Manager Compliance Questionnare
March 31, 2010
   
 
           
1. Have there been any changes in your organization? Have you undergone any change in ownership or control?
There have been no changes in ownership or control of Mutual of America Capital Management Corporation ("Capital Management"), as of March 31, 2010.  
2. Have there been any changes in your investment philosophy?
There have been no changes to the Mid-Cap Index investment philosophy, as of March 31, 2010.
3. Have there been any changes in your staff of investment professionals?
There have been no changes to Capital Management's staff of investment professionals, as of March 31, 2010. 
4. Have you lost a substantial amount of business (amount of percentage of assets under management)?
No business has been lost during the quarter ending March 31, 2010.
5.  Have you gained a substantial amount of business (amount of percentage of assets under management)?
No additional business has been gained during the quarter ending March 31, 2010.
6.  Have there been any new investigations begun by any state or federal government or their agencies, or any charges filed, with regard to any division or unit of your company, and in particular anyone who directly or indirectly performs services for this client? Please provide details (if there is any doubt, please err on the side of providing too much information).
No state, federal government or government agencies have begun any investigations, nor have filed any charges with regard to Capital Management or our parent, Mutual of America Life Insurance Company.  
7. For managers, with fixed income portfolios that we monitor,  are you currently invested in commercial mortgage backed securities (CMBS)? (If yes, please give % of fixed portfolio)
N/A.
8.  Are you invested in any unhedged and/or levereged derivatives?
No.  We do not invest in derivatives.  
9.  What percentage of equity is international?                                                                                                                                                                           The manager must immediately notify the Board and the Consultant when the international exposure reaches ten percent (10%). An explanation will be needed as to why the manager is changing their discipline. (This does not apply to managers that are 100% international equity and to those that have been previously given permission by the board and the consultant) 
0%.
10. Are you invested in any companies on the SBA's website? (Please review list of scrutinized companies on the following website: http://www.sbafla.com/fsb/ProtectinginvestmentsAct/tabid/402/Default.aspx
No.  We are not invested in any scrutinized companies listed on the SBA.
11 Name of person completing this form (please include company name)?
Chris Mottershead, 2nd VP, Marketing, Mutual of America Capital Management Corporation
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