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HomeMy WebLinkAboutCity of Tamarac Resolution R-2014-020Temp. Reso. # 12457 February 14, 2014 Page 1 CITY OF TAMARAC, FLORIDA RESOLUTION NO. R-2014- 0 'Q A RESOLUTION OF THE CITY COMMISSION OF THE CITY OF TAMARAC, FLORIDA, AUTHORIZING THE APPROPRIATE CITY OFFICIALS TO EXECUTE AGREEMENTS WITH ING LIFE INSURANCE AND ANNUITY COMPANY TO PROVIDE A 457 DEFERRED COMPENSATION PLAN AND A 401(A) RETIREMENT PLAN, ADOPTING PLAN DOCUMENTS; PROVIDING FOR CONFLICTS; PROVIDING FOR SEVERABILITY; AND PROVIDING FOR AN EFFECTIVE DATE. WHEREAS, the City of Tamarac ("City") currently has a 457 Deferred Compensation Plan and a 401(a) Retirement Plan available to City employees through multiple companies including the International City Manager's Association Retirement Corporation (ICMA-RC), AXA Equitable, Nationwide and ING; and WHEREAS, in August, 2013 the City through its advisor, SageView Advisory Group, solicited proposals in the market in order to improve these City programs, including reducing fees/costs to employees, improving portfolio lineup and investment options, and consolidating the programs under one trustee/vendor; and Temp. Reso. # 12457 February 14, 2014 Page 2 WHEREAS, the City Manager appointed a Committee of employees representing both the Federation of Public Employees (FPE) and the International Association of Firefighters (IAFF), and other employees representing a variety of employee groups, to review the proposals and make recommendations; and WHEREAS, SageView Advisors and the City received and analyzed eight (8) proposals, and the four -top ranked proposals were further reviewed by the Review Committee. All parties interviewed company representatives and conducted detailed references for the four finalists and the Review Committee unanimously identified ING Life Insurance and Annuity Company ("ING") as the firm best qualified to provide the desired services to the City and its employees and plan participants; and WHEREAS, the transition requires the adoption of a new 457 Deferred Compensation Plan document and a new 401(A) Retirement Plan document; and WHEREAS, ING has agreed to serve as the exclusive, successor Trustee to both of these plans; and Temp. Reso. #12457 February 14, 2014 Page 3 WHEREAS, the City Manager, the Director of Financial Services and the Director of Human Resources recommend the approval and execution of the Agreements with ING; and WHEREAS, the City Commission has deemed it to be in the best interest of the citizens and residents of the City of Tamarac to approve and execute the Agreements with ING as the firm selected to administer the City's 457 Deferred Compensation and 401(a) Retirement Plans. NOW, THEREFORE, BE IT RESOLVED BY THE CITY COMMISSION OF THE CITY OF TAMARAC, FLORIDA: SECTION 1: The foregoing "WHEREAS" clauses are hereby ratified and confirmed as being true and correct and are hereby made a specific part of this Resolution. SECTION 2: That ING National Trust is hereby appointed exclusive successor Trustee of the City of Tamarac 457 as the Deferred Compensation Plan and 401(a) Retirement Plan, effective May 1, 2014, or as soon thereafter as assets are received from the current Trustees. Temp. Reso. #12457 February 14, 2014 Page 4 SECTION 3: That the appropriate City officials are hereby authorized to execute the Agreements with ING Life Insurance & Annuity Company, substantially in the form attached hereto as Exhibit A and Exhibit B, and incorporated herein, and to undertake such acts as are necessary to implement the foregoing resolutions, subject to final review and approval by the City Manager and City Attorney. SECTION 4: That the appropriate City officials hereby adopt a new 457 Deferred Compensation Plan document and a new 401(A) Retirement Plan document, substantially in the form attached hereto as Exhibits C and D, and incorporated herein, subject to final review and approval by the City Manager and City Attorney. SECTION 5: The City of Tamarac hereby expressly authorizes participation in said Plans and Trusts and hereby authorizes the administration of said Plans. SECTION 6: All resolutions or parts of resolutions in conflict herewith are hereby repealed to the extent of such conflict. SECTION 7: If any clause, section, other part of application of this Resolution is held by any court of competent jurisdiction to be unconstitutional 0 Temp. Reso. #12457 February 14, 2014 Page 5 or invalid, in part or in application, it shall not affect the validity of the remaining portions or applications of this Resolution. SECTION 8: This Resolution shall become effective immediately upon its passage and adoption. PASSED, ADOPTED AND APPROVEI 2014. ATTEST: WI` PATRICIA TEUFEI�, CIVIC CITY CLERK HEREBY CERTIFY THAT I HAVE APPROVED THIS RESOLUTION AS Tor FORM En SAMU�L S. GORE CITY ATTORNEY �N-)) x 1* HARRY DRESSLER MAYOR RECORD OF COMMISSION VOTE: MAYOR DRESSLER DIST 1: COMM. BUSHNE DIST 2: VICE MAYOR GON DIST 3: COMM. GLASSEF LW151 i n Plan Name IRC SECTION 457 CUSTODIAL ACCOUNT AGREEMENT THIS CUSTODIAL ACCOUNT AGREEMENT 20 between (the "Employer") in its responsible under state or local law for maintaining the "Custodian"). (the "Agreement"), effective as of the day of rapacity employer and as the party authorized and (the "Plan") and ING National Trust (the WITNESSETH: WHEREAS, the Employer has adopted and maintains the Plan in accordance with the requirements of Section 457(b) of the Internal Revenue Code of 1986, as amended ("Code"), for the benefit of the employees therein described; and WHEREAS, Section 457(g)(3) of the Code provides that custodial accounts described in Section 401(f) of the .Code. shall be treated as trusts pursuant to that section; and WHEREAS, the Employer has established or desires to establish a custodial account in accordance with Section 457(g) and Section 401(f) of the Code constituting a part of the Plan, pursuant to which assets are held to provide for the funding of and payment of benefits under the Plan; and WHEREAS, the Employer has the power and authority to manage and control the assets of the Plan; and WHEREAS, the Employer has engaged ING Life Insurance and Annuity Company ("ILIAC") to provide recordkeeping services to the Plan; and WHEREAS, the Employer wishes to appoint the Custodian as custodian of the Plan and the Custodian's agent ILIAC (collectively referred to herein as the "Custodian"), in accordance with the terms and conditions of this Agreement. NOW, THEREFORE, the Employer on behalf of the Plan and the Custodian, each intending to be legally bound, agree as follows: SECTION 1 - ESTABLISHMENT AND OPERATION OF CUSTODY ACCOUNT 1.1 Appointment and Acceptance of Custodian/Affiliates. The Employer hereby establishes with the Custodian a custodial account consisting of such sums of money and such other property acceptable to the Custodian as shall from time to time be paid or delivered to the Custodian, and hereby appoints the Custodian as custodian with respect to the assets held pursuant to this Agreement as such assets shall exist from time to time (the "Account"). The Account shall not include any property or asset other than the assets delivered to and accepted by the Custodian from time to time. The Custodian shall have no responsibility for any property until it is received and accepted by the Custodian, or for any property of the Plan not delivered to the Custodian and accepted by the Custodian to be a part of the Account. The Custodian hereby accepts its appointment, acknowledges that it assumes the duties established by this Agreement, and agrees to be bound by the terms contained herein. The Employer hereby acknowledges that ILIAC is an affiliate of the Custodian and acts on its behalf as the Custodian's agent for the purpose of carrying out the Custodian's responsibilities under this Agreement. 