dealer Managers or any of the associates or affiliates thereof act as a member of a selling group distributing five percent or less of the underwritten securities. However, this de minimis exemption is not available to entities that are underwriting a Distribution (as opposed to being in the selling group), and therefore the Dealer Managed Funds cannot avail themselves of this exemption.

11. The Funds would not be restricted by the Investment Prohibition if, in accordance with subsection 4.1(4) of NI 81-102, certain conditions are met, including that a prospectus is filed in one or more of the Jurisdictions in connection with a Relevant Offering and an IRC established for the Funds under NI 81-107 has approved the investment under NI 81-107.

12. The Applicants will not be able to rely on subsection 4.1(4) of NI 81-102 in connection with a Relevant Offering as a prospectus would not be filed in connection with a Private Placement. However the Applicants will comply with each of the other conditions in subsection 4.1(4) including that the Funds' IRC will approve any purchases under the Relevant Offerings under subsection 5.2(2) of NI 81-107.

Decision

Each of the Decision Makers is satisfied that the test contained in the Legislation that provides the Decision Makers with the jurisdiction to make this Decision has been met.

The Decision of the Decision Makers under the Legislation is that the Requested Relief is granted provided that the following conditions are satisfied:

The Investment Decision

I. At the time of each purchase by a Dealer Managed Fund during a Prohibition Period for a Relevant Offering, the Dealer Managed Fund has an IRC that complies with NI 81-107 and the IRC of the Dealer Managed Fund will have approved the investment in accordance with each of subsection 4.1(4)(a) of NI 81-102 and NI 81-107. The Dealer Managed Funds will also comply with paragraphs (c)(ii) and (d) of subsection 4.1(4) of NI 81-102.

II. Each issuer of a Relevant Offering is a reporting issuer or equivalent under the Legislation in a Jurisdiction at the time of each purchase by a Dealer Managed Fund during the Prohibition Period for the Relevant Offering.

Transparency

III.

(a) Prior to the first reliance on the Decision, the internet website of the Dealer Managed Fund or Dealer Manager, as applicable, discloses,

and

(b) on the date which is the earlier of (i) the date when an amendment to the simplified prospectus of the Dealer Managed Funds is filed for reasons other than the Decision and (ii) the date on which the initial or renewal simplified prospectus is receipted, Part A of the simplified prospectus of the Dealer Managed Funds discloses,

that the Dealer Managed Funds may invest in Securities during the Prohibition Period pursuant to the Decision, notwithstanding that a Related Underwriter has acted as underwriter in the Relevant Offering of the same class of such Securities.

IV. On the date which is the earlier of:

(i) the date when an amendment to the annual information form of the Dealer Managed Funds is filed for reasons other than the Decision; and

(ii) the date on which the initial or renewal annual information form is receipted,

the annual information form of the Dealer Managed Funds discloses the information referred to in paragraph III above and describes the policies or procedures and, standing approvals if any, that have been approved by the IRC as related to investments that can only be made pursuant to the Decision.

Sunset

V. The Decision, as it relates to the jurisdiction of a Decision Maker, will terminate on the coming into force of any legislation or rule of the Decision Makers dealing with Private Placements in the context of section 4.1 of NI 81-102.

"Vera Nunes"
Vera Nunes -- Assistant Manager
Investment Funds Branch

 

APPENDIX "A" -- Existing Mutual Funds

BMO MUTUAL FUNDS (CONSOLIDATED)

BMO T-Bill Fund

BMO Money Market Fund

BMO AIR MILES Money Market Fund

BMO Premium Money Market Fund

BMO Mortgage and Short-Term Income Fund

(formerly, BMO Mortgage Fund)

BMO Bond Fund

BMO Monthly Income Fund

BMO World Bond Fund

(formerly, BMO International Bond Fund)

BMO Diversified Income Fund

BMO Global Monthly Income Fund

BMO Global High Yield Bond Fund

(formerly, BMO Global Bond Fund)

BMO Income Trust Fund

BMO Asset Allocation Fund

BMO Dividend Fund

BMO Equity Index Fund

BMO Equity Fund

BMO U.S. Equity Index Fund

(formerly, BMO RSP U.S. Equity Index Fund)

BMO U.S. Growth Fund

BMO U.S. Equity Fund

(formerly BMO U.S. Value Fund)

BMO International Index Fund

(formerly BMO RSP International Index Fund)

BMO International Equity Fund

BMO North American Dividend Fund

(formerly BMO NAFTA Advantage Fund)

