Processing Enhancements

• The ability to request a temporary trade restriction with specific expiration date.
• The ability to request the removal of an existing trade restriction.
• The ability to request a trade restriction for either a BIN Account # or an Advisor G#. An Advisor G# block will restrict the entire advisor firm from trading in your fund(s).
• The ability to request a restriction on multiple BIN Account #'s or Advisor G#'s within one request.
• The removal of the channel selector, so you no longer need to identify the Fidelity channel.

Log in to the site and go to the Trade Restriction tab to view these changes.

Overview
Mutual fund companies have several methods available to them to discourage short-term trading within their funds, including assessing short-term redemption trading fees.

Fidelity supports fund companies' efforts to protect long-term shareholders and encourages diligence in monitoring all trade activity. In addition, we are taking further steps to help funds collect short-term redemption fees in "omnibus" accounts that pool the assets of more than one beneficial owner.

At a fund company's request to enforce the collection of redemption fees within omnibus accounts, Fidelity will take the actions listed below on omnibus accounts identified in our Retail and Intermediary distribution channels:

For Retail Accounts
Retail omnibus accounts that have not converted to a fully disclosed "for the benefit of" account will be blocked from purchasing any of your mutual funds that impose a redemption fee.

For Intermediary Accounts
We have required each registered investment advisor account, third party administrator, and correspondent broker-dealer client (together, "Intermediaries") to certify to Fidelity that it can and will track, collect, and remit to Fidelity, on behalf of a mutual fund, short-term redemption fees at the sub-account/participant level. Further, as part of that certification, Intermediaries agreed to follow Fidelity's policies and procedures regarding the remittance of short-term redemption fees. Fidelity provided Intermediaries with notice that these policies and procedures were updated to include a reference to your funds' redemption fee policies and a link to your Web site where they can obtain more information regarding how to comply with your funds' policies.

Upon your notification to support the collection of redemption fees in omnibus accounts, Fidelity will act as follows: (1) any Intermediary omnibus account that does not provide the required certification to Fidelity will be prevented from purchasing any of your mutual funds that impose a redemption fee, and (2) for any Intermediary omnibus account that has provided the required certification, Fidelity will begin collecting and dispersing redemption fees remitted to it by the Intermediary.

How We Define an Omnibus Account
Fidelity used the following definition to identify its clients' and Intermediary clients' omnibus accounts. Omnibus accounts are defined as a single account that pools the holdings of more than one beneficial owner, whose identity is not disclosed to Fidelity, and who has the ability to affect transactions, and for which sub-accounting is performed by the pooled account owner or a third party, not Fidelity. This may include, but is not limited to, retirement plans, bank pooled accounts, and wrap programs.

How This Process Works
The Intermediaries who have tendered certifications with respect to omnibus accounts will be responsible for withholding the appropriate redemption fee amount from the shareholder-level mutual fund position and for remitting the proceeds to Fidelity. In turn, Fidelity will aggregate the redemption fees remitted to it and forward them to your transfer agent on a weekly basis. This will be consistent with our existing process for those fund companies on whose behalf we currently assess redemption fees on "fully-disclosed" accounts (meaning that the individual beneficial owner is known to Fidelity). Please note, Fidelity is not in a position to independently verify the accuracy of the Intermediary's omnibus account holder's redemption fee calculations.

Fidelity will make weekly reports available via FundsNetwork.com that will provide CUSIP-level data supporting the gross redemption fees that have been remitted to your transfer agent.

Fund companies that currently enforce their redemption fee policies via a Level 3 Networking basis who elect to follow the above outlined process should suspend enforcement of their current process for certified omnibus accounts. FundsNetwork.com will provide a list of all certified omnibus accounts holding your short term redemption fee funds. The omnibus account reporting will update daily with new or changed accounts on the system. It is the fund company's responsibility to check the site regularly for updates.

1. Complete the Omnibus Participation Form in order for Fidelity to remit short-term redemption fees from omnibus accounts that hold your funds.
2. Provide a link to a Web page that describes your redemption fee policies.
3. Effective date of support: Fidelity will initiate the support of omnibus account processing approximately 30 days after receipt of the participation form and Web site link. Your relationship manager will contact you with the effective date.
4. Networked companies:
   1. To avoid double billing of omnibus accounts, networked companies must suppress redemption fee processing on disclosed omnibus National Financial accounts.
   2. On the effective date, Fidelity will provide a listing of all omnibus accounts on our system.

Click here to see a sample report. The omnibus account reporting will be updated on a daily basis with new or changed accounts on the system. It is the fund company's responsibility to monitor the site regularly for updates.

Enabling Redemption Fee Waivers

Fidelity has enhanced its ability to support the processing of redemption fee waivers. If you have not filled out and remitted back to Fidelity the Redemption Fee Waiver Letter of Understanding, you must do so in order to avoid a disruption in service. Please contact your FundsNetwork relationship manager with any questions.

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