1.2 Custodian Responsibilities. The Custodian shall receive and hold the assets on behalf of Plan participants and beneficiaries in accordance with the terms of this Agreement. The duties of the Custodian hereunder as custodian shall be to act solely in accordance with the instructions of the Employer or Authorized Parties in accordance with Sections 2.2 and 2.3 of this Agreement ("Authorized Instructions"). Nothing in this Agreement is intended to give the Custodian any discretionary responsibility, authority or control with respect to the management or administration of the Plan or the management of the assets of the Plan. Further, the Custodian is not a party to the Plan and has no duties or responsibilities other than those that may be expressly contained in this Agreement, In any case in which a provision of this Agreement conflicts with any provision in the Plan, this Agreement shall control. Irc 457(b) Custodial Account Agreement SPECIMEN July_3 2013.doc 1.3 Exclusive Benefit. Except as may be permitted by law, by the terms of the Plan, or by this Agreement, at no time prior to the satisfaction of all liabilities with respect to participants and their beneficiaries under the Plan shall any part of the Account be used for or diverted to any purpose other than for the exclusive benefit of the participants and their beneficiaries. The assets of the Account shall be held for the exclusive purposes of providing benefits to participants of the Plan and their beneficiaries and defraying the reasonable expenses of administering the Plan and the Custody Account. 1.4 Limitation of Liability, . Neither the Custodian nor its agents shall be liable for any acts or omissions of another person other than the negligent acts or omissions of its own employees and agents. The Custodian shall not be responsible for the title, validity or genuineness of any asset or any Loan Document received by it or delivered by it pursuant to this Agreement and shall be held harmless in acting upon any notice, request, direction, instruction, consent, certification or other instrument believed by it to be genuine and delivered by the proper party or parries. 1.5 Contributions. The Custodian shall receive contributions or other amounts for deposit to the Plan that are delivered to the Custodian or its designated agent for deposit to or for the benefit of the Plan. In accordance with Authorized Instructions, the Custodian shall transmit contributions received for the purpose of settling the Plan's investment transactions. The Employer shall have sole duty and responsibility for the determination of the accuracy or sufficiency of the contributions to be made under the Plan and for the transmittal of contributions or other amounts to the Plan. The Custodian shall have no duty or responsibility (a) to determine the amounts to be contributed to or transferred to the Plan or on behalf of the participants of the Plan, (b) to collect any contributions or transfers to the Plan or to enforce the collection of any such contributions or transfers, or (c) for the adequacy of amounts deposited to the Fund to meet and discharge any of the Plan's liabilities. 1.6 Return of Contributions. Notwithstanding any other provision of this Agreement (a) contributions made by the Employer based upon mistake of fact may be returned to the Employer. The Custodian shall return contributions under this Section 1.6 only in accordance with Authorized Instructions and the Custodian shall have no duty to determine whether the return of such contributions is permitted under this Section 1.6 and the Plan. 1.7 Distributions. The Custodian shall make distributions and disbursements from the Account solely in accordance with Authorized Instructions. The Custodian shall not have any responsibility or duty under this Agreement to see to the proper application of any payment, to determine the tax effect of any payment, or to determine whether a distribution or disbursement to any person paid in accordance with Authorized Instructions is appropriate under the terms of the Plan and applicable law. 1.8 Compliance with Law. The Account is intended to be tax-exempt under Section 501(a) of the Code and this Agreement is intended to comply with Section 457(g) of the Code. The Employer represents that it intends that the Plan constitute an eligible deferred compensation plan under Section 457(b) and Section 414(d) of the Code. The Employer agrees to immediately notify the Custodian if the Plan ceases to be so eligible. SECTION 2 — AUTHORITIES 2.1 Authority to Execute Agreement. The Employer hereby certifies that it has the power and authority to enter into this Agreement on behalf of the Plan. The person(s) signing below on behalf of the Employer as Authorized Parties warrant, as individuals, that each is an authorized to act on behalf of the Employer all signatures are genuine and the persons indicated are authorized to sign. 2.2 Authorized Parties. The Employer shall concurrently with the execution of this Agreement, furnish the Custodian with a written list of the names, signatures, and extent of authority of all persons authorized to direct the Custodian and otherwise act on behalf of the Employer under the terms of this Agreement as "Authorized Parties." Such persons designated by the Employer to act on its behalf hereunder are "Authorized Parties". The Custodian shall be entitled to rely on and shall be fully protected in acting upon directions, instructions, and any information provided by an Authorized Party until notified in writing by the Employer of a change of the identity or extent of authority of an Authorized Party. w2 • 2.3 Authorized Instructions. All directions and instructions to the Custodian from an Authorized Party ("Authorized Instructions") shall be in writing, transmitted by mail (including electronic mail) or by facsimile. The Custodian shall be entitled to rely on and shall be fully protected in acting in accordance with all such directions and instructions which it reasonably believes to have been given by an Authorized Party and in failing to act in the absence thereof. SECTION 3 - POWERS AND DUTIES 3.1 General Powers and Duties of Custodian. In administering the Account, the Custodian shall be specifically authorized to: (a) In accordance with Authorized Instructions, receive, hold and maintain custody of, and disburse assets held in the Account; (b) Hold securities or other assets in book entry form or through another agent or nominee, including without limitation in an omnibus account arrangement, provided that the Custodian's records indicate that such securities or other property are held for the exclusive benefit of the Plan and its participants and beneficiaries; (c) Make distributions and disbursements from the Account and carry out related tax withholding remittance and reporting obligations under Federal, state and local law; (d) Appoint domestic agents, sub -trustees, sub -custodians or depositories (including affiliates of the Custodian) as to part or all of the Account, except that the indicia of ownership of any asset of the Account shall not be held outside the jurisdiction of the District Courts of the United States; (e) Collect income payable to and dividends or other distributions due to the Account and sign on behalf of the Plan any declarations, affidavits, and certificates of ownership required to collect income and principal payments; (f) Collect proceeds frorn assets of the Account that may mature or be called; (g) Until Authorized Instructions are received, hold the assets of the Account uninvested, or invest the assets of the Account in bank accounts of any bank, and the Custodian may retain any earnings on such deposits as part of its compensation for services hereunder; (h) Submit or cause to be submitted to the Employer all information received by the Custodian regarding ownership rights pertaining to property held in the Account; (i) Exercise all voting rights relating to securities held in the Account as directed by the Employer; provided that, with respect to securities allocated to the accounts of Plan participants, unless otherwise directed by the Employer in writing, the Custodian shall cause to be mailed to each Plan participant who has shares of such securities credited to his or her account a copy of the notice and all proxy solicitation materials together with a voting instruction form for return to the Custodian or its designee, and the Custodian shall vote the shares as directed by each participant and shall not vote shares for which it has not received instructions from a participant. Unless the Employer instructs the Custodian to vote shares not voted by participants, the Custodian shall not be liable and shall be held harmless for not voting such shares. 