BMO European Fund

BMO Japanese Fund

BMO Special Equity Fund

BMO U.S. Special Equity Fund

BMO Resource Fund

BMO Precious Metals Fund

BMO Global Science & Technology Fund

BMO Emerging Markets Fund

BMO U.S. Dollar Money Market Fund

BMO U.S. Dollar Monthly Income Fund

BMO U.S. Dollar Equity Index Fund

(formerly BMO RSP U.S. Equity Index Fund)

BMO Short-Term Income Class

BMO Dividend Class

BMO Canadian Equity Class

BMO Global Dividend Class

BMO U.S. Equity Class

BMO Global Equity Class

BMO Greater China Class

BMO LifeStage Plus 2015 Fund

BMO LifeStage Plus 2020 Fund

BMO LifeStage Plus 2025 Fund

BMO LifeStage PlusT 2030 Fund

BMO FundSelectTM Security Portfolio

BMO FundSelectTM Balanced Portfolio

BMO FundSelectTM Growth Portfolio

BMO FundSelectTM Aggressive Growth Portfolio

BMO HARRIS PRIVATE PORTFOLIOS

BMO Harris Canadian Money Market Portfolio

BMO Harris Canadian Bond Income Portfolio

BMO Harris Canadian Total Return Bond Portfolio

BMO Harris Canadian Corporate Bond Portfolio

BMO Harris Income Opportunity Bond Portfolio

BMO Harris Opportunity Bond Portfolio

BMO Harris Diversified Trust Portfolio

BMO Harris Canadian Dividend Income Portfolio

BMO Harris Canadian Income Equity Portfolio

BMO Harris Canadian Conservative Equity Portfolio

BMO Harris Canadian Growth Equity Portfolio

BMO Harris Growth Opportunities Portfolio

BMO Harris Canadian Special Growth Portfolio

BMO Harris U.S. Equity Portfolio

BMO Harris U.S. Growth Portfolio

BMO Harris International Equity Portfolio

BMO Harris International Special Equity Portfolio

BMO Harris Emerging Markets Equity Portfolio

BMO NESBITT BURNS GROUP OF FUNDS

BMO Nesbitt Burns Canadian Stock Selection Fund

BMO Nesbitt Burns U.S. Stock Selection Fund

BMO Nesbitt Burns Bond Fund

BMO Nesbitt Burns Balanced Fund

BMO Nesbitt Burns Balanced Portfolio Fund

BMO Nesbitt Burns Growth Portfolio Fund

BMO Nesbitt Burns All Equity Portfolio Fund

GUARDIAN GROUP OF FUNDS NO. 3

GGOF Canadian Bond Fund

GGOF Canadian Money Market Fund

GGOF Floating Rate Income Fund

GGOF Global Bond Fund

GGOF High Yield Bond Fund

GGOF Monthly Dividend Fund Ltd.

GGOF Monthly High Income Fund

GGOF Monthly High Income Fund II

GGOF U.S. Money Market Fund

GGOF American Equity Fund Ltd.

GGOF Canadian Equity Fund Ltd.

