USAA MUTUAL FUNDS TRUST
Interfund Lending N-CEN Certification
Period Ending March 31, 2021
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.
Colin Kinney Date
Chief Compliance Officer
Victory Funds