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D. Investment Advisors and Investment Managers. An Investment Entity established in Portugal that is a

Financial Institution solely because it (1) renders investment advice to, and acts on behalf of, or (2) manages

portfolios for, and acts on behalf of, a customer for the purposes of investing, managing, or administering funds

deposited in the name of the customer with a Financial Institution other than a Nonparticipating Financial

Institution.

E. Collective Investment Vehicle. An Investment Entity established in Portugal that is regulated as a collective

investment vehicle, provided that all of the interests in the collective investment vehicle (including debt interests

in excess of $50,000) are held by or through one or more exempt beneficial owners, Active NFFEs described in

subparagraph B(4) of section VI of Annex I, U.S. Persons that are not Specified U.S. Persons, or Financial

Institutions that are not Nonparticipating Financial Institutions.

F. Special Rules. The following rules apply to an Investment Entity:

1. With respect to interests in an Investment Entity that is a collective investment vehicle described in

paragraph E of this section, the reporting obligations of any Investment Entity (other than a Financial Institution

through which interests in the collective investment vehicle are held) shall be deemed fulfilled.

2. With respect to interests in:

a) An Investment Entity established in a Partner Jurisdiction that is regulated as a collective investment

vehicle, all of the interests in which (including debt interests in excess of $50,000) are held by or through one or

more exempt beneficial owners, Active NFFEs described in subparagraph B(4) of section VI of Annex I, U.S.

Persons that are not Specified U.S. Persons, or Financial Institutions that are not Nonparticipating Financial

Institutions; or

b) An Investment Entity that is a qualified collective investment vehicle under relevant U.S. Treasury

Regulations;

the reporting obligations of any Investment Entity that is a Portuguese Financial Institution (other than a

Financial Institution through which interests in the collective investment vehicle are held) shall be deemed fulfilled.

3. With respect to interests in an Investment Entity established in Portugal that is not described in paragraph

E or subparagraph F(2) of this section, consistent with paragraph 3 of Article 5 of the Agreement, the reporting

obligations of all other Investment Entities with respect to such interests shall be deemed fulfilled if the information

required to be reported by the first-mentioned Investment Entity pursuant to the Agreement with respect to such

interests is reported by such Investment Entity or another person.

4. An Investment Entity established in Portugal that is regulated as a collective investment vehicle shall not

fail to qualify under paragraph E or subparagraph F(2) of this section, or otherwise as a deemed-compliant FFI,

solely because the collective investment vehicle has issued physical shares in bearer form, provided that:

a) The collective investment vehicle has not issued, and does not issue, any physical shares in bearer form

after December 31, 2012;

b) The collective investment vehicle retires all such shares upon surrender;

c) The collective investment vehicle (or a Reporting Portuguese Financial Institution) performs the due

diligence procedures set forth in Annex I and reports any information required to be reported with respect to any

such shares when such shares are presented for redemption or other payment; and

d) The collective investment vehicle has in place policies and procedures to ensure that such shares are

redeemed or immobilized as soon as possible and in any event prior to January 1, 2017.

V. Accounts Excluded from Financial Accounts. The following accounts are excluded from the definition of

Financial Accounts and therefore shall not be treated as U.S. Reportable Accounts.

A. Certain Savings Accounts.

1. Retirement and Pension Account. A retirement or pension account maintained in Portugal that satisfies

the following requirements under the laws of Portugal.