Due to the entry into force on March 1, 2026, of amendments to Federal Laws No. 156-FZ dated 29.11.2001 “On Investment Funds” and No. 39-FZ dated 22.04.1996 “On the Securities Market”¹, which provide for a special procedure for transferring Payments² to the owners of mutual fund units (hereinafter – mutual fund units), whose rights to these units are recorded in depositories, and considering that management companies continue to act as tax agents with respect to Payments in accordance with the Tax Code of the Russian Federation, NSD, from March 1, 2026, ensures the following procedure for the implementation of the payment transfer mechanism for mutual fund units, the rights to which are recorded in the nominal holder's account and the nominal holder of the central depository's account, opened in the register of mutual fund unit holders in the name of NSD (hereinafter – NSD).

Considering the Bank of Russia's opinion, NSD will continue to collect mutual fund unit holder lists after March 1, 2026. List collection will be carried out based on a corresponding request from the person responsible for maintaining the register of mutual fund unit holders.

Available parameters for requesting a mutual fund unit holder list. List template:

0001 – Basic without banking details;
0002 – Basic with banking details. With the option to substitute the nominal holder's banking details;
0012 – Basic with banking details of the persons exercising rights to the securities.

When selecting template 0001, the list type must be specified as OWNL – Security Holder List without information on persons in whose interests rights to the securities are exercised.

Tax and fee legislation does not impose an obligation on subjects of record-keeping infrastructure (registrars and depositories) to act as tax agents with respect to Payments. With respect to Payments, prior to amendments to the Tax Code of the Russian Federation, the management company continues to act as the tax agent.

Given the above, when paying funds constituting a Payment for subsequent transfer in the manner provided for by Article 8.7 of Federal Law No. 39-FZ dated April 22, 1996 “On the Securities Market,” the management company must accompany the crediting of funds to NSD's bank account with information on the funds due to each mutual fund unit holder (hereinafter – Payment Distribution Register). An example of a Payment Distribution Register is provided below. Without a Payment Distribution Register, it will not be possible to transfer Payments to holders considering the tax withheld by the management company, as transferring Payments by proportionally distributing Payment amounts (i.e., without considering the tax withheld by the management company) would violate the rights of mutual fund unit holders. To form a Payment Distribution Register, the Management Company may take actions necessary to collect the information required for forming the register.

Failure by the management company to submit the Payment Distribution Register to NSD is grounds for returning the funds to the management company.

NSD is not empowered to control the correctness of tax withholding by the management company when making a Payment. Upon receiving funds constituting a Payment from the management company, NSD assumes that the management company has fulfilled its tax agent obligations in accordance with the requirements of tax and fee legislation.

NSD transfers Payments to depositors based on the Payment Distribution Register received from the registrar/management company. Payments are transferred using the banking details registered with NSD for the depositor. For each transfer to the depositor of their respective Payments, the depositor is provided with a Payment and Income Transfer Notice in form GSRUB.

NSD transfers Payments to its depositors who are nominees and managers no later than three business days after the day NSD receives them. Payments to other depositors are transferred no later than seven business days after the day NSD receives them. The transfer of Payments to depositors who are nominees and managers within a timeframe of no later than three business days is necessitated by the need to process information regarding the amounts due to each mutual fund unit holder on the NSD side.

In accordance with the requirements of paragraph 5 of Article 25 of Federal Law No. 156-FZ dated November 29, 2001 “On Investment Funds” and Bank of Russia Instruction No. 7233-U dated November 10, 2025, from March 1, 2026, NSD, on the account of which a record is entered regarding the restriction of disposing of mutual fund units associated with the partial redemption of mutual fund units, blocks the mutual fund units recorded in the depot accounts of its depositors by entering a record regarding the restriction of disposing of securities, provides depositaries with a report on the executed operation in form GS037, and carries out the transfer of a specific amount of mutual fund units, expressed in percentages, subject to partial redemption, to section 83 “Blocked for Corporate Actions,” and provides depositaries with a report on the executed operation in form MS101.

