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transcript

COVER SHEET

1c1s1210101s1011 IG/3/31

IEIOIUI I ITIYI 1, IN Io IE Ix I IF I u IN ID I' I I I IN IC I . I

(Company's Full Noma)

JslTIHI IAIVIEI. I, I JclolRI. I l2lslTIHI lslTI . 1, I IBIOINI I IFIAlcl I Joi IGILIO IBIA IL I lei I IT IYI, I I I IT IAIGIUIIIGl ,I IMIEITIR IOI IMIAINIIILIAI I I I

(Business Address : No. Street/City/Province)

ATTY. CHARLES ALBERT R. LEJANO 8880999 Contact Person Company Telephone Number

I 1 I 2 I 13 I 1 I Month Day

Letter FORM TYPE

I 1 I 2 I 11 I O I Month Day

Fiscal Year Annual Meeting

Secondary License Type, If Applicable

.__..._,,........__I Dept. Requiring this Doc. Amended Articles Number/Section

Total No. of Stockholders

.------....:.;To=ta:.:.:.I A=m=ou=;nt of B.~orr'--"..ow::::in.:.:,_gs~-----,

I Domestic Foreign

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I I I I I I File Number LCU

I I Document 1.0.

Cashier i : l !

! STAMPS i ' I

i·······-··········································································'

Remarks= pis. Use black ink for scanning purposes

16 February 2017

DIRECTOR JUSTINA F. CALLANGAN Corporate Governance and Finance Department Securities and Exchange Commission G/F North Wing Hall, Secretariat Building PICC Complex, Vicente Sotto Street Pasay City

Dear Director Callangan,

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T FEB 1 2017 @

JD aY'-.----U---l

We write in reply to your comments on the checklist attached to your letter of 14 February 2017 regarding the Preliminary Information Statement (SEC Form 20-IS) of PAMI Equity Index Fund, Inc.

Please find attached an updated version of said checklist with an additional column to reflect our responses.

We hope that we have provided you with sufficient clarification.

RTR. LEJANO Assistan orpo te Secretary PAMI Equity Index Fund, Inc.

COVER SHEET

Ip I A IM 11 I IEIOIUIIITIYI ! IINIDIE IXI IF I u IN ID I' I I I I IN IC I. I I I I

I I I (Company's Full Nomo)

ISIT IHI [A[VIEI. I' I ICIO IRI .1 [2l6 [TIH I IS[TI .1, I IBIO INI I [FIAICI I 10 1 IGILIOIBIA ILI ICI I ITIY I ' I I ITIAIGIU [ IIGl,I IMIE ITIRIOI IMIAINIIILIAI I I I

(Business Address: No. Street/City/Province)

A TTY. CHARLES ALBERT R. LEJANO 8880999 Contact Person Company Telephone Number

I Month

SEC Form 20-IS FORM TYPE

I 1 I 2 I Month

I 1 IO I Day

Fiscal Year Annual Meeting

Secondary License Type, If Applicable

Dept. Requiring this Doc. Amended Articles Number/Section

Total No. of Stockholders

~ -----'-'To=ta;.;..c.l A=m=ou"-';nt of B,:;.c..orr=ow=in=-gs"'--------,

I Domestic Foreign

~ ~ ~-,--~~~_To~b_e_a~cc~omplished by SEC Personnel concerned

I I I I I File Number LCU

I Document I.D.

Cashier ..................................................................................... ' ' : :

' i STAMPS 1 i i .......................... ,_,,., ...................... ...... ...................... •

Remarks= pis. Use black ink for scanning purposes

SECURITIES AND EXCHANGE COMMISSION SEC FORM 20-IS

INFORMATION STATEMENT PURSUANT TO SECTION 20 OF THE SECURITIES REGULATION CODE

1. Check the appropriate box: [ ) Preliminary Information Statement [ x ) Definitive Information Statement

2. Name of Registrant as specified in its charter PAMI Equity Index Fund, Inc. ("PEIF") or ("Fund")

3. Philippines Province, country or other jurisdiction of incorporation or organization

4. SEC Identification Number CS200901633

5. BIR Tax Identification Number 007-240-478-000

6. 17/F Philam Life Head Office, Net Lima Building, 5th Avenue corner 26th Street, Bonifacio Global City, Taguig City Address of principal office

7. Registrant's telephone number, including area code (632) 521-6300

8. Date, time and place of the meeting of security holders Date: March 13, 2017 Time: 2:00 p.m. Place: Premier Agency Centre, Philam Life Head Office

15/F Net Lima Building 5th Avenue corner 26th Street, Bonifacio Global City, Taguig City

1634 Postal Code

9. Approximate date on which the Information Statement is first to be sent or given to security holders February 20, 2017

10. Proxy Solicitation Name of Person filing the Statement/Solicitor: Mr. Eric S. Lustre Address and Telephone No.: 17/F Philam Life Head Office, Net Lima Building,

5th Avenue corner 26th Street, Bonifacio Global City, Taguig City (632) 521-6300

11. Securities registered pursuant to Sections 8 and 12 of the Code or Sections 4 and 8 of the RSA (information on number of shares and amount of debt is applicable only to corporate registrants):

Title of Each Class

Common Shares of PHP0.45 par value

Number of Shares of Common Stock Outstanding or Amount of Debt Outstanding

(as of December 31, 2016)

59,489,165

12. None of PEIF's securities is listed on the Philippine Stock Exchange.

NOTICE OF SPECIAL MEETING OF STOCKHOLDERS

Please be informed that a Special Meeting of the Stockholders of PAMI EQUITY INDEX FUND, INC. (the "Company") will be held on March 13, 2017, Monday, at 2:00 p.m. at Premier Agency Centre, Philam Life Head Office, 15th Floor Net Lima Building, 5th Avenue corner 26th Street, Bonifacio Global City, Taguig.

The agenda for the Special Stockholders' Meeting shall be as follows:

1. Call to Order

2. Certification of Notice and Quorum

3. Management Report

Items for Approval

4. Registration of Additional Shares

5. Authority of SEC to Examine Bank Accounts

6. Implementation of Exemptive Relief; Minimum and Additional Investment

7. Amendment of Dividend Policy

8. Amendment of Articles of Incorporation to Reflect Change in Principal Address; Certain Proposed Amendments to the Fund's Registration Statement and Prospectus, as indicated in Annex "A" Hereof

9. Amendment of the Registration Statement and Prospectus of the Company to reflect the matters from Items 4 through 8

10. Other Matters

11. Adjournment

The Board of Directors has fixed 12:00 noon on February 8, 2017 (the "Record Date") as the record date for the determination of stockholders entitled to notice of and to vote at the Special Meeting of the Stockholders. Only holders of shares of common stock as at the Record Date will be entitled to vote at the Special Meeting of the Stockholders.