GGOF Canadian Large Cap Equity Fund

GGOF Dividend Growth Fund

GGOF Emerging Markets Fund

GGOF Enterprise Fund

GGOF European Equity Fund

GGOF Global Absolute Return Fund

GGOF Global Dividend Growth Fund

GGOF Global Equity Fund

GGOF Global Real Estate Fund

GGOF Global Small Cap Fund

GGOF Global Technology Fund

GGOF Japanese Equity Fund

GGOF Resource Fund

GGOF Asian Growth and Income Fund

GGOF Canadian Balanced Fund

GGOF Canadian Diversified Monthly Income Fund

GGOF Global Diversified Fund

GGOF Small Cap Growth and Income Fund

GGOF U.S. Diversified Monthly Income Fund

GGOF Income Solution

GGOF Conservative Solution

GGOF Balanced Solution

GGOF Growth Solution

GGOF Aggressive Growth Solution

RBC FUNDS

RBC Canadian T-Bill Fund

RBC Canadian Short-Term Income Fund

RBC Bond Fund

RBC Canadian Bond Index Fund

RBC Monthly Income Fund

RBC $U.S. Income Fund

RBC Global Bond Fund

RBC Global Corporate Bond Fund

RBC Advisor Canadian Bond Fund

RBC Global High Yield Fund

RBC Cash Flow Portfolio

RBC Enhanced Cash Flow Portfolio

RBC Balanced Fund

RBC Tax Managed Return Fund

RBC Balanced Growth Fund

RBC Jantzi Balanced Fund

RBC Select Conservative Portfolio

RBC Select Balanced Portfolio

RBC Select Growth Portfolio

RBC Select Aggressive Growth Portfolio

RBC Select Choices Conservative Portfolio

RBC Select Choices Balanced Portfolio

RBC Select Choices Growth Portfolio

RBC Select Choices Aggressive Growth Portfolio

RBC Target 2010 Education Fund

RBC Target 2015 Education Fund

RBC Target 2020 Education Fund

RBC Target 2025 Education Fund

RBC Canadian Dividend Fund

RBC Canadian Equity Fund

RBC Jantzi Canadian Equity Fund

RBC Canadian Index Fund

RBC O'Shaughnessy Canadian Equity Fund

RBC O'Shaughnessy All-Canadian Equity Fund

RBC Canadian Diversified Income Trust Fund

RBC North American Dividend Fund

RBC North American Value Fund

RBC North American Growth Fund

RBC U.S. Equity Fund

RBC U.S. Equity Currency Neutral Fund

RBC U.S. Index Fund

RBC U.S. Index Currency Neutral Fund

RBC O'Shaughnessy U.S. Value Fund

RBC U.S. Mid-Cap Equity Fund

RBC U.S. Mid-Cap Equity Currency Neutral Fund

RBC O'Shaughnessy U.S. Growth Fund

RBC Life Science and Technology Fund

RBC International Equity Fund

RBC International Index Currency Neutral Fund

RBC O'Shaughnessy International Equity Fund

RBC European Equity Fund

RBC Asian Equity Fund

RBC Global Dividend Growth Fund

(formerly, RBC Global Titans Fund)

RBC Jantzi Global Equity Fund

RBC O'Shaughnessy Global Equity Fund

RBC Global Energy Fund

RBC Global Precious Metals Fund

RBC Global Consumer and Financials Fund

RBC Global Health Sciences Fund

RBC Global Resources Fund

RBC Global Technology Fund

RBC DS FOCUS FUNDS

RBC DS North American Focus Fund

RBC DS Canadian Focus Fund

RBC DS International Focus Fund

RBC DS Balanced Global Portfolio

RBC DS Growth Global Portfolio

RBC DS All Equity Global Portfolio

RBC PRIVATE POOLS

RBC Private Short-Term Income Pool

RBC Private Canadian Bond Pool

RBC Private Corporate Bond Pool

RBC Private Income Pool

RBC Private Global Bond Pool

RBC Private Canadian Dividend Pool (formerly, RBC Private Dividend Pool)

RBC Private Canadian Growth and Income Equity Pool

RBC Private Canadian Equity Pool

RBC Private Canadian Value Equity Pool

RBC Private O'Shaughnessy Canadian Equity Pool

RBC Private Core Canadian Equity Pool

RBC Private Canadian Mid Cap Equity Pool

RBC Private U.S. Value Equity Pool

RBC Private O'Shaughnessy U.S. Value Equity Pool

RBC Private U.S. Growth Equity Pool

RBC Private O'Shaughnessy U.S. Growth Equity Pool

RBC Private U.S. Mid Cap Equity Pool

RBC Private U.S. Small Cap Equity Pool

RBC Private International Equity Pool

RBC Private EAFE Equity Pool

RBC Private European Equity Pool

RBC Private Asian Equity Pool

RBC Private Global Titans Equity Pool

RBC Private World Equity Pool

AXIOM PORTFOLIOS

Axiom All Equity Portfolio

Axiom Balanced Growth Portfolio

Axiom Balanced Income Portfolio

Axiom Canadian Growth Portfolio

Axiom Diversified Monthly Income Portfolio

Axiom Foreign Growth Portfolio

Axiom Global Growth Portfolio

Axiom Long-Term Growth Portfolio

CIBC MUTUAL FUNDS AND

CIBC FAMILY OF MANAGED PORTFOLIOS

CIBC Asia Pacific Index Fund

CIBC Balanced Fund

CIBC Balanced Index Fund

CIBC Canadian Bond Fund

CIBC Canadian Bond Index Fund

CIBC Canadian Emerging Companies Fund

CIBC Canadian Equity Fund

(formerly CIBC Core Canadian Equity Fund)

CIBC Canadian Equity Value Fund

(formerly Canadian Imperial Equity Fund)

