Victory Pioneer ILS Interval Fund

NAV per share fell 13.1% from $9.93 to $8.63 (2019-04-30).
NAV per share fell 13.1% from $9.93 to $8.63 (2019-04-30). (Rule B12: NAV per share drop, severe: >= 5% decline month over month; Urgent.)

NAV per share fell 8.1% from $10.43 to $9.59 (2017-10-31).
NAV per share fell 8.1% from $10.43 to $9.59 (2017-10-31). (Rule B12: NAV per share drop, severe: >= 5% decline month over month; Urgent.)

NAV per share fell 6.0% from $11.09 to $10.43 (2017-04-30).
NAV per share fell 6.0% from $11.09 to $10.43 (2017-04-30). (Rule B12: NAV per share drop, severe: >= 5% decline month over month; Urgent.)

New share sales fell 100% versus the same period last year (208,600 -> 0.00, period ended 2025-04-30).
New share sales fell 100% versus the same period last year (208,600 -> 0.00, period ended 2025-04-30). (Rule C13: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year; Notify.)

New share sales fell 38% versus the same period last year (99,985 -> 137,590, period ended 2024-10-31).
New share sales fell 38% versus the same period last year (99,985 -> 137,590, period ended 2024-10-31). (Rule C13: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year; Notify.)

New share sales fell 165% versus the same period last year (107,590 -> 285,000, period ended 2024-07-31).
New share sales fell 165% versus the same period last year (107,590 -> 285,000, period ended 2024-07-31). (Rule C13: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year; Notify.)

New share sales fell 77% versus the same period last year (208,224 -> 48,000, period ended 2024-01-31).
New share sales fell 77% versus the same period last year (208,224 -> 48,000, period ended 2024-01-31). (Rule C13: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year; Notify.)

Net outflow of 6.1% of NAV in the period ended 2023-08-31.
Net outflow of 6.1% of NAV in the period ended 2023-08-31. (Rule B6: Single-period outflow at gate scale: net outflow >= 5% of NAV in one period; Notify.)

New share sales fell 49% versus the same period last year (72,187 -> 107,590, period ended 2023-07-31).
New share sales fell 49% versus the same period last year (72,187 -> 107,590, period ended 2023-07-31). (Rule C13: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year; Notify.)

Net outflow of 6.6% of NAV in the period ended 2023-05-31.
Net outflow of 6.6% of NAV in the period ended 2023-05-31. (Rule B6: Single-period outflow at gate scale: net outflow >= 5% of NAV in one period; Notify.)

New share sales fell 629% versus the same period last year (84,200 -> 614,013, period ended 2023-04-30).
New share sales fell 629% versus the same period last year (84,200 -> 614,013, period ended 2023-04-30). (Rule C13: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year; Notify.)

Net outflow of 11.5% of NAV in the period ended 2023-03-31.
Net outflow of 11.5% of NAV in the period ended 2023-03-31. (Rule B6: Single-period outflow at gate scale: net outflow >= 5% of NAV in one period; Notify.)

Net outflow of 9.5% of NAV in the period ended 2022-12-31.
Net outflow of 9.5% of NAV in the period ended 2022-12-31. (Rule B6: Single-period outflow at gate scale: net outflow >= 5% of NAV in one period; Notify.)

NAV per share fell 3.2% from $8.37 to $8.10 (2022-10-31).
NAV per share fell 3.2% from $8.37 to $8.10 (2022-10-31). (Rule B11: NAV per share drop >= 2% decline month over month; Notify.)

New share sales fell 64% versus the same period last year (202,152 -> 72,187, period ended 2022-07-31).
New share sales fell 64% versus the same period last year (202,152 -> 72,187, period ended 2022-07-31). (Rule C13: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year; Notify.)

Net outflow of 6.2% of NAV in the period ended 2022-06-30.
Net outflow of 6.2% of NAV in the period ended 2022-06-30. (Rule B6: Single-period outflow at gate scale: net outflow >= 5% of NAV in one period; Notify.)

NAV per share ($8.37) is 2.2% below its trailing four-observation average ($8.56) as of 2022-04-30.
NAV per share ($8.37) is 2.2% below its trailing four-observation average ($8.56) as of 2022-04-30. (Rule C23: Sustained NAV decline: NAV per share >= 2% below its trailing 4-observation average; Notify.)

Net outflow of 9.6% of NAV in the period ended 2021-12-31.
Net outflow of 9.6% of NAV in the period ended 2021-12-31. (Rule B6: Single-period outflow at gate scale: net outflow >= 5% of NAV in one period; Notify.)

New share sales fell 103% versus the same period last year (35,139 -> 71,436, period ended 2021-10-31).
New share sales fell 103% versus the same period last year (35,139 -> 71,436, period ended 2021-10-31). (Rule C13: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year; Notify.)