PART I.

INFORMATION REQUIRED IN INFORMATION STATEMENT

GENERAL INFORMATION

Date, time and place of meeting of security holders

Date: Time: Place:

March 13, 2017 2:00 p.m. Premier Agency Centre, Philam Life Head Office 15th Floor, Net Lima Building 5th Avenue corner 26th Street, Bonifacio Global City, Taguig City

Registrant's Mailing Address: 17/F Philam Life Head Office, Net Lima Building, 5th Avenue corner 26th Street. Bonifacio Global City, Taguig City

The date on which the Information Statement is first to be sent or given to stockholders is February 20, 2017.

2. Dissenters' Right of Appraisal

As provided by Title X of the Corporation Code of the Philippines (Batas Pambansa Big. 68) ("Corporation Code"), any stockholder of a corporation shall have the right to dissent and demand payment of the fair value of his shares in the following instances:

2.1 In case any amendment to the Articles of Incorporation has the effect of changing or restricting the rights of any stockholders or class of shares, or of authorizing preferences in any respect superior to those of outstanding shares of any class, or of extending or shortening the term of corporate existence;

2.2 In case of sale, lease, exchange, transfer, mortgage, pledge or other disposition of all or substantially all of the corporate property and assets as provided in the Corporation Code; and

2.3 In case of merger or consolidation.

In order for the stockholder to exercise the right, he or she must vote against any of the enumerated instances which the corporation will pursue. The procedures in the exercise of the right are the following:

2.4 Written demand on the corporation within 30 days after the date that the vote was taken. 2.5 Submission of the shares of the dissenting stockholder to the corporation for notation within 10 days

from the written demand. The corporation has to pay the stockholder with the fair value of the shares within 30 days after demanding payment for his or her shares.

2.6 Failure to make the demand within 30 days shall be deemed a waiver of the appraisal right.

There will be no matters that will be taken up at the meeting which may warrant the exercise of this right.

3. Interest of Certain Persons in or Opposition to Matters to be Acted Upon

There is no person who has been a director or officer of PEIF at any time since the beginning of the last calendar year, or who is a nominee for election as director, or an associate of any of the foregoing persons who has a substantial interest in any matter to be acted upon at the Special Stockholders' Meeting. No member of the Board of Directors (the "Board") has informed PEIF that he intends to oppose any action to be taken by PEIF at the Special Stockholders' Meeting.

B. CONTROL AND COMPENSATION INFORMATION

4. Voting Securities and Principal Holders Thereof

(a) The total number of outstanding shares as of December 31, 2016 is 59,489,165, all of which are common and voting. Each share shall be entitled to one vote with respect to all matters to be taken up during the Special Stockholders' Meeting.

(b) All stockholders of record as of February 8, 2017 are entitled to receive this Information Statement, and to receive notice of, and vote during the Special Stockholders' Meeting.

(c)(i) Security Ownership of Certain Record and Beneficial Owners

The name, address, citizenship, number of shares held, and percentage of total ownership of a person (including any group) owning more than 5% of the outstanding voting shares of PEIF's as of December 31, 2016 is as follows:

(2) Name and Address of Record (3) Name of Beneficial Owner (6)

(1) Title of Owner and Relationship with the and relationship with Record

(4) (5) No. of Percentage Class

issuer Owner Citizenship Shares of Class

Held The Philippine American Life and General Insurance Co (Philam Life) Philam Life Head Office 15-18/F Net Lima Building The Philippine American Life

Common 5th Avenue cor. 26th Street and General Insurance Co Filipino 40,057,666 67.3361% Bonifacio Global City, Taguig (Philam Life)'

Record Owner is an affiliate of the Issuer. Novaliches Development Cooperative NOVADECI Building

Common Buenamar Corner Sarmiento Street Record Owner is the Beneficial Filipino 3,639,228 6.1175% Nova Proper, Novaliches Owner2 Quezon City

No relationship to the Issuer.

The Board and Philam Asset Management, Inc., the investment adviser or fund manager ("Fund Manager") of PEIF have no knowledge of any person who, as of the Record Date, is or was directly or indirectly the beneficial owner of more than 5% of PEIF's outstanding shares of common stock or who has voting power or investment power with respect to shares comprising more than 5% of PEI F's outstanding common stock.

(c)(ii) Security Ownership of Management as of December 31, 2016

Title of Class Name of Beneficial Owner Amount and Nature of Beneficial Ownership

Citizenship Percent of Class

' Mr. Eduardo Banaag is the person with the power to vote and dispose of the shares of The Philippine American Life and General Insurance Co (Phi/am Life). Mr. Banaag is Head of the Equity Fund Management of Phi/am Ute. 2 The following officers of Novaliches Development Cooperative have been authorized to vote the shares of the cooperative: Ms. Nene C. Espinola (Chairperson), Ms. Evelyn C. Dimacale (Vice-Chairperson), Mr. Alexander R. Alvarez (Treasurer), and Ms. Marlene D. Sindayen (General Manager).

Roberto F. De Ocampo Eugenio Lopez Foundation Building

Common Col. Joseph R. Mcmicking Campus 1 (R} Filipino 0.00001% 123 Paseo de Roxas, Makati City (Chairman\ Elenita G. Villamar 17F Net Lima Building

Common 5th Avenue comer 26th Street 1 (R} Filipino 0.00001% Bonifacio Global City, Taguig /Director & Treasurer) Eric S. Lustre 17F Net Lima Building

Common 5th Avenue comer 26th Street 1 (R) Filipino 0.00001% Bonifacio Global City, Taguig I/Director\ Reynaldo G. Geronimo

Common No. 5 Zinia Street, Valle Verde 2, Pasig City 1 (R) Filipino 0.00001% President & Director)

Arleen May S. Guevara 17F Net Lima Building

Common 5th Avenue comer 26th Street 1 (R) Filipino 0.00001% Bonifacio Global City, Taguig I Director\

Armand F. Braun, Jr.

