Transamerica Asset Management, Inc..

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E.,
11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event.
If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and
only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11
that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD
or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
U.S. SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CENSURE DISGORGEMENT PREJUDGEMENT INTEREST CIVIL MONETARY PENALTIES
3.
Date Initiated (MM/DD/YYYY): 
08/27/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. 3-18681
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Mutual Fund(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON AUGUST 27TH, 2018 THE SEC INSTITUTED A SETTLED PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDING NAMING TRANSAMERICA ASSET
MANAGEMENT, INC AND CERTAIN OF ITS AFFILIATES. THE ORDER PERTAINS TO EVENTS DURING THE PERIOD BETWEEN JULY 2011 AND JUNE 2015, AND RELATES
TO, AMONG OTHER THINGS, ERRORS IN THE PAST OPERATION AND/OR IMPLEMENTATION OF ASSET ALLOCATION MODELS AND VOLATILITY OVERLAYS UTILIZED
BY AEGON USA INVESTMENT MANAGEMENT, LLC, AN AFFILIATE OF TAM, WHEN IT SERVED AS SUB-ADVISER TO CERTAIN TRANSAMERICA-SPONSORED MUTUAL
FUNDS AND FUNDS HELD BY CERTAIN VARIABLE PRODUCTS. TAM SERVED AS THE ADVISOR TO THOSE MUTUAL FUNDS AND FUNDS HELD BY CERTAIN VARIABLE
PRODUCTS. THE ORDER ALSO RELATES TO THE DESIGNATION OF THE PORTFOLIO MANAGER FOR CERTAIN OF THESE FUNDS. IN ADDITION, THE ORDER PERTAINS
TO DISCLOSURES RELATED TO THESE MATTERS AND THE ADEQUACY OF APPLICABLE COMPLIANCE POLICIES AND PROCEDURES. PLEASE SEE THE
"DISCIPLINARY INFORMATION" SECTION OF TAM'S BROCHURE FOR ADDITIONAL DETAILS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
08/27/2018
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 10,500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: 
TAM AGREED TO PAY CIVIL PENALTIES OF $10,500,000, $15,000,000 IN DISGORGEMENT AND $2,235,765 IN PREJUDGMENT INTEREST. PAYMENTS WERE
MADE ON 8/29/2018.

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit
within the space provided).
ON AUGUST 27TH, 2018 THE SEC INSTITUTED A SETTLED PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDING NAMING TRANSAMERICA ASSET
MANAGEMENT, INC AND CERTAIN OF ITS AFFILIATES. THE ORDER PERTAINS TO EVENTS DURING THE PERIOD BETWEEN JULY 2011 AND JUNE 2015, AND RELATES
TO, AMONG OTHER THINGS, ERRORS IN THE PAST OPERATION AND/OR IMPLEMENTATION OF ASSET ALLOCATION MODELS AND VOLATILITY OVERLAYS UTILIZED
BY AEGON USA INVESTMENT MANAGEMENT, LLC, AN AFFILIATE OF TAM, WHEN IT SERVED AS SUB-ADVISER TO CERTAIN TRANSAMERICA-SPONSORED MUTUAL
FUNDS AND FUNDS HELD BY CERTAIN VARIABLE PRODUCTS. TAM SERVED AS THE ADVISOR TO THOSE MUTUAL FUNDS AND FUNDS HELD BY CERTAIN VARIABLE
PRODUCTS. THE ORDER ALSO RELATES TO THE DESIGNATION OF THE PORTFOLIO MANAGER FOR CERTAIN OF THESE FUNDS. IN ADDITION, THE ORDER PERTAINS
TO DISCLOSURES RELATED TO THESE MATTERS AND THE ADEQUACY OF APPLICABLE COMPLIANCE POLICIES AND PROCEDURES. PLEASE SEE THE
"DISCIPLINARY INFORMATION" SECTION OF TAM'S BROCHURE FOR ADDITIONAL DETAILS.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E.,
11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event.
If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and
only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11
that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD
or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
U.S. SECURITIES AND EXCHANGE COMMISSION