CIBC Canadian Index Fund

CIBC Canadian Real Estate Fund

CIBC Canadian Resources Fund

CIBC Canadian Short-Term Bond Index Fund

CIBC Canadian Small Companies Fund

CIBC Canadian T-Bill Fund

CIBC Capital Appreciation Fund

CIBC Disciplined International Equity Fund

CIBC Disciplined U.S. Equity Fund

CIBC Diversified Income Fund

CIBC Dividend Fund

CIBC Emerging Economies Fund

CIBC Emerging Markets Index Fund

CIBC Energy Fund

CIBC European Equity Fund

CIBC European Index Fund

CIBC European Index RRSP Fund

CIBC Far East Prosperity Fund

CIBC Financial Companies Fund

CIBC Global Bond Fund

CIBC Global Bond Index Fund

CIBC Global Equity Fund

CIBC Global Monthly Income Fund

CIBC Global Technology Fund

CIBC High Yield Cash Fund

CIBC International Index Fund

CIBC International Index RRSP Fund

CIBC International Small Companies Fund

CIBC Japanese Equity Fund

CIBC Japanese Index RRSP Fund

CIBC Latin American Fund

CIBC Money Market Fund

CIBC Monthly Income Fund

CIBC Mortgage and Short-Term Income Fund

CIBC Nasdaq Index Fund

CIBC Nasdaq Index RRSP Fund

CIBC North American Demographics Fund

CIBC Precious Metals Fund

CIBC Premium Canadian T-Bill Fund

CIBC U.S. Dollar Money Market Fund

CIBC U.S. Equity Index Fund

CIBC U.S. Index RRSP Fund

CIBC U.S. Small Companies Fund

CIBC Managed Aggressive Growth Portfolio

CIBC Managed Aggressive Growth RRSP Portfolio

CIBC Managed Balanced Growth Portfolio

CIBC Managed Balanced Growth RRSP Portfolio

CIBC Managed Balanced Portfolio

CIBC Managed Growth Portfolio

CIBC Managed Growth RRSP Portfolio

CIBC Managed Income Plus Portfolio

CIBC Managed Income Portfolio

CIBC Managed Monthly Income Balanced Portfolio

CIBC U.S. Dollar Managed Balanced Portfolio

CIBC U.S. Dollar Managed Growth Portfolio

CIBC U.S. Dollar Managed Income Portfolio

FRONTIERS POOLS

Frontiers Canadian Equity Pool

Frontiers Canadian Fixed Income Pool

Frontiers Canadian Monthly Income Pool

Frontiers Canadian Short Term Income Pool

Frontiers Emerging Markets Equity Pool

Frontiers Global Bond Pool

Frontiers International Equity Pool

Frontiers U.S. Equity Pool

IMPERIAL POOLS

Imperial Canadian Bond Pool

Imperial Canadian Dividend Income Pool

Imperial Canadian Dividend Pool

Imperial Canadian Equity Pool

Imperial Canadian Income Trust Pool

Imperial Emerging Economies Pool

Imperial International Bond Pool

Imperial International Equity Pool

Imperial Money Market Pool

Imperial Overseas Equity Pool

Imperial Registered International Equity Index Pool

Imperial Registered U.S. Equity Index Pool

Imperial Short-Term Bond Pool

Imperial U.S. Equity Pool

RENAISSANCE INVESTMENTS FAMILY OF FUNDS

Renaissance Canadian Balanced Fund

Renaissance Canadian Balanced Value Fund

Renaissance Canadian Core Value Fund

Renaissance Canadian Dividend Income Fund

Renaissance Canadian Growth Fund

Renaissance Canadian High Yield Bond Fund

Renaissance Canadian Monthly Income Fund

Renaissance Canadian Real Return Bond Fund

Renaissance Canadian Small-Cap Fund

Renaissance Canadian T-Bill Fund

Renaissance Emerging Markets Fund

Renaissance Diversified Income Fund

Renaissance European Fund

Renaissance Global Growth Fund

Renaissance Global Infrastructure Fund

Renaissance Global Focus Fund

Renaissance Global Technology Fund

Renaissance International Index Fund

Renaissance Optimal Income Portfolio

Renaissance U.S. Equity Growth Fund

Renaissance U.S. Equity Value Fund

Renaissance U.S. Index Fund

Renaissance U.S. Money Market Fund

Renaissance Asian Fund

Renaissance Canadian Bond Fund

Renaissance Canadian Asset Allocation Fund

Renaissance China Plus Fund

Renaissance Dividend Fund

Renaissance Global Asset Allocation Fund

Renaissance Global Bond Fund

Renaissance Global Value Fund

Renaissance Global Health Care Fund

Renaissance Global Markets Fund

Renaissance Global Multi Management Fund

Renaissance Global Resource Fund

Renaissance Global Science & Technology Fund

Renaissance Global Small-Cap Fund

Renaissance Canadian Income Fund

Renaissance International Equity Fund

Renaissance Millennium High Income Fund

Renaissance Millennium Next Generation Fund

Renaissance Money Market Fund

SEQUENCE PORTFOLIOS

Sequence 2010 Conservative Portfolio

Sequence 2010 Moderate Portfolio

Sequence 2020 Conservative Portfolio

Sequence 2020 Moderate Portfolio

Sequence 2030 Conservative Portfolio

Sequence 2030 Moderate Portfolio

Sequence 2040 Conservative Portfolio

Sequence 2040 Moderate Portfolio

Sequence Income Portfolio