Common No. 45 Magdalena Circle, Magallanes Vi llage

1 (R} Filipino 0.00001% Makati City lndeoendent Director)

Meliton B. Salazar, Jr. Common No. 28 Hunt Street, Fllinvest East, Quezon City 1 (R) Filipino 0.00001%

' lndeoendent Director) Ma. Adelina S. Gatdula

Common Penthouse, Liberty Center, 104 H.V. Dela Costa 0 Filipino 0% Street Salcedo Village, Makati City ''Coroorate Secretarv) Chartes Albert R. Lejano

Common Penthouse, Liberty Center, 104 H.V. Dela Costa 0 Filipino 0% Street Salcedo Village, Makati City (Assistant Coroorate Secretarv) Jose Ivan T. Justiniano 18/F Net Lima Building, 5th Avenue comer 26th

Common Street 0 Filipino 0% Bonifacio Global City, Taguig City rcomnliance Officer\

TOTAL 7 (R} Filipino 0.00007%

(c)(iii) Voting Trust Holders of 5% or more

As of December 31, 2016, there is no voting trust or similar arrangement for 5% or more of PEIF's shares. There are no arrangements which may result in a change of control in PEIF.

(d) Change of Control

There was no change in control in PEIF that occurred since the beginning of the last calendar year.

C. MANAGEMENT REPORT

5. Financial and Other Information

The following are PEIF's top five (5) key performance indicators:

A. Assets Under Management ("AUM")

PEIF's AUM grew by 74.7% from Php1 .545 billion from July to December 2015 to Php 2.699 billion by the end of December 2016. Large portions of the increase is attributable to the increase in the Fund's investments in financials assets measured at fair value through profit or loss due to continuing client subscription and the strategy in managing the Fund's assets since commencement of operations on the second half of June 2015.

B. Net Asset Value Per Share ("NAVPS") per quarter

QTR YEAR DATE NAVPS YEAR DATE NAVPS

LOW 21-Jan 41.2533 1 49.6182 HIGH 21-Mar

- 2015 2016 LOW 16-Jun 50.6795 5-May 47.2763

2 HIGH 24-Jun 51.2991 29-Jun 52.2053

3 LOW 24-Aug 46.0271 14-Sep 50.3708

HIGH 5-Aug 51.4153 21-Jul 54.1357 - LOW 14-Dec 45.1817 23-Dec 43.4767 4

HIGH 26-0ct 49.3241 4-0ct 51.5882

Market Information

PEIF is not listed in the Philippine Stock Exchange (PSE). Its shares are sold by PAMl's main distribution channels. These channels are its certified investment solicitors, independent sales consultants, its Philam Life licensed agents, and its ten offices nationwide.

Holders

As of December 31, 2016, there were a total of 4,344 holders of redeemable common stock (one class of shares only) totaling 59,489,165 shares.

The top 20 shareholders are as follows:

CLIENT NAME NO. OF SHARES %OF TOTAL

1 THE PHILIPPINE AMERICAN LIFE AND GENERAL INSURANCE CO

40,057,666.00 67.3361% (PHILAM LIFE)

2 NOVALICHES DEVELOPMENT COOPERATIVE 3,639,228.00 6.1175%

3 RESINS INC 2,972,502.00 4.9967%

4 EWB TRUST DIVISION AS AGENT FOR TIO 999312008741 489,059.00 0.8221%

6 DE OCAMPO, ROBERTO FABROS 318,922.00 0.5361%

7 CED, AILEEN MANDA 298,150.00 0.5012%

8 PHILIPPINE INTERNATIONAL CONVENTION CENTER PROVIDENT

241,893.00 0.4066% FUND (PICC PF)

10 ANG, DIONISIO L 210,008.00 0.3530%

11 VALDES, ARSENIO NEPOMUCENO 206,658.00 0.3474%

12 PACO SORIANO PANDACAN DEVELOPMENT COOPERATIVE

186,218.00 0.3130% (PSPDC)

13 UANG, STANLEY LE 173,189.00 0.2911%

16 DELORME, MICHEL FRANCOIS ERIC 167,435.00 0.2815%

17 CED, AILEEN MANDA 149,462.00 0.2512%

19 ROVIC LAND INC 131,469.00 0.2210%

20 ANGELES UNIVERSITY FOUNDATION MULTI-PURPOSE 118,824.00 0.1997% COOPERATIVE

Dividends

Although there are no restrictions that limit the Fund's ability to pay dividends, PEIF has not declared any cash dividends for the last five (5) years. On October 27, 2016, during its Regular Quarterly Meeting, the Board of PEIF resolved that the Company does not plan to declare cash dividends. The Board further resolved that surplus profits of the Company (if any), will be used as additional proceeds to invest in eligible securities. 3

Under R.A. 2629 ("The Investment Company Act"), PEIF shall not pay any dividend, or make any distribution in the nature of a dividend payment, wholly or partly from any source other than: (i) from PEIF's accumulated undistributed net income, determined in accordance with good accounting practice and including profits or losses realized upon the sale of securities or properties; or (ii) from PEIF's earned surplus so determined for the current or preceding calendar year, unless such payment is accompanied by a written statement which adequately discloses the source or sources of such payment. The Securities and Exchange Commission ("SEC") may prescribe the form of such statement by rules or regulations or by order in the public interest and for the protection of investors. PEIF shall also not to advertise such dividends in terms of centavos or pesos per share without also stating the percentage they bear to the par value per share.

C. Sales & Redemptions

The following table summarizes the performance of PEIF (January to November 2016) in PhP':

3 Amendment is subject to approval by PEIF stockholders during the Special Shareholders Meeting on March 13, 2017.

FUND NAME SALES REDEMPTIONS NET SALES

PAMI Equity Index Fund, Inc. 1,476,990,946.74 464,696,945.33 1,012,294,001.41

*Source: Philippine Investment Funds Association (PIFA)

D. Fund Performance Against Competition

The following table summarizes a comparison of PEIF against its competitors for January to November 2016*:

FUND NAME SALES REDEMPTIONS NET SALES

ALFM Growth Fund, Inc. 888,368,616.67 1,401,679,758.93 (513,311,142.26)

ATRAM Alpha Opportunity Fund, Inc. (formerly, 98,614,414.52 20,087,350.95 78,527,063.57 ATRKE Alpha Opportunity Fund, Inc.)

ATRAM Phil. Equity Opportunity Fund, Inc. 368,476,434.99 1,457,234,013.63 (1,088,757,578.64) (formerly, ATRKE Equity Opportunity Fund, Inc.)

