FIJEX / Frost Family of Funds - Frost Total Return Bond Fund Institutional Class - Depositi SEC, Relazione annuale, dichiarazione di delega

2

January 23, 2023 VIA EDGAR AND EMAIL U.S. Securities and Exchange Commission Division of Investment Management Office of Disclosure and Review 100 F Street, NE Washington, DC 20549 Attention: Christina Fettig Re: Frost Family of Funds (File No. 811-23410) Dear Ms. Fettig: This letter responds to comments you provided to Eric Griffith, Senior Director at SEI Investments Global Funds Services (“SEI”

FROST GROWTH EQUITY FUND OCTOBER 31, 2022 (UNAUDITED)

FROST GROWTH EQUITY FUND OCTOBER 31, 2022 (UNAUDITED) Description Shares Value COMMON STOCK§ — 96.

FROST GROWTH EQUITY FUND OCTOBER 31, 2022 (UNAUDITED)

HTML FROST GROWTH EQUITY FUND OCTOBER 31, 2022 (UNAUDITED) Description Shares Value COMMON STOCK§ — 96.

FROST GROWTH EQUITY FUND OCTOBER 31, 2022 (UNAUDITED)

NPORT-EX 2 d409243d8k.htm SCHEDULE F FROST GROWTH EQUITY FUND OCTOBER 31, 2022 (UNAUDITED) Description Shares Value COMMON STOCK§ — 96.3% Communication Services — 7.1% Alphabet, Cl A * 105,080 $ 9,931,111 Alphabet, Cl C * 105,400 9,977,164 Match Group * 2,000 86,400 Meta Platforms, Cl A * 9,690 902,720 20,897,395 Consumer Discretionary — 19.1% Airbnb, Cl A * 12,500 1,336,375 Amazon.com * 217,420 2

FROST GROWTH EQUITY FUND OCTOBER 31, 2022 (UNAUDITED)

NPORT-EX 2 d409243d8k.htm SCHEDULE F FROST GROWTH EQUITY FUND OCTOBER 31, 2022 (UNAUDITED) Description Shares Value COMMON STOCK§ — 96.3% Communication Services — 7.1% Alphabet, Cl A * 105,080 $ 9,931,111 Alphabet, Cl C * 105,400 9,977,164 Match Group * 2,000 86,400 Meta Platforms, Cl A * 9,690 902,720 20,897,395 Consumer Discretionary — 19.1% Airbnb, Cl A * 12,500 1,336,375 Amazon.com * 217,420 2

FROST GROWTH EQUITY FUND OCTOBER 31, 2022 (UNAUDITED)

HTML FROST GROWTH EQUITY FUND OCTOBER 31, 2022 (UNAUDITED) Description Shares Value COMMON STOCK§ — 96.

COMMON STOCK§ — 97.1%

Description Shares Value COMMON STOCK§ — 97.1% Communication Services — 11.2% Alphabet, Cl C * 6,045 $ 13,899,450 Alphabet, Cl A * 6,029 13,759,324 Match Group * 15,000 1,187,250 Meta Platforms, Cl A * 36,690 7,355,244 Netflix * 9,750 1,856,010 Snap, Cl A * 34,500 981,870 39,039,148 Consumer Discretionary — 19.7% Airbnb, Cl A * 15,000 2,298,150 Amazon.com * 10,871 27,021,284 Booking Holdings * 2,0

COMMON STOCK§ — 97.1%

Description Shares Value COMMON STOCK§ — 97.1% Communication Services — 11.2% Alphabet, Cl C * 6,045 $ 13,899,450 Alphabet, Cl A * 6,029 13,759,324 Match Group * 15,000 1,187,250 Meta Platforms, Cl A * 36,690 7,355,244 Netflix * 9,750 1,856,010 Snap, Cl A * 34,500 981,870 39,039,148 Consumer Discretionary — 19.7% Airbnb, Cl A * 15,000 2,298,150 Amazon.com * 10,871 27,021,284 Booking Holdings * 2,0

COMMON STOCK§ — 97.1%

Description Shares Value COMMON STOCK§ — 97.1% Communication Services — 11.2% Alphabet, Cl C * 6,045 $ 13,899,450 Alphabet, Cl A * 6,029 13,759,324 Match Group * 15,000 1,187,250 Meta Platforms, Cl A * 36,690 7,355,244 Netflix * 9,750 1,856,010 Snap, Cl A * 34,500 981,870 39,039,148 Consumer Discretionary — 19.7% Airbnb, Cl A * 15,000 2,298,150 Amazon.com * 10,871 27,021,284 Booking Holdings * 2,0

COMMON STOCK§ — 97.1%

Description Shares Value COMMON STOCK§ — 97.1% Communication Services — 11.2% Alphabet, Cl C * 6,045 $ 13,899,450 Alphabet, Cl A * 6,029 13,759,324 Match Group * 15,000 1,187,250 Meta Platforms, Cl A * 36,690 7,355,244 Netflix * 9,750 1,856,010 Snap, Cl A * 34,500 981,870 39,039,148 Consumer Discretionary — 19.7% Airbnb, Cl A * 15,000 2,298,150 Amazon.com * 10,871 27,021,284 Booking Holdings * 2,0