0) Commence or defend suits or legal proceedings and represent the Account in all suits or legal proceedings in any court or before any other body or tribunal as the Custodian shall deem necessary to protect the Account provided, however, that the Custodian shall not be obligated to do so unless it has been indemnified by the Employer and the Plan against all expenses and liabilities sustained in connection with such action; (k) Employ suitable agents and legal counsel and, as part of its reimbursable expenses under this Agreement, pay their reasonable compensation and expenses. The Custodian shall be entitled to rely on and may act upon advice of counsel on all matters, and, if the use of such counsel is authorized by the Employer, the Custodian shall be without liability for any action reasonably taken or omitted pursuant to such advice; -3- (1) Make, execute and deliver any and all documents, agreements or other instruments in writing as is necessary or desirable for the accomplishment of any of the powers and duties in this Agreement; and (m) Retain and engage one or more affiliates of the Custodian to perform, at no additional cost to the Plan, the duties and responsibilities of the Custodian; and (n) Generally take any action, whether or not expressly authorized, which the Custodian may deem necessary or desirable for the fulfillment of its duties hereunder. SECTION 4 - INVESTMENT OF THE ACCOUNT 4.1 Investment of the Account. The assets of the Account shall be invested and reinvested among the investments selected by the Employer. The Employer shall have sole responsibility for the investment and reinvestment of the assets of the Account, except to the extent that the Plan permits participants to provide investment direction to the Plan's recordkeeper with respect to the investment of their individual accounts among investment options selected by the Employer. The Custodian shall have no duty or responsibility for (i) selecting or providing advice with respect to the selection of any investment options offered under the Plan, (ii) determining or reviewing any securities or other property purchased for or held by the Plan, or (iil) providing advice with respect to the purchase, retention, redemption, or sale of any securities or other property for the Plan. SECTION 5 - REPORTING AND RECORDKEEPING 5.1 Records and Reports. The Custodian shall keep accurate records of all assets and Loan Documents delivered to and from the Account for at least six years following the date of such transaction. The Custodian shall provide a report of the assets of the Account including the Loan _Documents held in the Account to the Employer from time to time, but at least annually. The Custodian may rely on the fair market value of the property of the Account as reported to it by authorized parties shall be fully protected in relying on such values. 5.2 Review of Reports. If, within ninety (90) days after the Custodian mails to the Employer a statement with respect to the Account, the Employer has not given the Custodian written notice of any exception or objection thereto, the statement shall be deemed to have been approved and, in such case, the Custodian shall not be liable for any matters in such statements. The Employer or its agent, upon giving prior written notice to the Custodian, shall have the right at its own expense to inspect the Custodian's books and records directly relating to the Account during normal business hours. Custodian shall be reimbursed its actual costs for making such books and records available for inspection. 5.3 Non -Account Assets. The duties of the Custodian shall be limited to the assets held in the Account, and the Custodian shall have no duties with respect to property or assets held by any other person including, without limitation, any trustee or other custodian for the Plan. The Employer hereby agrees that the Custodian shall not serve as, and shall not be deemed to be, a co -trustee or co -custodian under the circumstances, and shall have no co -fiduciary liability for any other person, trustee, custodian or other entity. SECTION 6 - COMPENSATION, EXPENSES, TAXES. INDEMNIFICATION (a) Compensation. The Custodian shall be entitled to compensation for services under this Agreement as set forth in Exhibit A and as otherwise provided for in this Agreement. The Employer acknowledges that the Custodian may increase the amount of compensation on an annual basis with sixty (60) days' prior written notice to the Employer. (b) Interest on Uninvested Cash. The Custodian shall also be entitled to receive as part of its compensation any amounts earned under Section 3.1(f) related to earnings on deposits. Such earnings shall include earnings on uninvested cash related to Plan contributions and earnings on uninvested cash pending distribution, or earnings on cash otherwise held uninvested as directed by Employer. -4- (c) Authorization. The Custodian shall also be authorized to charge and collect expenses incurred by it in the discharge of its duties under this Agreement in accordance with Section 3.1. The Custodian is authorized to charge and collect from the Account any and all such fees and expenses, unless the Employer objects within 30 days of receiving notice of the Trustee's intent to collect its fees and expenses from the Account. 6.2 Tax Obli ations. To the extent an Authorized Party has provided necessary information to the Custodian, the Custodian may use reasonable efforts to assist such Authorized Party to notify the Employer of any responsibility for payment of taxes, withholding, certification and reporting requirements, claims for exemptions or refund, interest, penalties and other related expenses of the Account ("Tax Obligations"). Notwithstanding the foregoing, the Custodian shall not have any responsibility or liability for any Tax Obligations now or hereafter imposed on the Employer or the Account by any taxing authorities, domestic or as foreign, except provided b g p p Y applicable law. To the extent the Custodian is responsible under any applicable law for payment of any Tax Obligation on behalf of the Account, the Employer shall cause the appropriate Authorized Party to inform the Custodian of all Tax Obligations, shall direct the Custodian with respect to the performance of such Tax Obligations, and shall provide the Custodian with all information required by the Custodian to meet such Tax Obligations. 6.3 Indemnification. The Employer, and to the extent permitted by law, the Plan, shall indemnify and hold harmless the Custodian from all claims, liabilities, losses, damages and expenses, including reasonable attorney's fees and expenses (including Tax Obligations) incurred by the Custodian in connection with this Agreement, except as a result of the Custodian's own negligence or willful misconduct. 