2.
Principal Sanction:
Disgorgement
Other Sanctions: 
CENSURE, CEASE AND DESIST, PREJUDGEMENT INTEREST
3.
Date Initiated (MM/DD/YYYY): 
09/30/2020
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-20105
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Money Market Fund(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON SEPTEMBER 30, 2020, TRANSAMERICA ASSET MANAGEMENT, INC. (TAM), THE INVESTMENT MANAGER OF THE FUNDS, ENTERED INTO A SETTLEMENT WITH
THE SECURITIES AND EXCHANGE COMMISSION (SEC) RELATING TO EXPENSE RECAPTURES. THE RECAPTURES AT ISSUE, WHICH TAM SELF-REPORTED TO THE
SEC, INVOLVED AMOUNTS PREVIOUSLY VOLUNTARILY WAIVED AND/OR REIMBURSED TO FOUR MONEY MARKET FUNDS TO PREVENT THE FUNDS FROM
EXPERIENCING A NEGATIVE YIELD. IN SOME CASES RECAPTURES UNDER THE VOLUNTARY YIELD WAIVER ARRANGEMENTS EXCEEDED CONTRACTUAL EXPENSE
LIMITS. THE RECAPTURED AMOUNTS WERE NOT REFLECTED IN THE FUNDS' PROSPECTUS FEE TABLES. THE FUNDS INVOLVED WERE TRANSAMERICA
GOVERNMENT MONEY MARKET, TRANSAMERICA BLACKROCK GOVERNMENT MONEY MARKET VP, TRANSAMERICA PARTNERS GOVERNMENT MONEY MARKET AND
TRANSAMERICA PARTNERS INSTITUTIONAL GOVERNMENT MONEY MARKET. THE TWO TRANSAMERICA PARTNERS GOVERNMENT MONEY MARKET FUNDS
REORGANIZED INTO TRANSAMERICA GOVERNMENT MONEY MARKET IN OCTOBER OF 2017. UNDER THE SETTLEMENT ORDER, TAM AGREED TO PAY AFFECTED
FUND INVESTORS APPROXIMATELY $5.3 MILLION IN DISGORGEMENT AND APPROXIMATELY $690,000 IN PREJUDGMENT INTEREST. THESE AMOUNTS REPRESENT
EXPENSES INCURRED ABOVE THE APPLICABLE EXPENSE LIMIT (PLUS INTEREST). TAM WAS ALSO CENSURED AND ORDERED TO CEASE AND DESIST FROM
COMMITTING OR CAUSING ANY VIOLATIONS OF CERTAIN STATUTORY PROVISIONS AND SEC RULES. THE SETTLEMENT ORDER IMPOSES NO CIVIL PENALTY ON
TAM BASED UPON TAM HAVING SELF-REPORTED THE MATTER, THE PROMPT REMEDIAL STEPS TAKEN BY TAM, AND TAM'S COOPERATION IN THE SEC STAFF'S
INVESTIGATION. THE SETTLEMENT ORDER DOES NOT AFFECT TAM'S ABILITY TO MANAGE THE FUNDS. THE FOREGOING IS ONLY A BRIEF SUMMARY OF THE
SETTLEMENT ORDER. A COPY OF THE SETTLEMENT ORDER IS AVAILABLE ON THE SEC'S WEBSITE
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
09/30/2020
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: 
TAM AGREED TO PAY AFFECTED FUND INVESTORS APPROXIMATELY $5.3 MILLION IN DISGORGEMENT AND APPROXIMATELY $690,000 IN PREJUDGMENT
INTEREST
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit
within the space provided).