COMMON STOCK§ — 97.1%

Description Shares Value COMMON STOCK§ — 97.1% Communication Services — 11.2% Alphabet, Cl C * 6,045 $ 13,899,450 Alphabet, Cl A * 6,029 13,759,324 Match Group * 15,000 1,187,250 Meta Platforms, Cl A * 36,690 7,355,244 Netflix * 9,750 1,856,010 Snap, Cl A * 34,500 981,870 39,039,148 Consumer Discretionary — 19.7% Airbnb, Cl A * 15,000 2,298,150 Amazon.com * 10,871 27,021,284 Booking Holdings * 2,0

1 FROST FAMILY OF FUNDS FROST FUNDS | OCTOBER 31, 2021 (UNAUDITED)

FROST FAMILY OF FUNDS FROST FUNDS | OCTOBER 31, 2021 (UNAUDITED) FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS Description Shares Value COMMON STOCK§ — 100.

1 FROST FAMILY OF FUNDS FROST FUNDS | OCTOBER 31, 2021 (UNAUDITED)

FROST FAMILY OF FUNDS FROST FUNDS | OCTOBER 31, 2021 (UNAUDITED) FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS Description Shares Value COMMON STOCK§ — 100.

1 FROST FAMILY OF FUNDS FROST FUNDS | OCTOBER 31, 2021 (UNAUDITED)

FROST FAMILY OF FUNDS FROST FUNDS | OCTOBER 31, 2021 (UNAUDITED) FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS Description Shares Value COMMON STOCK§ — 100.

1 FROST FAMILY OF FUNDS FROST FUNDS | OCTOBER 31, 2021 (UNAUDITED)

FROST FAMILY OF FUNDS FROST FUNDS | OCTOBER 31, 2021 (UNAUDITED) FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS Description Shares Value COMMON STOCK§ — 100.

1 FROST FAMILY OF FUNDS FROST FUNDS | OCTOBER 31, 2021 (UNAUDITED)

FROST FAMILY OF FUNDS FROST FUNDS | OCTOBER 31, 2021 (UNAUDITED) FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS Description Shares Value COMMON STOCK§ — 100.

COMMON STOCK§ — 99.2%

FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS April 30, 2021 (Unaudited) Description Shares Value COMMON STOCK§ — 99.

COMMON STOCK§ — 99.2%

FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS April 30, 2021 (Unaudited) Description Shares Value COMMON STOCK§ — 99.

COMMON STOCK§ — 99.2%

FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS April 30, 2021 (Unaudited) Description Shares Value COMMON STOCK§ — 99.

COMMON STOCK§ — 99.2%

FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS April 30, 2021 (Unaudited) Description Shares Value COMMON STOCK§ — 99.

COMMON STOCK§ — 99.2%

FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS April 30, 2021 (Unaudited) Description Shares Value COMMON STOCK§ — 99.

* * * * * * * * * * * *

Lauren A. Engel Associate +1.215.963.5503 [email protected] April 9, 2021 FILED AS EDGAR CORRESPONDENCE Alison White, Esq. U.S. Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Re: Frost Family of Funds (File Nos. 333-229001 and 811-23410) Dear Ms. White: On behalf of our client, Frost Family of Funds (the ?Trust?), this letter responds to the comments you prov

-

DEF 14A 1 fp0064089def14a.htm UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A (Rule 14a-101) INFORMATION REQUIRED IN A PROXY STATEMENT SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934, as amended Filed by the Registrant [X] Filed by a Party other than the Registrant [ ] Check the appropriate box: [ ] Prel

March 24, 2021

March 24, 2021 VIA EDGAR Securities and Exchange Commission 100 F Street, NE Washington, D.

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A (Rule 14a-101) INFORMATION REQUIRED IN A PROXY STATEMENT SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934, a

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 SCHEDULE 14A (Rule 14a-101) INFORMATION REQUIRED IN A PROXY STATEMENT SCHEDULE 14A INFORMATION Proxy Statement Pursuant to Section 14(a) of the Securities Exchange Act of 1934, as amended Filed by the Registrant [X] Filed by a Party other than the Registrant [ ] Check the appropriate box: [X] Preliminary Proxy Statement [ ] Co

COMMON STOCK§ — 99.3%

FOR VALIDATION PURPOSES ONLY - [93762.TX] FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS OCTOBER 31, 2020 (Unaudited) Description Shares Value COMMON STOCK§ — 99.3% Communication Services — 12.8% Alphabet, Cl A * 7,254 $ 11,723,262 Alphabet, Cl C * 7,470 12,108,945 Electronic Arts * 33,000 3,954,390 Facebook, Cl A * 56,190 14,784,151 Netflix * 15,000 7,136,100 49,706,848 Co

