Form 485BPOS PIMCO Managed Accounts

AMENDMENT

To

Amended and Restated Transfer Agency and Service Agreement

Between

DST Asset Manager Solutions, Inc.

and

Pacific Investment Management Company LLC

This amendment dated December 20, 2019 (the “Amendment”) is made by the parties to the Amended and Restated Transfer Agency and Service Agreement entered into on May 14, 2015, as amended, (the “Agreement”) between Pacific Investment Management Company LLC (the “Administrator”) on behalf of PIMCO Funds, PIMCO Variable Insurance Trust, PIMCO Equity Series, PIMCO Equity Series VIT and PIMCO Managed Accounts Trust (the “Trusts”) and DST Asset Manager Solutions, Inc. (formerly known as Boston Financial Data Services, Inc.) (the “Transfer Agent”). Capitalized terms used in this Amendment without definition shall have the respective meanings given to such terms in the Agreement.

WHEREAS, pursuant to the Agreement, the Administrator has appointed the Transfer Agent as transfer agent, dividend disbursing agent and agent in connection with certain other activities, as set forth in the Agreement for the Trusts and their respective Portfolios; and

WHEREAS, in accordance with Section 16.1 of the Agreement, the Administrator and the Transfer Agent desire to amend certain provisions of the Agreement to reflect additional services to be performed by the Transfer Agent for the Trusts.

NOW, THEREFORE, in consideration of the foregoing and the mutual covenants and agreements hereinafter contained, the sufficiency of which is hereby acknowledged, the Administrator and the Transfer Agent hereby agree to amend the Agreement pursuant to the terms thereof, as follows:

 

1.	Section 1.2 (Additional Services). Section 1.2 of the Agreement is amended as follows:

By adding the following new subsection 1.2(v):

“(v) Senior and Vulnerability (“SVI”) Review Services. The Transfer Agent will perform the SVI Review Services set forth on the attached schedule (“Schedule 1.2(v)” entitled “SVI Review Services”).”

 

2.	Schedule 1.2(v) (SVI Review Services). The Agreement is hereby amended to add new Schedule 1.2(v) entitled “SVI Review Services,” which is attached to this Amendment and incorporated into the Agreement hereby.

 

3.	Schedule 3.1. (Fees and Expenses) Schedule 3.1 to the Agreement is hereby amended to add the additional fees set forth on Appendix 1 to this Amendment.

 

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4.	Effectiveness. Upon its execution, this Amendment shall be effective as of December 16, 2019.

 

5.	Recitals Incorporated; Definitions. The foregoing recitals are true and correct and by this reference are incorporated herein. All capitalized terms not otherwise defined herein shall have the meanings set forth in the Agreement.

 

6.	Schedules Incorporated. All schedules referenced in this Amendment are incorporated herein and into the Agreement hereby.

 

7.	Continuing Provisions of the Agreement. Except as otherwise specifically set forth in this Amendment, all other terms of the Agreement shall remain unchanged and continue in full force and effect.

 

8.	Counterpart Signatures. This Amendment may be executed in any number of counterpart signatures with the same effect as if the parties had all signed the same document. All counterpart signatures shall be construed together and shall constitute one agreement.

IN WITNESS WHEREOF, the parties hereto have caused this Amendment to be executed in their names and on their behalf by and through their duly authorized officers, as of the day and year first above written.

 

PACIFIC INVESTMENT MANAGEMENT COMPANY LLC.

 

By:		/s/ Peter Strelow

 

Name: Peter Strelow

 

Title: Managing Director

 

DST ASSET MANAGER SOLUTIONS, INC.
By:		DocuSigned by:   /s/ Rahul Kanwar
Name:		Rahul Kanwar
Title:		Authorized Representative

 

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SCHEDULE 1.2(v)

SVI REVIEW SERVICES

Transfer Agent Responsibilities.

 

1.	Reports. The Transfer Agent will produce the following systematic daily reports:

 

a.

Financial Activity on a Dormant Account. Identifies accounts where the shareholder is aged 65 or older, has two or more redemptions within 90 calendar days, and had no financial activity for the previous 360 calendar days (other than dividends, capital gains and required minimum distributions (RMDs)).

 

b.

On-Line Redemption. Identifies accounts where the shareholder is aged 65 or older and has a redemption greater than or equal to $1,500 where the transaction originated through FANWeb or Audio Response.

 

c.

Maintenance Followed by Rapid Depletion of Account. Identifies accounts where the shareholder is aged 65 or older, and there have been two or more redemptions, and a power of attorney (“POA”) or new authorized signer was added to the account within the past 60 days.

 

d.

Shareholder Adding Joint Owner, POA or Conservator to Account. Identifies accounts that had a maintenance or transfer from a single account to an account with a Joint Owner, POA or Conservator.

 

e.

Elder Exploitation / Vulnerable Adult Heightened Monitoring. Identifies financial (redemptions) and non-financial activity on an account on the Elder Exploitation / Vulnerable Adult Heightened Monitoring list. The Elder Exploitation / Vulnerable Adult Heightened Monitoring list shall refer to activity on those accounts that have been identified by Transfer Agent or the Administrator as requiring heightened surveillance under one of the categories described in Paragraph a. through Paragraph d. of this Section 1.

 

2.

Reviews. The Transfer Agent will perform daily monitoring of the reports and an analysis of transactions for unusual activity based on the written guidelines for suspicious activity maintained by the Transfer Agent that have been made available to the Administrator. Following its review, the Transfer Agent will take the following actions:

 

a.

If no suspicious activity is observed in its review, the Transfer Agent will add comments in AWD with respect to those reviewed items.

 

b.

If activity is identified that appears suspicious or questionable, the Transfer Agent will escalate the particular items to the Administrator for review and further instruction.

 

c.

Once an item is escalated to the Administrator, the Transfer Agent will take such further actions with respect to the account as directed by the Administrator.

 

d.

If a Suspicious Activity Report (SAR) needs to be made with respect to any activity reviewed, the Transfer Agent will prepare and send the documentation to the Administrator for review and approval prior to filing.

In providing the foregoing SVI Review Services, the Transfer Agent agrees to carry out such services in accordance with the Standard of Care under the Agreement. The Administrator acknowledges that the Transfer Agent is not providing any guarantee or warranty that the SVI Review Services will identify all fraudulent activity in shareholder accounts in the Trusts or Portfolios. The Administrator further acknowledges and agrees that the Transfer Agent shall not be responsible for losses resulting from the fraudulent actions of third parties.

 

Page 3

Certain information has been excluded from this exhibit because it is both (1) not material and (2) would likely cause competitive harm to the registrant if publicly disclosed.

AMENDMENT

TO

AMENDED AND RESTATED

TRANSFER AGENCY AND SERVICE AGREEMENT

THIS AMENDMENT TO THE AMENDED AND RESTATED TRANSFER AGENCY AND SERVICE AGREEMENT DATED AS OF MAY 14, 2015, AS AMENDED AND SUPPLEMENTED, (the “Amendment”) is entered into on December 2, 2020 and made effective as of May 15, 2020 (the “Effective Date”) by and between PACIFIC INVESTMENT MANAGEMENT COMPANY LLC, a Delaware limited liability Company, having its principal office and place of business at 650 Newport Center Drive, Newport Beach, CA 92660 (the “Administrator”), on behalf of PIMCO Funds, PIMCO Variable Insurance Trust, PIMCO Equity Series, PIMCO Equity Series VIT and PIMCO Managed Accounts Trust (each, a “Trust”, and together, the “Trusts”), and DST ASSET MANAGER SOLUTIONS, INC. (previously named Boston Financial Data Services, Inc.) (“Transfer Agent”), a Massachusetts corporation having a principal place of business at 2000 Crown Colony Drive, Quincy, Massachusetts 02169. Each of Administrator and Transfer Agent is a “Party” and collectively they are the “Parties.”

WHEREAS, Administrator and Boston Financial Data Services, Inc. entered into that certain Amended and Restated Transfer Agency and Service Agreement, dated as of May 14, 2015 (as amended, the “Agreement”);

WHEREAS, on or about January 1, 2018, Boston Financial Data Services, Inc. changed its name to DST Asset Manager Solutions, Inc.; and

WHEREAS, Administrator, on behalf of each Trust, and Transfer Agent wish to amend the terms of the Agreement as outlined below.

NOW, THEREFORE, in consideration of the mutual promises, undertakings, covenants and conditions set forth herein, the Transfer Agent and Administrator agree as follows:

 

1.

Section 1.1. Section 1.1 is hereby amended by deleting the first paragraph (excluding the lettered sub-paragraphs that follow) and the following is inserted in lieu thereof:

1.1 Transfer Agency Services. Subject to the terms and conditions set forth in this Agreement, the Administrator, on behalf of each Trust and the Portfolios, hereby employs and appoints the Transfer Agent to act as, and the Transfer Agent agrees to act as, its transfer agent for each Trust’s authorized and issued shares of beneficial interest (“Shares”), dividend disbursing agent and agent in connection with any accumulation, open-account or similar plan provided to the shareholders of a Trust and of any Portfolios of a Trust (“Shareholders”) and described in the currently effective prospectus(es) and statement(s) of additional information of each Trust, on behalf of the applicable Portfolio, including without limitation any periodic investment plan, dividend reinvestment plan or periodic withdrawal program. In accordance with (i) procedures established from time to time by agreement between the Transfer Agent and the Administrator (the “Procedures”), with such changes or deviations therefrom as have been (or may from time to time be) agreed upon in writing by the parties, and (ii) the service level standards and exceptions set forth in Schedule 1.1 (the “Service

 

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Level Standards”), the Transfer Agent agrees that it will perform the following services:”

 

2.

Section 1.2. Section 1.2(a) is hereby deleted in its entirety and the following is inserted in lieu thereof:

“(a) Other Customary Services. Perform certain customary services of a transfer agent, dividend disbursing agent, service agent of certain retirement plans, and, as relevant, agent in connection with accumulation, open-account or similar plan (including without limitation any dividend reinvestment plan, periodic investment plan or periodic withdrawal program), including but not limited to: maintaining all Shareholder accounts; preparing Shareholder lists for meetings; providing print files to Administrator’s print vendor of choice for mailing of Shareholder reports and prospectuses and statements of additional information to current Shareholders; providing print files to Administrator’s print vendor of choice for delivery of prospectuses in conjunction with first dollar confirmations into a Portfolio by any investor, whether or not a current Shareholder; withholding taxes on U.S. resident and non-resident alien accounts; preparing and filing U.S. Treasury Department Forms 1099 and other appropriate forms required with respect to dividends and distributions by federal authorities for all Shareholders; providing print files to Administrator’s print vendor of choice for mailing confirmation forms and statements of account to Shareholders for all purchases and redemptions of Shares and other confirmable transactions in Shareholder accounts; providing print files to Administrator’s print vendor of choice for mailing activity statements for Shareholders; providing Shareholder account information; and receiving checks in the name of the Portfolios or the Trust and refusing checks that are in the name of the Administrator or PIMCO Investments, LLC (the “Distributor”), including the maintenance of a record through the automated work distributor system (“AWD”) containing pertinent details about any such checks. For the avoidance of doubt, the Transfer Agent does not accept securities on behalf of the Portfolios, the Trust, the Administrator or Distributor.”

 

3.

Section 3.5. Section 3.5 of the Agreement is hereby deleted in its entirety and the following is inserted in lieu thereof:

“Cost of Living Adjustment. A Cost of Living increase will apply starting June 1, 2023 and apply annually for each succeeding year of this Agreement in an amount equal to the annual percentage of change in the Consumer Price Index for all Urban Consumers (CPI-U) in the Midwest Statistical Area, All Items, Base 1982-1984=100, as last reported by the U.S. Bureau of Labor Statistics, or, in the event that publication of such Index is terminated, any successor or substitute index, appropriately adjusted, acceptable to both parties. In the event this Agreement was not signed as of the first day of the month, the fees and charges increase shall be effective as of the first day of the month immediately following the month during which the anniversary occurred and will be communicated to the Administrator in advance of the effective date. For clarification, if the change in the CPI-U is either zero or negative for the applicable period, the fees and charges for the succeeding calendar year will not decrease. Any Cost of Living increase shall be capped at a maximum rate of five percent (5%) per year.”

 

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4.

Section 10. The following new provisions are added to Section 10.

“Section 10.6. In the event the Administrator or a Trust obtains information from Transfer Agent or the TA2000 System which is clearly not intended for the Administrator or a Trust (“Unintended Information”), the Administrator agrees to: (i) promptly notify Transfer Agent after reaching an affirmative determination that such Information made available to the Administrator or a Trust constitutes or includes Unintended Information; (ii) not further review, disclose, release, or in any way use such Unintended Information; (iii) to the best of its ability, and subject to the requirements of applicable law or regulatory authority, provide Transfer Agent assistance to retrieve and/or destroy such Unintended Information; and (iv) deliver to Transfer Agent a certificate executed by an authorized officer of the Administrator certifying that all such unauthorized information in the Administrator’s possession or control has been delivered to Transfer Agent or destroyed as required by this provision.”

 

5.

Section 11.4. Section 11.4 of the Agreement is hereby deleted in its entirety and the following is inserted in lieu thereof:

11.4 Compliance Program. The Transfer Agent maintains and will continue to maintain a comprehensive compliance program reasonably designed to prevent violations of the federal securities laws pursuant to Rule 38a-1 under the 1940 Act. Pursuant to its compliance program, the Transfer Agent will provide periodic measurement reports to each Trust and its Chief Compliance Officer. Upon request of the Administrator, the Transfer Agent will provide to the Administrator in connection with any periodic annual or semi-annual shareholder report filed by a Trust or, in the absence of the filing of such reports, on a quarterly basis, a sub-certification pursuant to the Sarbanes-Oxley Act of 2002 in a form reasonably acceptable to the Administrator on behalf of each Trust with respect to the Transfer Agent’s performance of the services set forth in this Agreement and its internal controls related thereto. In addition, on a quarterly basis, the Transfer Agent will provide to the Administrator on behalf of each Trust a certification in a form reasonably acceptable to such Trust in connection with its compliance with Rule 38a-1 under the 1940 Act. On a quarterly basis, the Transfer agent will provide to the Administrator on behalf of each Trust a certification in a mutually agreed upon format in connection with DST’s performance of the SVI Review Services. The Transfer Agent reserves the right to amend and update its compliance program and the measurement tools and certifications provided thereunder from time to time in order to address changing regulatory and industry developments, and will promptly notify the Administrator of any such changes.

 

6.

Section 12.1. The following is added and inserted as the second sentence of Section 12.1:

“Effective May 15, 2020, the “Initial Term” shall be May 15, 2020 to May 14, 2027 unless terminated pursuant to the provisions of this Section 12 or Schedule 1.1.”

 

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7.

Section 14.1. Section 14.1 is hereby deleted in its entirety and the following is inserted in lieu thereof:

“The Transfer Agent may, without further consent on the part of the Administrator, subcontract for the performance hereof with an affiliate of the Transfer Agent. Notwithstanding the above, in the event any subcontracted functions require a duly registered transfer agent, such affiliate will be duly registered as a transfer agent pursuant to Section 17A(c)(2) of the 1934 Act and have the financial capacity and resources to provide the level of services required of the Transfer Agent hereunder. The Transfer Agent shall be fully responsible to the Administrator for the acts and omissions of its affiliate (and for any other agent or subcontractor selected and used by the Transfer Agent to provide services required hereunder) as it is for its own acts and omissions. The foregoing shall not be deemed to apply to any direct contracts between the Administrator and any affiliate of the Transfer Agent as to which the Transfer Agent is not a party. The Transfer Agent may provide the services hereunder from service locations within or outside of the United States subject to applicable law and regulations without the consent of the Administrator or a Trust, provided, however, if any service is to be provided from outside of the United States, the Transfer Agent shall provide written notification to the Administrator in advance.”

 

8.

Schedule A. The parties acknowledge and agree Schedule A is hereby deleted in its entirety and Schedule A attached hereto is inserted in its place.

 

9.

Schedule 3.1. The parties acknowledge and agree Schedule 3.1 (Fee Schedule) is hereby deleted in its entirety and Schedule 3.1 attached hereto is inserted in its place.

 

10.

Schedule 1.2(f). The following new provisions are added to Section 4.1 of Schedule 1.2(f) (AML Delegation):

“(r) Except with respect to any entities excluded under applicable regulation: (i) take reasonable steps to verify the identity of legal entities seeking to become new customers of the Trusts, including verifying the identity of the natural person(s) retaining ownership or controlling interest in such legal entity (the “ Beneficial Owner(s)”), as such ownership and controlling interests are defined in 31 C.F.R. 1010.230, (ii) notify the Trusts in the event that the identity of such Beneficial Owner(s) is not provided upon request to such entity or cannot be verified, (iii) maintain records of the information used to verify such Beneficial Owners, as required, and (iv) determine whether such persons appear on any lists of known or suspected terrorists or terrorist organizations provided to the Trusts by any government agency.”

 

11.

Effect on Agreement. As of the Effective Date, this Amendment shall be effective to amend the Agreement and to the extent of any conflict between the Agreement and this Amendment, this Amendment shall control.

 

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12.

Execution in Counterparts/Facsimile Transmission. This Amendment may be executed in separate counterparts, each of which will be deemed to be an original and all of which, collectively, will be deemed to constitute one and the same Amendment. This Amendment may also be signed by exchanging facsimile or electronic mail copies of this Amendment.

 

13.

Agreement in Full Force and Effect. Except as specifically modified by this Amendment, the terms and conditions of the Agreement shall remain in full force and effect, and the Agreement, as amended by this Amendment, and all of its terms, including, but not limited to any warranties and representations set forth therein, if any, are hereby ratified and confirmed by the Administrator and Transfer Agent as of the Effective Date.