6.4 Force Majeure. The Custodian shall not be responsible or liable for any losses to the Account resulting from nationalization, expropriation, devaluation, seizure, or similar action by any governmental authority, de facto or de jure; or enactment, promulgation, imposition or enforcement by any such governmental authority of currency restrictions, exchange controls, levies or other charges affecting the Account's property; or acts of war, terrorism, insurrection or revolution; or acts of God; or any other similar event beyond the control of the Custodian or its agents. 6.5 Survival. This Section Six (6) shall survive the termination of this Agreement. SECTION 7 - AMENDMENT, TERMINATION. RESIGNATION, REMOVAL 7.1 Amendment. The Custodian may amend this Agreement as necessary to comply with the provisions of applicable law and regulations. The Custodian shall deliver written notice of any such amendment to the Named Fiduciary. Other amendments may be made by written agreement signed by the parties hereto. 7.2 Removal or Resi nation of Custodian. The Custodian may be removed with respect to all or part of the Account upon receipt of sixty (60) days' written notice from the Employer. The Custodian may resign as custodian hereunder upon sixty (60) days' written notice delivered to the Employer. In the event of such removal or resignation, the successor custodian will be appointed by the Employer, and the retiring custodian shall transfer the Account, less such amounts as may be reasonable and necessary to cover its compensation and direct expenses including but not limited to, a pro-rata share of the fees described in Section 6.1. In the event the Employer fails to appoint a successor custodian within sixty (60) days of receipt of written notice of resignation, the Custodian reserves the right to seek the appointment of a successor custodian from a court of competent jurisdiction. The Employer shall indemnify the Custodian from any costs incurred by the Custodian in seeking such appointment. The Custodian shall have no duties, responsibilities or liability with respect to the acts or omissions of any successor custodian. 7.3 Mer er or Consolidation of Custodian. Any entity into which the Custodian may be merged or with which it may be consolidated, or any entity resulting from any merger or consolidation to which the Custodian is a party, or any entity succeeding to the custody business of the Custodian, shall become the successor of the Custodian hereunder, without the execution or filing of any instrument or the performance of any further act on the part of the parties hereto. -5- 7.4 Plan Termination. Upon termination of the Plan, the Custodian shall distribute all assets then constituting the Account, less any fees and expenses payable from the Account, pursuant to the instructions of the Employer. The Custodian shall be entitled to assume that such distributions are in full compliance with and not in violation of the terms of the Plan or any applicable law. 7.5 Property Not Transferred. The Custodian reserves the right to retain such property as is not suitable for distribution or transfer at the time of the termination of the Plan or this Agreement and shall hold such property for the benefit of those persons or other entities entitled to such property until such time as the Custodian is able to distribute or transfer such property. The Employer shall indemnify the Custodian from any costs incurred by the Custodian for retaining the property until it can be distributed or transferred. Upon the appointment and acceptance of a successor custodian, the Custodian's sole duties shall be those of a custodian with respect to the property not transferred. SECTION 8 - ADDITIONAL PROVISIONS 8.1 Assignment or Alienation. Except as may be provided by law, the Account shall not be subject to any form of attachment, garnishment, sequestration or other actions of collection afforded creditors of the Employer, participants or beneficiaries under the Plan. The Custodian shall not recognize any assignment or alienation of benefits unless an Authorized Instruction is received. 8.2 Governing Law. This Agreement shall be construed in accordance with and governed by the laws of the state of the Employer but the assets of the Account shall be held in the State of Connecticut. 8.3 Necessary Parties. The Custodian reserves the right to seek a judicial or administrative determination as to its proper course of action under this Agreement. Nothing contained herein will be construed or interpreted to deny the Custodian or the Employer the right to have the Custodian's account judicially determined. To the extent permitted by law, only the Custodian and the Employer shall be necessary parties in any application to the courts for an interpretation of this Agreement or for an accounting by the Custodian, and no participant under the Plan or other person having an interest in the Account shall be entitled to any notice or service of process. Any final judgment entered in such an action or proceeding shall, to the extent permitted by law, be conclusive upon all persons. The Employer shall indemnify the Custodian for any costs incurred by the Custodian in seeking such judgment. 8.4 Notices. All notices and other communications hereunder shall be in writing and shall be sufficient if delivered by hand or if sent by telefax or mail (including electronic mail), postage prepaid, addressed: (a) if to the Custodian: Molly Garrett Vice President ING Life Insurance and Annuity Company One Orange Way, C3N Windsor, Connecticut 06095-4774 With copy to: J. Denise Jackson President ING National Trust One Orange Way, C4R Windsor, Connecticut 06095-4774 -b- (b) If to the Employer: The parties may, by like notice, designate any future or different address to which subsequent notices shall be sent. Any notice shall be deemed given when received. 8.5 No Third Party Beneficiaries. The provisions of this Agreement are intended to benefit only the parties hereto, their respective successors and assigns, and participants and their beneficiaries under the Plan. There are no other third party beneficiaries. 8.6 Execution in Counterparts. This Agreement may be executed in any number of counterparts, each of which shall be deemed an original and said counterparts shall constitute but one and the same instrument and may be sufficiently evidenced by one counterpart. 8.7 Shareholder Communication. Until such time as the Trustee receives a written notice to the contrary with respect to a particular security, the Trustee may release the identity and the address of the Trust to the security issuer which requests such information pursuant to the Shareholder Communications Act of 1985 for the specific purpose of the direct communication between such security issuer and shareholder. IN WITNESS WHEREOF, the parties hereto have executed this Agreement as of the effective date set forth above. Name of Employer By: Name: Title: ING National Trust By. Name: Title: w�� EXHIBIT A FEES In consideration for services rendered according to the terms of this Agreement, the Custodian shall be paid according to the following fee schedule: $75 o for each calendar year: No explicit charge to the plan. Included as part of compensation received by ILIAC for its performance of recordkeeping services -$- INCUMBENCY CERTIFICATE — AUTHORIZED PARTIES , (the "Employer") hereby certifies that the persons whose names appear below are Authorized Parties to act on behalf of the Employer and the insert name of plan and to direct and instruct the Custodian through Authorized Instructions in accordance with Section 2.2. and Section 2.3 of the Section 457 Custodial Account Agreement (the "Agreement") between the Employer and ING National Trust, as Custodian dated insert date NAME EMPLOYER BY: TITLE: DATE: SIGNATURE -9- BA11MI I R Plan Name IRC SECTION 401(a) TRUST AGREEMENT- NON-ERISA PLAN THIS TRUST AGREEMENT (the "Agreement"), effective as of the day of , 20 between (the "Employer") in its capacity employer and as the party authorized and responsible under state or local