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I certify that during the year ended December 31, 2021:

  1. I have fully disclosed all securities holdings in which I have, or a member of my immediate family has, a beneficial interest.
  2. I have obtained clearance for all securities transactions in which I have, or an immediate member of my family has, a beneficial interest except for transactions exempt from clearance or for which I have received an exception in writing from the CCO.
  3. I have reported all securities transactions in which I have, or any member of my immediate family has, a beneficial interest except for transactions exempt from clearance or for which I have received an exception in writing from the CCO.
  4. I have complied with the Code of Ethics in all other respects.

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