Trading Policies

Since it opened its doors, ProFunds has — through an accommodating exchange policy and remarkable diversity in fund offerings — provided investment opportunities, flexibility and a level playing field for all shareholders.

Recently, the Securities and Exchange Commission and state regulators launched parallel investigations into allegations of improper or illegal mutual fund trading practices.

No allegations have been directed at ProFunds.

The allegations concerned three principal issues: frequent trading in funds by select shareholders in contravention of policies stated in fund prospectuses; the use of arbitrage trading strategies particularly in funds investing in securities trading overseas; and illegal trading in funds after U.S. markets close.

Frequent Trading

Since its inception, ProFunds' policy has been to permit exchanges among ProFunds with no upper limit on size or frequency and no transaction fees. These flexible exchange policies apply to all shareholders, not to only a select few, and are fully disclosed in the prospectus.

ProFunds' indexed mutual fund portfolios were designed to accommodate frequent trading and large movements of assets in and out of the ProFunds. ProFunds seeks to invest cash flows on a daily basis in order to remain fully invested and minimize the impact of frequent trading.

Stale Pricing

At ProFunds, before we introduced funds investing in companies based outside the U.S., we anticipated the problem of stale pricing and the potential for arbitrage. ProFunds addressed this issue head on by pricing these funds based on instruments that trade in U.S. markets at the time U.S. markets close.

Late Trading

At ProFunds, we do not permit late trading.

Our Commitment

ProFunds' trading and disclosure practices reflect our commitment of fairness to ProFunds shareholders. We greatly value the trust our shareholders have placed in us and will continue to operate in a manner that justifies that trust. We are following the current regulatory situation closely and reviewing our own procedures to ensure that we are in compliance with any new regulatory standards.

This report is intended for general information and should not be used to solicit prospective investors. For more complete information please review the prospectus.