 

14.

Capitalized Terms. All capitalized terms used but not defined in this Amendment will be deemed to be defined as set forth in the Agreement.

 

15.

Authorization. Each party hereby represents and warrants to the other that the person or entity signing this Amendment on behalf of such party is duly authorized to execute and deliver this Amendment and to legally bind the party on whose behalf this Amendment is signed to all of the terms, covenants and conditions contained in this Amendment.

IN WITNESS WHEREOF, the parties have caused this Amendment to be executed by their respective duly authorized officers, to be effective as of the day and year first above written.

 

PACIFIC INVESTMENT MANAGEMENT COMPANY, LLC
By:		/s/ Peter Strelow
Name:		Peter Strelow
Title:		Managing Director

 

DST ASSET MANAGER SOLUTIONS, INC.
By:		/s/ Rahul Kanwar
Name:		Rahul Kanwar
Title:		Authorized Representative

 

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Schedule A

 

Trust		Type of Entity		Jurisdiction
PIMCO FUNDS		MA Business Trust		MA
				CLASS
PIMCO All Asset All Authority Fund				All Classes
PIMCO All Asset Fund				All Classes
PIMCO California Intermediate Municipal Bond Fund				All Classes
PIMCO California Municipal Bond Fund				All Classes
PIMCO California Short Duration Municipal Income Fund				All Classes
PIMCO Climate Bond Fund				All Classes
PIMCO CommoditiesPLUS Strategy Fund				All Classes
PIMCO CommodityRealReturn Strategy Fund®				All Classes
PIMCO Credit Opportunities Bond Fund				All Classes
PIMCO Diversified Income Fund				All Classes
PIMCO Dynamic Bond Fund				All Classes
PIMCO Emerging Markets Bond Fund				All Classes
PIMCO Emerging Markets Corporate Bond Fund				All Classes
PIMCO Emerging Markets Currency and Short-Term Investments Fund				All Classes
PIMCO Emerging Markets Full Spectrum Bond Fund				All Classes
PIMCO Emerging Markets Local Currency and Bond Fund				All Classes
PIMCO ESG Income Fund				All Classes
PIMCO Extended Duration Fund				All Classes
PIMCO Global Advantage Strategy Bond Fund				All Classes
PIMCO Global Bond Opportunities Fund (U.S. Dollar-Hedged)				All Classes
PIMCO Global Bond Opportunities Fund (Unhedged)				All Classes
PIMCO Global Core Asset Allocation Fund				All Classes
PIMCO GNMA and Government Securities Fund				All Classes
PIMCO Government Money Market Fund				All Classes
PIMCO Gurtin California Municipal Intermediate Value Fund				All Classes
PIMCO Gurtin California Municipal Opportunistic Value Fund				All Classes
PIMCO Gurtin National Municipal Intermediate Value Fund				All Classes
PIMCO Gurtin National Municipal Opportunistic Value Fund				All Classes
PIMCO High Yield Fund				All Classes
PIMCO High Yield Municipal Bond Fund				All Classes
PIMCO High Yield Spectrum Fund				All Classes
PIMCO Income Fund				All Classes
PIMCO Inflation Response Multi-Asset Fund				All Classes
PIMCO International Bond Fund (U.S. Dollar-Hedged)				All Classes
PIMCO International Bond Fund (Unhedged)				All Classes
PIMCO Investment Grade Credit Bond Fund				All Classes
PIMCO Long Duration Total Return Fund				All Classes
PIMCO Long-Term Credit Bond Fund				All Classes

 

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PIMCO Long-Term Real Return Fund				All Classes
PIMCO Long-Term U.S. Government Fund				All Classes
PIMCO Low Duration ESG Fund				All Classes
PIMCO Low Duration Fund				All Classes
PIMCO Low Duration Fund II				All Classes
PIMCO Low Duration Income Fund				All Classes
PIMCO Moderate Duration Fund				All Classes
PIMCO Mortgage Opportunities and Bond Fund				All Classes
PIMCO Mortgage-Backed Securities Fund				All Classes
PIMCO Multi-Strategy Alternative Fund				All Classes
PIMCO Municipal Bond Fund				All Classes
PIMCO National Intermediate Municipal Bond Fund				All Classes
PIMCO New York Municipal Bond Fund				All Classes
PIMCO Preferred and Capital Securities Fund				All Classes
PIMCO RAE Fundamental Advantage PLUS Fund				All Classes
PIMCO RAE PLUS Fund				All Classes
PIMCO RAEPLUS EMG Fund				All Classes
PIMCO RAE PLUS International Fund				All Classes
PIMCO RAE PLUS Small Fund				All Classes
PIMCO RAE Worldwide Long/Short PLUS Fund				All Classes
PIMCO Real Return Fund				All Classes
PIMCO RealEstateRealReturn Strategy Fund				All Classes
PIMCO Senior Floating Rate Fund				All Classes
PIMCO Short Asset Investment Fund				All Classes
PIMCO Short Duration Municipal Income Fund				All Classes
PIMCO Short-Term Fund				All Classes
PIMCO StocksPLUS® Absolute Return Fund				All Classes
PIMCO StocksPLUS® Fund				All Classes
PIMCO StocksPLUS® International Fund (U.S. Dollar-Hedged)				All Classes
PIMCO StocksPLUS® International Fund (Unhedged)				All Classes
PIMCO StocksPLUS® Long Duration Fund				All Classes
PIMCO StocksPLUS® Short Fund				All Classes
PIMCO StocksPLUS® Small Fund				All Classes
PIMCO Strategic Bond Fund				All Classes
PIMCO Total Return ESG Fund				All Classes
PIMCO Total Return Fund				All Classes
PIMCO Total Return Fund II				All Classes
PIMCO Total Return Fund IV				All Classes
PIMCO TRENDS Managed Futures Strategy Fund				All Classes

 

PAPS
PIMCO ABS and Short-Term Investments Portfolio
PIMCO All Asset: Multi-RAE PLUS Fund

 

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PIMCO All Asset: Multi-Real Fund
PIMCO All Asset: Multi-Short PLUS Fund
PIMCO EM Bond and Short-Term Investments Portfolio
PIMCO High Yield and Short-Term Investments Portfolio
PIMCO International Portfolio
PIMCO Investment Grade Credit Bond Portfolio
PIMCO Long Duration Credit Bond Portfolio
PIMCO Low Duration Portfolio
PIMCO Moderate Duration Portfolio
PIMCO Mortgage and Short-Term Investments Portfolio
PIMCO Municipal Portfolio
PIMCO Real Return Portfolio
PIMCO Short Asset Portfolio
PIMCO Short-Term Floating NAV Portfolio II
PIMCO Short-Term Floating NAV Portfolio III
PIMCO Short-Term Portfolio
PIMCO US Government and Short-Term Investments Portfolio

 

PIMCO VARIABLE INSURANCE TRUST		DE Statutory Trust		DE
				CLASSES
PIMCO All Asset Portfolio				All Classes
PIMCO Balanced Allocation Portfolio				All Classes
PIMCO CommodityRealReturn Strategy Portfolio				All Classes
PIMCO Dynamic Bond Portfolio				All Classes
PIMCO Emerging Markets Bond Portfolio				All Classes
PIMCO Global Bond Opportunities Portfolio (Unhedged)				All Classes
PIMCO Global Core Bond (Hedged) Portfolio				All Classes
PIMCO Global Diversified Allocation Portfolio				All Classes
PIMCO Global Managed Asset Allocation Portfolio				All Classes
PIMCO High Yield Portfolio				All Classes
PIMCO Income Portfolio				All Classes
PIMCO International Bond Portfolio (U.S. Dollar-Hedged)				All Classes
PIMCO International Bond Portfolio (Unhedged)				All Classes
PIMCO Long-Term U.S. Government Portfolio				All Classes
PIMCO Low Duration Portfolio				All Classes
PIMCO Real Return Portfolio				All Classes
PIMCO Short-Term Portfolio				All Classes
PIMCO Total Return Portfolio				All Classes

 

PIMCO EQUITY SERIES		Delaware Statutory		DE
		Trust		CLASS
PIMCO Dividend and Income Fund				All Classes
PIMCO RAE Emerging Markets Fund				All Classes

 

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PIMCO RAE Global ex-US Fund				All Classes
PIMCO RAE Global Fund				All Classes
PIMCO RAE International Fund				All Classes
PIMCO RAE US Fund				All Classes
PIMCO RAE US Small Fund				All Classes
PIMCO RealPath Blend 2025 Fund				All Classes
PIMCO RealPath Blend 2030 Fund				All Classes
PIMCO RealPath Blend 2035 Fund				All Classes
PIMCO RealPath Blend 2040 Fund				All Classes
PIMCO RealPath Blend 2045 Fund				All Classes
PIMCO RealPath Blend 2050 Fund				All Classes
PIMCO RealPath Blend 2055 Fund				All Classes
PIMCO RealPath Blend 2060 Fund				All Classes
PIMCO RealPath Blend Income Fund				All Classes

 

PIMCO EQUITY SERIES VIT		Delaware Statutory		DE
		Trust		CLASS
PIMCO StocksPLUS Global Portfolio				All Classes

 

PIMCO Managed Account Trust
Fund
PIMCO Fixed Income SHares: Series C		All Classes
PIMCO Fixed Income SHares: Series LD		All Classes
PIMCO Fixed Income SHares: Series M		All Classes
PIMCO Fixed Income SHares: Series R		All Classes
PIMCO Fixed Income SHares: Series TE		All Classes
Private Funds (Limited to Blue Sky Services)
Fund		CIK
PIMCO Distressed Senior Credit Opportunities Fund II Offshore Feeder, LP		1532935
PIMCO Distressed Senior Credit Opportunities Fund II, LP		1532934
PIMCO Global Credit Opportunity Employee Onshore Fund LLC		1571718
PIMCO Global Credit Opportunity Offshore Fund Ltd.		1370509
PIMCO Global Credit Opportunity Onshore Fund LLC.		1459533
PIMCO Loan Interests and Credit Onshore Master Fund LLC		1559671
PIMCO Loan Interests and Credit Offshore Master Fund LTD.		1555573
PIMCO Muni Real Return		1139696
PIMCO Municipal Funds LLC		1348864
PIMCO Absolute Return Strategy 3 Offshore Fund Ltd. (f/k/a PIMCO Absolute Return
Strategy II Offshore Fund Ltd.)		1412058
PIMCO Absolute Return Strategy 3 Onshore Fund LLC (f/k/a PIMCO Absolute Return		1336837
Strategy II Onshore Fund LLC)
PIMCO Absolute Return Strategy 3E Offshore Fund Ltd. (f/k/a PIMCO Absolute Return		1324636
Strategy III Offshore Fund Ltd.)
PIMCO Absolute Return Strategy 3E Onshore Fund LLC (f/k/a PIMCO Absolute Return		1438677
Strategy III Onshore Fund LLC)

 

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PIMCO Absolute Return Strategy IV Employee Onshore Fund LLC		1571731
PIMCO Absolute Return Strategy IV Fund 1 Ltd.		1171964
PIMCO Absolute Return Strategy IV Fund 2 Ltd.		1171962
PIMCO Absolute Return Strategy IV LLC.		1171963
PIMCO Absolute Return Strategy V Offshore Fund Ltd.		1430674
PIMCO Large Cap StocksPLUS Total Return Fund		1460669
PIMCO Tactical Opportunities Offshore Fund L.P.		1569540
PIMCO Tactical Opportunities Onshore Fund L.P.		1569541
PIMCO Absolute Return Strategy III Overlay Offshore Fund Ltd.		1577866
PIMCO Combined Alpha Strategies Offshore Fund Ltd		1389537
PIMCO Dividend Emerging Market Sector Fund LLC Form D		1637306
PIMCO RAE Fundamental Global Fund LLC		1644762
PIMCO RAE Fundamental Global ex-US Fund LLC		1644759
PIMCO RAE Fundamental International Fund LLC		1644757
PIMCO RAE Fundamental Emerging Markets Fund LLC		1644758
PIMCO RAE Fundamental US Fund LLC		1644801
PIMCO Absolute Return Strategy V Onshore Fund LLC		1653768
PHFS II SP, A Segregated Portfolio of PHFS Series SPC		1647780
PIMCO Global Inflation Linked Bond Fund Ltd.		1628775
PHFS I SP, a Segregated Portfolio of PHFS Series SPC		1647779
PHFS III SP, a Segregated Portfolio of PHFS Series SPC		1656582
PHFS IV SP, a Segregated Portfolio of PHFS Series SPC		1668220
PHFS V SP, A Segregated Portfolio of PHFS Series SPC		1673677
PIMCO Money Market Fund Ltd.		1689296
PIMCO Multi-Asset Alternative Risk Premia Strategy Offshore Fund L.P.		1702456
PIMCO Multi-Asset Alternative Risk Premia Strategy Onshore Fund L.P.		1720593
PIMCO Absolute Return Strategy IV IDF LLC		1426150
StocksPLUS, L.P. A		1459534
StocksPLUS, L.P. B		1459534
PIMCO Commodities Alpha Fund		1570965
PIMCO Commodities Alpha Offshore Fund		1570879
PHFS Residential Opportunities Offshore Fund, L.P		1810622
PIMCO ILS Fund SP I, A Segregated Portfolio of PIMCO ILS Series SPC		1778560
PIMCO ILS Fund SP II, A Segregated Portfolio of PIMCO ILS Series SPC		1798640
PIMCO Multi-Asset Alternative Risk Premia Strategy Risk Off Version Offshore Fund L.P.		1793835
PIMCO Commodity Risk Premia Onshore Fund L.P.		1744003
PIMCO Commodity Risk Premia Offshore Fund Ltd.		1744028
PIMCO Multi-Asset Alternative Risk Premia Strategy Risk Off Version Onshore Fund L.P.		1793851

 

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SCHEDULE 1.1

SERVICE LEVEL STANDARDS

1. TRANSACTION PROCESSING ACCURACY

 

CATEGORY		TARGET
Transaction Processing		Each quarter, overall Transfer Agent accuracy will meet or exceed 98.0%.
		Transaction processing accuracy percentage measured by the total number of manual transactions processed by the Transfer Agent, reduced by the number of as-of transactions ultimately determined to have been caused solely by the Transfer Agent, divided by the total number of manual transactions processed by the Transfer Agent.

2. TELEPHONE TIMELINESS

 

CATEGORY		TARGET
Average Speed of Answer		Each quarter, 80% of overall calls will be answered within 20 seconds during applicable hours.

 

If after a span of three consecutive quarters Transfer Agent is not able to meet the same respective Service Level Standard provided above, the Transfer Agent will be provided a 90-day time period to successfully maintain the provided targets (the “Remediation Period”). If at the conclusion of the Remediation Period the Transfer Agent fails to meet the targets provided above during the Remediation Period, then the Administrator may terminate the Agreement without penalty upon written notice to Transfer Agent within 30 days.

 

11

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SCHEDULE 1.1

 

SERVICE LEVEL EXCEPTIONS   Performance with respect to a Service Level shall not be calculated for any period or portion of a period where the Transfer Agent is unable to achieve a Service Level as a result of any of the following:   1.  Failure or unavailability of communication lines outside of the Transfer Agent’s facilities.   2.  Failure or unavailability of any system, which is substantially required for the performance of the Services, provided that the Transfer Agent has adopted and implemented a program reasonably designed to prevent such failures or unavailability.   3.  Failure by a third party outside of the Transfer Agent’s control (and whose performance is a prerequisite for the Transfer Agent’s performance) to perform properly or in a timely manner. Third parties over which the Transfer Agent exerts control (and whose performance is a prerequisite for the Transfer Agent’s performance)will not be included in this exception.   4.  A pre-planned, extraordinary event that the Administrator was informed about in advance.   5.  A failure in equipment controlled in whole or in part by the Administrator or an agent of the Administrator.   6.  With respect to telephone related service levels, a call volume of fewer than fifty (50) overall calls per day resulting in a statistically unreliable sample for measurement.   7.  An unexpected increase in volume that is more than 15% higher than the previous twelve (12) week average.   8.  A disaster which requires the Transfer Agent to process at its disaster recovery facility or when the Transfer Agent’s transaction processing is impeded by a Force Majeure event.

 

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CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

We hereby consent to the incorporation by reference in this Registration Statement on Form N-1A of PIMCO Managed Accounts Trust of our report dated February 25, 2021, relating to the financial statements and financial highlights, which appears in Fixed Income SHares: Series C’s, Fixed Income SHares: Series LD’s, Fixed Income SHares: Series M’s, Fixed Income SHares: Series R’s and Fixed Income SHares: Series TE’s Annual Report on Form N-CSR for the year ended December 31, 2020. We also consent to the references to us on the cover page of the Statement of Additional Information and under the headings “Financial Statements”, “Independent Registered Public Accounting Firm” and “Financial Highlights” in such Registration Statement.

/s/ PricewaterhouseCoopers LLP

Kansas City, Missouri

April 29, 2021

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PIMCO’s Code of Ethics (“Code”) contains the rules that govern your personal trading and outside business activities. These rules are summarized below. Please see the Code for more details (capitalized terms are defined in the Appendix).

YOU HAVE THE FOLLOWING FUNDAMENTAL RESPONSIBILITIES:

 

●

You have a duty to place the interests of Clients first

 

●

You must avoid any actual or potential conflict of interest

 

●

You must not take inappropriate advantage of your position at PIMCO

 

●

You must comply with all applicable Securities and Commodities Laws

You must pre-clear and receive approval for your Personal Securities Transactions, unless an exemption is available. Personal Securities Transaction is a very broad concept and includes transactions in Securities, Derivatives, currencies for investment purposes and commodities for investment purposes, but does not include direct transactions in Cryptocurrencies. It is your responsibility to understand the treatment of any proposed transaction under the Code by checking the definitions found in Appendix I. You are encouraged to consult with a Compliance Officer if you have any question as to the status of a particular instrument under the Code.