COMMON STOCK§ — 99.3%

FOR VALIDATION PURPOSES ONLY - [93762.TX] FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS OCTOBER 31, 2020 (Unaudited) Description Shares Value COMMON STOCK§ — 99.3% Communication Services — 12.8% Alphabet, Cl A * 7,254 $ 11,723,262 Alphabet, Cl C * 7,470 12,108,945 Electronic Arts * 33,000 3,954,390 Facebook, Cl A * 56,190 14,784,151 Netflix * 15,000 7,136,100 49,706,848 Co

COMMON STOCK§ — 99.3%

FOR VALIDATION PURPOSES ONLY - [93762.TX] FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS OCTOBER 31, 2020 (Unaudited) Description Shares Value COMMON STOCK§ — 99.3% Communication Services — 12.8% Alphabet, Cl A * 7,254 $ 11,723,262 Alphabet, Cl C * 7,470 12,108,945 Electronic Arts * 33,000 3,954,390 Facebook, Cl A * 56,190 14,784,151 Netflix * 15,000 7,136,100 49,706,848 Co

COMMON STOCK§ — 99.3%

FOR VALIDATION PURPOSES ONLY - [93762.TX] FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS OCTOBER 31, 2020 (Unaudited) Description Shares Value COMMON STOCK§ — 99.3% Communication Services — 12.8% Alphabet, Cl A * 7,254 $ 11,723,262 Alphabet, Cl C * 7,470 12,108,945 Electronic Arts * 33,000 3,954,390 Facebook, Cl A * 56,190 14,784,151 Netflix * 15,000 7,136,100 49,706,848 Co

COMMON STOCK§ — 99.3%

FOR VALIDATION PURPOSES ONLY - [93762.TX] FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS OCTOBER 31, 2020 (Unaudited) Description Shares Value COMMON STOCK§ — 99.3% Communication Services — 12.8% Alphabet, Cl A * 7,254 $ 11,723,262 Alphabet, Cl C * 7,470 12,108,945 Electronic Arts * 33,000 3,954,390 Facebook, Cl A * 56,190 14,784,151 Netflix * 15,000 7,136,100 49,706,848 Co

COMMON STOCK§ — 99.3%

FOR VALIDATION PURPOSES ONLY - [93762.TX] FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS OCTOBER 31, 2020 (Unaudited) Description Shares Value COMMON STOCK§ — 99.3% Communication Services — 12.8% Alphabet, Cl A * 7,254 $ 11,723,262 Alphabet, Cl C * 7,470 12,108,945 Electronic Arts * 33,000 3,954,390 Facebook, Cl A * 56,190 14,784,151 Netflix * 15,000 7,136,100 49,706,848 Co

August 7, 2020

August 7, 2020 VIA EDGAR AND EMAIL U.S. Securities and Exchange Commission Division of Investment Management Office of Disclosure and Review 100 F Street, NE Washington, DC 20549 Attention: Mr. David Manion Re: Frost Family of Funds (File No. 811-23410) Mr. Manion: This letter responds to comments given by you to Brian Galm, Director of Fund Administration at SEI Investments Global Funds Services

August 7, 2020

August 7, 2020 VIA EDGAR AND EMAIL U.S. Securities and Exchange Commission Division of Investment Management Office of Disclosure and Review 100 F Street, NE Washington, DC 20549 Attention: Mr. David Manion Re: Frost Family of Funds (File No. 811-23410) Mr. Manion: This letter responds to comments given by you to Brian Galm, Director of Fund Administration at SEI Investments Global Funds Services

- SCHEDULE F

HTML FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS APRIL 30, 2020 (Unaudited) Description Shares Value COMMON STOCK§ — 96.

- SCHEDULE F

HTML FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS APRIL 30, 2020 (Unaudited) Description Shares Value COMMON STOCK§ — 96.

- SCHEDULE F

HTML FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS APRIL 30, 2020 (Unaudited) Description Shares Value COMMON STOCK§ — 96.

- SCHEDULE F

HTML FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS APRIL 30, 2020 (Unaudited) Description Shares Value COMMON STOCK§ — 96.

COMMON STOCK§ — 96.2%

HTML FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS APRIL 30, 2020 (Unaudited) Description Shares Value COMMON STOCK§ — 96.

COMMON STOCK§ — 96.2%

HTML FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS APRIL 30, 2020 (Unaudited) Description Shares Value COMMON STOCK§ — 96.

COMMON STOCK§ — 95.3%

FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS OCTOBER 31, 2019 Description Shares Value COMMON STOCK§ — 95.

COMMON STOCK§ — 95.3%

FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS OCTOBER 31, 2019 Description Shares Value COMMON STOCK§ — 95.

COMMON STOCK§ — 95.3%

FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS OCTOBER 31, 2019 Description Shares Value COMMON STOCK§ — 95.