Considering the Bank of Russia's opinion, NSD will continue to collect mutual fund unit holder lists after March 1, 2026. List collection will be carried out based on a corresponding request from the person responsible for maintaining the register of mutual fund unit holders. Available request parameters are provided below.

Notification

A notice regarding the convening of a general meeting or mail-in voting (hereinafter – general meeting of mutual fund unit holders), and materials for the general meeting of mutual fund unit holders, are sent to NSD in the form of an ISO20022 standard electronic document, Meeting Notification (hereinafter – Meeting Notice) for forwarding to depositors, whose depot accounts hold units as of the date of compiling the list of persons entitled to participate in the general meeting of mutual fund unit holders.

Compilation of the list of persons entitled to vote when making decisions at the general meeting of mutual fund unit holders

The procedure for compiling the list of persons entitled to vote when making decisions at the general meeting of mutual fund unit holders is changing.

Based on the received Meeting Notice, depositaries will send NSD messages in the Meeting Instruction format according to ISO20022 (hereinafter – Voting Instruction) with information on persons entitled to vote at the general meeting of mutual fund unit holders.

NSD will forward the Voting Instructions received from depositaries to the registrar to compile the list of persons entitled to vote at the general meeting of mutual fund unit holders.

¹ In accordance with the norms of Article 4 of the Civil Code of the Russian Federation (CC RF), these norms become mandatory for record-keeping infrastructure participants (depositories, registrars) from the moment of their entry into force, regardless of the conditions provided for by the mutual fund trust management rules. Record-keeping infrastructure participants are not parties to the trust management agreement for a mutual fund concluded with the management company, and the terms of such an agreement do not impose any obligations on record-keeping infrastructure participants (Article 308 of the CC RF).

² Payment of monetary compensation upon partial redemption of mutual fund units and payment of income from the trust management of mutual fund units.

Effective March 1, 2026, amendments to Federal Law No. 156-FZ “On Investment Funds” (hereinafter – “the Law”) enter into force, changing the depository service procedure for mutual fund units.

The amendments are introduced by Federal Law No. 532-FZ dated December 28, 2024 “On Amendments to the Federal Law “On Investment Funds” and certain legislative acts of the Russian Federation.” These amendments concern, among other things:

• the system of rights record-keeping for mutual fund units regarding the record-keeping of units of different classes;
• the procedure for management companies transmitting information related to the implementation of rights vested in mutual fund units;
• the procedure for exercising the rights of mutual fund unit holders.

If rights to mutual fund units are recorded in depot accounts opened at NSD, then in accordance with the law, the management company will be obliged to use documents in electronic form when interacting with NSD. This rule also applies to the procedure for transmitting applications for the acquisition, exchange, and redemption of mutual fund units.

Currently, for exchanging documents in electronic form signed with an electronic signature with management companies, the Central Depository already uses a specially developed electronic document management system for these purposes – the PIF Platform.

The PIF Platform is an electronic platform based on NSD's electronic document management system. The platform is designed for automated interaction between NSD depositaries and management companies of mutual funds regarding the exchange of messages, the fulfillment by the management company of obligations provided for by law to provide information and documents, as well as when transmitting applications for the acquisition, redemption, or exchange of both traded and untraded mutual fund units of any mutual funds (including ETFs, Closed-end Mutual Funds, Investment Mutual Funds, Real Estate Mutual Funds).

Using the PIF Platform when interacting with NSD allows management companies to fully ensure compliance with the legal requirement to use documents in electronic form.

If your company is not yet connected to the PIF Platform or is connected but not using it, we ask you to promptly contact NSD at sales@nsd.ru or contact your personal manager to arrange connection and/or schedule testing.

For your convenience, we provide detailed information below on the procedure for connecting to the PIF Platform, including necessary technical specifications:

NSD analyzes the impact of the changes provided for by the law on the interaction procedure with depositaries and management companies, the units of which are recorded at NSD. We will consistently report about all actions required from depositaries and management companies in connection with the mentioned changes on our official website.