Personal Real Estate Investment Transactions (as defined in Appendix II) that constitute Private Placements are Personal Securities Transactions that are subject to the Code, and must be pre-cleared and receive prior approval in accordance with Section III.C.

You can pre-clear and receive approval for your transaction by the following two-step process:

 

		Step 1: To pre-clear a transaction, you must input the details of the proposed transaction into the Compliance Portal system (accessible through the PIMCO Intranet) and follow the instructions.   Step 2: You will receive notification as to whether your proposed transaction is approved or denied. If your proposed transaction is approved, the approval is valid only for the day on which the approval was granted and the following business day, unless otherwise indicated in the approval confirmation or unless you are notified differently by a Compliance Officer. If you do not execute your transaction within the required timeframe or if the information in your request changes, you must repeat the pre-clearance process prior to undertaking the transaction.

Generally, certain types of transactions, such as purchases or sales of government securities, open-end mutual funds, and interval funds, do not require pre-clearance and approval. See Sections III.C.2. and III.C.3. of the Code for specific guidance.

However, Portfolio Persons (see Appendix I) are subject to more restrictive pre-clearance requirements, which are set forth in Section III.C.2.a.

 

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BLACK-OUT PERIODS FOR PORTFOLIO PERSONS

Employees classified as Portfolio Persons are prohibited from executing certain transactions during black-out periods, as defined below:

 

●

Purchases or sales prior to, and including, seven calendar days before a Client transaction in the same Financial Instrument or any Related Financial Instrument (each as defined in Appendix I)

 

●

Purchases or sales within three calendar days following a Client transaction in the same Financial Instrument or any Related Financial Instrument

CIRCUMSTANCES THAT MAY RESTRICT YOUR PERSONAL SECURITIES TRANSACTIONS:

 

●

When there are pending Client orders in the same Financial Instrument or a Related Financial Instrument

 

●

Black-out periods in closed-end funds advised or sub-advised by PIMCO

 

●

Section 16 holding periods

 

●

Investments in:

 

o

Initial Public Offerings (with certain exemptions for fixed income and other securities)

 

o

Special Purpose Acquisition Companies (SPACs)

 

o

Private Placements and hedge funds

 

o

Securities issued by Allianz SE

 

o

Securities on PIMCO’s Restricted Securities List

The Code has other requirements that may restrict your personal securities transactions in addition to those summarized above. Please review the entire Code. Remember that you can be sanctioned for failing to comply with the Code. If you have any questions, please ask a Compliance Officer.

PIMCO CODE OF ETHICS

 

I.	INTRODUCTION

This Code of Ethics (“Code”) sets out standards of conduct to help PIMCO’s directors, officers and employees (each, an “Employee” and collectively, “Employees”)¹ avoid potential conflicts that may arise from their Personal Securities Transactions and outside business activities. You must read and understand this Code. Compliance can assist you with any questions.

 

II.	YOUR FUNDAMENTAL RESPONSIBILITIES

PIMCO insists on a culture that promotes honesty and high ethical standards. This Code is intended to assist Employees in meeting the high ethical standards PIMCO follows in conducting its business. The following general fiduciary principles must govern your activities:

 

●

You have a duty to place the interests of Clients first

 

●

You must avoid any actual or potential conflict of interest

 

●

You must not take inappropriate advantage of your position at PIMCO

 

●

You must comply with all applicable Securities and Commodities Laws

If you violate this Code or its associated policies and procedures, PIMCO may impose disciplinary action against you, including full or partial disgorgement of profits, a reduction in discretionary compensation,

 

 

1

Employees also include certain employees of PIMCO Investments and employees designated as dual-personnel of Gurtin Municipal Bond Management (“Gurtin Dual-Personnel”). For the avoidance of doubt, Gurtin Dual-Personnel are subject to the Code of Ethics in their capacity as both PIMCO employees and Gurtin Dual-Personnel. Additionally, employees of certain non-U.S. affiliates of PIMCO are known as “Associated Persons.” Associated Persons are subject to the respective Code of Ethics of the affiliate with which they are employed.

 

CODE OF ETHICS | March 2021     3

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censure, demotion, suspension or dismissal, or any other sanction or remedial action required or permitted by law, rule or regulation.

 

III.	PERSONAL INVESTMENTS

 

A.

In General

In general, when making personal investments you must exercise extreme care to ensure that you do not violate this Code and your fiduciary duties. You may not take inappropriate advantage of your position at PIMCO in connection with your personal investments. In addition, any excessive or inappropriate trading that, in PIMCO’s view, interferes with job performance, or compromises the duty that PIMCO owes to its Clients, will not be tolerated. This Code covers the personal investments of all Employees and their Immediate Family Members (see Appendix I). Therefore, you and your Immediate Family Members must conduct all your personal investments consistent with this Code.

 

B.

Prohibition on Short-Term Trading (“30 Calendar Day Rule”)

Employees are prohibited from engaging in short-term trading strategies for their own accounts. Unless specifically exempted under this Code, a short term trade is any purchase followed by a sell, or any sell followed by a purchase, of the same Financial Instrument within 30 calendar days.

This prohibition applies on a last in, first out basis: 1) even if the purchase and sell transactions occur in different accounts; 2) regardless of any designated tax lots associated with the purchase or sell transaction; and 3) only to Financial Instruments that require pre-clearance under the Section III.C. of the Code.

The date of the first transaction is considered day one, and Employees may not execute a transaction in the opposite direction until day 31. Employees will absorb any losses and will be instructed to disgorge any profits associated with short term trades in any Financial Instrument that requires pre-clearance. Compliance will calculate profits based on any or all opposite way transactions that occur within a 30 calendar day period, even if the transactions result in realized losses in one or more individual account(s). Transaction costs and potential tax liabilities will not be included in the profit calculations. Compliance also may instruct the employee to reverse a transaction that violates the 30 Calendar Rule.

Profits from such trades must be disgorged as required by a Compliance Officer.

Note, an Option transaction with an expiration date within the 30 calendar days, as described above, of the initial purchase or sale date is also prohibited. Options must have an expiration date that is at least 31 days from the initial purchase or sale date.

See the Appendix for specific guidance on options trading with regards to pre-clearance and the 30 Calendar Day Rule.

Notwithstanding the foregoing, disgorgement will not be required for transactions in which the calculated profit is less than $25.

The following transactions are exempt from the 30 Calendar Day Rule:

 

1.

Transactions that are exempt from the pre-clearance and approval requirement as provided in Sections III.C.2. and III.C.3. of the Code (i.e., Exempt Reportable Transactions and Exempt Transactions as defined in those Sections). For purposes of this exclusion, although Portfolio Persons must observe the pre-clearance requirements specified in Section II.C.2.a., Portfolio Persons’ transactions in direct obligations of the U.S. or non-U.S. Government are excluded from the 30 Calendar Day Rule.

 

2.

Transactions that ‘roll forward’ Options or Futures, i.e., the simultaneous closing and opening of Options or Futures contracts solely to extend the expiration or maturity of the initial position to the month

 

CODE OF ETHICS | March 2021     4

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immediately following such expiration or maturity, but that otherwise maintain the economic features (e.g., size and strike price) of the position.

 

a.

When a transaction is rolled forward, day one for purposes of calculating compliance with the 30 Calendar Day Rule will be the date of the initial purchase and not the date of any subsequent roll forward transaction(s).

Note: Notwithstanding the exemption from the 30 Calendar Day Rule, transactions that roll forward Options or Futures positions are still subject to the applicable pre-clearance requirements of the Code.

 

3.

Transactions in cash-equivalent ETFs provided permission is obtained from Compliance in advance.

 

Prior to transacting, all Employees must represent in their pre-clearance request that the transaction is not in contravention of the 30 Calendar Day Rule.

 

C.

Pre-clearance and Approval of Personal Securities Transactions

You must pre-clear and receive prior approval for all Personal Securities Transactions unless the transaction is subject to an exemption under this Code.

The Pre-clearance and Approval Process described below applies to all Employees and their Immediate Family Members.

 

1.

Pre-clearance and Approval Process

Pre-clearance and approval of Personal Securities Transactions helps PIMCO prevent certain investments that may conflict with Client trading activities or other regulatory requirements. Except as provided in Sections III.C.2. and III.C.3. below, you must pre-clear and receive prior approval for all Personal Securities Transactions by following the two-step process below:

 

 

2.

Transactions Excluded from the Pre-clearance and Approval Requirement (but still subject to the Reporting Requirements)

Except as otherwise provided below, you are not required to pre-clear and receive prior approval for the

 

CODE OF ETHICS | March 2021     5

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following Personal Securities Transactions, although you are still responsible for complying with the reporting requirements of Section V. of this Code for these transactions (each, an “Exempt Reportable Transaction”):

 

a.

Purchases2 or sales of direct obligations of the U.S. Government or any other national government . However, if you are a Portfolio Person, as defined in the Code, you are required to pre-clear and receive prior approval for purchases and sales of direct obligations of the U.S. Government or any other national government except as set forth in Section III.C.3.f. below;

 

b.

The acquisition or disposition of a Financial Instrument as the result of a stock dividend, stock split, reverse stock split, merger, consolidation, spin-off or other similar corporate distribution or reorganization applicable to such holders of a class of Financial Instrument or, with respect to Financial Instruments except Futures, a non-volitional assignment or call pursuant to an options contract (voluntary corporate actions require pre-clearance);

 

c.

Transactions in open-end mutual funds or interval funds (including those held through a variable insurance product account) managed or sub-advised by PIMCO or an Allianz affiliated entity (in other words, transactions in funds managed or sub-advised by PIMCO or an Allianz affiliated entity must be reported but do not need to be pre-cleared).

Similarly, direct investments in open-end mutual funds or interval funds managed or sub-advised by PIMCO or an Allianz affiliated entity that are held within a qualified tuition program sponsored by a state, state agency or educational institution and authorized by Internal Revenue Code Section 529 (also known as a 529 Plan) must be reported but do not need to be pre-cleared. Further, investments in an Allianz 529 Plan must also be reported, even if such account does not hold PIMCO or Allianz affiliated funds. The Compliance department has access to information on your holdings in PIMCO private funds and open-end mutual funds in your PIMCO/Allianz 401(k). However, your personal accounts including PCRA, deferred compensation plans, Fund Invest and Allianz Employee Stock Purchase Plan must be disclosed via the Compliance Portal;

 

d.

Transactions in any Non-Discretionary Account for which you and your Immediate Family Member(s): (i) do not exercise investment discretion; (ii) do not receive notice of specific transactions prior to execution; and (iii) otherwise have no direct or indirect influence or control. You must still disclose the account and complete a managed account certification in Compliance Portal.

 

e.

Transactions pursuant to an Automatic Investment Plan, including the Allianz Employee Stock Purchase Plan, except that any transaction overriding the Automatic Investment Plan’s predetermined schedule and allocation must be pre-cleared and approved. Notwithstanding the foregoing, an employee may make adjustments to the future percentage investment allocations in the Allianz employee stock purchase plan without pre-clearance.

Employee/Immediate Family Member directed sales from an Automatic Investment Plan, including the Allianz Employee Stock Purchase Plan, are subject to pre-clearance; and

 

f.

Transactions in accounts held on automated asset allocation platforms over which neither you nor an Immediate Family Member exercises any investment discretion, including with respect to the Financial Instruments involved in such transactions and the allocation percentages utilized within the asset allocation platform. You must contact the Compliance Officer if you have this type of account.

 

It is important to remember that transactions in Closed-End Funds and ETFs are subject to the pre-clearance and blackout period requirements.

 

 

2	See Section III.C.3.f. for certain additional exemptions.

 

CODE OF ETHICS | March 2021     6

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3.

Transactions Excluded from the Pre-clearance and Approval Requirement and Reporting Requirements

All Personal Securities Transactions by Employees must be reported under the Code with a few limited exceptions set forth below. The following Personal Securities Transactions are exempt from the pre-clearance, approval, and reporting requirements provided in Sections III.C and V. of the Code (each, an “Exempt Transaction”):

 

a.

Purchases or sales of bank certificates of deposit (“CDs”), bankers acceptances, commercial paper and other high quality, non-sovereign short-term debt instruments (with an original maturity of less than one year), including repurchase agreements;

 

b.

Purchases which are made by reinvesting dividends (cash or in-kind) on a Financial Instrument including reinvestments pursuant to an Automatic Investment Plan;

 

c.

Purchases/sales of physical currencies or physical commodities not for investment purposes;3

 

d.

Purchases or sales of open-end mutual funds or interval funds (including those held through a variable insurance product direct account or a 529 Plan account) that are not managed or sub-advised by PIMCO or an Allianz affiliated entity

 

e.

Purchases or sales of unit investment trusts that are invested exclusively in one or more open-end mutual funds that are not advised or sub-advised by PIMCO or an Allianz affiliated entity; and

 

f.

Purchases of direct obligations of the U.S. Government where such transactions are effected via non-competitive bid or of U.S. savings bonds through the U.S. Department of the Treasury’s TreasuryDirect system.

 

D.

Additional Requirements Applicable to Portfolio Persons

If you are a “Portfolio Person” (see Appendix I) with respect to a Client transaction, you are subject to the blackout periods listed below. Note that transactions that do not require pre-clearance under Sections III.C.2. and III.C.3. of the Code are not subject to these blackout periods. Regardless of whether you are required to pre-clear your transaction, you must not take inappropriate advantage of your position as a Portfolio Person in violation of the Code.

 

1.

Purchases and sales seven calendar days prior to a Client transaction

A Portfolio Person may not transact in a Financial Instrument prior to, and including, seven calendar days before transacting in the same Financial Instrument or a Related Financial Instrument for a Client. Similarly, a Portfolio Person may not transact in a Financial Instrument prior to, and including, seven calendar days if the Portfolio Person knows of another Portfolio Person’s intention to transact in the same Financial Instrument for a Client. Thus, if you personally transact within seven calendar days (inclusive) of a Client transaction in the same or Related Financial Instrument, your personal securities transaction will be considered a violation of the Code of Ethics unless the Client transaction was directed by someone else without your knowledge or you disclose to Compliance that you are aware of a pending firm transaction, and a Compliance Officer approves your personal securities transaction outside of the Compliance Portal.

Specific conditions for research analysts

A research analyst may not transact in the same Financial Instrument, any other Financial Instrument issued by the same issuer or a Related Financial Instrument that such research analyst is analyzing for a

 

 

3

For the avoidance of doubt, direct purchases/sales of Cryptocurrencies are not “Personal Securities Transactions” (as defined in Appendix I) and thus are not subject to the pre-clearance and reporting requirements. However, Derivatives on and indirect investments in Cryptocurrencies are “Personal Securities Transactions” and are subject to the pre-clearance and reporting requirements.

 

CODE OF ETHICS | March 2021     7

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Client (whether such analysis was requested by another person or was undertaken on the research analyst’s own initiative). Such prohibition remains in effect until the research analyst is notified in writing that the Financial Instrument has been selected or rejected for purchase or sale for a Client account or until the research analyst obtains permission to transact in the same Financial Instrument, any other Financial Instrument issued by the same issuer or a Related Financial Instrument from a Managing Director supervisor and a Compliance Officer.

 

2.

Purchases and sales within three calendar days following a Client transaction

A Portfolio Person may not transact in a Financial Instrument within three calendar days after (i) transacting in the same Financial Instrument or a Related Financial Instrument for a Client; or (ii) a Client’s transaction in the same Financial Instrument or a Related Financial Instrument if the Portfolio Person knows that another Portfolio Person has transacted in such Financial Instrument or a Related Financial Instrument for a Client.

 

3.

Specific provisions for Real Estate Portfolio Persons with respect to PIMCO advised private funds that invest in real estate4

Real Estate Portfolio Persons must report Personal Real Estate Investment Transactions⁵ and pre-clear and receive prior approval of certain Personal Real Estate Investment Transactions.

Please refer to Appendix II for a discussion of the pre-clearance and reporting requirements for Personal Real Estate Investment Transactions.

Please note that Personal Real Estate Investment Transactions that constitute Private Placements are Personal Securities Transactions and must be pre-cleared and receive prior approval in accordance with Section III.C of the Code.

 

Prior to transacting, Portfolio Persons must represent in their pre-clearance request that they are not aware of any pending transactions or proposed transactions in the next seven calendar days in the same Financial Instrument or a Related Financial Instrument for any Client. Please consider the timing of your personal transactions carefully.

 

E.

Circumstances that May Restrict Your Trading

If your Personal Securities Transaction falls within one of the following categories, it will generally be denied by the Compliance Officer. It is your responsibility to initially determine if any of the following categories apply to your situation or transaction:

 

1.

Pending Orders

If the gross aggregate market value exposure of your transaction in the Financial Instrument requiring pre-clearance over a 30 calendar day period across all your Personal Securities Accounts exceeds $25,000 and (i) the Financial Instrument or a Related Financial Instrument has been purchased or sold by a Client on that day; or (ii) there is a pending Client order in the Financial Instrument or a Related Financial Instrument, then you CANNOT trade the Financial Instrument or any Related Financial Instrument on the same day and your pre-clearance request will be denied. This prohibition is in addition to any other requirements or prohibitions in this Code that may be applicable (e.g., under “III.D. Additional Requirements Applicable to Portfolio Persons”).