COMMON STOCK§ — 95.3%

FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS OCTOBER 31, 2019 Description Shares Value COMMON STOCK§ — 95.

COMMON STOCK§ — 95.3%

FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS OCTOBER 31, 2019 Description Shares Value COMMON STOCK§ — 95.

COMMON STOCK§ — 95.3%

FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS OCTOBER 31, 2019 Description Shares Value COMMON STOCK§ — 95.

COMMON STOCK§ — 95.3%

FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS OCTOBER 31, 2019 Description Shares Value COMMON STOCK§ — 95.

COMMON STOCK§ — 95.3%

FROST FAMILY OF FUNDS FROST GROWTH EQUITY FUND SCHEDULE OF INVESTMENTS OCTOBER 31, 2019 Description Shares Value COMMON STOCK§ — 95.

FCFIX / FROST CREDIT FUND CORRESP - -

CORRESP 1 filename1.htm David W. Freese Associate +1.215.963.5862 [email protected] October 21, 2019 FILED AS EDGAR CORRESPONDENCE Alison White, Esq. U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Frost Family of Funds 485(a) Filing (File Nos. 333-229001 and 811-23410) Dear Ms. White: On behalf of our client, Frost Family of Funds (the “Trust”), this l

August 6, 2019

August 6, 2019 VIA EDGAR Securities and Exchange Commission 100 F Street, NE Washington, D.

Expense Limitation Agreement, dated May 31, 2019, between the Registrant and the Adviser, is incorporated herein by reference to Exhibit (d)(2) of Pre-Effective Amendment No. 2 to the Registrant’s Registration Statement on Form N-1A (File No. 333-229001), filed with the SEC via EDGAR Accession No. 0001398344-19-010543 on June 17, 2019.

EXPENSE LIMITATION AGREEMENT EXPENSE LIMITATION AGREEMENT, effective as of May 31, 2019, by and between Frost Investment Advisors, LLC (the “Adviser”) and the Frost Family of Funds (the “Trust”) (the “Agreement”), on behalf of the series of the Trust set forth in Schedule A attached hereto (each, a “Fund” and together, the “Funds”).

AS FILED WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ON JUNE 14, 2019

AS FILED WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ON JUNE 14, 2019 File No. 333-229001 File No. 811-23410 U.S. SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 /X/ PRE-EFFECTIVE AMENDMENT NO. 2 AND REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940 /X/ AMENDMENT NO. 2 FROST FAMILY OF FUNDS (Exact Name o

June 14, 2019

June 14, 2019 VIA EDGAR Securities and Exchange Commission 100 F Street, NE Washington, D.

CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We consent to the references to our firm under the caption "Financial Highlights" in the Prospectuses of Frost Growth Equity Fund, Frost Mid Cap Equity Fund, Frost Value Equity Fund, Frost Low Duration Bond Fund, Frost Municipal Bond Fund, Frost Total Return Bond Fund and Frost Credit Fund included in the Pre-Effective Amendment No.

Code of Ethics for the Registrant, is incorporated herein by reference to Exhibit (p)(1) of Pre-Effective Amendment No. 1 to the Registrant’s Registration Statement on Form N-1A (File No. 333-229001), filed with the SEC via EDGAR Accession No. 0001398344-19-009853 on May 30, 2019.

Code of Ethics – Personal Securities Trading (Rule 17j-1) CODE OF ETHICS – PERSONAL SECURITIES TRADING (RULE 17j-1) This policy applies to all Trusts identified in Appendices I and II Compliance Monitoring Responsibility Monitoring Frequency Recordkeeping Responsibility Periodic Testing Funds, Advisers, Sub-Advisers, SEIGFS, SIDCo.

Transfer Agency Agreement, dated May 29, 2019, between the Registrant and DST Systems, Inc., is incorporated herein by reference to Exhibit (h)(2) of Pre-Effective Amendment No. 1 to the Registrant’s Registration Statement on Form N-1A (File No. 333-229001), filed with the SEC via EDGAR Accession No. 0001398344-19-009853 on May 30, 2019.

Services Agreement This Services Agreement (the ?Agreement?) is entered into and effective as of May 29, 2019 (the ?Effective Date?) by and between: 1.

CODE OF ETHICS Frost Investment Advisors, LLC 100 West Houston Street 15th Floor P.O. Box 2509 San Antonio, TX 78299-2509

CODE OF ETHICS Frost Investment Advisors, LLC 100 West Houston Street 15th Floor P.

Investment Advisory Agreement, dated May 31, 2019, between the Registrant and Frost Investment Advisors, LLC (the “Adviser”), is incorporated herein by reference to Exhibit (d)(1) of Pre-Effective Amendment No. 1 to the Registrant’s Registration Statement on Form N-1A (File No. 333-229001), filed with the SEC via EDGAR Accession No. 0001398344-19-009853 on May 30, 2019.

investment ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT (the ?Agreement?) made as of this 31st day of May, 2019 by and between the Frost Family of Funds (the ?Trust?), a Delaware statutory trust registered as an investment company under the Investment Company Act of 1940, as amended (the ?1940 Act?), and Frost Investment Advisors, LLC (the ?Adviser?), a limited liability company with its principal place of business at 100 West Houston Street, 15th Floor Tower, San Antonio, Texas, 78205.

