Transamerica Asset Management, Inc.

Allegations: ON SEPTEMBER 12, 2023, TRANSAMERICA ASSET MANAGEMENT, INC. (TAM) ENTERED INTO A SETTLEMENT WITH THE NATIONAL FUTURES ASSOCIATION (NFA) RELATING TO A COMPLAINT ISSUED BY THE BUSINESS CONDUCT COMMITTEE OF THE NFA ALLEGING THAT TAM VIOLATED AN NFA RULE. THE COMPLAINT ISSUED ON JUNE 29, 2023 ALLEGED THAT TAM FAILED TO IMPLEMENT AN ADEQUATE SUPERVISORY STRUCTURE TO OVERSEE THE FIRM'S COMMODITY FUTURES TRADING COMMISSION REGISTRATION AS A COMMODITY POOL OPERATOR AND ITS NFA MEMBERSHIP OBLIGATIONS. AS PART OF THE SETTLEMENT, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS MADE AGAINST IT, TAM AGREED TO PAY A FINE OF $140,000 TO THE NFA, WHICH RESOLVED TAM'S LIABILITY FOR ALL ALLEGATIONS AND MATTERS SET FORTH IN THE COMPLAINT. Status: Final Sanction Detail: TAM AGREED TO PAY A FINE OF $140,000 WHICH WAS PAID ON SEPTEMBER 27, 2023 Summary: ON SEPTEMBER 12, 2023, TRANSAMERICA ASSET MANAGEMENT, INC. (TAM) ENTERED INTO A SETTLEMENT WITH THE NATIONAL FUTURES ASSOCIATION (NFA) RELATING TO A COMPLAINT ISSUED BY THE BUSINESS CONDUCT COMMITTEE OF THE NFA ALLEGING THAT TAM VIOLATED AN NFA RULE. THE COMPLAINT ISSUED ON JUNE 29, 2023 ALLEGED THAT TAM FAILED TO IMPLEMENT AN ADEQUATE SUPERVISORY STRUCTURE TO OVERSEE THE FIRM'S COMMODITY FUTURES TRADING COMMISSION REGISTRATION AS A COMMODITY POOL OPERATOR AND ITS NFA MEMBERSHIP OBLIGATIONS. AS PART OF THE SETTLEMENT, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS MADE AGAINST IT, TAM AGREED TO PAY A FINE OF $140,000 TO THE NFA, WHICH RESOLVED TAM'S LIABILITY FOR ALL ALLEGATIONS AND MATTERS SET FORTH IN THE COMPLAINT.

Allegations: ON AUGUST 27TH, 2018 THE SEC INSTITUTED A SETTLED PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDING NAMING TRANSAMERICA ASSET MANAGEMENT, INC AND CERTAIN OF ITS AFFILIATES. THE ORDER PERTAINS TO EVENTS DURING THE PERIOD BETWEEN JULY 2011 AND JUNE 2015, AND RELATES TO, AMONG OTHER THINGS, ERRORS IN THE PAST OPERATION AND/OR IMPLEMENTATION OF ASSET ALLOCATION MODELS AND VOLATILITY OVERLAYS UTILIZED BY AEGON USA INVESTMENT MANAGEMENT, LLC, AN AFFILIATE OF TAM, WHEN IT SERVED AS SUB-ADVISER TO CERTAIN TRANSAMERICA-SPONSORED MUTUAL FUNDS AND FUNDS HELD BY CERTAIN VARIABLE PRODUCTS. TAM SERVED AS THE ADVISOR TO THOSE MUTUAL FUNDS AND FUNDS HELD BY CERTAIN VARIABLE PRODUCTS. THE ORDER ALSO RELATES TO THE DESIGNATION OF THE PORTFOLIO MANAGER FOR CERTAIN OF THESE FUNDS. IN ADDITION, THE ORDER PERTAINS TO DISCLOSURES RELATED TO THESE MATTERS AND THE ADEQUACY