As a general matter, transactions up to $250,000 per day in common stock publicly issued by an issuer, and options thereon, included in the Standard & Poor’s 500 Index (“S&P 500^® Index”) will be permitted

 

 

4	For purposes of this clause 3 and Appendix II, the term Financial Instrument as it applies to Personal Securities Transactions of Portfolio Persons shall include Real Estate Investment Transactions.

 

5	See Appendix II for definition of Real Estate Portfolio Person and Personal Real Estate Investment Transactions.

 

CODE OF ETHICS | March 2021     8

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(subject to any other applicable requirements of the Code, such as the pre-clearance and blackout period requirements). Note, with respect to an option transaction, exposure is measured by the underlying notional value of the option.

Transactions that ‘roll forward’ Futures contracts or Options on Futures contracts may be approved. Such a roll is considered to be the simultaneous closing and opening of Futures or Options on Futures solely to extend the expiration or maturity of the previous position to the next available contract period immediately following such expiration or maturity, but that otherwise maintains the same economic features (e.g., size and strike price) of the position.

 

2.

Initial Public Offerings, SPACs, Private Placements and Investments in Hedge Funds

As a general matter, you should expect that pre-clearance requests involving Initial Public Offerings (except for fixed-income, preferred, business development companies, registered investment companies, commodity pools and convertible securities offerings) and SPACs will be denied. Proposed transactions in private placements, or hedge funds will be reviewed by the Compliance Officer and subject to a number of criteria, including whether the investment opportunity should be reserved for Clients.

 

3.

Allianz SE Investments

You may not trade in shares of Allianz SE during any designated blackout period. In general, the trading windows end six weeks prior to the release of Allianz SE annual financial statements and two weeks prior to the release of Allianz SE quarterly results. This restriction applies to the exercise of cash-settled options or any kind of rights granted under compensation or incentive programs that completely or in part refer to Allianz SE. Allianz SE blackout dates are communicated to employees and are posted on the employee trading center. A list of such blackout periods is accessible through the PIMCO Intranet.

 

4.

Blackout Period in any Closed End Fund Advised or Sub-Advised by PIMCO

You may not trade any closed end fund advised or sub-advised by PIMCO during a designated blackout period. A list of such blackout periods is accessible through the PIMCO Intranet.

 

5.

Trade Restricted Securities List

The Legal and Compliance department maintains and periodically updates the Trade Restricted Securities List that contains certain securities that may not be traded by Employees. The Trade Restricted Securities List is not distributed to employees, but requests to purchase or sell any security on the Trade Restricted Securities List will be denied.

 

6.

Section 16 Holding Periods

If you are a reporting person under Section 16 of the Securities Exchange Act of 1934, with respect to any closed end fund advised or sub-advised by PIMCO, you are subject to a six month holding period and you must make certain filings with the SEC. It is your responsibility to determine if you are subject to Section 16 requirements and to arrange for appropriate filings. Please consult a Compliance Officer for more information.

 

F.

Excessive Trading and Market Timing of Mutual Fund Shares.

The issue of excessive trading and market timing by mutual fund shareholders is serious and not unique to PIMCO. You are subject to the terms and restrictions of an open-end mutual fund’s prospectus, including restrictions such fund may impose on excessive trading. You may not engage in trading of shares of an open-end mutual fund that is inconsistent with the prospectus of that fund.

 

G.

Your Actions are Subject to Review by a Compliance Officer and Your Supervisor

The Compliance Officer may undertake such investigation as he or she considers necessary to determine if your proposed transaction complies with this Code, including post-trade monitoring. The Compliance Officer

 

CODE OF ETHICS | March 2021     9

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may impose measures intended to avoid potential conflicts of interest or to address any trading that requires additional scrutiny.

In addition to the Compliance Officer, your supervisor may, unless restricted by relevant regulations, review your personal trading activity on a periodic or more frequent basis. This individual will work with the Compliance Officer on any such reviews.

H. Consequences for Violations of this Code

 

1.

If determined appropriate by the General Counsel or Compliance Officer you may be subject to remedial actions (a) if you violate this Code; or (b) to protect the integrity and reputation of PIMCO even in the absence of a proven violation. Such remedial actions may include, but are not limited to, full or partial disgorgement of the profits you earned on an investment transaction, a reduction in discretionary performance compensation, censure, demotion, suspension or dismissal, or any other sanction or remedial action required or permitted by law, rule or regulation. As part of any remedial action, you may be required to reverse an investment transaction and forfeit any profit or to absorb any loss from the transaction.

 

2.

PIMCO’s General Counsel or Compliance Officer shall have the authority to determine whether you have violated this Code and, if so, to impose, in consultation with an employee’s supervisor and other relevant parties, the remedial actions they consider appropriate or required by law, rule or regulation. In making their determination, the General Counsel or Compliance Officer, in consultation with an employee’s supervisor and other relevant parties, may consider, among other factors, the gravity of your violation, the frequency of your violations, whether any violation caused harm or the potential of harm to a Client, your efforts to cooperate with their investigation, and your efforts to correct any conduct that led to a violation.

 

IV.	YOUR ONGOING OBLIGATIONS UNDER THIS CODE

This Code imposes certain ongoing obligations on you. If you have any questions regarding these obligations please contact the Compliance Officer.

 

A.

Insider Trading

The fiduciary principles of this Code and Securities and Commodities Laws prohibit you from trading while in possession of material, non-public information (“MNPI”) received from any source or communicating this information to others.⁶ If you believe you may have access to material, non-public information or are unsure about whether information is material or non-public, please consult a Compliance Officer and the PIMCO MNPI Policy. Any violation of PIMCO’s MNPI Policy may result in penalties that could include termination of employment with PIMCO.

 

B.

Compliance with Securities Laws

You must comply with all applicable Securities and Commodities Laws.

 

C.

Duty to Report Violations of this Code

You are required to promptly report any violation of this Code of which you become aware, whether your own or another Employee’s. Reports of violations other than your own may be made anonymously and confidentially to the Compliance Officer.

 

D.

Right to Communicate Directly with Governmental, Regulatory or Self-Regulatory Bodies

This Code will not be interpreted or applied in any manner that would violate any PIMCO employee’s legal

 

 

6

As described in Section III.C.2, purchases or sales of open-end mutual funds and interval funds managed or sub-advised by PIMCO are exempt from the pre-clearance and approval process; however, the insider trading prohibition described above applies to MNPI received with respect to an open-end mutual fund or interval fund advised or sub-advised by PIMCO or its affiliates. Non-public information regarding a mutual fund or interval fund is MNPI if such information could materially impact the fund’s net asset value.

 

CODE OF ETHICS | March 2021     10

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rights as an employee under applicable law. For example, nothing in this Code or Appendices attached hereto prohibits or in any way restricts any PIMCO employee from reporting possible violations of law or regulation to, otherwise communicating directly with, cooperating with or providing information to any governmental or regulatory body or any self-regulatory organization or making other disclosures that are protected under applicable law or regulations of the Securities and Exchange Commission or any other governmental or regulatory body or self-regulatory organization. A PIMCO employee does not need prior PIMCO authorization before taking any such action and a PIMCO employee is not required to inform PIMCO if he or she chooses to take such action.

 

V.	YOUR REPORTING REQUIREMENTS

 

A.

On-Line Certification of Receipt and Quarterly Compliance Certification

You will be required to certify your receipt of this Code. On a quarterly basis you must certify that any personal investments effected during the quarter were done in compliance with this Code. You will also be required to certify your ongoing compliance with this Code on a quarterly basis. Required certifications must be completed within 30 calendar days following the end of the quarter, unless otherwise approved by a Compliance Officer.

 

B.

Reports of Securities Holdings

You and your Immediate Family Members must report all your Personal Securities Accounts and all transactions in your Personal Securities Accounts unless the transaction is an Exempt Transaction. You must agree to allow your broker-dealer to provide the Compliance Officer with electronic reports of your Personal Securities Accounts and transactions and to allow the Compliance department to access all Personal Securities Account information. You will also be required to certify on a quarterly basis that you have reported all of your Personal Securities Accounts to Compliance via the personal trading system (accessible through the PIMCO Intranet). Required certifications must be completed within 30 calendar days following the end of the quarter.

 

1.

Approved Brokers

You and your Immediate Family Members must maintain your Personal Securities Accounts with an Approved Broker. The list of Approved Brokers is accessible through the PIMCO Intranet or a Compliance Officer.

If you maintain a Personal Securities Account at a broker-dealer other than at an Approved Broker, you will need to close those accounts or transfer them to an Approved Broker within a specified period of time, unless otherwise granted an exemption by a Compliance Officer. Upon opening a Personal Securities Account at an Approved Broker, Employees are required to disclose the Personal Securities Account to Compliance via the personal trading system (accessible through the PIMCO Intranet). By maintaining your Personal Securities Account with one or more of the Approved Brokers, you and your Immediate Family Member’s quarterly and annual transaction summaries will be sent directly to the Compliance department for review.

 

2.

Initial Holdings Report

Within ten calendar days of becoming an Employee, you must submit via the personal trading system (accessible through the PIMCO Intranet) an Initial Report of Personal Securities Accounts and all holdings in Financial Instruments except Exempt Transactions. This includes all holdings in Private Placements, such as private equity and hedge fund investments. Please contact the Compliance Officer if you have not already completed this Initial Report of Personal Securities Accounts and all holdings in Financial Instruments.

 

CODE OF ETHICS | March 2021     11

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3.

Quarterly and Annual Holdings Report

If you maintain (i) Personal Securities Accounts with broker-dealers that are not on the list of Approved Brokers, or (ii) a Beneficial Interest in Financial Instruments not held in a Personal Securities Account, please contact the Compliance Officer to arrange for providing quarterly and annual reports within 30 days following quarter end.

 

4.

Changes in Your Immediate Family Members

You must promptly notify a Compliance Officer of any change to your Immediate Family Members (e.g., as a result of a marriage, divorce, legal separation, death, adoption, movement from your household or change in dependence status) that may affect the Personal Securities Accounts for which you have reporting or other responsibilities.

 

VI.	COMPLIANCE DEPARTMENT RESPONSIBILITIES

 

A.

Authority to Grant Waivers of the Requirements of this Code

The Compliance Officer, in consultation with PIMCO’s General Counsel or his or her designee, has the authority to exempt any Employee or any personal investment transaction from any or all of the provisions of this Code if the Compliance Officer determines that such exemption would not be against the interests of any Client and is consistent with applicable laws and regulations, including Rule 204A-1 under the Advisers Act and Rule 17j-1 under the Investment Company Act. The Compliance Officer will prepare and file a written memorandum of any exemption granted, describing the circumstances and reasons for the exemption.

 

B.

Annual Report to Boards of Funds that PIMCO Advises or Sub-Advises

PIMCO will furnish a written report annually to the directors or trustees of each fund that PIMCO advises or sub-advises. Each report will describe any issues arising under this Code, or under procedures implemented by PIMCO to prevent violations of this Code, since PIMCO’s last report, including, but not limited to, information about material violations of this Code, procedures and sanctions imposed in response to such material violations, and certify that PIMCO has adopted procedures reasonably necessary to prevent its Employees from violating this Code.

 

C.

Maintenance of Records

The Compliance Officer will keep all records maintained at PIMCO’s primary office for at least two years and will otherwise keep in an easily accessible place for at least five years from the end of either the fiscal year in which the document was created or the last fiscal year during which the document was effective or in force, whichever is later. Such records include: copies of this Code and any amendments hereto, all Personal Securities Account statements and reports of Employees, a list of all Employees and persons responsible for reviewing Employees reports, copies of all pre-clearance forms, records of violations and actions taken as a result of violations, and acknowledgments, certifications and other memoranda relating to the administration of this Code.

 

VII.	ACTIVITIES OUTSIDE OF PIMCO

 

A.

Approval of Activities Outside of PIMCO

 

1.

You may not engage in full-time or part-time service as an officer, director, partner, manager, member, proprietor, principal, consultant or employee of any Business Organization or Non-Profit Organization other than PIMCO, PIMCO Investments, the PIMCO Foundation, PIMCO Partners, or a

 

CODE OF ETHICS | March 2021     12

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fund for which PIMCO is an adviser (whether or not that business organization is publicly traded) unless you have received the prior written approval from PIMCO’s General Counsel or other designated person.

 

2.

Without prior written approval, you may not provide financial advice (e.g., through service on a finance or investment committee) to a private, educational or charitable organization (other than a trust or foundation established by you or an Immediate Family Member) or enter into any agreement to be employed or to accept compensation in any form (e.g., in the form of commissions, salary, fees, bonuses, shares or contingent compensation) from any person or entity other than PIMCO or one of its affiliates.

 

3.

Certain non-compensated positions in which you would serve in a decision-making capacity (such as on a board of directors for a charity or Non-Profit Organization) must also have been reviewed or approved by PIMCO’s General Counsel or other designated person.

 

4.

PIMCO’s General Counsel or other designated person may approve such an outside activity if he or she determines that your service or activities outside of PIMCO would not be inconsistent with the interests of PIMCO and its Clients. Other factors that may be considered include any remuneration received or proposed to be received as part of the activity, whether the activity or expected time spent is consistent with your duties to PIMCO and its Clients, and any other factors deemed relevant. PIMCO’s General Counsel or other designated person may also stipulate that approval of your participation in the outside activity is subject to specified conditions. Requests to serve on the board of a publicly traded entity will generally be denied.

 

5.

Regardless of the outcome of PIMCO’s review of your participation in any proposed outside activity, you may not, directly or indirectly, publicly suggest, claim or imply that PIMCO is associated with or in any way approves the activity.

 

VIII.

TEMPORARY EMPLOYEES

Temporary Employees that are classified as Contingent Workforce are considered “Employees” for purposes of this Code. The Compliance Officer may exempt such persons from any requirement hereunder if the Compliance Officer determines that such exemption would not have a material adverse effect on any Client account. It is the Temporary Employee’s responsibility to understand the applicability of the Code (including any exemptions) based on the specific facts and circumstances of the employee’s role, responsibilities and access to information.

 

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APPENDIX I

Glossary

The following definitions apply to the capitalized terms used in this Code:

Approved Broker – means a broker-dealer approved by the Compliance Officer. The list of Approved Brokers for each PIMCO location is accessible through the PIMCO Intranet or can be obtained from the Compliance Officer.

Associated Persons – means an employee of PIMCO LLC’s non-U.S. affiliates. Associated Persons are subject to the respective Code of Ethics of the non-U.S. affiliate with whom they are employed, which are, in relevant part, substantially the same as this Code. Associated Persons are subject to the oversight and supervision of PIMCO LLC.

Automatic Investment Plan – means a program in which regular periodic purchases (or withdrawals) are made automatically in (or from) investment accounts in accordance with a predetermined schedule and allocation. An Automatic Investment Plan includes a dividend reinvestment plan.

Beneficial Interest – means when a person has or shares direct or indirect pecuniary interest in accounts or in reportable Financial Instruments. Pecuniary interest means that a person has the ability to profit, directly or indirectly, or share in any profit from a transaction. Indirect pecuniary interest extends to, unless specifically excepted by a Compliance Officer, an interest in a Financial Instrument held by: (1) a joint account to which you are a party; (2) a partnership in which you are a general partner; (3) a partnership in which you or an Immediate Family Member holds a controlling interest and with respect to which Financial Instrument you or an Immediate Family Member has investment discretion; (4) a limited liability company in which you are a managing member; (5) a limited liability company in which you or an Immediate Family Member holds a controlling interest and with respect to which Financial Instrument you or an Immediate Family Member has investment discretion; (6) a trust in which you or an Immediate Family Member has a vested interest or serves as a trustee with investment discretion; (7) a closely-held corporation in which you or an Immediate Family Member holds a controlling interest and with respect to which Financial Instrument you or an Immediate Family Member has investment discretion; or (8) any account (including retirement, pension, deferred compensation or similar account) in which you or an Immediate Family has a substantial economic interest. A pecuniary interest (thus, Beneficial Interest) may arise with respect to any Financial Instrument including without limitation those (such as private equity and hedge fund investments) obtained through Private Placements.

Business Organization – means an entity formed for the purpose of carrying on a commercial enterprise and/or to achieve certain commercial goals. It may take the form a sole proprietorship, partnership, limited liability company, corporation or other structure.

Client – means any person or entity to which PIMCO provides investment advisory services.

Contingent Workforce – means individuals subject to provisional work agreements which may include temporary contract workers, independent contractors or independent consultants.

Cryptocurrency – means any virtual or digital representation of value, token or other asset in which encryption techniques are used to regulate the generation of such assets and to verify the transfer of assets, which is not a Security or otherwise characterized as a security under the relevant law.

Derivative – means (1) any Futures (as defined below); and (2) a forward contract, a “swap”, a “cap”, a “collar”, a “floor” and an over-the-counter option (other than an option on a foreign currency, an option on a basket of currencies, an option on a Security or an option on an index of Securities, which are included in the definition of “Security”). Questions regarding whether a particular instrument or transaction is a Derivative for purposes of this policy should be directed to the Compliance Officer or his or her designee. For avoidance of doubt, a derivative on a Cryptocurrency is considered to be a “Derivative” for purposes of the Code.

Financial Instrument – means a Security, Derivative, commodity or currency as investment, but does not include

 

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Cryptocurrencies. For the avoidance of doubt, futures contracts on Cryptocurrencies are “Financial Instruments” for purposes of the Code.

Futures – means a futures contract and an option on a futures contract traded on a U.S. or non-U.S. board of trade, such as the Chicago Board of Trade or the London International Financial Futures Exchange.

Immediate Family Member of an Employee – means: (1) any of the following persons sharing the same household with the Employee (which does not include temporary house guests): a person’s child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, sister-in-law, legal guardian, adoptive relative, or domestic partner; (2) any person sharing the same household with the Employee (which does not include temporary house guests)that holds an account in which the Employee is a joint owner or listed as a beneficiary; or (3) any person sharing the same household with the Employee in which the Employee contributes to the maintenance of the household and material financial support of such person.