GLOBAL CUSTODY AGREEMENT

GLOBAL CUSTODY AGREEMENT For Foreign and Domestic Securities This Custodian Agreement (?Agreement?) is made as of May 15, 2019 by and between Frost Family of Funds ("Principal") and MUFG Union Bank, N.

Distribution Plan adopted pursuant to Rule 12b-1 under the Investment Company Act of 1940 (the “1940 Act”), is incorporated herein by reference to Exhibit (m) of Pre-Effective Amendment No. 1 to the Registrant’s Registration Statement on Form N-1A (File No. 333-229001), filed with the SEC via EDGAR Accession No. 0001398344-19-009853 on May 30, 2019.

Frost Family of Funds DISTRIBUTION PLAN WHEREAS, Frost Family of Funds (the ?Trust?) is engaged in business as an open-end investment company registered under the Investment Company Act of 1940, as amended (the ?1940 Act?); WHEREAS, SEI Investments Distribution Co.

EXPENSE LIMITATION AGREEMENT

EXPENSE LIMITATION AGREEMENT EXPENSE LIMITATION AGREEMENT, effective as of May 31, 2019, by and between Frost Investment Advisors, LLC (the ?Adviser?) and the Frost Family of Funds (the ?Trust?) (the ?Agreement?), on behalf of the series of the Trust set forth in Schedule A attached hereto (each, a ?Fund? and together, the ?Funds?).

Sample Account Opening Letters to Brokers/Dealers (Sent Directly by Employee)

EX-99.28.P.4 16 fp0042641ex9928p4.htm NOTE - This document is very important. Please take the time to read it thoroughly before you submit the required annual certification. Any questions regarding this Code of Ethics should be referred to a member of the SEI Compliance Department. See page 2 for more information. A copy of this Code may be accessed on the SEI intranet site under the Corporate Gov

Administration Agreement, dated May 31, 2019, between the Registrant and SEI Investments Global Funds Services (“SIGFS”), is incorporated herein by reference to Exhibit (h)(1) of Pre-Effective Amendment No. 1 to the Registrant’s Registration Statement on Form N-1A (File No. 333-229001), filed with the SEC via EDGAR Accession No. 0001398344-19-009853 on May 30, 2019.

ADMINISTRATION AGREEMENT THIS ADMINISTRATION AGREEMENT (this “Agreement”) is made as of the 31st day of May, 2019 (the “Effective Date”), by and between the Frost Family of Funds (the “Trust”), Frost Investment Advisors, LLC (the “Investment Adviser”), and SEI Investments Global Funds Services, a statutory trust formed under the laws of the State of Delaware (the “Administrator”).

Shareholder Services Plan, is incorporated herein by reference to Exhibit (h)(3) of Pre-Effective Amendment No. 1 to the Registrant’s Registration Statement on Form N-1A (File No. 333-229001), filed with the SEC via EDGAR Accession No. 0001398344-19-009853 on May 30, 2019.

Frost Family of Funds SHAREHOLDER SERVICES PLAN WHEREAS, Frost Family of Funds (the ?Trust?) is engaged in business as an open-end investment company registered under the Investment Company Act of 1940 (the ?1940 Act?) and the Trust desires to compensate service providers who provide the services described herein (?Service Providers?) to clients (the ?Clients?) who from time to time beneficially o

FROST INVESTMENT ADVISORS, LLC 100 West Houston Street, 15th Floor P.O. Box 2509 San Antonio, Texas 78299-2509 May 31, 2019

EX-99.28.D.3 4 fp0042641ex9928d3.htm FROST INVESTMENT ADVISORS, LLC 100 West Houston Street, 15th Floor P.O. Box 2509 San Antonio, Texas 78299-2509 May 31, 2019 Frost Family of Funds One Freedom Valley Drive Oaks, PA 19456 Ladies and Gentlemen: In the interest of limiting the expenses of the Frost Value Equity Fund and Frost Municipal Bond Fund (each, a “Fund” and together, the “Funds”), each a se

Multiple Class Plan adopted pursuant to Rule 18f-3 under the 1940 Act, is incorporated herein by reference to Exhibit (n) of Pre-Effective Amendment No. 1 to the Registrant’s Registration Statement on Form N-1A (File No. 333-229001), filed with the SEC via EDGAR Accession No. 0001398344-19-009853 on May 30, 2019.