ON SEPTEMBER 30, 2020, TRANSAMERICA ASSET MANAGEMENT, INC. (TAM), THE INVESTMENT MANAGER OF THE FUNDS, ENTERED INTO A SETTLEMENT WITH
THE SECURITIES AND EXCHANGE COMMISSION (SEC) RELATING TO EXPENSE RECAPTURES. THE RECAPTURES AT ISSUE, WHICH TAM SELF-REPORTED TO THE
SEC, INVOLVED AMOUNTS PREVIOUSLY VOLUNTARILY WAIVED AND/OR REIMBURSED TO FOUR MONEY MARKET FUNDS TO PREVENT THE FUNDS FROM
EXPERIENCING A NEGATIVE YIELD. IN SOME CASES RECAPTURES UNDER THE VOLUNTARY YIELD WAIVER ARRANGEMENTS EXCEEDED CONTRACTUAL EXPENSE
LIMITS. THE RECAPTURED AMOUNTS WERE NOT REFLECTED IN THE FUNDS' PROSPECTUS FEE TABLES. THE FUNDS INVOLVED WERE TRANSAMERICA
GOVERNMENT MONEY MARKET, TRANSAMERICA BLACKROCK GOVERNMENT MONEY MARKET VP, TRANSAMERICA PARTNERS GOVERNMENT MONEY MARKET AND
TRANSAMERICA PARTNERS INSTITUTIONAL GOVERNMENT MONEY MARKET. THE TWO TRANSAMERICA PARTNERS GOVERNMENT MONEY MARKET FUNDS
REORGANIZED INTO TRANSAMERICA GOVERNMENT MONEY MARKET IN OCTOBER OF 2017. UNDER THE SETTLEMENT ORDER, TAM AGREED TO PAY AFFECTED
FUND INVESTORS APPROXIMATELY $5.3 MILLION IN DISGORGEMENT AND APPROXIMATELY $690,000 IN PREJUDGMENT INTEREST. THESE AMOUNTS REPRESENT
EXPENSES INCURRED ABOVE THE APPLICABLE EXPENSE LIMIT (PLUS INTEREST). TAM WAS ALSO CENSURED AND ORDERED TO CEASE AND DESIST FROM
COMMITTING OR CAUSING ANY VIOLATIONS OF CERTAIN STATUTORY PROVISIONS AND SEC RULES. THE SETTLEMENT ORDER IMPOSES NO CIVIL PENALTY ON
TAM BASED UPON TAM HAVING SELF-REPORTED THE MATTER, THE PROMPT REMEDIAL STEPS TAKEN BY TAM, AND TAM'S COOPERATION IN THE SEC STAFF'S
INVESTIGATION. THE SETTLEMENT ORDER DOES NOT AFFECT TAM'S ABILITY TO MANAGE THE FUNDS. THE FOREGOING IS ONLY A BRIEF SUMMARY OF THE
SETTLEMENT ORDER. A COPY OF THE SETTLEMENT ORDER IS AVAILABLE ON THE SEC'S WEBSITE

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E.,
11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event.
If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and
only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11
that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD
or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:

SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NATIONAL FUTURES ASSOCIATION (NFA)
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
06/29/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
NFA CASE NO. 23-BCC-005
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
COMMODITY POOL
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON SEPTEMBER 12, 2023, TRANSAMERICA ASSET MANAGEMENT, INC. (TAM) ENTERED INTO A SETTLEMENT WITH THE NATIONAL FUTURES ASSOCIATION (NFA)
RELATING TO A COMPLAINT ISSUED BY THE BUSINESS CONDUCT COMMITTEE OF THE NFA ALLEGING THAT TAM VIOLATED AN NFA RULE. THE COMPLAINT ISSUED
ON JUNE 29, 2023 ALLEGED THAT TAM FAILED TO IMPLEMENT AN ADEQUATE SUPERVISORY STRUCTURE TO OVERSEE THE FIRM'S COMMODITY FUTURES TRADING
COMMISSION REGISTRATION AS A COMMODITY POOL OPERATOR AND ITS NFA MEMBERSHIP OBLIGATIONS. AS PART OF THE SETTLEMENT, WITHOUT ADMITTING
OR DENYING THE ALLEGATIONS MADE AGAINST IT, TAM AGREED TO PAY A FINE OF $140,000 TO THE NFA, WHICH RESOLVED TAM'S LIABILITY FOR ALL
ALLEGATIONS AND MATTERS SET FORTH IN THE COMPLAINT.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision & Order of Offer of Settlement
11. Resolution Date (MM/DD/YYYY):
09/12/2023
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 140,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: 
TAM AGREED TO PAY A FINE OF $140,000 WHICH WAS PAID ON SEPTEMBER 27, 2023
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit
within the space provided).
ON SEPTEMBER 12, 2023, TRANSAMERICA ASSET MANAGEMENT, INC. (TAM) ENTERED INTO A SETTLEMENT WITH THE NATIONAL FUTURES ASSOCIATION (NFA)
RELATING TO A COMPLAINT ISSUED BY THE BUSINESS CONDUCT COMMITTEE OF THE NFA ALLEGING THAT TAM VIOLATED AN NFA RULE. THE COMPLAINT ISSUED
ON JUNE 29, 2023 ALLEGED THAT TAM FAILED TO IMPLEMENT AN ADEQUATE SUPERVISORY STRUCTURE TO OVERSEE THE FIRM'S COMMODITY FUTURES TRADING
COMMISSION REGISTRATION AS A COMMODITY POOL OPERATOR AND ITS NFA MEMBERSHIP OBLIGATIONS. AS PART OF THE SETTLEMENT, WITHOUT ADMITTING
OR DENYING THE ALLEGATIONS MADE AGAINST IT, TAM AGREED TO PAY A FINE OF $140,000 TO THE NFA, WHICH RESOLVED TAM'S LIABILITY FOR ALL

ALLEGATIONS AND MATTERS SET FORTH IN THE COMPLAINT.