Initial Public Offering – means an offering of securities registered under the Securities Act of 1933, the issuer of which, immediately before the registration, was not subject to the reporting requirements of Sections 13 or 15(d) of the Securities Exchange Act of 1934.

Non-Discretionary Account – means any account managed by a broker dealer, futures commission merchant, or trustee as to which neither the Employee nor an Immediate Family Member: (1) exercises investment discretion; (2) receives notice of specific transactions prior to execution; and (3) has direct or indirect influence or control over the account.

Non-Profit Organization – means an organization (generally tax-exempt) that serves the public interest. In general, the purpose of this type of organization must be charitable, educational, scientific, religious or literary. A nonprofit organization is often dedicated to furthering a particular social cause or advocating for a particular point of view.

Personal Securities Account – means (1) any account (including any custody account, safekeeping account, retirement account such as an IRA or 401(k) plan, and any account maintained by an entity that may act as a broker or principal) in which an Employee has any direct or indirect Beneficial Interest, including Personal Securities Accounts and trusts for the benefit of such persons; and (2) any account maintained for a financial dependent. Thus, the term “Personal Securities Accounts” also includes, among others:

 

(i)	Trusts for which the Employee acts as trustee, executor or custodian;

 

(ii)	Accounts of or for the benefit of a person who receives financial support from the Employee;

 

(iii)

Accounts of or for the benefit of an Immediate Family Member; and

 

(iv)	Accounts in which the Employee is a joint owner or has trading authority.

For the avoidance of doubt, the term “Personal Securities Account” does not include: (1) an account on the U.S. Department of the Treasury’s TreasuryDirect system, so long as the securities purchased through and/or held in such account may only be, or were, purchased through a non-competitive bid process; or (2) any account with direct holdings of Cryptocurrencies. For avoidance of doubt, an account that holds Derivatives on Cryptocurrencies would constitute a “Personal Securities Account” for purposes of the Code, and is subject to the requirements of Section V.B above.

Personal Securities Transaction – means transactions in Securities (whether publicly offered or a Private Placement), Derivatives, currencies for investment purposes and commodities for investment purposes, but does not include direct transactions in a Cryptocurrency. For the avoidance of doubt, “Personal Securities Transaction” includes Derivatives on a Cryptocurrency.

 

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PIMCO – means “Pacific Investment Management Company LLC”.

PIMCO Investments – means “PIMCO Investments LLC”.

Portfolio Person – means an Employee, including a portfolio manager with respect to an account, who: (1) provides information or advice with respect to the purchase or sale of a Financial Instrument, such as a research analyst; or (2) helps execute a portfolio manager’s investment decisions. Members of Portfolio Risk Management, and Economists are also considered to be Portfolio Persons. Generally, a Portfolio Person with respect to a Client transaction includes the generalist portfolio manager for the Client, the specialist portfolio manager or trading assistant with respect to the transactions in that account attributable to that specialist or trading assistant, and any research analyst that played a role in researching or recommending a particular Financial Instrument.

Private Placement – means an offering that is exempt from registration under the Securities Act of 1933 pursuant to Section 4(2) or Section 4(6) or pursuant to SEC Rules 504, 505 or 506 under the Securities Act of 1933, including hedge funds or private equity funds or similar laws of non-U.S. jurisdictions.

Related Financial Instrument – means any Derivative directly tied to the same underlying Financial Instrument, including, but not limited to, any swap, option or warrant to purchase or sell that same underlying Financial Instrument, and any Derivative convertible into or exchangeable for that same underlying Financial Instrument. For example, the purchase and exercise of an option to acquire a Security is subject to the same restrictions that would apply to the purchase of the Security itself.

Securities and Commodities Laws – means the securities and/or commodities laws of any jurisdiction applicable to any Employee, including for any employee located in the U.S. or employed by PIMCO, the following laws: Securities Act of 1933, the Securities Exchange Act of 1934, the Sarbanes-Oxley Act of 2002, the Investment Company Act of 1940, the Investment Advisers Act of 1940, Title V of the Gramm-Leach-Bliley Act, any rules adopted by the U.S. Securities and Exchange Commission under any of these statutes, the Bank Secrecy Act as it applies to funds, broker-dealers and investment advisers, and any rules adopted thereunder by the U.S. Securities and Exchange Commission or the U.S. Department of the Treasury, the Commodity Exchange Act, any rules adopted by the U.S. Commodity Futures Trading Commission under this statute, and applicable rules adopted by the National Futures Association.

Security – means any note, stock, treasury stock, security future, security-based swap, bond, debenture, evidence of indebtedness, certificate of indebtedness, certificate of interest or participation in any profit-sharing agreement, collateral-trust certificate, preorganization certificate or subscription, transferable share, investment contract (e.g., investment in a business), voting-trust certificate, certificate of deposit for a security, fractional undivided interest in oil, gas or other mineral rights, any put, call, straddle, option, or privilege on any security, (including a certificate of deposit) or on any group or index of securities (including any interest therein or based on the value thereof), or any put, call, straddle, option, or privilege entered into on a national securities exchange relating to foreign currency, or in general, any interest of instrument commonly known as a “security”, or any certificate of interest or participation in, temporary or interim certificate for, receipt for, guaranty of, or warrant or right to subscribe to or purchase any of the foregoing.

Compliance Portal – means PIMCO’s proprietary employee trading pre-clearance system.

 

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APPENDIX II

PIMCO-advised private funds and accounts make investments in real estate.

Real Estate Portfolio Persons must generally pre-clear and receive prior approval from the Compliance Officer for Personal Real Estate Investment Transactions like other Personal Securities Transactions.

Real Estate Portfolio Person – means a Portfolio Person, or any other Employee designated by a Compliance Officer, with respect to PIMCO advised private funds that executes Real Estate Investment Transactions.

Real Estate Investment Transactions – means transactions involving real estate (such as, without limitation, purchases, sales, financings or other forms of investments in office, multifamily, retail, commercial, industrial or hospitality properties or interest in real estate services or service providers), either directly or through investments in funds (other than registered investment companies or publicly traded Securities that are otherwise subject to the Code of Ethics), joint ventures, partnerships, limited liability companies, mortgage or mezzanine loans or other Securities (other than publicly traded Securities that are otherwise subject to the Code of Ethics).

Personal Real Estate Investment Transactions – means Real Estate Investment Transactions for investment purposes.

Indirect investments (e.g., real estate funds or partnerships) may also be subject to pre-clearance as Private Placements under the Code of Ethics. Like other types of personal investments, you are required to report Personal Real Estate Investment Transactions on a quarterly basis.

Notwithstanding the above:

 

●

Transactions involving residential properties owned for personal use (such as a primary residence or a vacation home), as well as loans, advances or gifts to Immediate Family Members to assist in their purchase or maintenance of such properties, are not subject to pre-clearance or the reporting requirements.

●

Transactions involving one- to four-unit residential properties purchased for investment purposes are not subject to pre-clearance, so long as such transaction would not (i) constitute a Security (e.g., an interest in an entity of which you are not the general partner, managing member or equivalent), or (ii) violate any of your responsibilities under the Code of Ethics. Such transactions are subject to the reporting requirements, however.

Trades of Securities or instruments that are identified by a ticker, CUSIP, ISIN or Sedol must be pre-cleared using Compliance Portal (accessible through the PIMCO Intranet).

The Code of Ethics requires you to avoid conflicts of interest related to personal investments, including Personal Real Estate Investment Transactions. You are expected to avoid any investment, interest or association which interferes or might interfere with your independent exercise of judgment in the best interest of PIMCO and its Clients, including funds advised by PIMCO. Disclosure of personal or other circumstances constituting a conflict of interest should be reported to the Compliance Officer.

 

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APPENDIX III

See the below for specific guidance on options trading with regards to pre-clearance and the 30 Calendar Day Rule.

 

Option Trading		Pre-clearance Required		Subject to Short Term Trading Restriction (“30 Calendar Day Rule”)
Purchasing/Selling an Option		Yes		Yes The option’s expiration date must be greater than 30 days from the date of the option transaction.   An options contract cannot be bought and sold, or sold and bought, within 30 calendar days.   For avoidance of doubt, employees may trade a different options contract (ie. different expiration or strike) within 30 calendar days.
Involuntary Option Assignment/Exercise of Existing Option Position		No Purchase or sale of underlying Security not directed by the Employee		No The acquisition/disposition of a security resulting from an existing option position via an involuntary assignment/exercise is not subject to the 30 Calendar Day Rule
Directing an Option Exercise of Existing Options Position		Yes To exercise an option, the purchase or sale of the underlying security must be pre-cleared before directing the option exercise		Yes After the receipt or disposal of the underlying security due to a directed option exercise, employees are prohibited from executing an opposite way transaction in the underlying security for 30 calendar days
Rolling an Option on a Future7 (see section III.B.2.)		Yes Pre-clearance of both legs of the transaction is required to roll the option		No The same option on a futures contract bought and sold, or sold and bought within 30 days to roll the exposure is not subject to the 30 Calendar Day Rule
Rolling an Option on All Other Underlying Securities		Yes Pre-clearance of both legs of the transaction is required to roll the option		Yes Other options are not allowed to roll within 30 calendar days (i.e., they are subject to the 30 Calendar Day Rule)

 

 

7	For the avoidance of doubt, futures are allowed to be rolled within 30 calendar days.

 

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Code of Ethics

PIMCO Funds

PIMCO Variable Insurance Trust

PIMCO ETF Trust

PIMCO Equity Series

PIMCO Equity Series VIT

PIMCO Managed Accounts Trust

PIMCO Sponsored Closed-End Funds

PIMCO Sponsored Interval Funds

Pacific Investment Management Company LLC (“PIMCO”), the investment adviser and administrator or investment manager to PIMCO Funds, PIMCO Variable Insurance Trust, PIMCO ETF Trust, PIMCO Equity Series, PIMCO Equity Series VIT, PIMCO Managed Accounts Trust, the PIMCO Sponsored Closed-End Funds, and the PIMCO Sponsored Interval Funds (each a “Fund”, and collectively the “Funds”), has adopted a Code of Ethics that applies to any officer, director, or employee of PIMCO. The following Code of Ethics (the “Code”) is adopted by each Fund pursuant to Rule 17j-1 of the Investment Company Act of 1940 (the “Act”). This Code is intended to ensure that all acts, practices and courses of business engaged in by access persons (as defined in this Code) of each Fund reflect high standards and comply with the requirements of Section 17(j) of the Act and Rule 17j-1 thereunder. This Code incorporates the PIMCO Code of Ethics (the “PIMCO Code”) with respect to any officer, employee, associated person, or director of PIMCO who may be an “access person” or “advisory person” of each Fund, as defined in the Rule.

This Code is not applicable to any Trustee¹ or officer of a Fund or any other access person who is employed by PIMCO or Allianz Asset Management of America L.P. (“AAM”) as each such person is already covered by the PIMCO Code or the Code of Ethics adopted by AAM (the “AAM Code”).

This Code sets forth general fiduciary standards and standards of business conduct that govern the personal investment activities of access persons in accordance with Rule 17j-1. Certain personal trading restrictions and reporting obligations under the Code may not be applicable under circumstances in which an access person does not obtain access to particular types of information (as defined in the Code). Access persons should contact the Chief Compliance Officer (the “CCO”) of the relevant Fund with any questions regarding the applicability of the Code’s provisions.

 

I.	Definitions

(A)      “Access person” means any director, trustee, officer, general partner, or advisory person (as defined in this Code) of a Fund or PIMCO. However, the term “access person,” as contained herein, shall not include any Trustee or officer of the Fund or any other access person of the Fund who is subject to the Code of Ethics adopted by PIMCO (“PIMCO Personnel”) or the AAM Code. PIMCO has represented to the Trustees of each Fund that the PIMCO Code covers all of the officers of the Fund and any other access persons of the Fund, with the exception of (i) the

 

¹ References to “Trustees” include Directors, as applicable.

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Code of Ethics

 

Trustees who are not “interested persons” of the Fund within the meaning of Section 2(a)(19) of the Act (“Independent Trustees”) and (ii) Trustee(s) who are “interested persons” of the Fund but are covered by the AAM Code (such Trustee(s), together with the Independent Trustees, the “Non-PIMCO Trustees”).

(B)      “Advisory person” means (1) any director, trustee, officer, general partner or employee of a Fund or PIMCO (or of any company in a control relationship to the Fund or PIMCO), who, in connection with his or her regular functions or duties, makes, participates in, or obtains information regarding the purchase or sale of a financial instrument (as defined in this Code) by the Fund, or whose functions relate to the making of any recommendations with respect to such purchases or sales; and (2) any natural person in a control relationship to the Fund or PIMCO who obtains information concerning recommendations made to the Fund with regard to the purchase or sale of a financial instrument.

(C)      A financial instrument is “being considered for purchase or sale” when a recommendation to purchase or sell a financial instrument has been made and communicated or, with respect to the person making the recommendation, when such person seriously considers making such a recommendation.

(D)      A financial instrument is “being purchased or sold” by a Fund from the time when a purchase or sale program has been communicated to the person who places the buy and sell orders for the Fund until the time when such program has been fully completed or terminated.

(E)      “Beneficial ownership” shall be interpreted in the same manner as it would be under Rule 16a-1(a)(2) in determining whether a person is subject to the provisions of Section 16 of the Securities Exchange Act of 1934 and the rules and regulations thereunder.

(F)      “Control” has the same meaning as that set forth in Section 2(a)(9) of the Act. Section 2(a)(9) provides that “control” generally means the power to exercise a controlling influence over the management or policies of a company, unless such power is solely the result of an official position with such company.

(G)      A “financial instrument held or to be acquired” by a Fund means: (1) any financial instrument which, within the most recent 15 days: (a) is or has been held by the Fund; or (b) is being or has been considered by the Fund or PIMCO for purchase by the Fund; and (2) any option to purchase or sell, and any financial instrument convertible into or exchangeable for, a financial instrument described in Section I (K) of this Code.

(H)      An “initial public offering” means an offering of securities registered under the Securities Act of 1933, the issuer of which, immediately before the registration, was not subject to the reporting requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934.

(I)      “Investment personnel” means: (1) any employee of a Fund or PIMCO (or of any company in a control relationship to the Fund or PIMCO) who, in connection with his or her regular functions or duties, makes or participates in making recommendations regarding the purchase or

 

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sale of financial instruments by the Fund; and (2) any natural person who controls the Fund or PIMCO and who obtains information concerning recommendations made to the Fund regarding the purchase or sale of financial instruments by the Fund.

(J)      A “limited offering” means an offering that is exempt from registration under the Securities Act of 1933 pursuant to Section 4(a)(2) or Section 4(a)(6) or pursuant to Rule 504, Rule 505, or Rule 506 under the Securities Act of 1933.

(K)      “Security” has the meaning set forth in Section 2(a)(36) of the Act, except that it shall not include direct obligations of the Government of the United States, bankers’ acceptances, bank certificates of deposit, commercial paper and high quality short-term debt instruments, including repurchase agreements, and shares of registered open-end investment companies (excluding exchange-traded funds other than a series of the Funds), or such other securities as may be excepted under the provisions of Rule 17j-1 (such securities, “excluded securities”). For the avoidance of doubt, exchange-traded funds, whether registered as open-end investment companies or unit investment trusts, are deemed to be securities, provided that series of the Funds shall not be deemed to be securities.

(L)      “Automatic Investment Plan” means a program in which regular periodic purchases (or withdrawals) are made automatically in (or from) investment accounts in accordance with a predetermined schedule and allocation. An Automatic Investment Plan includes a dividend reinvestment plan.

(M)      “Financial instrument” means a security, derivative, commodity or currency as investment.

(N)      “Derivative” means (1) a futures contract and an option on a futures contract traded on a U.S. or non-U.S. board of trade, such as the Chicago Board of Trade or the London International Financial Futures Exchange; and (2) a forward contract, a “swap”, a “cap”, a “collar”, a “floor” and an over-the-counter option (other than an option on a foreign currency, an option on a basket of currencies, an option on a security or an option on an index of securities, which are included in the definition of “security”). Questions regarding whether a particular instrument or transaction is a derivative for purposes of this policy should be directed to PIMCO Compliance.

(O)      “Personal securities transactions” shall include transactions in securities, derivatives, currencies for investment purposes and commodities for investment purposes.

 

II.	Prohibited Purchases and Sales

(A)      No access person shall, in connection with the purchase or sale, directly or indirectly, by such person of a financial instrument held or to be acquired by a Fund:

(1)      employ any device, scheme or artifice to defraud the Fund;

(2)      make to the Fund any untrue statement of a material fact or omit to state to

 

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the Fund a material fact necessary in order to make the statements made, in light of the circumstances under which they are made, not misleading;

(3)      engage in any act, practice or course of business which would operate as a fraud or deceit upon the Fund; or

(4)      engage in any manipulative practice with respect to the Fund.

(B)      In this connection, it shall be impermissible for any access person to purchase or sell, directly or indirectly, any financial instrument (or any option to purchase or sell such financial instrument) in which he or she has, or by reason of such transaction acquires, any direct or indirect beneficial ownership and which he or she knows or, in the ordinary course of fulfilling his or her official duties as such access person, should have known, at the time of such purchase or sale:

(1)      is being considered for purchase or sale by a Fund, or

(2)      is being purchased or sold by a Fund.

This prohibition shall apply to a transaction if it occurs within 15 days prior to or after either:

(1)      the purchase or sale of such financial instrument by a Fund; or

(2)      the consideration of such purchase or sale by a Fund or PIMCO.