EX-99.28.N 12 fp0042641ex9928n.htm FROST FAMILY OF FUNDS Rule 18f-3 Multiple Class Plan (the “Plan”) Frost Family of Funds (the “Trust”), a registered investment company that consists of a number of series, has elected to rely on Rule 18f-3 under the Investment Company Act of 1940, as amended (the “1940 Act”), in offering multiple classes of shares in each series listed on the Schedules attached h

AS FILED WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ON MAY 30, 2019

AS FILED WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ON MAY 30, 2019 File No. 333-229001 File No. 811-23410 U.S. SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 /X/ PRE-EFFECTIVE AMENDMENT NO. 1 AND REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940 /X/ AMENDMENT NO. 1 FROST FAMILY OF FUNDS (Exact Name of

May 30, 2019

May 30, 2019 Frost Family of Funds One Freedom Valley Drive Oaks, Pennsylvania 19456 Re: Opinion of Counsel regarding Pre-Effective Amendment No.

SEI INVESTMENTS DISTRIBUTION CO. RULE 17j-1 CODE OF ETHICS

SEI INVESTMENTS DISTRIBUTION CO. RULE 17j-1 CODE OF ETHICS A copy of this Code may be accessed on the SEI intranet site under the Corporate Governance section. This is an important document. You should take the time to read it thoroughly before you submit the required annual certification. Any questions regarding this Code of Ethics should be referred to a member of the SIDCO Compliance Department

Distribution Agreement, dated May 31, 2019, between the Registrant and SEI Investments Distribution Co. (“SIDCo.”), is incorporated herein by reference to Exhibit (e) of Pre-Effective Amendment No. 1 to the Registrant’s Registration Statement on Form N-1A (File No. 333-229001), filed with the SEC via EDGAR Accession No. 0001398344-19-009853 on May 30, 2019.

DISTRIBUTION AGREEMENT THIS DISTRIBUTION AGREEMENT (this "Agreement") is made as of this 31st day of May, 2019, by and between the Frost Family of Funds, SEI Investments Distribution Co.

Frost Family of Funds Power of Attorney

Frost Family of Funds Power of Attorney KNOW ALL PERSONS BY THESE PRESENTS, that the undersigned trustee and/or officer of the above referenced fund (the "Trust"), a statutory trust (commonly known as a ?business trust?) organized under the laws of the State of Delaware, hereby constitutes and appoints Michael Beattie and Dianne M.

AUTHORIZATION FOR ATTORNEY-IN-FACT TO SIGN REGISTRATION STATEMENT ON BEHALF OF PRESIDENT (CHIEF EXECUTIVE OFFICER) AND TREASURER (CHIEF FINANCIAL OFFICER)

AUTHORIZATION FOR ATTORNEY-IN-FACT TO SIGN REGISTRATION STATEMENT ON BEHALF OF PRESIDENT (CHIEF EXECUTIVE OFFICER) AND TREASURER (CHIEF FINANCIAL OFFICER) VOTED: That the President (Chief Executive Officer) and the Treasurer (Chief Financial Officer) of Frost Family of Funds (the ?Trust?) are granted the authority to execute a power of attorney in favor of other appropriate persons, as determined by such officers, for the purpose of signing the Trust?s Registration Statement on Form N-1A and N-14, as applicable, and any amendments thereto.

AS FILED WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ON APRIL 25, 2019

N-14/A 1 fp0041592n14a.htm AS FILED WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ON APRIL 25, 2019 1933 Act File No. 333-230339 U.S. SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N-14 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 /X/ Pre-Effective Amendment No. 1 Post-Effective Amendment No. FROST FAMILY OF FUNDS (Exact Name of Registrant as Specified in Charter) One

Frost Family of Funds One Freedom Valley Drive Oaks, Pennsylvania 19456

CORRESP 1 filename1.htm Frost Family of Funds One Freedom Valley Drive Oaks, Pennsylvania 19456 April 25, 2019 VIA EDGAR Filing Room U.S. Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Attn: Raymond Be, Esq. Kathy Churko Re: Frost Family of Funds (the “Trust”) Pre-Effective Amendment No. 1 to the Registration Statement on Form N-14 (File No. 333-230339) Dear Mr. Be and

* * * * * * * * * * * *

David W. Freese Associate +1.215.963.5862 [email protected] April 25, 2019 FILED AS EDGAR CORRESPONDENCE Raymond Be, Esq. Kathy Churko U.S. Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Re: Frost Family of Funds N-14 Filing (File No. 333-230339) Dear Mr. Be and Ms. Churko: On behalf of our client, Frost Family of Funds (the ?Registrant?), this letter respond

CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

EX-99.16.14.A 2 fp0041592ex991614a.htm CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We consent to the references to our firm under the captions “Target Funds and Acquiring Funds – Service Providers” and "Financial Highlights" in the Proxy Statement/Prospectus of Frost Growth Equity Fund, Frost Mid Cap Equity Fund, Frost Value Equity Fund, Frost Low Duration Bond Fund, Frost Municipal B

April 25, 2019

April 25, 2019 VIA EDGAR Securities and Exchange Commission 100 F Street, NE Washington, D.