First Metro Save and Learn Equity Fund, Inc. 462,587,358.89 1,387,420,930.64 (924,833,571.75)

One Wealthy Nation Fund, Inc. 1,300,490.97 13,851,928.39 (12,551,437.42)

PAMI Equity Index Fund, Inc. 1,476,990,946.74 464,696,945.33 1,012,294,001.41

Philam Strategic Growth Fund, Inc. 4,935,559,772.81 2,261,811,638.07 2,673,748,134.74

Philequity Dividend Yield Fund, Inc. 320,312,694.26 295,191,046.24 25,121,648.02

Philequity Fund, Inc. 1,307,612,860.33 1,882,530,054.53 (574,917,194.20)

Philequity PSE Index Fund, Inc. 744,489,942.73 179,138,555.55 565,351,387.18

Philippine Stock Index Fund Corp. 2,803,793,231 .70 3,086,761,829.57 (282,968,597.87)

Soldivo Strategic Growth Fund, Inc. 318,340,569.32 54,755,760.27 263,584,809.05

Sun life Prosperity Philippine Equity Fund, Inc. 1,655,057,582.71 4,714,164,056.03 (3,059,106,473.32)

Sun life Prosperity Phil. Stock Index Fund, Inc. 1,519,548,270.75 297,889,664.19 1,221,658,606.56

United Fund, Inc. 6,068,164.79 56,058,609.51 (49,990,444.72) ..

•source: Ph,lippme Investment Funds Assoc,at,on (PIFA)

E. Fund Management & Environmental Analysis

Market and Economic Review

The PSEi was down for the fourth straight month, dropping 8.4% to 6,781 on the back of the Trump victory and EM-to-DM fund flows ahead of the looming Fed rate h ike. Net foreign selling was the largest in any single month this year at $383million. Daily value traded rose 7% month-on-month to average P7.2billion.

Third quarter GDP grew 7.1%, beating the 6.7% consensus forecast. This was primarily driven by strong growth in capital formation (20%year-on-year). Inflation rose further to 2.5%, its highest level since February 2015. The10-year yield rose for the fourth straight month, climbing 59bps to 4.5198.The Peso depreciated 2.5% to 49.676, its weakest level since 2006.

Outlook

A domestically-driven demand for its goods and services implies that the stock market will weather the ups and downs of the global economy.

DISCUSSION OF FINANCIAL CONDITIONS

Financial Position (in Millions of Pesos)

FY 2016

Net assets as of the year ending 2016 was Php2,699, a Php1, 154 growth from December 31, 2015's net assets and a Php2,584 growth from launch date mid-year 2015.

NAVPS on December 31, 2016 was at Php45.3843, sliding down by 2.85% from the NAVPS of December 31, 2015 and decreased further by 10.45% from the NAVPS at launch date in mid-June of 2015.

Interim Period for the Year Ending September 30, 2016 vs. FY 2015

Net assets as of September 30, 2016 was at Php2,324, a Php779 growth from the net assets as of the year ending 201 5.

NAVPS on September 30, 2016 was at 51.01 , increasing by 4 .29 from December 31, 2015.

Results of Operations (in Millions of Pesos)

FY 2016

Net loss as of the end of 2016 was at Php101 million. This figure amounted to a Php33 million slide from the end of December of the previous year. PEIF started commercial operations mid-year of 2015.

Loss Per Share as of December 31, 2016 was Php2.3233, a Php3.2067 improvement from the end of the previous year. Loss Per Share as of December 31 , 2015 was Php5.5300.

Interim Period for the Year Ending September 30, 2016 vs. FY 2015

The Fund posted a net income of Php176.9 as a result of the positive performance of the Fund's investments, net of operating expenses.

Earnings Per Share (EPS) as of September 30, 2016 was posted at 4.41 , an improvement of 9.67 from the same period in 2015.

Uquidity

There are no demands, commitments, events or uncertainties which will impair the liquidity of the Fund. The Fund is mandated by SEC, through the Investment Company Act, to maintain at least 10% of its net assets to be invested at liquid assets (ICA Rule 35 - 1 p. d4). There are no events that triggered direct or contingent financial obligations that are material to the Fund.

Material Transactions

There are no material off-balance sheet transactions, arrangements, obligations and other relationships of the Fund with unconsolidated entities or other persons created during the period. There are no known trends, events or uncertainties that have had or that are reasonably expected to have material favorable or unfavorable impact on net sales, revenues or income from continuing operations. PEIF knows no events that will cause a material change in the relationship between costs and revenues.

The Fund, being subjected to mark-to-market revaluation, depends significantly on the market value fluctuations of listed stocks being held by it.

Recent Sales of Unregistered or Exempt Securities including Recent Issuances of Securities Constituting and Exempt Transactions - NONE

External Audit Fees

The following are the aggregate fees billed by the external auditors for each of the last two calendar years (in Php):

Year Amount 2016 (Estimated) 125,000.00

2015 120,912.93 2014 5 000.00 Total 250,912.93

Note: No tax fees were paid since there were no professional services rendered by Isla Lipana & Co for tax

accounting compliance, advice, planning and any other form of tax service.

Similarly, no other fees were paid for products and services provided by Isla Lipana & Co other than the regular annual audit report.

Corporate Governance

The evaluation system adopted by PEIF to determine the level of compliance of the Board and top level management with its Manual of Corporate Governance is based primarily on the SEC Corporate Governance Self-Rating Form (CG-SRF).

PEIF has undertaken the following measures to fully comply with the adopted leading practices on good corporate governance:

o Consider changes, improvements, or additions to current corporate disclosure procedures o Implement processes for identifying items where timely corporate disclosure is necessary

Except for the required changes mandated by SEC, PEIF has no material deviations from its Manual of Corporate Governance since it filed its CG-SRF with the SEC.

Apart from the foregoing changes or improvements being considered for corporate disclosures, there are no plans to improve the current corporate governance of PEIF.

Other Disclosures

• There were no disagreements with the former accountant, on any matter of accounting any financial disclosure.

• There were no known trends, events or uncertainties with material impact on liquidity and sales. Neither were there events that would trigger direct or contingent financial obligations that are material to the Fund, including any default or acceleration of an obligation.

• There were no material off-balance sheet transactions, arrangements or obligations (including contingent obligations) and other relationships of the Fund with unconsolidated entities or other persons created during the reporting period.