(C)      With respect to investment personnel not subject to the PIMCO Code or the AAM Code, no such investment personnel may acquire any direct or indirect beneficial ownership in any securities in an initial public offering or in a limited offering unless the CCO of the Fund (or his or her designee), as appropriate, has authorized the transaction in advance. All other investment personnel are subject to the PIMCO Code or AAM Code, which contain substantively equivalent provisions concerning initial public offerings and limited offerings.

(D)      With respect to the PIMCO Sponsored Closed-End Funds and PIMCO Sponsored Interval Funds, Non-PIMCO Trustees who serve on the Board of the applicable Fund may not transact in the shares of such Fund unless he or she receives preclearance from the Fund’s CCO, or his or her designee, in writing. In order to receive preclearance:

 

(1)

A Non-PIMCO Trustee must have submitted a preclearance request in writing on the applicable form attached to this Code as Appendix VI, or in such other form as is deemed acceptable by the CCO or his or her designee; and

 

(2)

It must be determined that the purchase or sale of the Closed-End Fund or Interval Fund shares complies with this Code, including the other provisions of this Section II.

 

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It is noted that PIMCO Personnel may be subject to preclearance requirements for shares of PIMCO Sponsored Closed-End Funds and the PIMCO Sponsored Interval Funds, restrictions on transactions in initial public offerings, private placements and hedge funds and trading in closed-end funds during certain periods, as set forth in the PIMCO Code.

(E)      The fiduciary principles of this Code and securities and commodities laws prohibit any access person from purchasing or selling, directly or indirectly, any financial instrument based on material, non-public information (“MNPI”) received from any source or communicating this information to others. The insider trading prohibition also applies to MNPI received with respect to any Fund, including information concerning events that may immediately impact the publicly traded share price or net asset value of a Fund. Accordingly, the Independent Trustees are prohibited from purchasing or selling, directly or indirectly, any shares of a Fund based on MNPI. The CCO, PIMCO legal counsel and/or counsel to the Independent Trustees will monitor for situations in which the Independent Trustees receive MNPI relating to a Fund and, if the Independent Trustees receive such MNPI, advise the Independent Trustees as appropriate. The same procedure will be followed with respect to MNPI that may be received by the Independent Trustees with respect to a financial instrument held by a Fund. If an access person believes he or she may have access to material, non-public information or is unsure about whether information is material or non-public, such access person should consult the CCO of the relevant Fund. Please refer to Appendix VII for a brief reference guide regarding MNPI.

(F)      Any access person who questions whether a contemplated transaction is prohibited by this Code should discuss the transaction with the CCO of the relevant Fund (or his or her designee), or both, as appropriate, prior to proceeding with the transaction.

 

III.	Exempted Transactions

The prohibitions of Section II(B), II(C) and, to the extent indicated below, II(D) of this Code shall not apply to the following transactions by access persons:

(1)      Purchases or sales of financial instruments over which the access person has no direct or indirect influence or control (exemption applies to Section II(D));

(2)      Purchases or sales of financial instruments which are not eligible for purchase or sale by a Fund;

(3)      Purchases or sales of financial instruments which are non-volitional on the part of either the access person or a Fund (exemption applies to Section II(D));

(4)      Purchases of financial instruments which are part of an Automatic Investment Plan (exemption applies to Section II(D));

(5)      Purchases of securities effected upon the exercise of rights issued by an issuer pro rata to all holders of a class of its securities, to the extent such rights were acquired from

 

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such issuer (exemption applies to Section II(D));

(6)      Transactions which appear to the CCO of the Fund (or his or her designee), as appropriate, to present no reasonable likelihood of harm to the Fund, which are otherwise in accordance with Rule 17j-1, and which the CCO of the Fund (or his or her designee), as appropriate, has authorized in advance;

(7)      Purchases or sales of derivatives on broad-based indices and major market currencies; and

(8)      Purchases or sales of physical currencies and physical commodities.

 

IV.

Reporting

(A)      Every access person shall file with the Fund reports containing the information described in Sections IV(B), (C) and (D) of this Code with respect to transactions in any financial instrument in which such access person has, or by reason of such transaction acquires, any direct or indirect beneficial ownership in the financial instrument (regardless of whether such transaction is listed in Section III (1) through (6)), provided, however, that such access person shall not be required to make a report with respect to transactions effected for any account over which such person does not have any direct or indirect influences or control; provided, further, that if such access person is an Independent Trustee, and would be required to make such a report solely by reason of being a Trustee of the Fund, such Trustee is not required to file a report under this Section IV, except that, where such Trustee knew or, in the ordinary course of fulfilling his or her official duties as a Trustee of the Fund, should have known that during the 15-day period immediately preceding or after the date of the transaction in a financial instrument by the Trustee, such financial instrument is or was purchased or sold by the Fund or such purchase or sale by the Fund is or was considered by the Fund or PIMCO, such Trustee must file a Quarterly Transaction Report under Section IV(C). PIMCO does not intend to provide any information to the Independent Trustees in the ordinary course about Fund transactions occurring within the 15 day period immediately preceding or after a transaction by a Trustee, and as such, Quarterly Transaction Reports will typically not be required to be filed by Independent Trustees.

(B)      Initial Holding Reports. No later than ten (10) days after a person becomes an access person, the person shall file a report containing the following information (which information must be current as of a date no more than 45 days prior to the date the person becomes an access person):

(1)      The title, number of shares and principal amount of each financial instrument in which the access person had any direct or indirect beneficial ownership when the person became an access person;

(2)      The name of any broker, dealer or bank with whom the access person maintained an account in which any financial instruments (including excluded securities) were held for the direct or indirect benefit of the access person as of the date the person became an access

 

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person; and

(3)      The date that the report is submitted by the access person.

(C)      Quarterly Reports. Transaction Report. No later than thirty (30) days after the end of the calendar quarter in which the transaction to which the report relates was effected, every access person shall file a report containing the following information:

(1)      The date of the transaction, the title, the interest rate and maturity (if applicable), the number of shares, and the principal amount of each financial instrument involved;

(2)      The nature of the transaction (i.e., purchase, sale or any other type of acquisition or disposition), including information sufficient to establish any exemption listed in Section III (2) through (6), or exception to Section II(C) which is relied upon;

(3)      The price at which the transaction was effected;

(4)      The name of the broker, dealer or bank with or through whom the transaction was effected; and

(5)      The date that the report is submitted by the access person.

Account Report. With respect to any account established by an access person in which any financial instruments (including excluded securities) were held during the quarter for the direct or indirect benefit of the access person, the access person shall file a report containing the following information:

(1)      The name of the broker, dealer or bank with whom the access person established the account;

(2)       The date the account was established; and

(3)       The date that the report is submitted by the access person.

Automatic Investment Plans. An access person need not make a quarterly transaction report with respect to transactions effected pursuant to an Automatic Investment Plan.

(D)      Annual Holdings Reports. Annually, every access person shall file a report containing the following information (which information must be current as of a date no more than 45 days before the report is submitted):

(1)      The title, number of shares and principal amount of each financial instrument in which the access person had any direct or indirect beneficial ownership;

(2)      The name of any broker, dealer or bank with whom the access person

 

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maintains an account in which any financial instruments (including excluded securities) are held for the direct or indirect benefit of the access person; and

(3)      The date that the report is submitted by the access person.

(E)      Any report may contain a statement that the report shall not be construed as an admission by the person making such report that he or she has any direct or indirect beneficial ownership in the financial instrument to which the report relates, and the existence of any report shall not be construed as an admission that any event reported on constitutes a violation of Section II(A) hereof.

(F)      If any access person is required to file reports of all his or her personal securities transactions on a current basis with the CCO of a Fund (or his or her designee), and such reports contain the information required by Section IV (C), such reports shall be deemed to be sufficient for purposes of Section IV(C) of this Code and no separate report shall be required.

(G)      All reports of personal securities transactions and any other information filed with a Fund pursuant to this Code shall be treated as confidential, except as regards appropriate examinations by representatives of the SEC or other regulatory body having jurisdiction.

 

V.	Review, Enforcement and Compliance

(A)      Review

(1)      The CCO of each Fund (or his or her designee) shall from time to time review the reported personal securities transactions of the access persons to determine whether any transaction (“Reviewable Transactions”) listed in Section II may have occurred.²

(2)      If the CCO of the relevant Fund (or his or her designee) determines that a Reviewable Transaction may have occurred, he or she shall then determine whether a violation of this Code may have occurred, taking into account all the exemptions provided under Section III. Before making any determination that a violation has been committed by an individual, the CCO of the relevant Fund (or his or her designee) shall give such person an opportunity to supply additional information regarding the transaction in question.

(B)      Enforcement

(1)      If the CCO of a Fund (or his or her designee) determines that a violation of this Code may have occurred, he or she shall take such steps as he or she deems appropriate under the circumstances, including, if appropriate, notification of the Trustees of the Fund. The Trustees, with the exception of any person whose transaction is under consideration, shall take such actions as they consider appropriate, including imposition of any sanctions that they consider appropriate.

 

 

²         The CCO of PIMCO, or his or her designee, reviews the personal trading activity of access persons subject to the PIMCO Code on a quarterly basis.

 

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(2)      No person shall participate in a determination of whether he or she has committed a violation of this Code or in the imposition of any sanction against himself/herself. If, for example, a personal securities transaction of the CCO of a Fund is under consideration, a Trustee of the Fund designated for the purpose by the Trustees of the Fund shall act in all respects in the manner prescribed herein for the CCO.

(C)      Compliance

(1)      The CCO of each Fund (or his or her designee) shall identify all access persons required to make reports under this Code and inform them of their reporting obligation.

(2)      Each access person shall be required to sign an acknowledgement that such person has read and understands this Code. A form for this purpose is attached to this Code as Appendix I.

(3)      Each access person shall be required to certify annually that such person has complied with the requirements of this Code during the prior year, and that such person has disclosed, reported, or caused to be reported all transactions during the prior year in financial instruments of which such person had or acquired beneficial ownership. A form for this purpose is attached to this Code as Appendix II.

(4)      No less frequently than annually, each Fund shall furnish to the Fund’s Board of Trustees, and the Board must consider, a written report that:

(i)      Describes any issues arising under the Code or procedures since the last report to the Board of Trustees, including, but not limited to, information about material violations of the Code or procedures and sanctions imposed in response to the material violations; and

(ii)      Certifies that the Fund has adopted procedures reasonably necessary to prevent access person from violating the Code. A form for this purpose is attached to this Code as Appendices III, IV and V.

 

VI.

Records

Each Fund shall maintain records in the manner and to the extent set forth below, under the conditions described in Rule 31a-2(f)(1) under the Act and shall be available for appropriate examination by representatives of the Securities and Exchange Commission (“SEC”).

(1)      A copy of this Code and any other Code of Ethics which is, or at any time within the past five years has been, in effect shall be preserved in an easily accessible place;

(2)      A record of any violation of this Code and of any action taken as a result of such violation shall be preserved in an easily accessible place for a period of not less than five years

 

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following the end of the fiscal year in which the violation occurs;

(3)      A copy of each report made pursuant to this Code by an access person, including any information provided under Section IV(F) in lieu of the reports under Section IV(C), shall be preserved by the Fund for a period of not less than five years from the end of the fiscal year in which it is made, the first two years in an easily accessible place;

(4)      A list of all persons who are, or within the past five years have been, required to make reports pursuant to this Code, or who are or were responsible for reviewing these reports, shall be maintained in an easily accessible place.

(5)      A copy of each report required by Section V(C)(4) of the Code shall be preserved by the Fund for at least five years after the end of the fiscal year in which it is made, the first two years in an easily accessible place.

(6)      The Fund shall preserve a record of any decision, and the reasons supporting the decision, to approve the acquisition by investment personnel of financial instruments under Section II(C) of this Code, for at least five years after the end of the fiscal year in which the approval is granted.

 

VII.	Fiduciary Duties

(A)      Disclosure of Non-Public Portfolio Holdings Information. If an access person has access to non-public portfolio holdings information of a Fund, then he or she must treat non-public portfolio holdings information of a Fund in accordance with the Funds’ Portfolio Holdings Disclosure Policies and Procedures.

(B)      Confidentiality. The officers and Trustees of each Fund acknowledge that each Fund discloses to its officers and Trustees, and such persons will otherwise come into possession of while acting in their capacities as officers or Trustees, certain information and data which a Fund wishes to keep confidential, including, but not limited to, information regarding a Fund’s governance, Board of Trustees, officers and other management (including regarding the Fund’s investment advisers and sub-advisers), minutes and other records of meetings, investment program, strategies and performance, portfolio holdings, dividends and distributions, secondary offerings, investment leverage, compliance, legal and regulatory matters (including Fund policies and procedures), valuation of assets, administration, custody, finances or operations (including information relating to financial statements), corporate actions, strategic plans, litigation and regulatory inquiries, communications, examinations and enforcement activities, shareholders and related communications, marketing, intellectual property and trade secrets, and information which is proprietary to the Fund or its advisers or which the Fund has obtained from third parties and with respect to which the Fund is obligated to maintain confidentiality (collectively, “Confidential Information”). The officers and Trustees of each Fund acknowledge that each Fund’s business is extremely competitive, dependent in part upon the maintenance of confidentiality, and that any disclosure of Confidential Information could result in serious harm to a Fund or its officers, Trustees or management. For these reasons, as officers or Trustees of one or more Funds, you must

 

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use Confidential Information only in connection with your duties as a Fund officer or Trustee and may not use Confidential Information in any way that is or could be deemed to be detrimental to a Fund or its officers, Trustees or management. Further, you may not disclose, directly or indirectly, Confidential Information with respect to a Fund to any third person or entity, other than representatives of Fund management and their affiliates and authorized representatives or agents of the Fund, and only to the extent that such person or entity requires such Confidential Information in order to perform services for a Fund, and must treat all such information as confidential and proprietary property of the Fund. Individuals who no longer serve as Fund officers or Trustees may not disclose, directly or indirectly, Confidential Information that they obtained during their service as a Fund officer or Trustee, other than as provided for in the preceding sentence.

From time to time, the Boards of Trustees of the Funds may conduct joint meetings of the Boards of Trustees of some or all of the Funds. In connection with such joint meetings, a Trustee or officer may come into possession of Confidential Information with respect to a Fund that he or she does not oversee. The preceding paragraph shall apply to the receipt of Confidential Information by a Trustee or officer under such circumstances.

In addition to the general obligations regarding Confidential Information discussed above and in acknowledgement of the fact that the role of Independent Trustees and of chairpersons and members of committees of the Board of Trustees may be misconstrued by the general public, Independent Trustees should not comment to the press or make any postings or comments on the internet or any form of social media, including blogs or other similar forums, regarding their position or matters related to their service as Independent Trustees or members of committees. Failure to abide by this policy may lead to a full range of sanctions permitted by a Fund’s organizational documents, up to and including removal from the Board of Trustees. In the event that an Independent Trustee resigns or otherwise no longer serves as an Independent Trustee, such individual is expected to continue to abide by this policy with respect to information obtained during his or her service as an Independent Trustee. This policy does not apply to legally compelled disclosure or testimony to a regulator or court of law.

In addition, this Code will not be interpreted or applied in any manner that would violate the legal rights of any person subject to this Code as an employee under applicable law. For example, nothing in this Code or the Appendices attached hereto prohibits or in any way restricts any person subject to this Code from reporting possible violations of law or regulation to, otherwise communicating directly with, cooperating with or providing information to any governmental or regulatory body or any self-regulatory organization or making other disclosures that are protected under applicable law or regulations of the SEC or any other governmental or regulatory body or self-regulatory organization. A person subject to this Code does not need prior authorization of PIMCO or a Fund before taking any such action and is not required to inform PIMCO or a Fund if he or she chooses to take such action.

 

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VIII.

Amendment; Interpretation of Provisions

The Trustees may from time to time amend this Code or adopt such interpretations of this Code as they deem appropriate.

 

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History of Amendments

PIMCO Funds

PIMCO Variable Insurance Trust

PIMCO ETF Trust

Adopted: September 29, 2004

Effective: October 5, 2004

Amended: November 16, 2004

Effective: February 1, 2005

Amended: August 16, 2005

Effective: August 16, 2005

Amended: February 28, 2006

Effective: February 28, 2006

Amended: February 24, 2009

Effective: February 24, 2009

Amended: May 19, 2009

Effective: May 19, 2009

Amended: May 25, 2010

Effective: May 25, 2010

Amended: March 1, 2011

Effective: March 1, 2011

Amended: November 5, 2013

Effective: November 5, 2013

Amended: August 14, 2014

Amended: September 18, 2014

Effective: September 18, 2014

Amended: August 11, 2015

Effective: August 11, 2015

Amended: February 14, 2017

Effective: February 14, 2017

PIMCO Equity Series

PIMCO Equity Series VIT

Adopted: March 30, 2010

Effective: March 30, 2010

Amended: May 25, 2010

Effective: May 25, 2010

Amended: March 1, 2011

Effective: March 1, 2011

Amended: November 7, 2013

Effective: November 7, 2013

Amended: August 14, 2014

Amended: September 18, 2014

 

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Effective: September 18, 2014

Amended: August 11, 2015

Effective: August 12, 2015

Amended: February 15, 2017

Effective: February 15, 2017

Amended: May 17, 2017

Effective: May 17, 2017

PIMCO Managed Accounts Trust

PIMCO Sponsored Closed-End Funds

Adopted: June 24, 2014

Effective: September 5, 2014

Amended: September 18, 2014

Effective: September 18, 2014

Amended: August 11, 2015

Effective: October 6, 2015

Amended: March 23, 2017

Effective: March 23, 2017

PIMCO Sponsored Interval Funds

Adopted: December 14, 2016

Effective: December 14, 2016

Amended: March 23, 2017

Effective: March 23, 2017

 

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Appendix I

ACKNOWLEDGMENT CERTIFICATION

PIMCO FUNDS

PIMCO VARIABLE INSURANCE TRUST

PIMCO ETF TRUST

PIMCO EQUITY SERIES

PIMCO EQUITY SERIES VIT

PIMCO MANAGED ACCOUNTS TRUST

PIMCO SPONSORED CLOSED-END FUNDS

PIMCO SPONSORED INTERVAL FUNDS

I hereby certify that I have read and understand the attached Code of Ethics. Pursuant to such Code, I have recognized that I must disclose or report all personal securities transactions required to be disclosed or reported thereunder and comply in all other respects with the requirements of such Code. I also agree to cooperate fully with any investigation or inquiry as to whether a possible violation of the foregoing Code has occurred.