law for maintaining the Plan (the "Plan") and ING National Trust (the "Trustee"). WITNESSETH: WHEREAS, the Employer has adopted and maintains the Plan in accordance with the requirements of state law and Section 401(a) of the Internal Revenue Code of 1986, as amended ("Code"), for the benefit of the employees therein described; and WHEREAS, the Employer has established or desires to establish a trust constituting a part of the Plan, pursuant to which assets are held to provide for the funding of and payment of benefits under the Plan; and WHEREAS, the Employer has the power and authority to manage and control the assets of the Plan; and WHEREAS, the Employer has engaged ING Life Insurance and Annuity Company ("ILIAC") to provide recordkeeping services to the Plan; and WHEREAS, the Employer wishes to appoint the Trustee as trustee of the Plan and the Trustee's agent ILIAC (collectively referred to herein as "Trustee") in accordance with the terms and conditions of this Agreement. NOW, THEREFORE, the Employer and the Trustee, each intending to be legally bound, agree as follows: SECTION[ 1- ESTABLISHMENT AND OPERATION OF TRUST 1.1 Appointment and Acceptance of Trustee/Affiliates. The Employer hereby establishes with the Trustee a trust consisting of such sums of money and such other property acceptable to the Trustee as shall from time to time be paid or delivered to the Trustee, and hereby appoints the Trustee as trustee with respect to the assets held pursuant to the Agreement as such assets shall exist from time to time (the "Fund"). The Fund shall not include any property or asset other than the assets delivered to and accepted by the Trustee from time to time. The Trustee shall have no responsibility for any property until it is received and accepted by the Trustee, or for any properly of the Plan not delivered to the Trustee and accepted by the Trustee to be a part of the Fund. The Trustee hereby accepts its appointment, acknowledges that it assumes the duties established by this Agreement, and agrees to be bound by the terms contained herein. The Employer hereby acknowledges that ILIAC is an affiliate of the Trustee and acts on its behalf as the Trustee's agent for purposes of carrying out the Trustee's responsibilities under this Agreement. 1.2 Trustee Responsibilities. The Trustee shall receive and hold the assets of the Fund on behalf of Plan participants and beneficiaries in accordance with the terms of this Agreement. The duties of the Trustee hereunder as Trustee shall be to act solely in accordance with the instructions of the Employer or Authorized Parties in accordance with Sections 2.2 and 2.3 of this Agreement ("Authorized Instructions"). Nothing in this Agreement is intended to give the Trustee any discretionary responsibility, authority or control with respect to the management or administration of the Plan or the management of the assets of the Plan. Further, the Trustee is not a party to the Plan and has no duties or responsibilities other than those that may be expressly contained in this Agreement. In any case in which a provision of this Agreement conflicts with any provision in the Plan, this Agreement shall control. 1.3 Exclusive Benefit. Except as may be permitted by law, by the terms of the Plan, or by this Agreement, at no time prior to the satisfaction of all liabilities with respect to participants and their beneficiaries under the Plan shall any part of the Fund be used for or diverted to any purpose other than for the exclusive benefit of the participants and their beneficiaries. The assets of the Fund shall be held for the exclusive purposes of Specimen 401(a) \non-ERISA TRUST AGREEMENTjuly_3_2011doe providing benefits to participants of the Plan and their beneficiaries and defraying the reasonable expenses of administering the Plan and the Fund. 1.4 Limitation of Liability. Neither the Trustee nor its agents shall not be liable for any acts or omissions of another person other than the negligent acts or omissions of its own employees and agents. The Trustee shall not be responsible for the title, validity or genuineness of any property or evidence of title thereto received by it or delivered by it pursuant to this Agreement and shall be held harmless in acting upon any notice, request, direction, instruction, consent, certification or other instrument believed by it to be genuine and delivered by the proper party or parties. 1.5 Contributions. The Trustee shall receive contributions or other amounts for deposit to the Plan that are delivered to the Trustee or its designated agent for deposit to or for the benefit of the Plan. The Employer shall have sole duty and responsibility for the determination of the accuracy or sufficiency of the contributions to be made under the Plan and for the transmittal of contributions or other amounts to the Plan. The Trustee shall have no duty or responsibility (a) to determine the amounts to be contributed to or transferred to the Plan or on behalf of the participants of the Plan, (b) to collect any contributions or transfers to the Plan or to enforce the collection of any such contributions or transfers, or (c) for the adequacy of amounts deposited to the Fund to meet and discharge any of the Plan's liabilities. 1.6 Return of Contributions. Notwithstanding any other provision of this Agreement (a) contributions made by the Employer based upon mistake of fact may be returned to the Employer within one year of such contribution, and (b) as all contributions to the Plan are conditioned upon their deductibility under the Code, if a deduction for such a contribution is disallowed, such contribution may be returned to the Employer within one year of the disallowance of such deduction; provided that the return of contributions under this Section 1.6 may not violate any provision of the Plan. The Trustee shall return contributions under this Section 1.6 only in accordance with Authorized Instructions and the Trustee shall have no duty to determine whether the return of such contributions is permitted under this Section 1.6 and the Plan. 1.7 Distributions. The Trustee shall make distributions and disbursements from the Fund solely in accordance with Authorized Instructions. The Employer agrees that the Trustee shall not have any responsibility or duty under this Agreement to see to the proper application rof any payment, to determine the tax effect of any payment, or to determine whether a distribution or disbursement to any person paid in accordance with Authorized Instructions is appropriate under the terms of the Plan and applicable law. 1.8 Compliance with Law. The Trust is intended to be tax-exempt under Section 501(a) of the Code. If the Plan is not an approved prototype plan, the Employer represents that it has received a determination letter from the Internal Revenue Service indicating that the Plan meets the requirements of Section 401(a) of the Code. The Employer agrees to immediately notify the Trustee if the Plan ceases to be so qualified. SECTION 2 - AUTHORITIES 2.1 Authority to Execute Agreement. The Employer hereby certifies that it has the power and authority to enter into this Agreement on behalf of the Plan. The person(s) signing below as representatives of the Employer each warrant, as individuals, that each is an authorized representative of the Employer all signatures are genuine and the persons indicated are authorized to sign. 2.2 Authorized Parties. The Employer shall, concurrently with the execution of this Agreement, furnish the Trustee with a written list of the names, signatures, and extent of authority of all persons authorized to direct the Trustee and otherwise act on behalf of the Plan under the terms of this Agreement. Such persons designated by the Employer to act on its behalf hereunder are "Authorized Parties". The Trustee shall be entitled to rely on and shall be fully protected in acting upon directions, instructions, and any information provided by an Authorized Party until notified in writing by the Employer of a change of the identity or extent of authority of an Authorized Party. 