• There were no material commitments for capital expenditures. , The realized and unrealized gains on stock and fixed income investments brought by market appreciation represent the significant element of income from continuing operations.

6. Mergers, Consolidations, Acquisitions and Similar Matters

PEIF does not have any plans to merge or consolidate with any entity. Neither does it have any plans to acquire the securities of any other entity, any other going business, or the assets thereof. It does not have any plan to sell or transfer all or any substantial parts of its assets. Neither does it have any plans to dissolve or liquidate.

7. Acquisition or Disposition of Property

PEIF does not own any real property and does not intend to acquire any real property.

8. Restatement of Accounts

PEIF does not intend to restate any of its asset, capital or surplus accounts.

OTHER MATTERS

Matters Required to be Submitted and Amendment of Charter, By-laws or Other Documents

The Fund will submit the following matters to the stockholders for approval, which matters were approved by the Board during its meeting on October 27, 2016:

A. Registration of Additional Shares

The Board approved the registration of additional shares amounting to Eighty-Seven Million Nine Hundred Forty-Six Thousand Nine Hundred (87,946,900) shares, resulting in an increase from Four Million (4,000,000) to Ninety One Million Nine Hundred Forty-Six Thousand Nine Hundred (91,946,900) registered shares of stock.

On December 10, 2015, the Board of Directors approved an increase in the Fund's authorized share capital from 4,000,000 shares to 91,946,900 shares with par value of Php0.45 per share. The Fund received cash from certain investors as deposits for future subscriptions amounting to Php1 ,421,849. On January 4, 2016, the Fund filed an application with the Securities and Exchange Commission for the increase in authorized capital stock which approved the application on October 19, 2016.

Pursuant to Section 8.1 of the Securities Regulation Code, the Fund was advised on October 10, 2016 by the Corporate Governance and Finance Department of the Commission to file its application to register the 87,946,900 additional common shares on SEC Form 12-1 . This section of the SRC requires that "Securities shall not be sold or offered for sale or distribution within the Philippines, without a registration statement duly filed with and approved by the Commission. Prior to such sale, information on the securities, in such form and with such substance as the Commission may prescribe, shall be made available to each prospective purchaser."

B. Authority of SEC to Examine Bank Accounts

The Board further approved the granting of authority to the Securities and Exchange Commission ("SEC") to examine its bank accounts.

C. Implementation of Exemptive Relief; Minimum and Additional Investment

The Board confirmed and ratified the authority to request from the SEC exemptive relief from the minimum investment of Five Thousand Pesos (Php5,000.00), proposing that the following amounts be set: (i) minimum investment of Php1,000.00 or the minimum amount allowed by the SEC and (ii) minimum additional investment of Php500.00 or the minimum amount allowed by the SEC.

Total Financial Inclusion is among the objectives of Philam Asset Management, Inc. (PAMI) as a fund manager. Total Financial Inclusion means the delivery of financial services, including investment management, at affordable costs to sections of disadvantaged and low-income segments of society.

Said investment management services are intended to be total and complete, and include proper advice and execution of investment choices depending on the customer's risk profile and financial goals. As such, a complete range of investment options should also be made available to the customer, who should be in no way forced or coerced to invest in a fund which is not within his or her investment appetite.

In line with this objective, the Fund has requested for the exemptive relief from the Securities and Exchange Commission to allow for lower minimum investment amounts, namely Php1 ,000 minimum initial investment and Php500 minimum subsequent investment. The Commission en Banc in its meeting held on October 18, 2016 resolved to grant the request, subject to the condition that the Fund Prospectus be amended indicating the foregoing changes, before the same can be implemented.

D. Dividend Policy

The Board approved the amendment of the Company's dividend policy to read, as follows:

"The Company does not plan to declare cash dividends. Surplus profits of the Company (if any) will be used as additional proceeds to invest in eligible securities."

The Fund will likewise submit the following matters to the stockholders for approval, which matters were approved by the Board during its meeting on June 14, 2016:

E. Amendment of Arlie/es of Incorporation to Reflect Change in Principal Address; Amendment of Registration Statement and Prospectus to Reflect Certain Proposed Amendments, as indicated in Annex "A" hereof

F. Amendment of Registration Statement and Prospectus

The Board then approved the amendment of the Registration Statement and the Prospectus of the Company to reflect the matters from items (A) through (E) above. This is in compliance with the condition that the Prospectus should be amended prior to implementation of these changes.

10. Other Proposed Action

There are no other proposed actions with respect to any matter not specifically referred to above.

11. Voting Procedures

Unless otherwise provided by law, each stockholder shall, at every meeting of the stockholders, be entitled to one vote, in person or by proxy, for each share with voting rights held by such stockholder.

In accordance with the Corporation Code, the Third Article of the Articles of Incorporation of PFI shall be amended to reflect its principal address through the affirmative vote of stockholders representing at least twothirds (2/3) of the outstanding capital stock of PFI, a quorum (majority of the issued and outstanding capital stock having voting powers) being present.

The amendment of the Registration Statement and Prospectus of PEIF shall be approved by the affirmative vote of stockholders representing at least a majority of the outstanding capital stock of PEIF, a quorum (majority of the issued and outstanding capital stock having voting powers) being present.

Unless required by law, or demanded by a stockholder present in person or by proxy at any meeting and entitled to vote thereat, the vote on any question will not be by ballot, and will be conducted and counted by a raising of hands. In case of a vote by ballot, each ballot shall be signed by the stockholder voting in his name or by his proxy if there be such proxy, and shall state the number of shares voted by him or her. The Corporate Secretary of PEIF will count the votes.

12. Interest of Certain Persons in or Opposition to Matters to be Acted Upon

No person who has been a director or officer of PEif, or a nominee for election as a director of PEif, nor any of their associates, has a substantial interest in any matter to be acted upon at the Special Stockholders' Meeting.

No director of PEif has informed it in writing that he or she intends to oppose any matter to be acted upon at the Special Stockholders' Meeting.

UPON WRITIEN REQUEST OF ANY OF THE STOCKHOLDERS OF RECORD ENTITLED TO NOTICE OF, AND TO VOTE AT, THE MEETING, PEIF SHALL FURNISH HIM WITH A COPY OF ITS ANNUAL REPORT ON SEC FORM 17-A AND ITS QUARTERLY REPORT FOR THE PERIOD ENDED 31 DECEMBER 2016 WITHOUT CHARGE. ANY SUCH WRITIEN REQUEST SHOULD BE ADDRESSED TO:

PAMI EQUITY INDEX FUND, INC. 17/F Philam Life Head Office

Net Lima Building, 5th Avenue corner 6th Street Bonifacio Global City, Taguig City 1634

Philippines

PARTII.