 

Date:
								Signature

 

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Appendix II

ANNUAL CERTIFICATION OF COMPLIANCE

PIMCO FUNDS

PIMCO VARIABLE INSURANCE TRUST

PIMCO ETF TRUST

PIMCO EQUITY SERIES

PIMCO EQUITY SERIES VIT

PIMCO MANAGED ACCOUNTS TRUST

PIMCO SPONSORED CLOSED-END FUNDS

PIMCO SPONSORED INTERVAL FUNDS

I hereby certify that I have complied with the requirements of the Code of Ethics for the year ended December 31, ___. Pursuant to such Code, I have disclosed or reported all personal securities transactions required to be disclosed or reported thereunder and complied in all other respects with the requirements of such Code. I also agree to cooperate fully with any investigation or inquiry as to whether a possible violation of the foregoing Code has occurred.

 

Date:
								Signature

 

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Appendix III

ANNUAL CERTIFICATION

PIMCO EQUITY SERIES

PIMCO EQUITY SERIES VIT

I, the undersigned, hereby certify on behalf of PIMCO Equity Series and PIMCO Equity Series VIT (each a “Fund”), to the Board of Trustees pursuant to Rule 17j-1(c)(2)(B) under the Investment Company Act of 1940, and pursuant to Section V(C)(4)(ii) of the Fund’s Code of Ethics (the “Code”), that each Fund has adopted procedures that are reasonably necessary to prevent access persons from violating the Code.

 

Date:
								Fund CCO

 

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Appendix IV

ANNUAL CERTIFICATION

PIMCO FUNDS

PIMCO VARIABLE INSURANCE TRUST

PIMCO ETF TRUST

I, the undersigned, hereby certify on behalf of PIMCO Funds, PIMCO Variable Insurance Trust and PIMCO ETF Trust (each a “Fund”), to the Board of Trustees pursuant to Rule 17j-1(c)(2)(B) under the Investment Company Act of 1940, and pursuant to Section V(C)(4)(ii) of the Fund’s Code of Ethics (the “Code”), that each Fund has adopted procedures that are reasonably necessary to prevent access persons from violating the Code.

 

Date:
								Fund CCO

 

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Appendix V

ANNUAL CERTIFICATION

PIMCO MANAGED ACCOUNTS TRUST

PIMCO SPONSORED CLOSED-END FUNDS

PIMCO SPONSORED INTERVAL FUNDS

I, the undersigned, hereby certify on behalf of PIMCO Managed Accounts Trust, the PIMCO Sponsored Closed-End Funds, and the PIMCO Sponsored Interval Funds (each a “Fund”), to the Board of Trustees pursuant to Rule 17j-1(c)(2)(B) under the Investment Company Act of 1940, and pursuant to Section V(C)(4)(ii) of the Fund’s Code of Ethics (the “Code”), that each Fund has adopted procedures that are reasonably necessary to prevent access persons from violating the Code.

 

Date:
								Fund CCO

 

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Appendix VI

PACIFIC INVESTMENT MANAGEMENT COMPANY LLC

PRE-CLEARANCE FORM

PIMCO SPONSORED CLOSED-END FUND

(To be submitted to [email protected])

 

1.  Today’s Date
2.  Name of Trustee
3.  Name of Closed-End Fund/Ticker
4.  Broker
5.  Last 3-digits of Account Number
6.  Type of Security		☐ Common stock		☐ Preferred stock		☐ Other (please describe)
7.  Transaction Type		☐ Market purchase ☐ Market sale ☐ Gift		☐ Grant, exercise or vesting of equity award ☐ Transfer from one plan account to another plan account ☐ Other (please describe)
8.  Intended Number of Shares
9.  Has the fund completed all its initial common and preferred shares offerings and is not otherwise engaged in an offering of its shares?		☐ Yes				☐ No
10. Do you possess material non-public information regarding the financial instrument or the issuer of the financial instrument?		☐ Yes				☐ No
11. Have you transacted in the same fund/issuer in the opposite direction within the last 6 months?		☐ Yes				☐ No
12. Type of Account/Plan		Select One: ☐ 401(k) plan ☐ Corporation ☐ Custodial		☐ Deferred compensation plan ☐ Immediate family member account ☐ Individual account ☐ Jointly-owned account		☐ LLC ☐ Partnership ☐ Trust ☐ Other

 

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a.  Have you previously pre-cleared transactions in this account?		☐ Yes				☒ No
b.  If you answered “No” to question 12.a, please complete the relevant section of Annex A below.
c.  If there has been any changes regarding your total share ownership, or account ownership structure, please complete Annex B below.
d.  Once Compliance approval is received and the pre-cleared transaction is executed, please provide execution details as noted in Annex C below.

NOTE: If you have any questions about how to complete this form, please contact the Code of Ethics Compliance team at (949) 720-7821 or by email at [email protected] (Fax 949-718-2674).

Approvals are valid on the day approval has been granted (the “Approval Period”). Accordingly, GTC (good till canceled) orders are prohibited. If a trade is not executed by the close of business of the Approval Period, you must submit a new preclearance request. Obtaining preclearance satisfies the preclearance requirements of the Fund’s Code of Ethics (the “Code”) and does not imply compliance with the Code’s other provisions.

* * * * * *

By signing below, the undersigned certifies the following: The undersigned agrees that the above requested transaction is in compliance with the Code and Section 16 of the Securities and Exchange Act of 1934 and Section 30(h) of the Investment Company Act of 1940.

 

 

Trustee Signature

 

 

Date Submitted

Authorized _____ Not Authorized _____

 

By:
Printed Name:
Date:

 

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Annex A to PIMCO Section 16 Reportable Transaction Information (Form 4)

Once Compliance approval is received and the pre-cleared transaction is executed, please provide execution details as noted below. Provide price execution details at the individual tax lot/block level. Attach an additional sheet/spreadsheet as necessary.

 

Trade Date		Name of Closed-End Fund/Ticker		Number of Shares		Executed Price		Broker		Last 3-digits of Account Number

 

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Annex B to PIMCO Section 16 Reportable Transaction Information (Form 4)

If there has been any changes regarding your total share ownership, or account ownership structure, please complete the applicable section(s) below as necessary.

Other Details Affecting Ownership

Please provide information on any applicable changes as indicated below since your last Section 16 filing for the applicable Fund/Issuer referenced above in your pre-clearance request.

If the answer is yes to any of the following, please provide the details, including parties, relationships, securities and dates:

 

Has a change in ownership of any securities occurred as a result of a divorce?
Has a change in ownership of any securities occurred as a result of an inheritance?
Has an immediate family member moved into or out of the Reporting Person’s household who owns shares of the Fund/Issuer?
Has the Reporting Person engaged in any hedging or similar transactions related to any securities of the Fund/Issuer (e.g., swaps, collars, pre-paid forward contracts, options, calls, puts, etc.)?
Has the Reporting Person received any securities of the Fund/Issuer as an in-kind distribution from another entity?
Have there been any other changes in the Reporting Person’s form(s) of ownership of securities in the Fund/Issuer not otherwise reported?
Have there been any other changes in the Reporting Person’s amount of ownership of securities in the Fund/Issuer not otherwise reported?

 

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Annex C to PIMCO Section 16 Reportable Transaction Information (Form 4)

If you answered “No” to question 12a, please complete the applicable section(s) below, in addition to Annex B as necessary.

  401(k) Plan or Deferred Compensation Plan:

 

Name of plan:
Was a new payroll or cash contribution used to acquire the securities?
Was cash or another investment accrued under the plan used to acquire the securities?
Does the Plan offer a Fund/Issuer stock fund as an investment alternative under the plan?

  Custodial Account:

 

Name of custodial account:
Name of custodian:
Name of beneficiary (or beneficiaries)::
Relationship of Reporting Person to beneficiary (or beneficiaries)):

 

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  Trust:

 

Name of trust:
Type of trust:
Governing jurisdiction of the trust:
Relationship of trust to Reporting Person:
Name of trustee(s) and relationship(s) to Reporting Person:
Does the Reporting Person influence or control the power to vote or dispose the securities held in trust?
Name of settlor(s) and relationship(s) to Reporting Person:
Name of beneficiary(or beneficiaries) and relationship(s) to Reporting Person:
Does the Reporting Person share a household with the beneficiary (or beneficiaries)?
Is the trust revocable by the Reporting Person?
If the Reporting Person’s spouse is a co-trustee of a revocable trust, does the Reporting Person need spousal consent to revoke the trust?
Is there a remainder interest created by the trust?

 

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  Corporation:

 

Name of corporation:
Is Reporting Person a director of the corporation? If so, please provide the number of directors in the corporation.
Is Reporting Person an executive officer of the corporation? If so, please provide title(s).
Is the Reporting Person a stockholder of the corporation? If so, please provide the approximate percentage of shares (and voting power) of the corporation beneficially held by the Reporting Person.
Who makes decisions regarding voting and/or disposition of the securities held by the corporation?

  LLC:

 

Name of LLC:
Nature of LLC (e.g., member-managed or manager-managed):
Is the Reporting Person a direct or indirect managing member of the LLC?
How many members are on the board or similar managing body of the LLC?
Is Reporting Person an executive officer of the LLC? If so, please provide title(s).
What percentage ownership interest does the Reporting Person have in the LLC?
Who makes decisions regarding voting and/or disposition of the securities held by the LLC?
Was the transaction at issue an in-kind distribution by the LLC?

 

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  Partnership:

 

Name of partnership:
Nature of partnership (e.g., general partnership or limited partnership):
Relationship(s) of Reporting Person to the partnership:
Is the Reporting Person a general partner or a limited partner?
How many general partners are in the partnership?
Does the partnership have a board of directors or similar managing body?
Is Reporting Person an executive officer of the partnership? If so, please provide title(s).
Who in the partnership makes decisions regarding the voting and/or disposition of securities held by the partnership?
Were the securities a result of an in-kind distribution by the partnership?

 

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Appendix VII

Guidelines Regarding Material, Non-Public Information

Whether information is material and non-public (“MNPI”) must be evaluated on a fact-specific, case-by-case basis and will be judged by regulators and prosecutors with the benefit of hindsight. Identifying MNPI is highly complex and risky. DO NOT attempt to make this judgment on your own. Contact the relevant Fund’s CCO if you think you have received or may receive MNPI. DO NOT share the information you have with anyone.

Examples of “Material” Information

A common definition is “information that a reasonable investor would consider important to making an investment decision.” Examples include:

 

●

Earnings Results

●

Earnings projections or guidance

●

Merger, tender offer or joint venture

●

Major change in issuer assets

●

Change in control or management

●

Major events regarding financial instruments (e.g., cash flows, losses, defaults)

●

Financial liquidity problems, bankruptcy or receivership

●

Actual or threatened litigation

●

Departure of key personnel

Examples of “Non-Public” Information

Information is generally deemed non-public if it has not been widely disseminated to the public. Key questions when evaluating whether information is non-public include:

 

●

Can the information be found in an SEC filing or in any other document that is publicly available?

●

Has the information appeared in a newspaper or other publication of general circulation?

●

Is the information available on a public website?

Exercise extreme caution when information has been disseminated to only a small number of investors or others outside the issuer. The prevalence of a market rumor does not constitute public disclosure of otherwise non-public information.

What is MNPI when Purchasing or Selling Funds?

MNPI in the context of buying or selling Fund shares could generally include the recent or pending occurrence of one of the items below or significant likelihood that such an item

 

A-14

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will occur, that you are aware of at the time of a possible trade, and that has not yet been made public, such as:

For All Funds:

 

●

Material changes in value of the Fund’s portfolio securities that have not yet been reflected in NAV

●

Material undisclosed revenues or liabilities to be realized by the Fund (such as from litigation or resolution of a regulatory or compliance matter)

For Open-End Funds and ETFs:

 

●

Material increases in illiquid or fair valued assets in the portfolio

●

Actions or events likely to lead to material redemptions and/or a “fire sale” of Fund assets

For Closed-End Funds and Interval Funds (as applicable):

 

●

Changes in dividend rates or a special dividend

●

Material changes to the Fund’s leverage or other strategies that will materially impact income and dividend levels and/or result in a “fire sale” of Fund shares

●

Actions to address trading discounts (e.g., open-ending, tender offers, open-market purchases) or secondary offerings

●

Other material corporate actions involving the Fund (e.g., a Fund merger)

●

Material changes in the Fund’s stated investment objectives or fundamental policies

●

A determination to liquidate a Fund

●

Material regulatory action or litigation involving the Fund or PIMCO

●

Material developments involving senior management at PIMCO

●

Material transactions involving PIMCO (e.g., resulting in a change in control or ownership)

●

The amount and/or timing of shares repurchased pursuant to a share repurchase program, including pursuant to Rule 23c-3 under the 1940 Act or otherwise

 

A-15

POWER OF ATTORNEY

We, the undersigned Trustees/Directors of the registered investment companies listed on Schedule A attached hereto (each, a “Fund”), hereby severally constitute and appoint each of Wu-Kwan Kit, Ryan G. Leshaw, David C. Sullivan and Adam T. Teufel, and each of them singly, with full powers of substitution and resubstitution, our true and lawful attorney, with full power to him to sign for us, and in our names and in the capacities indicated below, any Registration Statement of any Fund on Form N-1A, Form N-2 or Form N-14, all Pre-Effective Amendments to any such Registration Statement of such Fund, any and all subsequent Post-Effective Amendments to such Registration Statement, including, without limitation, pursuant to Rule 462(d), any and all supplements or other instruments in connection therewith, and any subsequent Registration Statements for the same offering which may be filed under Rule 462(b), and to file the same, with all exhibits thereto, and other documents in connection therewith, with the Securities and Exchange Commission, the securities regulators of the appropriate states and territories and any other regulatory authority having jurisdiction over the issuance of rights and the offer and sale of shares of beneficial interest of the Fund, any and all agreements, filings, documents, registrations, notices, and other instruments required or permitted to be filed pursuant to the Securities Act of 1933, as amended, the Securities Exchange Act of 1934, as amended, the Investment Company Act of 1940, as amended (the “1940 Act”), the Investment Advisers Act of 1940, as amended, the Commodities Exchange Act, as amended, the Federal Securities Laws (as that term is defined in Rule 38a-1 under the 1940 Act), and the rules thereunder, and/or any rules or regulations passed or adopted by the New York Stock Exchange or any other exchange on which a Fund’s shares trade (an “Exchange”), the National Futures Association (“NFA”), the Financial Industry Regulatory Authority (“FINRA”), and/or any other self-regulatory organization (each, an “SRO”) to whose authority a Fund is subject, and any and all agreements, filings, documents, registrations, notices, and other instruments required or permitted to be filed to comply with the statutes, rules, regulations or law of any state or jurisdiction, including those required to qualify to do business in any such state or jurisdiction (collectively, the “Securities and Commodities Laws”), and to file the same, with all exhibits thereto, and other agreements, documents and other instruments in connection therewith, with the appropriate regulatory body including, but not limited to, the Securities and Exchange Commission, the Commodity Futures Trading Commission, an Exchange, the NFA, FINRA, and any SRO, and/or the securities regulators or other agency or regulatory body of the appropriate states and territories, and generally to do all such things in our names and on our behalves in connection therewith as such attorney deems necessary or appropriate to comply with the Securities and Commodities Laws and all related requirements, granting unto such attorney full power and authority to do and perform each and every act and thing requisite or necessary to be done in connection therewith, as fully to all intents and purposes as any of us might or could do in person, hereby ratifying and confirming all that such attorney lawfully could do or cause to be done by virtue hereof. This Power of Attorney may be executed in written form, by facsimile or by other means using electronic or digital technology, whether it is a computer-generated signature, an electronic copy of the party’s true ink signature or otherwise.