DISTRIBUTION AGREEMENT

DISTRIBUTION AGREEMENT THIS DISTRIBUTION AGREEMENT (this "Agreement") is made as of this day of , 2019, by and between the Frost Family of Funds, SEI Investments Distribution Co.

FROST FAMILY OF FUNDS Rule 18f-3 Multiple Class Plan (the “Plan”)

FROST FAMILY OF FUNDS Rule 18f-3 Multiple Class Plan (the ?Plan?) Frost Family of Funds (the ?Trust?), a registered investment company that consists of a number of series, has elected to rely on Rule 18f-3 under the Investment Company Act of 1940, as amended (the ?1940 Act?), in offering multiple classes of shares in each series listed on the Schedules attached hereto (each, a ?Fund,? and together, the ?Funds?).

Frost Family of Funds SHAREHOLDER SERVICES PLAN

Frost Family of Funds SHAREHOLDER SERVICES PLAN WHEREAS, Frost Family of Funds (the ?Trust?) is engaged in business as an open-end investment company registered under the Investment Company Act of 1940 (the ?1940 Act?) and the Trust desires to compensate service providers who provide the services described herein (?Service Providers?) to clients (the ?Clients?) who from time to time beneficially o

March 15, 2019

March 15, 2019 VIA EDGAR Securities and Exchange Commission 100 F Street, NE Washington, D.

Morgan, Lewis & Bockius LLP

Morgan, Lewis & Bockius LLP 1701 Market Street Philadelphia, PA 19103-2921 Tel: +1.

EX-99.16.17.A

Very truly yours,

EX-99.16.12 11 fp0040397ex991612.htm [●], 2019 Board of Trustees The Advisors’ Inner Circle Fund II One Freedom Valley Drive Oaks, Pennsylvania 19456 Board of Trustees Frost Family of Funds One Freedom Valley Drive Oaks, Pennsylvania 19456 Re: Agreement and Plan of Reorganization, dated as of [●], 2019 (the “Agreement”), by and among (i) Frost Family of Funds, a [Delaware statutory trust] (“Acquir

FROST INVESTMENT ADVISORS, LLC 100 West Houston Street, 15th Floor P.O. Box 2509 San Antonio, Texas 78299-2509 ________, 2019

FROST INVESTMENT ADVISORS, LLC 100 West Houston Street, 15th Floor P.O. Box 2509 San Antonio, Texas 78299-2509 , 2019 Frost Family of Funds One Freedom Valley Drive Oaks, PA 19456 Ladies and Gentlemen: In the interest of limiting the expenses of the Frost Value Equity Fund and Frost Municipal Bond Fund (each, a ?Fund? and together, the ?Funds?), each a series of Frost Family of Funds (the ?Trust?)

Services Agreement

Services Agreement This Services Agreement (the ?Agreement?) is entered into and effective as of , 2019 (the ?Effective Date?) by and between: 1.

[SIGNATURES ON NEXT PAGE]

GLOBAL CUSTODY AGREEMENT For Foreign and Domestic Securities This Custodian Agreement (?Agreement?) is made as of , 20 by and between ("Principal") and MUFG Union Bank, N.

FROST FAMILY OF FUNDS POWER OF ATTORNEY

FROST FAMILY OF FUNDS POWER OF ATTORNEY I, the undersigned trustee and/or officer of Frost Family of Funds, a Delaware statutory trust (the ?Trust?), do hereby constitute and appoint Michael Beattie and Dianne Descoteaux, and each of them singly, my true and lawful attorneys, with full power to them and each of them, to sign for me and in my name and the capacity listed below, the Registration Sta

ADMINISTRATION AGREEMENT

EX-99.16.13.A 12 fp0040397ex991613a.htm ADMINISTRATION AGREEMENT THIS ADMINISTRATION AGREEMENT (this “Agreement”) is made as of the day of , 2019 (the “Effective Date”), by and between the Frost Family of Funds (the “Trust”), Frost Investment Advisors, LLC (the “Investment Adviser”), and SEI Investments Global Funds Services, a statutory trust formed under the laws of the State of Delaware (the “A

AS FILED WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ON MARCH 15, 2019

AS FILED WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ON MARCH 15, 2019 1933 Act File No. 333- U.S. SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N-14 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 /X/ Pre-Effective Amendment No. Post-Effective Amendment No. FROST FAMILY OF FUNDS (Exact Name of Registrant as Specified in Charter) One Freedom Valley Drive Oaks, Pennsyl

EXPENSE LIMITATION AGREEMENT

EXPENSE LIMITATION AGREEMENT EXPENSE LIMITATION AGREEMENT, effective as of [], 2019, by and between Frost Investment Advisors, LLC (the ?Adviser?) and the Frost Family of Funds (the ?Trust?) (the ?Agreement?), on behalf of the series of the Trust set forth in Schedule A attached hereto (each, a ?Fund? and together, the ?Funds?).

