Investor Center Seminars: Provide Select Fund Companies the Opportunity to Make Marketing

Fidelity Investments FundsNetwork

Procedures for FundsNetwork Regulatory and Marketing Mailings through ADP

Revised July 2006 Overview of Fidelity/ADP Fulfillment – Retail Customers

At Fidelity we believe in taking every opportunity to educate and inform our customers about mutual fund investing and the products and services available to help them meet their goals. As a FundsNetwork No Transaction Fee participant we encourage you to communicate to your investors here at Fidelity.

Our goal is that customers will receive the same communication and attention as those that invest directly with your firm. Below you will find procedures to perform direct mail activities to your shareholders.

ADP performs all regulatory and non-regulatory mailings for participating FundsNetwork companies, if you have any questions about working with ADP please call your Fidelity Relationship Manager.

Two Types of Mailings

1. Non-Regulatory Mailings: These are marketing mailings which can be “passed-through” to Fidelity retail customers who hold mutual fund positions in your funds. All marketing material must be filed with the NASD and a Marketing Mailing Approval Form must be completed prior to distribution to ADP. ADP will invoice your firm directly for mailing costs.

 Quarterly Newsletters  New Fund Announcements  Marketing Insertions

2. Regulatory Mailings: These are required mailings and are not subject to approval by Fidelity. ADP will invoice your firm directly for mailing costs.

 Annual Report  Prospectus  Semi-Annual Reports  Proxies  Supplements/Stickers

2 Non-Regulatory Mailings

Mailing procedures for NTF Fund Partners: Newsletters New Fund Announcements, Marketing Insertions: Direct Mail Campaigns

As a FundsNetwork NTF participant you may mail to your retail shareholders during the calendar year. These mailings can be stand-alone or included with your regular Annual and Semi-Annual Report mailings through ADP.

For each type of mailing follow the guidelines below.

Please contact FundsNetwork’s Peter Mahoney (401) 292-4162 regarding marketing pass-through mailings.

1. Quantity Estimates: Please review your “Brokerage Total Positions by Cusip” report for print quantity estimates. This monthly report is distributed via the FundsNetwork.com web site. If you don’t have a password to enter the web site, please contact Steve Paltsios at 617-392-8646 or [email protected].

Also, contact the ADP FundsNetwork Team to confirm recent household figures.

2. Production Schedule: Contact your ADP Team to set-up the mailing program. ADP will need your schedule for delivery to customers. ADP is only permitted to pass retail marketing mailings through to your Fidelity Retail customers. Marketing mailings to Financial Advisors must be coordinated through Fidelity’s IBG group.

3. Fidelity Retail Version: Create one version of your insert that is applicable to “Retail” customers (see standard Fidelity Standard Language section). Institutional customers will be suppressed from the marketing mailing.

4. NASD Approvals: All marketing material must be filed with the NASD. If the marketing piece has previously been filed in its original format, not including the Fidelity logo or phone number, a past approval letter will suffice provided it was issued within the past 12 months.

5. Fidelity Approvals: Please fax inserts to Peter Mahoney at Fidelity for approval before printing. Approval will be provided within 4 business days; because of your companies NASD filling, Fidelity legal review is not required. The Retail fax number is (401) 292-3455. A signed Marketing Approval Form must be provided to ADP before any retail marketing mailing is sent. Once printed please send 2 samples of actual mailings to:

Peter Mahoney 100 Salem St. OR3N1 Smithfield, RI 02903

3 6. ADP Delivery: Please mail final printed materials/inserts to:

ADP Proxy Services 51 Mercedes Way Edgewood, New York 11717 ATTN: Mutual Funds Department

7. Self Mailers: If you are using self-mailers for any of your mailings, you can contact your ADP Team for the appropriate printing process. Indicia should not be printed on documents. ADP will apply mailing information directly to the self- mailer in lieu of envelopes.

8. Envelopes: ADP provides envelopes for mailings. The company has available most standard size envelopes both with and without windows. These envelopes are laser printed with the Fidelity return address and a message “This information is being forwarded to you at the request of XXX Funds for your account at National Financial Services Corp.”. For larger mailers a buckslip with the above information is included in the envelope.

9. Class of Mail: Please identify the class of mail to ADP.

Standard Fidelity Direct Mail/Marketing Language

The following copy guidelines should be followed:

· Fund Partner phone number, fax number, address, and web address should not be printed on any of the mailing components.

· Fidelity’s FundsNetwork Phone number (1-800-544-8888) should be prominently displayed in the call to action. Example 1: To invest, call 1-800-544-8888 to speak with a Fidelity Representative or use the web at www.Fidelity.com. Example 2: To invest, call Fidelity FundsNetwork at 1-800-544-8888 or use the web at www.Fidelity.com. Example 3: For a prospectus, call Fidelity FundsNetwork at 1-800-544-8888.

 The Fidelity Brokerage relationship with the customer must be clearly recognized in a footnote. FundsNetwork is a service of Fidelity Brokerage Services LLC (FBS), Member NYSE, SIPC. FBS may receive remuneration for providing certain recordkeeping and shareholder services to the fund family. FBS does not recommend or endorse any particular mutual fund.

· The funds and/or topics that are described in the mailings should be relevant to FundsNetwork (ex. funds that are not available through FundsNetwork should not be featured in any of the communication vehicles).

4 Regulatory Mailings to Fidelity Customers

There are two areas of ADP that handle prospectus mailings, depending on the type of customer and the purpose of the prospectus, as follows:

(1) Regulatory/Mandatory Mailings*

Regulatory mailings are the responsibility of each fund partner. ADP will handle all Annual Reports, Proxy and Prospectus mailings for Fidelity customers who hold third party funds in Fidelity Brokerage accounts. *Please contact ADP for print quantity estimates.

Fidelity FundsNetwork ADP Account Manager Contact

Victor Tagliareni 631-254-7636 [email protected]

(2) Pre-Sale and Confirming Prospectus Mailing Procedures

Fidelity Investments is primarily responsible for pre-sale and confirming prospectuses for daily buys. ADP will contact fund partners and request an inventory of prospectuses that will be used in fulfilling Pre-Sale and Confirming prospectus requirements.

Contact: Naadia Burrows (631) 254-7112 Initial quantities are generally 250-500. Only naked prospectuses should be mailed to ADP for confirming and pre-sale orders unless otherwise agreed.

ADP Mailing/Shipping Address :

ADP Prospectus Plus 55 Mercedes Way Edgewood, NY 11717

5 MARKETING MAILING APPROVAL FORM

Attach Marketing Materials and Fax to: Peter Mahoney Fax: 401-292-3455 FundsNetwork Marketing Fidelity Investments 100 Salem St, OR3N1 Smithfield, RI 02903

Requested by: Name Fund Company Phone

Fax # EMAIL address

Type of Marketing Piece: (i.e., Newsletter, Postcard)

Target Mail Date: ______Total Quantity: ______

Documentation Attached: Yes No . NASD transmittal letter (please fax to Peter Mahoney when avail.)

. NASD comment letter (please fax to Peter Mahoney when avail.)

*If yes to comment letter, please indicate date documentation will be sent to Fidelity Material submitted will be reviewed within 4 business day of receipt.

Fidelity Investments Sign-Off The above Fund Company has provided a NASD Transmittal Letter and is authorized by Fidelity Investments to mail to Retail customers only the attached marketing material.

Signed: Date:

Print Name:

ADP Sign-Off ADP has made best efforts to exclude from this marketing mailing correspondent, advisor customers of Fidelity Investments as outlined by Account Type Code Definition.

Signed: Date:

Print Name: