VICTORY FUNDS
Interfund Lending N-CEN Certification Period Ending October 31, 2020


In regards to the InterFund Lending Program, I certify that the
Adviser on behalf of the Funds has implemented procedures reasonably
designed to achieve compliance with the terms and conditions of the
InterFund Lending Order which includes 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 the interfund borrowing and lending demand in an
equitable manner and in accordance with procedures established by the
Trustees; 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.

January 11, 2021
Colin Kinney	Date
Chief Compliance Officer Victory Funds