Ref. No. NSD-I-2025-10421 dated June 17, 2025

To Depositories of NSD

The key change concerns the mandatory use of electronic documents when the management company interacts with a person whose account is opened under the nominal holder for the record-keeping of rights to mutual fund units. The transmission of applications by the nominal holder to the management company will also be carried out in electronic form.

To comply with these requirements when interacting with NSD for the purpose of acquiring, redeeming, or exchanging mutual fund units, depositaries must use instruction forms with operation codes 35/3 and 36/3 for transmitting applications to the management company for the acquisition, redemption, or exchange of mutual fund units.

Depositories will gain access to the Centralized Record-keeping System for Mutual Fund Units (PIF)** (hereinafter – PIF Platform) starting June 30, 2025. However, from March 1, 2026, NSD will not accept depositary instructions for submitting applications and conducting depository operations with operation codes 36/2, 35/2, 36/35. Therefore, NSD recommends that depositaries familiarize themselves with the functionality of the PIF Platform in advance, no later than November 1, 2025, and decide on the method of interaction (WEB-Cabinet/WEB-service).

The PIF Platform is an electronic platform based on NSD's Electronic Document Management (EDM) system, designed for automated interaction between NSD depositaries and management companies of mutual funds regarding the exchange of messages and the transmission of applications for the acquisition, redemption, or exchange of mutual fund units of Open-end Mutual Funds (OMF), Investment Mutual Funds (IMF), Closed-end Mutual Funds (CMF), and Exchange Traded Funds (ETF).

At the same time, the use of the PIF Platform ensures:

• timely automated and seamless interaction between collective investment market participants;

• minimization of operational risks and reduction of operational costs on both the side of NSD depositaries and the side of management companies.

We also recommend reviewing the answers to frequently asked questions in the Appendix to this notice.

For questions related to testing and demonstrating the PIF Platform service, as well as for obtaining additional information, please contact your personal NSD manager by phone: +7 495 956-27-90, +7 495 956-27-91 or by email to pif@nsd.ru.

For software configuration issues, you may contact NSD's Technical Support department by phone at +7 (495) 956-09-34 and by email: SOED@nsd.ru.

1. Conduct testing of new instruction formats for the acquisition, redemption, and exchange of mutual fund units via the PIF Platform, using your method of electronic interaction with NSD.

Submit an Application for Testing Participation.

Specifications of Electronic Documents Used in the PIF Platform.

2. To connect to the PIF Platform WEB-Cabinet, provide rights to PIF Platform users. As of June 30, 2025, the Site Participant Administrator registered in the Unified Administrator Cabinet (hereinafter – UAC) based on a previously submitted EDM application by the depositor and having access to the DCM WEB-Cabinet, receives similar access to the Centralized Record-keeping System for Mutual Fund Units WEB-Cabinet (PIF Platform). To provide access to the PIF Platform functionality for the Site Participant Administrator, it is required to configure the authorized users' role of your organization in the UAC. The question is described in more detail in the UAC User Manuals, PIF Platform WEB-Cabinet (PIF Platform).

Review Standard Instruction Forms.

If NSD depositaries and/or management companies are not connected to the PIF Platform, applications to the management company are transmitted in paper form, which increases the application processing time and the issuance of mutual fund units, and may also entail operational costs and risks for all process participants.

If the management company is connected to the PIF Platform, the depositor must submit instructions for submitting applications with operation codes 35/3 and 36/3 via the PIF Platform.

NSD reserves the right to refuse to execute instructions with operation codes 36/2, 35/2, 36/35 from depositaries submitted via Best Software and/or DCM for submitting applications and conducting operations with mutual fund units of mutual funds, whose management companies are connected to the PIF Platform.

Please note that from March 1, 2026, NSD will not be authorized to transmit applications to the management company in paper form and will be forced to refuse to accept depositary instructions with operation codes 36/2, 35/2, 36/35. This may lead to the inability to acquire mutual fund units upon issuance and to the holder's inability to exercise the rights vested in the mutual fund units.

Currently, management companies are actively connecting to the PIF Platform, and by March 1, 2026, all management companies whose mutual fund units are recorded at NSD will be connected to the PIF Platform.