2.3 Authorized Instructions. All directions and instructions to the Trustee from an Authorized Party ("Authorized Instructions") shall be in writing, transmitted by mail (including electronic mail) or by facsimile. The 2 Trustee shall be entitled to rely on and shall be fully protected in acting in accordance with all such directions and instructions that it reasonably believes to have been given by an Authorized Party and in failing to act in the absence thereof. SECTION 3 - POWERS AND DUTIES 3.1 General Powers and Duties of Trustee. In administering the Fund, the Trustee shall be specifically authorized to: (a) In accordance with Authorized Instructions, receive, hold and maintain custody of, and disburse assets of the Fund; (b) Hold securities or other assets in book entry form or through another agent or nominee, including without limitation in an omnibus account arrangement, provided that the Trustee's records indicate that such securities or other property are held for the exclusive benefit of the Plan and its participants and beneficiaries; (c) Make distributions and disbursements from the Fund and carry out related tax withholding remittance and reporting obligations under Federal, state and local law; (d) Appoint domestic agents, sub -trustees, sub -custodians or depositories (including affiliates of the Trustee) as to part or all of the Fund, except that the indicia of ownership of any asset of the Fund shall not be held outside the jurisdiction of the District Courts of the United States;; (e) Collect income payable to and dividends or other distributions due to the Fund and sign on behalf of the Plan any declarations, affidavits, and certificates of ownership required to collect income and principal payments; (f) Collect proceeds from assets of the Fund that may mature or be called; (g) Until Authorized Instructions are received, hold the assets of the Fund uninvested, or invest the assets of the Fund in bank accounts of any bank, and the Trustee may retain any earnings on such deposits as part of its compensation for services hereunder; (h) Submit or cause to be submitted to the Employer all information received by the Trustee regarding ownership rights pertaining to property held in the Fund; W Exercise all voting rights relating to securities held in the Account as directed by the Employer; provided that, with respect to securities allocated to the accounts of Plan participants, unless otherwise directed by the Employer in writing, the Trustee shall cause to be mailed to each Plan participant who has shares of such securities credited to his or her account a copy of the notice and all proxy solicitation materials together with a voting instruction form for return to the Trustee or its designee, and the Trustee shall vote the shares as directed by each participant and shall not vote shares for which it has not received instructions from a participant. Unless the Employer instructs the Trustee to vote shares not voted by participants, the Trustee shall not be liable and shall be held harmless for not voting such shares. 0) Commence or defend suits or legal proceedings and represent the Fund in all suits or legal proceedings in any court or before any other body or tribunal as the Trustee shall deem necessary to protect the Fund provided, however, that the Trustee shall not be obligated to do so unless it has been indemnified by the Employer and the Plan against all expenses and liabilities sustained in connection with such action; (k) Employ suitable agents and legal counsel and, as part of its reimbursable expenses under this Agreement, pay their reasonable compensation and expenses. The Trustee shall be entitled to rely on and may act upon advice of counsel on all matters, and, if the use of such counsel is authorized by the Employer, the Trustee shall be without liability for any action reasonably taken or omitted pursuant to such advice; 3 (1) Make, execute and deliver any and all documents, agreements or other instruments in writing as is necessary or desirable for the accomplishment of any of the powers and duties in this Agreement; (m) Retain and engage one or more affiliates of the Trustee to perform, at no additional cost to the Plan, the duties and responsibilities of the Trustee; and (n) Generally take any action, whether or not expressly authorized, which the Trustee may deem necessary or desirable for the fulfillment of its duties hereunder. SECTION 4 - INVESTMENT OF THE FUND 4.1 Investment of the Fund.. The assets of the Fund shall be invested and reinvested among the investments selected by the Employer. The Employer or its authorized representative shall have sole responsibility for the investment and reinvestment of the assets of the Fund, except to the extent that the Plan permits participants to instruct the Employer or its authorized representative with respect to the investment of their individual accounts among investment options selected by the Employer. The Trustee shall have no duty or responsibility for (i) selecting or providing advice with respect to the selection of any investment options offered under the Plan, (ii) determining or reviewing any securities or other property purchased for or held by the Plan, or (iii) providing advice with respect to the purchase, retention, redemption, or sale of any securities or other property for the Plan. SECTION 5 - REPORTING AND RECORDKEEPING 5.1 Records and Reports. The Trustee shall keep accurate records of all amounts received to and disbursed from the Fund and the investments and other transactions of the Fund for a period of six years following the date of such transaction. The Trustee shall provide a report of the assets of the Fund to the Employer from time to time, but at least annually. The Trustee may rely on the fair market value of the property of the Fund as reported to by authorized parties and the Trustee shall be fully protected in relying on such values. 5.2 Review of K orts. If, within ninety (90) days after the Trustee mails to the Employer a statement with respect to the Fund, the Employer has not given the Trustee written notice of any exception or objection thereto, the statement shall be deemed to have been approved by the Employer and the Trustee shall not be liable for any matters in such statements. The Employer or its agent, upon giving prior written notice to Trustee, shall have the right at its own expense to inspect the Trustee's books and records directly relating to the Fund during normal business hours. The Trustee shall be reimbursed its actual costs for making such books and records available for inspection. 