OF APPLICABLE COMPLIANCE POLICIES AND PROCEDURES. PLEASE SEE THE "DISCIPLINARY INFORMATION" SECTION OF TAM'S BROCHURE FOR ADDITIONAL DETAILS. Status: Final Sanction Detail: TAM AGREED TO PAY CIVIL PENALTIES OF $10,500,000, $15,000,000 IN DISGORGEMENT AND $2,235,765 IN PREJUDGMENT INTEREST. PAYMENTS WERE MADE ON 8/29/2018. Summary: ON AUGUST 27TH, 2018 THE SEC INSTITUTED A SETTLED PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDING NAMING TRANSAMERICA ASSET MANAGEMENT, INC AND CERTAIN OF ITS AFFILIATES. THE ORDER PERTAINS TO EVENTS DURING THE PERIOD BETWEEN JULY 2011 AND JUNE 2015, AND RELATES TO, AMONG OTHER THINGS, ERRORS IN THE PAST OPERATION AND/OR IMPLEMENTATION OF ASSET ALLOCATION MODELS AND VOLATILITY OVERLAYS UTILIZED BY AEGON USA INVESTMENT MANAGEMENT, LLC, AN AFFILIATE OF TAM, WHEN IT SERVED AS SUB-ADVISER TO CERTAIN TRANSAMERICA-SPONSORED MUTUAL FUNDS AND FUNDS HELD BY CERTAIN VARIABLE PRODUCTS. TAM SERVED AS THE ADVISOR TO THOSE MUTUAL FUNDS AND FUNDS HELD BY CERTAIN VARIABLE PRODUCTS. THE ORDER ALSO RELATES TO THE DESIGNATION OF THE PORTFOLIO MANAGER FOR CERTAIN OF THESE FUNDS. IN ADDITION, THE ORDER PERTAINS TO DISCLOSURES RELATED TO THESE MATTERS AND THE ADEQUACY OF APPLICABLE COMPLIANCE POLICIES AND PROCEDURES. PLEASE SEE THE "DISCIPLINARY INFORMATION" SECTION OF TAM'S BROCHURE FOR ADDITIONAL DETAILS.

Allegations: ON SEPTEMBER 30, 2020, TRANSAMERICA ASSET MANAGEMENT, INC. (TAM), THE INVESTMENT MANAGER OF THE FUNDS, ENTERED INTO A SETTLEMENT WITH THE SECURITIES AND EXCHANGE COMMISSION (SEC) RELATING TO EXPENSE RECAPTURES. THE RECAPTURES AT ISSUE, WHICH TAM SELF-REPORTED TO THE SEC, INVOLVED AMOUNTS PREVIOUSLY VOLUNTARILY WAIVED AND/OR REIMBURSED TO FOUR MONEY MARKET FUNDS TO PREVENT THE FUNDS FROM EXPERIENCING A NEGATIVE YIELD. IN SOME CASES RECAPTURES UNDER THE VOLUNTARY YIELD WAIVER ARRANGEMENTS EXCEEDED CONTRACTUAL EXPENSE LIMITS. THE RECAPTURED AMOUNTS WERE NOT REFLECTED IN THE FUNDS' PROSPECTUS FEE TABLES. THE FUNDS INVOLVED WERE TRANSAMERICA GOVERNMENT MONEY MARKET, TRANSAMERICA BLACKROCK GOVERNMENT MONEY MARKET VP, TRANSAMERICA PARTNERS GOVERNMENT MONEY MARKET AND TRANSAMERICA PARTNERS INSTITUTIONAL GOVERNMENT MONEY MARKET. THE TWO TRANSAMERICA PARTNERS GOVERNMENT MONEY MARKET FUNDS REORGANIZED INTO TRANSAMERICA GOVERNMENT MONEY MARKET IN OCTOBER OF 2017. UNDER THE SETTLEMENT ORDER, TAM AGREED TO PAY AFFECTED FUND INVESTORS APPROXIMATELY $5.3 MILLION IN DISGORGEMENT AND APPROXIMATELY $690,000 IN PREJUDGMENT INTEREST. THESE AMOUNTS REPRESENT