List of Management Companies Already Connected to the PIF Platform.

If the list does not include management companies of mutual funds with whose mutual fund units you conduct acquisition upon issuance, redemption, and/or exchange operations, we recommend contacting such management companies to expedite their connection to the PIF Platform.

Remind you that NSD does not charge a fee for accepting mutual fund units for storage and/or record-keeping, acquired upon issuance, and from October 1, 2024, to December 31, 2025, a Marketing Period is in effect for NSD services for the redemption or exchange of mutual fund units of mutual funds, if the instruction for submitting the corresponding application was submitted via the PIF Platform.

For your convenience, we provide detailed information about the PIF Platform below, including the necessary technical specifications:

1. Procedure for Connecting to the PIF Platform

2. Instruction for Interaction with NSD and User Manual

* Federal Law No. 156-FZ dated November 29, 2001 “On Investment Funds” in the edition of Federal Law No. 532-FZ dated December 28, 2024 “On Amendments to the Federal Law “On Investment Funds” and certain legislative acts of the Russian Federation”

** Centralized Record-keeping System for Mutual Fund Units

Within the framework of changes to Law No. 156-FZ “On Investment Funds,” from March 1, 2026, Non-Bank Credit Institution Joint Stock Company “National Clearing Depository” (hereinafter – NSD) will transfer to depositaries in a cascade information related to the exercise of rights on mutual fund units of Russian mutual funds (hereinafter – Mutual Funds) and income payments to mutual fund unit holders, in cases where the record-keeping of mutual fund units is carried out in the nominal holder's account/nominal holder of the central depository's account, opened in the name of NSD.

We recommend you prepare in advance and plan measures to ensure the receipt from NSD and subsequent transfer to your depositaries of information about corporate actions (hereinafter – CA) and income payments from the trust management of Mutual Funds. Currently, NSD is working on adapting the corresponding message formats. Information about new message formats will be posted additionally in the “Client Notifications” section.

* Bank of Russia Instruction No. 5609-U dated November 2, 2020 “On the Disclosure, Dissemination, and Provision of Information by Share Investment Funds, Management Companies of Investment Funds, Mutual Funds, and Non-State Pension Funds, as well as on the Requirements for the Calculation of Investment Activity Returns by a Share Investment Fund and the Management Company of a Mutual Fund” (together with “Information Subject to Disclosure, the Procedure and Timeframe for its Disclosure”, “Information Subject to Disclosure in the Form of a Key Information Document, as well as the Procedure and Timeframe for its Disclosure”) (Registered in the Ministry of Justice of Russia on December 4, 2020 No. 61277)

** Bank of Russia Regulation No. 796-P dated June 28, 2022 “On Additional Requirements for the General Meeting of Closed-end Mutual Fund Unit Holders” (Registered in the Ministry of Justice of Russia on November 7, 2022 No. 70835)

NSD's Interaction Procedure with Management Companies and Registrars in the Framework of Transmitting Mutual Fund Unit Information from March 1, 2026

From March 1, 2026, management companies and registrars must transmit to Non-Bank Credit Institution Joint Stock Company “National Clearing Depository” (NSD) (hereinafter – NSD) information mandatory for disclosure and provision in accordance with Law No. 156-FZ “On Investment Funds.”

What information must the registrar transmit to NSD?

All information that the management company is obliged to provide to holders in accordance with Article 8.9 of Law No. 39-FZ “On the Securities Market.”

This includes information:

• About the convening of a general meeting or mail-in voting at the general meeting of mutual fund unit holders (p. 8 of Article 18);

• About the results of the voting (p. 8, p. 11.1 of Article 18);

• About the payment date and the amount of income from trust management per one mutual fund unit (subp. 8.5 of p. 2, p. 7 of Article 39);

• About the agreement on amendments and additions to the mutual fund trust management rules, mutual fund units of which are restricted in circulation (p. 1 of Article 20).

• Information, materials, and voting ballots, as well as information about mutual fund unit classes providing the right to vote at the general meeting (p. 8 of Article 18);

What information must the registrar receive from NSD?