5.3 Non -Fund Assets. The duties of the Trustee shall be limited to the assets held in the Fund, and the Trustee shall have no duties with respect to assets held by any other person including, without limitation, any other trustee for the Plan. The Employer hereby agrees that the Trustee shall not serve as, and shall not be deemed to be, a co -trustee under the circumstances, and shall have no co -fiduciary liability for any other person or trustee. SECTION 6 - COMPENSATION EXPENSES, TAXES, INDEMNIFICATION 6.1 Compensation and Expenses. (a) Compensation. The Trustee shall be entitled to compensation for services under this Agreement as set forth in Exhibit A and as otherwise provided for in this Agreement. The Named Fiduciary acknowledges that the Trustee may increase the amount of compensation on an annual basis with sixty (60) days' prior written notice to the Named Fiduciary. (b) Interest on Uninvested Cash. The Trustee shall also be entitled to receive as part of its compensation any amounts earned under Section 3.1(f) related to earnings on deposits. Such earnings shall include earnings on uninvested cash related to Plan contributions and earnings on uninvested cash pending distribution, or earnings on cash otherwise held uninvested as directed by Employer. El (c) Authorization. The Trustee shall also be authorized to charge and collect expenses incurred by it in the discharge of its duties under this Agreement in accordance with Section 3.1 The Trustee is authorized to charge and collect from the Fund any and all such fees and expenses, unless the Named Fiduciary objects within 30 days of receiving notice of the Trustee's intent to collect its fees and expenses from the Fund. 6.2 Tax Obliizations., To the extent an Authorized Party has provided necessary information to the Trustee, the Trustee may use reasonable efforts to assist such Authorized Party to notify the Employer or the Plan (as appropriate) of any responsibility for payment of taxes, withholding, certification and reporting requirements, claims for exemptions or refund, interest, penalties and other related expenses of the Fund ("Tax Obligations"). Notwithstanding the foregoing, the Trustee shall have no responsibility or liability for any Tax Obligations now or hereafter imposed on the Employer or the Fund by any taxing authorities, domestic or foreign, except as provided by applicable law. To the extent the Trustee is responsible under any applicable law for payment of any Tax Obligation on behalf of the Fund or the Trust, the Employer shall cause the appropriate Authorized Party to inform the Trustee of all Tax Obligations, shall direct the Trustee with respect to the performance of such Tax Obligations, and shall provide the Trustee with all information required by the Trustee to meet such Tax Obligations. 6.3 Indemnification. The Employer and the Plan, shall indemnify and hold harmless the Trustee from all claims, liabilities, losses, damages and expenses, including reasonable attorney's fees and expenses (including Tax Obligations) incurred by the Trustee in connection with this Agreement, except as a result of the Trustee's own negligence or willful misconduct. 6.4 Force Maj eure. The Trustee shall not be responsible or liable for any losses to the Fund resulting from nationalization, expropriation, devaluation, seizure, or similar action by any governmental authority, de facto or de jure; or enactment, promulgation, imposition or enforcement by any such governmental authority of currency restrictions, exchange controls, levies or other charges affecting the Fund's property; or acts of war, terrorism, insurrection or revolution; or acts of God; or any other similar event beyond the control of the Trustee or its agents. This Section shall survive the termination of this Agreement. 6.5 Survival. This Section Six (6) shall survive the termination of this Agreement. SECTION 7 - AMENDMENT, TERMINATION, RESIGNATION, REMOVAL 7.1 Amendment. The Trustee may amend this Agreement as necessary to comply with the provisions of applicable law and regulations. The Trustee shall deliver written notice of any such amendment to the Employer. Other amendments may be made by written agreement signed by the parties hereto. 7.2 Removal or Resignation of Trustee. The Trustee may be removed with respect to all or part of the Fund upon receipt of sixty (60) days' written notice from the Employer. The Trustee may resign as Trustee hereunder upon sixty (60) days' written notice delivered to the Employer. In the event of such removal or resignation, the successor trustee will be appointed by the Employer, and the retiring Trustee shall transfer the Fund, less such amounts as may be reasonable and necessary to cover its compensation and direct expenses including but not limited to, a pro-rata share of the fees described in Section 6.1. In the event the Employer fails to appoint a successor trustee within sixty (60) days of receipt of written notice of resignation, the Trustee reserves the right to seek the appointment of a successor trustee from a court of competent jurisdiction. The Employer shall indemnify the Trustee from any costs incurred by the Trustee in seeking such appointment. The Trustee shall have no duties, responsibilities or liability with respect to the acts or omissions of any successor trustee. 7.3 Merger or Consolidation of Trustee. Any entity into which the Trustee may be merged or with which it may be consolidated, or any entity resulting from any merger or consolidation to which the Trustee is a party, or any entity succeeding to the trust business of the Trustee, shall become the successor of the Trustee hereunder, without the execution or filing of any instrument or the performance of any further act on the part of the parties hereto. 7.4 Plan Termination. Upon termination of the Plan, the Trustee shall distribute all assets then constituting the Fund, less any fees and expenses payable from the Fund, pursuant to the instructions of the 5 Employer. The Trustee shall be entitled to assume that such distributions are in full compliance with and not in violation of the terms of the Plan or any applicable law. 7.5 Property Not Transferred. The Trustee reserves the right to retain such property as is not suitable for distribution or transfer at the time of the termination of the Plan or this Agreement and shall hold such property for the benefit of those persons or other entities entitled to such property until such time as the Trustee is able to make distribution. The Employer shall indemnify the Trustee from any costs incurred by the Trustee for retaining the property until it can be distributed. Upon the appointment and acceptance of a successor trustee, the Trustee's sole duties shall be those of a custodian with respect to the property not transferred. SECTION 8 - ADDITIONAL PROVISIONS 8.1 Assignment or Alienation._ Except as may be provided by law, the Fund shall not be subject to any form of attachment, garnishment, sequestration or other actions of collection afforded creditors of the Employer, participants or beneficiaries under the Plan. The Trustee shall not recognize any assignment or alienation of benefits unless an Authorized Instruction is received. 8.2 Goveminp, Law. This Agreement shall be construed in accordance with and governed by the laves of the State of Connecticut. 8.3 Necessm Parties._ The Trustee reserves the right to seek a judicial or administrative determination as to its proper course of action under this Agreement. Nothing contained herein will be construed or interpreted to deny the Trustee, or the Employer the right to have the Trustee's account judicially determined. To the extent permitted by law, only the Trustee and_ the Employer shall be necessary parties in any application to the courts for an interpretation of this Agreement or for an accounting by the Trustee, and no participant under the Plan or other person having an interest in the Fund shall be entitled to any notice or service of process. Any final judgment entered in such an action or proceeding shall, to the extent permitted by law, be conclusive upon all persons. The Employer shall indemnify the Trustee for any costs incurred by the Trustee in seeking such judgment. 8.4 Notices. All notices and other communications hereunder shall be in writing and shall be sufficient if delivered by hand or if sent by telefax or mail (including electronic mail), postage prepaid, addressed: (a) If to the Trustee: Molly Garret _ Vice President ING Life Insurance and Annuity Company One Orange Way, C3N Windsor, Connecticut 06095-4774 J. Denise Jackson President ING National Trust One Orange Way, C4R Windsor, Connecticut 06095-4774 (b) If to the Employer: The parties may by like notice, designate any future or different address to which subsequent notices shall be sent. Any notice shall be deemed given when received. 