New share sales fell 30% versus the same period last year (156,024 -> 202,152, period ended 2021-07-31).
New share sales fell 30% versus the same period last year (156,024 -> 202,152, period ended 2021-07-31). (Rule C13: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year; Notify.)

Net outflow of 5.9% of NAV in the period ended 2021-06-30.
Net outflow of 5.9% of NAV in the period ended 2021-06-30. (Rule B6: Single-period outflow at gate scale: net outflow >= 5% of NAV in one period; Notify.)

NAV per share fell 3.6% from $8.88 to $8.56 (2021-04-30).
NAV per share fell 3.6% from $8.88 to $8.56 (2021-04-30). (Rule B11: NAV per share drop >= 2% decline month over month; Notify.)

New share sales fell 23% versus the same period last year (28,500 -> 35,139, period ended 2020-10-31).
New share sales fell 23% versus the same period last year (28,500 -> 35,139, period ended 2020-10-31). (Rule C13: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year; Notify.)

Gross share sales: Inflow stall (fundraising flywheel): gross sales down >= 50% vs same period prior year [Notify, 2020-07-31]
Gross share sales triggered rule C13 for the period ending 2020-07-31.

Net outflow of 7.2% of NAV in the period ended 2020-06-30.
Net outflow of 7.2% of NAV in the period ended 2020-06-30. (Rule B6: Single-period outflow at gate scale: net outflow >= 5% of NAV in one period; Notify.)

NAV per share fell 3.8% from $8.79 to $8.46 (2020-04-30).
NAV per share fell 3.8% from $8.79 to $8.46 (2020-04-30). (Rule B11: NAV per share drop >= 2% decline month over month; Notify.)

NAV per share ($8.46) is 5.5% below its trailing four-observation average ($8.95) as of 2020-04-30.
NAV per share ($8.46) is 5.5% below its trailing four-observation average ($8.95) as of 2020-04-30. (Rule C23: Sustained NAV decline: NAV per share >= 2% below its trailing 4-observation average; Notify.)

Net outflow of 7.2% of NAV in the period ended 2020-03-31.
Net outflow of 7.2% of NAV in the period ended 2020-03-31. (Rule B6: Single-period outflow at gate scale: net outflow >= 5% of NAV in one period; Notify.)

Redemptions accelerated to $59.6M from $15.3M the prior period (period ended 2019-12-31).
Redemptions accelerated to $59.6M from $15.3M the prior period (period ended 2019-12-31). (Rule C14: Redemption acceleration: repurchase/redemption dollars up >= 25%; Notify.)

NAV per share ($8.79) is 4.9% below its trailing four-observation average ($9.24) as of 2019-10-31.
NAV per share ($8.79) is 4.9% below its trailing four-observation average ($9.24) as of 2019-10-31. (Rule C23: Sustained NAV decline: NAV per share >= 2% below its trailing 4-observation average; Notify.)

NAV per share ($8.63) is 8.6% below its trailing four-observation average ($9.44) as of 2019-04-30.
NAV per share ($8.63) is 8.6% below its trailing four-observation average ($9.44) as of 2019-04-30. (Rule C23: Sustained NAV decline: NAV per share >= 2% below its trailing 4-observation average; Notify.)

NAV per share ($9.93) is -0.4% below its trailing four-observation average ($9.89) as of 2018-10-31.
NAV per share ($9.93) is -0.4% below its trailing four-observation average ($9.89) as of 2018-10-31. (Rule C23: Sustained NAV decline: NAV per share >= 2% below its trailing 4-observation average; Notify.)

NAV per share ($9.61) is 5.6% below its trailing four-observation average ($10.18) as of 2018-04-30.
NAV per share ($9.61) is 5.6% below its trailing four-observation average ($10.18) as of 2018-04-30. (Rule C23: Sustained NAV decline: NAV per share >= 2% below its trailing 4-observation average; Notify.)

Canonical class: not designated · basis: no qualifying monthly chain · qualifying history: 0 months.

1y: Pending; 3y: Pending; 5y: Pending Manager-published observations remain distinct from SEC-filed facts and publish only after source-terms, class, date, and reconciliation gates pass.

Management fees payable under the Fund's Investment Advisory Agreement with the Adviser are calculated daily and paid monthly at the annual rate of 1.75% of the Fund's average daily net assets up to $1 billion, and 1.70% of the Fund's average daily net assets over $1 billion. For the year ended October 31, 2025, the effective management fee was equivalent to 1.75% of the Fund's average daily net assets (the Fund's net assets have not yet crossed the $1 billion tier threshold) -- not a documented skip, since the filing itself states this current effective rate. Effective April 1, 2025 the Adviser has separately contractually agreed to waive fees/reimburse expenses so total annual fund operating expenses do not exceed 1.93%, through April 1, 2028.