---

Name		Capacity		Date
/s/ Deborah A. DeCotis		Trustee/Director		March 30, 2020
Deborah A. DeCotis
/s/ James A. Jacobson		Trustee/Director		March 30, 2020
James A. Jacobson
/s/ Hans W. Kertess		Trustee/Director		March 30, 2020
Hans W. Kertess
/s/ William B. Ogden, IV		Trustee/Director		March 30, 2020
William B. Ogden, IV
/s/ Alan Rappaport		Trustee/Director		March 30, 2020
Alan Rappaport

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SCHEDULE A

FUND NAME AND SYMBOL

 

1.		PCM FUND, INC.		PCM
2.		PIMCO CALIFORNIA MUNICIPAL INCOME FUND		PCQ
3.		PIMCO CALIFORNIA MUNICIPAL INCOME FUND II		PCK
4.		PIMCO CALIFORNIA MUNICIPAL INCOME FUND III		PZC
5.		PIMCO CORPORATE & INCOME STRATEGY FUND		PCN
6.		PIMCO CORPORATE & INCOME OPPORTUNITY FUND		PTY
7.		PIMCO DYNAMIC CREDIT AND MORTGAGE INCOME FUND		PCI
8.		PIMCO DYNAMIC INCOME FUND		PDI
9.		PIMCO INCOME STRATEGY FUND		PFL
10.		PIMCO INCOME STRATEGY FUND II		PFN
11.		PIMCO GLOBAL STOCKSPLUS & INCOME FUND		PGP
12.		PIMCO HIGH INCOME FUND		PHK
13.		PIMCO INCOME OPPORTUNITY FUND		PKO
14.		PIMCO MUNICIPAL INCOME FUND		PMF
15.		PIMCO MUNICIPAL INCOME FUND II		PML
16.		PIMCO MUNICIPAL INCOME FUND III		PMX
17.		PIMCO NEW YORK MUNICIPAL INCOME FUND		PNF
18.		PIMCO NEW YORK MUNICIPAL INCOME FUND II		PNI
19.		PIMCO NEW YORK MUNICIPAL INCOME FUND III		PYN
20.		PIMCO STRATEGIC INCOME FUND, INC.		RCS
21.		PIMCO MANAGED ACCOUNTS TRUST
		Fixed Income Shares: Series M		FXIMX
		Fixed Income Shares: Series C		FXICX
		Fixed Income Shares: Series R		FXIRX
		Fixed Income Shares: Series TE		FXIEX
		Fixed Income Shares: Series LD		FXIDX
22.		PIMCO FLEXIBLE CREDIT INCOME FUND		PFLEX
23.		PIMCO FLEXIBLE MUNICIPAL INCOME FUND		PMFLX
24.		PIMCO ENERGY AND TACTICAL CREDIT OPPORTUNITIES FUND		NRGX
25.		PIMCO DYNAMIC INCOME OPPORTUNITIES FUND		PDO

POWER OF ATTORNEY

We, the undersigned Trustees/Directors of the registered investment companies listed on Schedule A attached hereto (each, a “Fund”), hereby severally constitute and appoint each of Wu-Kwan Kit, Ryan G. Leshaw, David C. Sullivan and Adam T. Teufel, and each of them singly, with full powers of substitution and resubstitution, our true and lawful attorney, with full power to him to sign for us, and in our names and in the capacities indicated below, any Registration Statement of any Fund on Form N-1A, Form N-2 or Form N-14, all Pre-Effective Amendments to any such Registration Statement of such Fund, any and all subsequent Post-Effective Amendments to such Registration Statement, including, without limitation, pursuant to Rule 462(d), any and all supplements or other instruments in connection therewith, and any subsequent Registration Statements for the same offering which may be filed under Rule 462(b), and to file the same, with all exhibits thereto, and other documents in connection therewith, with the Securities and Exchange Commission, the securities regulators of the appropriate states and territories and any other regulatory authority having jurisdiction over the issuance of rights and the offer and sale of shares of beneficial interest of the Fund, any and all agreements, filings, documents, registrations, notices, and other instruments required or permitted to be filed pursuant to the Securities Act of 1933, as amended, the Securities Exchange Act of 1934, as amended, the Investment Company Act of 1940, as amended (the “1940 Act”), the Investment Advisers Act of 1940, as amended, the Commodities Exchange Act, as amended, the Federal Securities Laws (as that term is defined in Rule 38a-1 under the 1940 Act), and the rules thereunder, and/or any rules or regulations passed or adopted by the New York Stock Exchange or any other exchange on which a Fund’s shares trade (an “Exchange”), the National Futures Association (“NFA”), the Financial Industry Regulatory Authority (“FINRA”), and/or any other self-regulatory organization (each, an “SRO”) to whose authority a Fund is subject, and any and all agreements, filings, documents, registrations, notices, and other instruments required or permitted to be filed to comply with the statutes, rules, regulations or law of any state or jurisdiction, including those required to qualify to do business in any such state or jurisdiction (collectively, the “Securities and Commodities Laws”), and to file the same, with all exhibits thereto, and other agreements, documents and other instruments in connection therewith, with the appropriate regulatory body including, but not limited to, the Securities and Exchange Commission, the Commodity Futures Trading Commission, an Exchange, the NFA, FINRA, and any SRO, and/or the securities regulators or other agency or regulatory body of the appropriate states and territories, and generally to do all such things in our names and on our behalves in connection therewith as such attorney deems necessary or appropriate to comply with the Securities and Commodities Laws and all related requirements, granting unto such attorney full power and authority to do and perform each and every act and thing requisite or necessary to be done in connection therewith, as fully to all intents and purposes as any of us might or could do in person, hereby ratifying and confirming all that such attorney lawfully could do or cause to be done by virtue hereof. This Power of Attorney may be executed in written form, by facsimile or by other means using electronic or digital technology, whether it is a computer-generated signature, an electronic copy of the party’s true ink signature or otherwise.

---

Name		Capacity		Date
/s/ John C. Maney		Trustee/Director		November 5, 2020
John C. Maney
/s/ David N. Fisher		Trustee/Director		November 5, 2020
David N. Fisher
/s/ Sarah E. Cogan		Trustee/Director		November 5, 2020
Sarah E. Cogan

---

SCHEDULE A

FUND NAME AND SYMBOL

 

1.		PCM FUND, INC.		PCM
2.		PIMCO CALIFORNIA MUNICIPAL INCOME FUND		PCQ
3.		PIMCO CALIFORNIA MUNICIPAL INCOME FUND II		PCK
4.		PIMCO CALIFORNIA MUNICIPAL INCOME FUND III		PZC
5.		PIMCO CORPORATE & INCOME STRATEGY FUND		PCN
6.		PIMCO CORPORATE & INCOME OPPORTUNITY FUND		PTY
7.		PIMCO DYNAMIC CREDIT AND MORTGAGE INCOME FUND		PCI
8.		PIMCO DYNAMIC INCOME FUND		PDI
9.		PIMCO INCOME STRATEGY FUND		PFL
10.		PIMCO INCOME STRATEGY FUND II		PFN
11.		PIMCO GLOBAL STOCKSPLUS & INCOME FUND		PGP
12.		PIMCO HIGH INCOME FUND		PHK
13.		PIMCO INCOME OPPORTUNITY FUND		PKO
14.		PIMCO MUNICIPAL INCOME FUND		PMF
15.		PIMCO MUNICIPAL INCOME FUND II		PML
16.		PIMCO MUNICIPAL INCOME FUND III		PMX
17.		PIMCO NEW YORK MUNICIPAL INCOME FUND		PNF
18.		PIMCO NEW YORK MUNICIPAL INCOME FUND II		PNI
19.		PIMCO NEW YORK MUNICIPAL INCOME FUND III		PYN
20.		PIMCO STRATEGIC INCOME FUND, INC.		RCS
21.		PIMCO MANAGED ACCOUNTS TRUST
		Fixed Income Shares: Series M		FXIMX
		Fixed Income Shares: Series C		FXICX
		Fixed Income Shares: Series R		FXIRX
		Fixed Income Shares: Series TE		FXIEX
		Fixed Income Shares: Series LD		FXIDX
22.		PIMCO FLEXIBLE CREDIT INCOME FUND		PFLEX
23.		PIMCO FLEXIBLE MUNICIPAL INCOME FUND		PMFLX
24.		PIMCO ENERGY AND TACTICAL CREDIT OPPORTUNITIES FUND		NRGX
25.		PIMCO DYNAMIC INCOME OPPORTUNITIES FUND		PDO

POWER OF ATTORNEY

I, the undersigned Treasurer and Principal Financial and Accounting Officer of the registered investment companies listed on Schedule A attached hereto (each, a “Fund”), hereby severally constitute and appoint each of Wu-Kwan Kit, Ryan G. Leshaw, David C. Sullivan and Adam T. Teufel, and each of them singly, with full powers of substitution and resubstitution, my true and lawful attorney, with full power to him or her to sign for me, and in my name and in the capacity indicated below, any Registration Statement of any Fund on Form N-1A, Form N-2 or Form N-14, all Pre-Effective Amendments to any such Registration Statement of such Fund, any and all subsequent Post-Effective Amendments to such Registration Statement, including, without limitation, pursuant to Rule 462(d), any and all supplements or other instruments in connection therewith, and any subsequent Registration Statements for the same offering which may be filed under Rule 462(b), and to file the same, with all exhibits thereto, and other documents in connection therewith, with the Securities and Exchange Commission, the securities regulators of the appropriate states and territories and any other regulatory authority having jurisdiction over the issuance of rights and the offer and sale of shares of beneficial interest of the Fund, any and all agreements, filings, documents, registrations, notices, and other instruments required or permitted to be filed pursuant to the Securities Act of 1933, as amended, the Securities Exchange Act of 1934, as amended, the Investment Company Act of 1940, as amended (the “1940 Act”), the Investment Advisers Act of 1940, as amended, the Commodities Exchange Act, as amended, the Federal Securities Laws (as that term is defined in Rule 38a-1 under the 1940 Act), and the rules thereunder, and/or any rules or regulations passed or adopted by the New York Stock Exchange or any other exchange on which a Fund’s shares trade (an “Exchange”), the National Futures Association (“NFA”), the Financial Industry Regulatory Authority (“FINRA”), and/or any other self-regulatory organization (each, an “SRO”) to whose authority a Fund is subject, and any and all agreements, filings, documents, registrations, notices, and other instruments required or permitted to be filed to comply with the statutes, rules, regulations or law of any state or jurisdiction, including those required to qualify to do business in any such state or jurisdiction (collectively, the “Securities and Commodities Laws”), and to file the same, with all exhibits thereto, and other agreements, documents and other instruments in connection therewith, with the appropriate regulatory body including, but not limited to, the Securities and Exchange Commission, the Commodity Futures Trading Commission, an Exchange, the NFA, FINRA, and any SRO, and/or the securities regulators or other agency or regulatory body of the appropriate states and territories, and generally to do all such things in my name and on my behalf in connection therewith as such attorney deems necessary or appropriate to comply with the Securities and Commodities Laws and all related requirements, granting unto such attorney full power and authority to do and perform each and every act and thing requisite or necessary to be done in connection therewith, as fully to all intents and purposes as I might or could do in person, hereby ratifying and confirming all that such attorney lawfully could do or cause to be done by virtue hereof.

 

Name		Capacity		Date
/s/ Bijal Parikh		Treasurer (Principal Financial and Accounting Officer)		January 1, 2021
Bijal Parikh

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SCHEDULE A

FUND NAME AND SYMBOL

 

1.		PCM FUND, INC.		PCM
2.		PIMCO CALIFORNIA MUNICIPAL INCOME FUND		PCQ
3.		PIMCO CALIFORNIA MUNICIPAL INCOME FUND II		PCK
4.		PIMCO CALIFORNIA MUNICIPAL INCOME FUND III		PZC
5.		PIMCO CORPORATE & INCOME STRATEGY FUND		PCN
6.		PIMCO CORPORATE & INCOME OPPORTUNITY FUND		PTY
7.		PIMCO DYNAMIC CREDIT AND MORTGAGE INCOME FUND		PCI
8.		PIMCO DYNAMIC INCOME FUND		PDI
9.		PIMCO INCOME STRATEGY FUND		PFL
10.		PIMCO INCOME STRATEGY FUND II		PFN
11.		PIMCO GLOBAL STOCKSPLUS & INCOME FUND		PGP
12.		PIMCO HIGH INCOME FUND		PHK
13.		PIMCO INCOME OPPORTUNITY FUND		PKO
14.		PIMCO MUNICIPAL INCOME FUND		PMF
15.		PIMCO MUNICIPAL INCOME FUND II		PML
16.		PIMCO MUNICIPAL INCOME FUND III		PMX
17.		PIMCO NEW YORK MUNICIPAL INCOME FUND		PNF
18.		PIMCO NEW YORK MUNICIPAL INCOME FUND II		PNI
19.		PIMCO NEW YORK MUNICIPAL INCOME FUND III		PYN
20.		PIMCO STRATEGIC INCOME FUND, INC.		RCS
21.		PIMCO MANAGED ACCOUNTS TRUST
		Fixed Income Shares: Series M		FXIMX
		Fixed Income Shares: Series C		FXICX
		Fixed Income Shares: Series R		FXIRX
		Fixed Income Shares: Series TE		FXIEX
		Fixed Income Shares: Series LD		FXIDX
22.		PIMCO FLEXIBLE CREDIT INCOME FUND		PFLEX
23.		PIMCO FLEXIBLE MUNICIPAL INCOME FUND		PMFLX
24.		PIMCO ENERGY AND TACTICAL CREDIT OPPORTUNITIES FUND		NRGX
25.		PIMCO DYNAMIC INCOME OPPORTUNITIES FUND		PDO

POWER OF ATTORNEY

I, the undersigned Trustee of the registered investment companies listed on Schedule A attached hereto (each, a “Fund”), hereby constitute and appoint each of Wu-Kwan Kit, Ryan G. Leshaw, David C. Sullivan and Adam T. Teufel, and each of them singly, with full powers of substitution and resubstitution, my true and lawful attorney, with full power to him to sign for me, and in my name and in the capacities indicated below, any Registration Statement of any Fund on Form N-2 or Form N-14, all Pre-Effective Amendments to any such Registration Statement of such Fund, any and all subsequent Post-Effective Amendments to such Registration Statement, including, without limitation, pursuant to Rule 462(d), any and all supplements or other instruments in connection therewith, and any subsequent Registration Statements for the same offering which may be filed under Rule 462(b), and to file the same, with all exhibits thereto, and other documents in connection therewith, with the Securities and Exchange Commission, the securities regulators of the appropriate states and territories and any other regulatory authority having jurisdiction over the issuance of rights and the offer and sale of shares of beneficial interest of the Fund, any and all agreements, filings, documents, registrations, notices, and other instruments required or permitted to be filed pursuant to the Securities Act of 1933, as amended, the Securities Exchange Act of 1934, as amended, the Investment Company Act of 1940, as amended (the “1940 Act”), the Investment Advisers Act of 1940, as amended, the Commodities Exchange Act, as amended, the Federal Securities Laws (as that term is defined in Rule 38a-l under the 1940 Act), and the rules thereunder, and/or any rules or regulations passed or adopted by the New York Stock Exchange or any other exchange on which a Fund’s shares trade (an “Exchange”), the National Futures Association (“NFA”), the Financial Industry Regulatory Authority (‘‘FINRA”), and/or any other self-regulatory organization (each, an “SRO”) to whose authority a Fund is subject, and any and all agreements, filings, documents, registrations, notices, and other instruments required or permitted to be filed to comply with the statutes, rules, regulations or law of any state or jurisdiction, including those required to qualify to do business in any such state or jurisdiction (collectively, the “Securities and Commodities Laws”), and to file the same, with all exhibits thereto, and other agreements, documents and other instruments in connection therewith, with the appropriate regulatory body including, but not limited to, the Securities and Exchange Commission, the Commodity Futures Trading Commission, an Exchange, the NFA, FINRA, and any SRO, and/or the securities regulators or other agency or regulatory body of the appropriate states and territories, and generally to do all such things in my name and on my behalf in connection therewith as such attorney deems necessary or appropriate to comply with the Securities and Commodities Laws and all related requirements, granting unto such attorney full power and authority to do and perform each and every act and thing requisite or necessary to be done in connection therewith, as fully to all intents and purposes as I might or could do in person, hereby ratifying and confirming all that such attorney lawfully could do or cause to be done by virtue hereof.

 

Name		Capacity		Date
/s/ Joseph Baker Kittredge, Jr.		Trustee		6/13, 2020
Joseph Baker Kittredge, Jr.

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SCHEDULE A

FUND NAME AND SYMBOL*

 

1.		PCM FUND, INC.		PCM
2.		PIMCO CALIFORNIA MUNICIPAL INCOME FUND		PCQ
3.		PIMCO CALIFORNIA MUNICIPAL INCOME FUND II		PCK
4.		PIMCO CALIFORNIA MUNICIPAL INCOME FUND III		PZC
5.		PIMCO CORPORATE & INCOME STRATEGY FUND		PCN
6.		PIMCO CORPORATE & INCOME OPPORTUNITY FUND		PTY
7.		PIMCO DYNAMIC CREDIT AND MORTGAGE INCOME FUND		PCI
8.		PIMCO DYNAMIC INCOME FUND		PDI
9.		PIMCO ENERGY AND TACTICAL CREDIT OPPORTUNITIES FUND		NRGX
10.		PIMCO GLOBAL STOCKSPLUS & INCOME FUND		PGP
11.		PIMCO HIGH INCOME FUND		PHK
12.		PIMCO INCOME OPPORTUNITY FUND		PKO
13.		PIMCO INCOME STRATEGY FUND		PFL
14.		PIMCO INCOME STRATEGY FUND II		PFN
15.		PIMCO MUNICIPAL INCOME FUND		PMF
16.		PIMCO MUNICIPAL INCOME FUND II		PML
17.		PIMCO MUNICIPAL INCOME FUND III		PMX
18.		PIMCO NEW YORK MUNICIPAL INCOME FUND		PNF
19.		PIMCO NEW YORK MUNICIPAL INCOME FUND II		PNI
20.		PIMCO NEW YORK MUNICIPAL INCOME FUND III		PYN
21.		PIMCO STRATEGIC INCOME FUND, INC.		RCS
22.		PIMCO MANAGED ACCOUNTS TRUST		PMAT
23.		PIMCO FLEXIBLE CREDIT INCOME FUND		PFLEX
24.		PIMCO FLEXIBLE MUNICIPAL INCOME FUND		PMFLX
25.		PIMCO DYNAMIC INCOME OPPORTUNITIES FUND		PDO

*While one ticker symbol per Fund is listed, this Power of Attorney covers all ticker symbols of each Fund.

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