Messages about expressions of will by mutual fund unit holders regarding voting at general meetings of mutual fund unit holders.

What channels and interaction formats must be used?

• The Corporate Action (CA) Web-Cabinet, providing the user with interactive access to electronic interaction;

• WEB-service/API for sending messages in ISO20022 format, formed in the registrar's own software.

What actions must the registrar take?

• When interacting with NSD via the WEB-service/API channel, plan software modifications that will allow the transmission of structured messages in ISO20022 format. Currently, NSD is working on adapting the corresponding message formats. Information about the publication of new formats will be posted in the “Client Notifications” section;

• Agree with the management companies on the list of information to be transmitted to NSD (if the management company plans to transfer the function of transmitting information to NSD to the registrar).

What information must the management company transmit to NSD?

All information that the management company is obliged to disclose in accordance with the requirements of Law No. 156-FZ “On Investment Funds” (p. 3.2 of Article 51) and the regulatory acts adopted in accordance with it. The list of information to be transmitted to NSD is provided below.

What channels and interaction formats must be used?

• The PIF Platform WEB-Cabinet, providing the user with interactive access to electronic interaction;

• WEB-service/API for sending messages in ISO20022 format, formed in the management company's own software.

What actions must the management company take?

• Ensure that the management company is connected to the PIF Platform. If the management company is not connected to the PIF Platform, it is necessary to promptly contact NSD at sales@nsd.ru or contact the personal manager to arrange the connection. The process is described in detail in the presentation: Procedure for Connecting to the PIF Platform;

• When interacting with NSD via the WEB-service/API channel, plan software modifications that will allow the transmission of structured messages in ISO20022 format. Currently, NSD is working on adapting the corresponding message formats. Information about the publication of new formats will be posted in the “Client Notifications” section;

• Agree with the registrar on the list of information to be transmitted to NSD (if the management company plans to transfer the function of transmitting information to NSD to the registrar).

What changes will occur in the income payment process for mutual fund units?

• Income from Trust Management

  For mutual fund unit holders recorded in the nominal holder's accounts/nominal holder of the central depository of NSD, income is transferred by crediting funds to the NSD account. NSD will transfer funds to its depositaries in the manner provided for by Article 8.7 of Law No. 39-FZ “On the Securities Market” (“in a cascade”).

• Monetary Compensation in Connection with Partial Redemption of Mutual Fund Units

  For mutual fund unit holders recorded in the nominal holder's accounts/nominal holder of the central depository of NSD, income is transferred by crediting funds to the NSD account. NSD will transfer funds to its depositaries in the manner provided for by Article 8.7 of Law No. 39-FZ “On the Securities Market” (“in a cascade”).

If the management company has not previously transmitted funds to NSD accounts, we recommend contacting the personal manager at NSD by phone at +7 495 956-27-90, +7 495 956-27-91 or by email at manager@nsd.ru to clarify the details for income transfers.

List of Information for Transmission to NSD

* Bank of Russia Instruction No. 5609-U dated November 2, 2020 “On the Disclosure, Dissemination, and Provision of Information by Share Investment Funds and Management Companies of Investment Funds, Mutual Funds, and Non-State Pension Funds, as well as on the Requirements for the Calculation of Investment Activity Returns by a Share Investment Fund and the Management Company of a Mutual Fund” (together with “Information Subject to Disclosure, the Procedure and Timeframe for its Disclosure”, “Information Subject to Disclosure in the Form of a Key Information Document, as well as the Procedure and Timeframe for its Disclosure”) (Registered in the Ministry of Justice of Russia on December 4, 2020 No. 61277)

Bank of Russia Instruction No. 3758-U dated August 25, 2015 (ed. dated June 28, 2024) “On Determining the Net Asset Value of Investment Funds, Including the Procedure for Calculating the Average Annual Net Asset Value of a Mutual Fund and the Net Asset Value of a Share Investment Fund, the Estimated Value of Mutual Fund Units, and the Value of Property Transferred in Payment for Mutual Fund Units” (Registered in the Ministry of Justice of Russia on October 8, 2015 No. 39234)