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Plymouth Retirement Board Investment Regulations

Regulations accepted by the board and approved by PERAC

PERAC Approval Date: July 19, 2011

Investment/Supplemental Regulation

Notwithstanding the provisions of 840 CMR 21.01(3)(a)&(b), 4(a)&(b), 6 and 8 the Plymouth Retirement Board (“the Board”) is authorized to invest in the Babson Floating Rate Income Fund L.P. (“the Fund”) provided that the use of derivatives is for the purpose of hedging risk in the portfolios managed by the Fund, restricted stock is held in connection with a restructuring and is offered in a distressed credit situation, and that “collateral loans” pertain to loans, bonds and other debt instruments secured by assets of the relevant issuer.

Since this is a private investment fund and an institutional commingled fund, in which the manager makes investment recommendations and actions on behalf of all investors in the Fund rather than any particular investor, 840 CMR 17.04(3)(b) will not apply.  The provisions of 840 CMR 17.04(10) 16.09 and 16.03(2) will be limited by the provisions of the partnership agreement entered into by the Board and the Fund and the Investment Management Agreement between the Fund and the Manager.  That Management Agreement provides, in part, that “In the absence of willful misconduct or gross negligence on the part of the Investment Manager, neither the Investment Manager nor any of its officers, directors, employees or shareholders … or the legal representatives of any of them shall be subject to liability to the partnership or any limited partner of the Partnership for any act or omission in the course of, or connected with, rendering services hereunder or for any losses that may be sustained in the purchase, holding or sale of any security.

PERAC Approval Date: June 16, 2011

Investment/Supplemental Regulation

Regulation Number 17.04(3)(b), 21.01(1), 21.01(3)-(6), 21.01(8): The Plymouth Retirement Board is authorized to invest in the INVESCO High Yield Fund.  Since this is a registered mutual fund, in which the manager makes investment recommendations and actions on behalf of all the shareholders in the Fund rather than any particular investor, 840 CMR 17.04(3)(b) will not apply.  To the extent that the Fund reserves the right to make purchases on margin and to use futures contracts, options, restricted stock, and collateral loans as part of its basic strategy, 840 CMR 21.01 (1), (3), (4), (5), (6), and (8) will not apply.  The Board expects INVESCO to comply with all other state statutes and investment regulations.

PERAC Approval Date: September 23, 2009

Investment/Supplemental Regulation

Regulation Number 21.01(1): The Plymouth Retirement Board is authorized to invest in the Wellington Legacy Securities PPIF, which is part of the US Treasury’s Public-Private Investment Program. As part of this program, the manager may employ leverage up to 1x.

PERAC Approval Date: October 17, 2008

Investment/Supplemental Regulation

The provisions of 840 CMR 21.01(2)(3)(4) and (5) shall not apply to the investment of the Plymouth Retirement Board in the fund known as the Westfield Large Cap Growth Fund Limited Partnership.

PERAC Approval Date: October 17, 2008

Investment/Supplemental Regulation

The provisions of 840 CMR 21.01(2)(3)(4) and (5) shall not apply to the investment of the Plymouth Retirement Board in the fund known as the Eaton Vance Large Cap Value Fund.

PERAC Approval Date: May 12, 2000

Investment/Supplemental Regulation

Regulation Number16.08: In accordance with PERAC Investment Guideline 99-2, the Plymouth Retirement Board may transfer assets out of the State Street Global Advisors “Equal Weighted” S&P 500 Index Fund into the SSGA Flagship S&P 500 Index Fund.  Both funds invest in the same universe of securities.  In making this change, the Board is choosing a fund with a slightly higher opportunity/risk profile.  The Flagship Fund also has slightly lower annual expenses.

Contact   for Plymouth Retirement Board Investment Regulations

Fax

508-830-4019

Address

212 South Meadow Road, Unit 3, Plymouth, MA 02360

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