INFORMATION REQUIRED IN A PROXY FORM

1. Identification

The proxy solicitation is made by PAMI EQUITY INDEX FUND, INC. (the "Company"), represented by Mr. Eric S. Lustre, the President and Chief Executive Officer of Philam Asset Management, Inc. ("PAMI"), the Company's investment adviser. The proxy solicitation is in favor of Mr. Lustre or in case of his nonattendance, the Chairman of the Special Stockholders' Meeting chosen in accordance with the Company's By-Laws.

All costs and expenses incidental to the proxy solicitation will be borne, directly or indirectly, by the Company.

2. Instructions

(a) The security holder is instructed to complete and affix his or her signature on the attached form.

(i) If the securities are owned by two or more joint owners, the proxy form must be signed by all of the joint owners.

(ii) If the securities are owned in an "and/or" capacity, the proxy form must be signed by either one of the owners.

(iii) If the securities are owned by a corporation, association, partnership or unincorporated entity, the proxy form must be accompanied by a certification, signed by a duly authorized officer, partner or representative of such corporation, association, partnership or unincorporated entity, that designates and empowers an authorized signatory to sign the proxy form pursuant to the constitutive documents or duly approved policies of such corporation, association, partnership or unincorporated entity for this particular purpose.

(b) The security holder appoints Mr. Eric S. Lustre, or in case of his non-attendance, the Chairman of the Special Stockholders' Meeting, to represent and vote all shares registered in his or her name as proxy of the undersigned security holder. ·

(c) The security holder shall clearly indicate the date of execution of the proxy form. A proxy form which is undated, post-dated, or which provides that it shall be deemed to be dated as of any date subsequent to the date on which it is signed by the security holder, shall not be valid.

(d) The security holder shall sign the proxy form or have the form signed by a duly authorized representative, and file the same with the Corporate Secretary not later than 5:00 p.m. on March 10, 2017.

(e) Retrieval and validation of all the proxy forms shall be administered by the Corporate Secretary and persons designated by the Corporate Secretary who shall be under his supervision and control from February 20, 2017 to March 13, 2017.

3. Revocability and Validity of Proxy

The proxy form in favor of the Company shall be irrevocable and shall be effective and valid for a period of five (5) years from the date of its execution. There is no formal procedure or limitation for the right of revocation of a proxy before it is exercised.

4. Persons Making the Solicitation

PEIF is not soliciting any votes. Neither is PEIF aware of any director who intends to oppose any action intended to be taken by PEIF.

5. Interest of Certain Persons in Matters to be Acted Upon

There is no person who has been a director, independent director, or nominee for election as director, or independent director, or officer of the Company and, to the best knowledge of the Company, no associate of a director or independent director, or officer, or nominee for election as a director or independent director, or officer of the Company, at any time since the beginning of the last calendar year, has any substantial interest in any matter to be acted upon at the Special Stockholders' Meeting.

PARTIII.

SIGNATURE PAGE

After reasonable inquiry and to the best of my knowledge and belief, I certify that the information set forth in this report is true, complete and correct. This report is signed in Makati City on 1 6 r EB 2017

*PLEASE FILL UP AND SIGN THIS PROXY FORM AND RETURN OR FAX IMMEDIATELY TO: PHILAM ASSET MANAGEMENT, INC.

17'h Floor Net Lima Building, 5th Avenue corner 26th Street, Bonifacio Global City, Taguig City Email: phi.philamasset@aia.com

Fax: (02) 5285093

STOCKHOLDER PROXY

The undersigned stockholder (the "Stockholder") of PAMI EQUITY INDEX FUND, INC. (the "Company"), hereby appoints: Eric S. Lustre, with full power of substitution and delegation, or, in case of his non-attendance, the Chairman of the Special Stockholders' Meeting of the Company, chosen in accordance with the Company's By-Laws, as the Stockholder's proxy to represent the Stockholder and vote all shares registered in the Stockholder's name in the books of the Company, at the Special Meeting of the Stockholders to be held at Premier Agency Centre, Philam Life Head Office, 15th Floor Net Lima Building, 5th

Avenue comer 26th Street, Bonifacio Global City, Taguig on March 13, 2017 at 2:00 pm, and any adjournments and postponements thereof, as fully to all intents and purposes as the stockholder might or could do if present in person, hereby ratifying and confirming any and all actions to be taken during any said meetings and adjournments thereof for the purpose of acting on the following matters:

1. Registration of Additional Shares

o For o Against o Abstain

2. Authority of SEC to Examine Bank Accounts

3. Implementation of Exemptive Relief; Minimum and Additional Investment

o For o Against D Abstain

4. Approval to amend the Dividend Policy

5. Approval of amendment of Articles of Incorporation to reflect change in principal address and of certain proposed amendments to the Fund's Registration Statement and Prospectus, as indicated in Annex "A" hereof

6. Approval to amend the Fund's Registration Statement and Prospectus to reflect items (1) through (5) above

o For D Against o Abstain

This proxy revokes and supersedes any previously executed proxy or proxies. This proxy shall be valid for a period of five (5) years from the date of its execution.

This proxy, when properly executed, will be voted in the manner as directed herein by the stockholder. If no direction is made, this proxy will be voted "For" the approval of the matter stated above and for such other matters as may properly come before the meeting, including matters which the solicitors do not know a reasonable time before the solicitation are to be presented at the meeting, and those incidental to the conduct of the meeting, in the manner described in the information statement and/or as recommended by management or the board of directors.

S igned on this ___ day of _ _ ______ in ___ ______ _

Signature of Stockholder or Stockholder's Representative over Printed Name / Portfolio Number

Annex "A"

I. Insertion of paragraphs under Introduction

The Fund is exposed to financial risk. The more important components of this financial risk are. in order of importance. credit risk. liquidity risk and market risk. More details are discussed in the "Risk Factors" section of this Prospectus (pages 9 to 10).

The SEC. pursuant to SEC Memorandum Circular No. 7, series of 2005. or the "Guidelines on the Evaluation of Foreign Investments by Mutual Fund Companies" allows mutual fund companies to invest up to 100% of its assets in foreign securities.

