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ARS Redemption Policy

Generally, redemptions of auction rate securities (ARS) are allocated to broker-dealers by Depository Trust Corporation and broker-dealers are notified of the number of units to be redeemed from clients of the broker-dealer. William Blair & Company has adopted the following allocation policy to promote a fair and objective allocation process for partial redemptions of ARS among its clients.

For ARS issues where William Blair & Company is allocated a number of units that is equal to or exceeds the number of clients who own units in that particular issue being redeemed , William Blair & Company uses a three-step process as described below:

1. The firm initially allocates one unit to each client.
2. From the remaining number of units available for redemption, the firm allocates whole units on a pro rata basis among all client accounts that were not completely redeemed through step 1.
3. If there are units available after the application of step 2 (as a result of rounding), such units will be assigned on a random basis (automated lottery assignment) to any remaining accounts that were not completely redeemed through step 2.

For ARS issues where the number of units eligible for redemption is less than the number of clients who own units in that particular issue, the firm performs steps 2 and 3 above. ARS issues held in William Blair & Company employee accounts are not eligible for redemption until all client positions in that issue are redeemed.