March 15, 2019

March 15, 2019 Frost Family of Funds One Freedom Valley Drive Oaks, Pennsylvania 19456 Re: Registration Statement Filed on Form N-14 under the Securities Act of 1933 Ladies and Gentlemen: We hereby consent to the references to our Firm and the discussion of our Firm?s opinions regarding certain tax matters (the ?Opinions?) in Frost Family of Funds? Registration Statement filed on Form N-14 (the ?Registration Statement?) under the Proxy Statement/Prospectus heading ?THE PROPOSED REORGANIZATIONS - Federal Income Tax Considerations.

Frost Family of Funds DISTRIBUTION PLAN

Frost Family of Funds DISTRIBUTION PLAN WHEREAS, Frost Family of Funds (the ?Trust?) is engaged in business as an open-end investment company registered under the Investment Company Act of 1940, as amended (the ?1940 Act?); WHEREAS, SEI Investments Distribution Co.

investment ADVISORY AGREEMENT

investment ADVISORY AGREEMENT INVESTMENT ADVISORY AGREEMENT (the ?Agreement?) made as of this th day of , 2019 by and between the Frost Family of Funds (the ?Trust?), a Delaware statutory trust registered as an investment company under the Investment Company Act of 1940, as amended (the ?1940 Act?), and Frost Investment Advisors, LLC (the ?Adviser?), a limited liability company with its principal place of business at 100 West Houston Street, 15th Floor Tower, San Antonio, Texas, 78205.

CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM We consent to the references to our firm under the captions ?Target Funds and Acquiring Funds ? Service Providers? and "Financial Highlights" in the Proxy Statement/Prospectus of Frost Growth Equity Fund, Frost Mid Cap Equity Fund, Frost Value Equity Fund, Frost Low Duration Bond Fund, Frost Municipal Bond Fund, Frost Total Return Bond Fund

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-8A NOTIFICATION OF REGISTRATION FILED PURSUANT TO SECTION 8(a) OF THE INVESTMENT COMPANY ACT OF 1940

N-8A 1 fp0037980n8a.htm UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM N-8A NOTIFICATION OF REGISTRATION FILED PURSUANT TO SECTION 8(a) OF THE INVESTMENT COMPANY ACT OF 1940 The undersigned investment company hereby notifies the U.S. Securities and Exchange Commission that it registers under and pursuant to the provisions of Section 8(a) of the Investment Company Act

AS FILED WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ON DECEMBER 21, 2018

AS FILED WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ON DECEMBER 21, 2018 File No. 033-[] File No. 811-23410 U.S. SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 FORM N-1A REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 /X/ PRE-EFFECTIVE AMENDMENT NO. / / AND REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940 /X/ AMENDMENT NO. / / FROST FAMILY OF FUNDS (Exact Na

2

David W. Freese Associate 215.963.5862 [email protected] December 21, 2018 VIA EDGAR U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: Frost Family of Funds: Initial Registration Statement on Form N-1A (File Nos. 333- and 811-23410) Ladies and Gentlemen: On behalf of our client, Frost Family of Funds (the “Trust”), we are filing the Trust’s registration statem

Registrant’s By-Laws are incorporated herein by reference to Exhibit (b) of the Registrant’s Registration Statement on Form N-1A (File No. 333-229001), filed with the SEC via EDGAR Accession No. 0001398344-18-018438 on December 21, 2018.

BY-LAWS OF FROST FAMILY OF FUNDS ARTICLE 1 Agreement and Declaration of Trust and Offices 1.

See Article III and Article V of the Registrant’s Agreement and Declaration of Trust, which is incorporated herein by reference to Exhibit (c) of the Registrant’s Registration Statement on Form N-1A (File No. 333-229001), filed with the SEC via EDGAR Accession No. 0001398344-18-018438 on December 21, 2018.

AGREEMENT AND DECLARATION OF TRUST OF FROST FAMILY OF FUNDS WHEREAS, THIS AGREEMENT AND DECLARATION OF TRUST is made and entered into as of the date set forth below by the Trustees named hereunder, for the purpose of forming a Delaware statutory trust in accordance with the provisions hereinafter set forth, to be effective upon the filing of the executed Certificate of Trust with the State of Delaware.

Registrant’s Certificate of Trust, dated December 11, 2018, is incorporated herein by reference to Exhibit (a)(1) of the Registrant’s Registration Statement on Form N-1A (File No. 333-229001), filed with the U.S. Securities and Exchange Commission (the “SEC”) via EDGAR Accession No. 0001398344-18-018438 on December 21, 2018.

CERTIFICATE OF TRUST OF FROST FAMILY OF FUNDS This Certificate of Trust of Frost Family of Funds, a statutory trust (the “Trust”), executed by the undersigned trustee, and filed under and in accordance with the provisions of the Delaware Statutory Trust Act (Title 12 of the Delaware Code, Section 3801 et seq.