EXPENSES INCURRED ABOVE THE APPLICABLE EXPENSE LIMIT (PLUS INTEREST). TAM WAS ALSO CENSURED AND ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OF CERTAIN STATUTORY PROVISIONS AND SEC RULES. THE SETTLEMENT ORDER IMPOSES NO CIVIL PENALTY ON TAM BASED UPON TAM HAVING SELF-REPORTED THE MATTER, THE PROMPT REMEDIAL STEPS TAKEN BY TAM, AND TAM'S COOPERATION IN THE SEC STAFF'S INVESTIGATION. THE SETTLEMENT ORDER DOES NOT AFFECT TAM'S ABILITY TO MANAGE THE FUNDS. THE FOREGOING IS ONLY A BRIEF SUMMARY OF THE SETTLEMENT ORDER. A COPY OF THE SETTLEMENT ORDER IS AVAILABLE ON THE SEC'S WEBSITE Status: Final Sanction Detail: TAM AGREED TO PAY AFFECTED FUND INVESTORS APPROXIMATELY $5.3 MILLION IN DISGORGEMENT AND APPROXIMATELY $690,000 IN PREJUDGMENT INTEREST Summary: ON SEPTEMBER 30, 2020, TRANSAMERICA ASSET MANAGEMENT, INC. (TAM), THE INVESTMENT MANAGER OF THE FUNDS, ENTERED INTO A SETTLEMENT WITH THE SECURITIES AND EXCHANGE COMMISSION (SEC) RELATING TO EXPENSE RECAPTURES. THE RECAPTURES AT ISSUE, WHICH TAM SELF-REPORTED TO THE SEC, INVOLVED AMOUNTS PREVIOUSLY VOLUNTARILY WAIVED AND/OR REIMBURSED TO FOUR MONEY MARKET FUNDS TO PREVENT THE FUNDS FROM EXPERIENCING A NEGATIVE YIELD. IN SOME CASES RECAPTURES UNDER THE VOLUNTARY YIELD WAIVER ARRANGEMENTS EXCEEDED CONTRACTUAL EXPENSE LIMITS. THE RECAPTURED AMOUNTS WERE NOT REFLECTED IN THE FUNDS' PROSPECTUS FEE TABLES. THE FUNDS INVOLVED WERE TRANSAMERICA GOVERNMENT MONEY MARKET, TRANSAMERICA BLACKROCK GOVERNMENT MONEY MARKET VP, TRANSAMERICA PARTNERS GOVERNMENT MONEY MARKET AND TRANSAMERICA PARTNERS INSTITUTIONAL GOVERNMENT MONEY MARKET. THE TWO TRANSAMERICA PARTNERS GOVERNMENT MONEY MARKET FUNDS REORGANIZED INTO TRANSAMERICA GOVERNMENT MONEY MARKET IN OCTOBER OF 2017. UNDER THE SETTLEMENT ORDER, TAM AGREED TO PAY AFFECTED FUND INVESTORS APPROXIMATELY $5.3 MILLION IN DISGORGEMENT AND APPROXIMATELY $690,000 IN PREJUDGMENT INTEREST. THESE AMOUNTS REPRESENT EXPENSES INCURRED ABOVE THE APPLICABLE EXPENSE LIMIT (PLUS INTEREST). TAM WAS ALSO CENSURED AND ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OF CERTAIN STATUTORY PROVISIONS AND SEC RULES. THE SETTLEMENT ORDER IMPOSES NO CIVIL PENALTY ON TAM BASED UPON TAM HAVING SELF-REPORTED THE MATTER, THE PROMPT REMEDIAL STEPS TAKEN BY TAM, AND TAM'S COOPERATION IN THE SEC STAFF'S INVESTIGATION. THE SETTLEMENT ORDER DOES NOT AFFECT TAM'S ABILITY TO MANAGE THE FUNDS. THE FOREGOING IS ONLY A BRIEF SUMMARY OF THE SETTLEMENT ORDER. A COPY OF THE SETTLEMENT ORDER IS AVAILABLE ON THE SEC'S WEBSITE