PRINCIPAL FUNDS’ CCO ANNUAL CERTIFICATION |
Pursuant to Item G.1.a.v of Form N-CEN |
For the year ended December 31, 2020 |
I, as the Chief Compliance Officer for Principal Funds, Inc. and Principal Variable Contracts |
Funds, Inc. (collectively, the “Funds”) certify that the Funds and Principal Global Investors, LLC |
have established procedures reasonably designed to achieve compliance with the terms and |
conditions of their application to participate in a joint lending and borrowing facility, which |
application was granted by order of the Securities and Exchange Commission dated October 25, |
2011 (the “Application”). This includes procedures designed to achieve the following objectives: |
a) that the Interfund Loan Rate will be higher than the Repo Rate, but lower than the Bank |
Loan Rate; |
(b) compliance with the collateral requirements as set forth in the Application; |
(c) compliance with the percentage limitations on interfund borrowing and lending; |
(d) allocation of interfund borrowing and lending demand in an equitable manner and in |
accordance with procedures established by the Board of each Fund; and |
(e) that the Interfund Loan Rate does not exceed the interest rate on any third party |
borrowings of a borrowing Fund at the time of the Interfund Loan. |
Capitalized terms that are used but not defined herein have the meanings given them in the |
Application. |
Teri R. Root |
Chief Compliance Officer – Principal Funds |