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:
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.
Chief Compliance Officer – Principal Funds