The Company does not plan to declare dividends. Surplus profits of the Company (if any). will be used as additional proceeds to invest in stock companies comprising the PSEi.

PEIF will be denominated in Philippine Peso. and its shares will be offered to the public based on its Net Asset Value per Share (NAVPS).AII sales shall be on a cash basis and installment sales are prohibited.

II. Change in Principal Business Address

5TH FLOOR. SALUSTIANA D. TY TOWER, 104 PASEO DE ROXAS CORNER NIEVA & PEREA STREETS.LEGASPI VILLAGE, MAKATI CITY 1226 TELEPHONE NUMBERS: (632) 867-39-12 to 18 FAX NUMBERS: (632) 813-68-13 and 18

17th FLOOR NET LIMA BUILDING, 5TH AVENUE CORNER 26TH STREET BONIFACIO GLOBAL CITY, TAGUIG 1634 TELEPHONE NUMBERS: (632) 5216300 FAX NUMBERS: (632) 5285093

Ill. Revisions to standardize all PAM/ mutual funds

Shares of the Fund may be held by any person of legal age or any duly organized and existing corporation, partnership, or any other legal entity regardless of citizenship or nationality. If the applicant is a corporation. partnership or other legal entity. copies of the articles of incorporation and by-laws, certificate of registration and the resolution of the applicant's Board of Directors authorizing the investment. all duly certified. must be submitted with the application.

The PEIF shares shall be sold at Net Asset Value (NAV) per share for the banking day, if payment is made within the daily cut-off time: otherwise. the NAV per share on the following banking day will be used for payment made after the daily cut-off time. The daily cut-off time will be 12:00 noon of a banking day. A banking day is defined as a day when commercial banks in Metro Manila are not required or authorized to close by law.

IV. Deletion of paragraphs under Minimum Purchase and Benefits to Investor

Shares sold shall be on a cash basis. Installment sales are prohibited. Minimum initial purchase is PHP5,000.00 and a minimum of PHP1 .000.00 for each additional purchase.

Professional Management and Supervision

Investing in the Fund enables access to numerous retail investor services which is normally available among institutional investors and individuals with extensive resources. The Investor has the opportunity to take part of a professionally managed portfolio of securities.

Diversification

Investors in this Fund would achieve instant diversification for a minimal investment. With this particular type of Fund, investments can be proportionately allocated among all Index stocks. As the goal of the Fund is to match the performance of the PSE Composite Index, the Investor is given an opportunity to participate in the equities market.

Liquidity

Shareholders of the Fund can any time convert his proportionate share of the Fund to cash. There is no need for the shareholder to look for a buyer. The Fund is always ready to redeem or buy its shares back provided that the shareholder submits all the needed requirements.

V. Change in Investment Restrictions

The maximum investment of the Fund in any single enterprise shall not exceed an amount equivalent to fifteen percent (15%} of the Fund's net asset value except obligations of the Philippine government or its instrumentalities; provided that in no case shall the total investment of the Fund exceed ten percent (10%) of the outstanding securities of any one investee company.

For liquidity purposes, unless otherwise prescribed by the SEC, in case of open-end companies, at least five percent (5%} of its fund shall be invested in liquid/semi-liquid assets.

Provided that. the open-end company fund shall submit a liquidity contingency plan to the Commission before it implements a decreased investment of less than ten percent (10%} in liquid/semi-liquid assets.

VI. Inclusion of Taxpayers Identification Number (TIN) requirement for applications

VII. Insertion of paragraph on Acceptance of Applications

PAMI reserves the right to reject subscriptions, or to restrict purchases by an investor, when such purchase is disruptive to the interests of the other shareholders and management of the Fund as determined by the Fund Manager. The subscription amount will be returned to the investor without interest and after deducting applicable bank charges. within five business days.

VIII. Deleted paragraphs under Plan of Operations

PEIF is capable of managing its cash requirements as the Fund is held and will continue to be held in liquid fixed income and equity securities which have a standard settlement cycle of between T+1 /trade day plus one business day} and four (4} days, respectively. Given excellent fund management. the Fund's entire portfolio could be liquidated within the said time frame.

Also, there are no known trends nor demands, commitments. events or uncertainties that will drastically affect its liquidity nor will there be a negative impact on sales from operations. Furthermore. there are no known events that can trigger direct or contingent financial obligations of the Fund. PEIF has no off-balance sheet transactions.

Operational expenses are also minimized as PEIF employs no personnel. It functions solely through its primary Fund Manager. PAMI. Also. PEIF does not own any real or personal properties (such as real estate, plant and equipment. mines, patents. etc.}. Neither does the Fund lease any property nor does it intend to acquire any real or personal properties within the next 12 months.

IX. Revisions to Determination of Offering Price

The offering price is determined at NAVPS for the banking day. if payment is made within the daily cut-off time. The NAVPS on the following banking day will be used for payment made after the daily cut-off time. The daily cut-off time shall be 12:00 noon of a banking day. A banking day is defined as a day when commercial banks in Metro Manila are not required or authorized to close by law.

X. Revisions to Description of Securities to be registered

On December 10. 2015. the Board of Directors of the Fund. by a vote of the majority of its members. resolved to increase PEif's authorized capital stock from One Million Eight Hundred Thousand Pesos (PHP1.800.000.00} to Forty One Million Three Hundred Seventy Six Thousand One Hundred Five Pesos /PHP41.376, 105.00). representing the first tranche of the increase in the authorized capital stock of the Corporation to up to Seven Billion One Million Eight Hundred Thousand /PHP 7.001,800.000.00)

On December 10, 2015. the Board of Directors of the Fund, by a vote of the majority of its members, resolved to increase PEif's authorized capital stock from Three Billion Five Hundred Seventy Nine Million Three Hundred Twenty Four Thousand Four Hundred Pesos /PhP3.579.324,400.00} divided into Thirty Five Million Seven Hundred Ninety Three Thousand Two Hundred Forty Four 135,793.244} shares with par value of One Hundred Pesos (PhP100.00) each to Six Billion One Hundred Seventy Three Million Seven Hundred Twenty Two Thousand Four Hundred Pesos (PhPS.173.722,400.00} divided into Sixty One Million Seven Hundred Thirty Seven Thousand Two Hundred Twenty Four (61,737.224} shares with par value of One Hundred Pesos

/PhP100.00}. representing the third tranche of the increase in the authorized capital stock of the Corporation to up to Ten Billion Pesos (PhP10,000,000,000.00L

XI. Revisions to reflect increase in Authorized Capital Stock

On December 10, 2015. the Board of Directors of the Fund, by a vote of the majority of its members. resolved to increase PEIF's authorized capital stock from Three Billion Five Hundred Seventy Nine Million Three Hundred Twenty Four Thousand Four Hundred Pesos /PhP3.579.324.400.00) divided into Thirty Five Million Seven Hundred Ninety Three Thousand Two Hundred Forty Four /35,793,244) shares with par value of One Hundred Pesos /PhP100.00) each to Six Billion One Hundred Seventy Three Million Seven Hundred Twenty Two Thousand Four Hundred Pesos /PhP6173,722,400.00l divided into Sixty One Million Seven Hundred Thirty Seven Thousand Two Hundred Twenty Four /61,737,224) shares with par value of One Hundred Pesos /PhP100.00), representing the third tranche of the increase in the authorized capital stock of the Corporation to up to Ten Billion Pesos /PhP10.000,000,000.00\.

XII. Revisions to Corporate Profile

The Fund's sole product is securities distributed as shares of PEIF. PAMI will directly distribute the Fund's shares. PEIF is an open-ended mutual fund offering shares to the public at NAV.

XIII. Update on Compliance with Regulations

Anti-Money Laundering Act

SEC Memorandum Circular No. 2, Series of 2015, describes Money Laundering as "the processing of the proceeds of a crime to disguise their origin. It is a process intended to mask the benefits derived from serious offenses or criminal conduct as described under the Act. so that they appear to have originated from a legitimate source." Money Laundering whether it be facilitating or assisting in such act is considered as a criminal offense.

PAMI strictly enforces its PAMI Anti-Money Laundering SOP and Guidelines, procedures and training. This is also in compliance with the laws and regulations under the Anti-Money Laundering Act.

PAMI Sales Representatives shall ascertain the identity of each client by performing their KYC /Know Your Customer\. PAMI Sales Representative shall also obtain competent evidence of their client's identity and/or proof of source of funds by requiring the submission of certain documents as stated in the Anti-Money Laundering Guidelines prior to opening an account. Any additional subscriptions /top ups should also be in compliance of the said guidelines.

PAMI reserves the right to reject any application to purchase shares of the Fund if found to be non-compliant with the foregoing.

Foreign Account Tax Compliance Act /"FATCA"\

The U.S. Foreign Account Tax Compliance Act ("FATCA") has the objective of preventing tax evasion by U.S. persons by placing certain compliance and reporting obligations on Foreign Financial Institutions /"FFls") including mutual funds such as PAMI Income Payout Fund. If the Fund is found to be non-compliant it may be subject to a 30% withholding on U.S. source income or proceeds. As such establishing and continually maintaining FATCA-compliant processes across all business functions is of critical importance to PAMI and the mutual funds it manages.

The requirements of FATCA are complex and requires FFls such as PAMI Income Payout Fund to undertake due diligence to identify U.S. customers, report U.S. customers to the U.S. Inland Revenue Services /"IRS") or the Philippines Bureau of Internal Revenue /"BIR"\ together with customers who are unable or unwilling to confirm their corresponding U.S. status /recalcitrant customers\ and in certain circumstances to withhold against or terminate accounts of recalcitrant customers. In line with this, PAMI strictly enforces its PAMI FATCA SOP and Guidelines, procedures and training.

Similarly. as an internal control. PAMI will not accept clients who are U.S. Citizens. However. PAMI will accept clients with U.S. lndicias provided that, together with the Customer Information Sheet or Subscription form. they submit the required FATCA documents.

PAMI reserves the right to reject any application to purchase shares of the Fund if found to be non-compliant with the foregoing.

XIV. Change in Legal Counsel from SyCip Salazar Hernandez and Gatmaitan ("SyCip'J to Picazo Buyco Tan Fider & Santos

XV. Change in Corporate Secretary and Assistant Corporate Secretary

XVI. Change in Transfer Agency from Deutsche Bank ("DB") to Phi/am Asset Management, Inc. ("PAMl'J

XVII. Insertion of paragraph on effectivity of Service Agreement between PEIF and PAM/

XVIII. Insertion of paragraphs on Executive Compensation

The Fund pays its directors a per diem of Php7.500 for every Board Meeting. The Fund estimates total aggregate per diems of Php150.000 for the year 2016.

There are no other arrangements between the Fund and each of the Directors. pursuant to which directors of the Company are compensated. or are to be compensated. directly or indirectly, for any services provided as a director. including any additional amounts payable for committee participation or special assignments. for the last completed fiscal year and the ensuing year. Neither are there arrangements. including consulting contracts. pursuant to which any director of the Company was compensated. or is to be compensated. directly or indirectly, since incorporation. for any service.

XIX. Updates on Sales Load, Redemption Fee and Other Fees

Updates to the Sales Load

Sales load for each investment will not be more than 3% (exclusive of VAT).

Total Relationship Amount (in Php) Sales Load Sales Load with VAT less than 100,000 3% 3.36% 100,000 - 499,999.99 2.5% 2.80% 500,000 - 999,999.99 2% 2.24% 1 M-4.99M 1.5% 1.68% 5 M-9.99M 1% 1.12% 10M & up 0.5% 0.56%

Changes to the Redemption Fee

The entry fee is 3%, aggregated of all investments of the client (exclusive of V.A.T). For exit fee, the applicable holding period is six (6) months. Redemptions made within six (6) months are subjected to an exit fee of no more than 1 % (exclusive of twelve percent V.A.T.) of the redemption proceeds.

Updates to the Management Fee

The management fee to be charged by PAMI is 1.5% per year (exclusive of V.A.T.).

Amendment on Subscription and Redemption Process for 8-Shares

For B-shares option, a client needs to open a new portfolio number to allow required tagging in the system.

The applicable holding period for option B or B-shares is five (5) years. Redemptions made before 5 years are subject to an exit fee of no more than 5% (exclusive of twelve percent VAT) of the redemption proceeds. Redemption fee is based on the following schedule:

Placement Period Exit 12% VAT on Exit Exit Fee+ 12% Less than 1 year 5.00% 0.60% 5.60% More than 1 year but less than 4.00% 0.48% 4.48% More than 2 years but less 3.00% 0.36% 3.36% More than 3 years but less 2.00% 0.24% 2.24% More than 4 years but less 1.00% 0.1 2% 1.12%