2 8.5 No Third Party Beneficiaries. The provisions of this Agreement are intended to benefit only the parties hereto, their respective successors and assigns, and participants and their beneficiaries under the Plan. There are no other third party beneficiaries. 8.6 Execution in Counterparts. This Agreement may be executed in any number of counterparts, each of which shall be deemed an original, and said counterparts shall constitute but one and the same instrument and may be sufficiently evidenced by one counterpart. IN WITNESS WHEREOF, the parties hereto have executed this Agreement as of the effective date set forth above. Employer ING National Trust By: Name: Title: By: Name: Title: 7 EXHIBIT A FEES In consideration for services rendered according to the terms of this Agreement, the Trustee shall be paid according to the following fee schedule: $750 for each calendar year: No explicit charge to the plan. Included as part of compensation received by ILIAC for its performance of recordkeeping services [-Ohl INCUMBENCY CERTIFICATE — AUTHORIZED PARTIES , (the "Employer") hereby certifies that the persons whose names appear below are Authorized Parties to act on behalf of the Employer and the - and to direct and instruct the ING National Trust through Authorized Instructions in accordance with Section 2.2 and Section 2.3 of the Trust agreement between the Employer and ING National Trust, as Trustee dated insert date. - NAME EMPLOYER BY: TITLE : DATE: SIGNATURE 6 liL1111L11 ING SPECIMEN 457(b) DEFERRED COMPENSATION PLAN FOR GOVERNMENTAL EMPLOYERS BASIC PLAN DOCUMENT This specimen plan document, consisting of a basic plan document and adoption agreement, is for illustrative purposes only presented by ING for consideration of a plan sponsor's legal counsel and reflects a good faith interpretation of the Internal Revenue Code and 457 regulations. Because specific facts, circumstances, and laws of various states may impact a 457(b) plan, interested parties should consult legal counsel regarding any modifications that may be required. This document has not been reviewed or approved by the Internal Revenue Service, and the submission of the document to the IRS for a Private Letter Ruling by any interested party is also solely the responsibility of the plan sponsor. ING may update this specimen document from time to time as new guidance become available. Therefore, modifications to the document may be required. (10/11) 0 2011 ING North America Insurance Corporation. TABLE OF CONTENTS Preamble Article I — Definitions Article II — Participation Article III — Contributions and Limitations Article IV — Benefit Distributions Article V — Administration Article VI — Amendment and Termination Article VII — Miscellaneous This specimen plan is intended to assist you and your counsel in adopting a governmental 457(b) plan. Modifications may be required to meet your plan's particular objectives. (10/11) SPECIMEN DOCUMENT SPECIMEN 457(b) DEFERRED COMPENSATION PLAN FOR GOVERNMENTAL EMPLOYERS PREAMBLE The Employer hereby establishes the Code Section 457(b) Deferred Compensation Plan for Governmental Employers (the "Plan"). The Plan is established pursuant to applicable state law and is intended to comply with the provisions of Section 457(b) of the Internal Revenue Code of 1986, as amended, Income Tax Regulations thereunder and applicable law. The Plan consists of the provisions set forth in this basic plan document and the Adoption Agreement, and is applicable to each Eligible Individual. ARTICLE I DEFINITIONS As used in this Plan, the following words and phrases will have the meanings set forth herein unless a different meaning is clearly required by the context. 1.1 "Administrator" means the person(s), committee or organization appointed by the Employer pursuant to Section 5.2 to administer the Plan and perform administrative functions for the Plan as specified by the Employer. 1.2 "Adoption Agreement" means the separate agreement that is executed by the Employer and sets forth the elective provisions of the Plan. The Adoption Agreement is considered a part of the Plan. 1.3 ' "Age 50 Plus Catch -Up Contribution" means the catch-up contribution for Participants who attain'age 50 by the end of the calendar year, as permitted under Code Section 414(v) and pursuant to Section 3.3. 1.4 "Beneficiary" means the individual, individuals or trust designated by the Participant in writing on a form acceptable to the Administrator, and received by the Administrator before the Participant's death, to receive any undistributed amounts under the Participant Account which becomes payable upon the Participant's death. A Beneficiary may designate his own Beneficiary. If a Participant or Beneficiary does not designate a Beneficiary in a form acceptable to the Administrator, then his estate will be deemed to be his Beneficiary. In addition, any Beneficiary designation will meet the requirements of applicable state law. 1.5 "Code" means the Internal Revenue Code of 1986, as now in effect or as hereafter amended. All citations to sections of the Code are to such sections as they may from time to time be amended or renumbered. This specimen plan is intended to assist you and your counsel in adopting a governmental 457(b) plan. Modifications may be required to meet your plan's particular objectives. (10/11) 1.6 "Compensation" means for an Employee all cash compensation for services to the Employer, including salary, wages, fees, commissions, bonuses, and overtime pay, that is includible in the Employee's gross income for the calendar year, plus amounts that would be cash compensation for services to the Employer includible in the Employee's gross income for the calendar year but for a compensation reduction election under Code Sections 125, 132(f), 401(k), 403(b) or 457(b) (including an election under Article III to defer Compensation under the Plan). For purposes of an Independent Contractor, "Compensation" will mean all amounts payable to a Participant from the Employer as remuneration for services rendered which would be includible in income for federal tax purposes if not deferred under this Plan, subject to the provisions of the current Code. 1.7 "Deferrals" means the amount of Compensation deferred by a Participant to the Plan, comprising of Elective Deferrals and, if elected by the Employer in the Adoption Agreement and the Participant so elects on a Participation Agreement, Roth 457(b) Contributions. 1.8 "Elective Deferrals" means amounts made by the Employer to the Plan on a voluntary pre-tax basis pursuant to a Participation Agreement entered into by a Participant, 1.9 "Eligible Individual" means any Employee who is in one or more of the classifications specified in the Adoption Agreement, and, if elected by the Employer, may include Independent Contractors. 1.10 "Employee" means any common law employee who is employed by the Employer and who performs services for the Employer for which Compensation is payable. 1.11 "Employer" means a state or the District of Columbia, any political subdivision of a state or the District of Columbia, or any agency or instrumentality of a state or the District of Columbia, which satisfies the definition of Code Section 457(e)(1)(A) (together with any other entity required to be aggregated with such governmental employer under Code Sections 414(b), (c), (m) or (o)) and which has adopted this Plan as indicated in the Adoption Agreement. 1.12 "Includible Compensation" means an Employee's actual wages in box 1 of Form w-2 for the Employer, but increased (up to the dollar maximum) by any compensation reduction election under Code Section 125, 132(f), 402(g)(3) or 457(b). The amount of Includible Compensation is determined without regard to any community property laws. Pursuant to Section 1.457-4(d)(1) of the Income Tax Regulations, Includible Compensation will include any payments made to a Participant who has had a Severance from Employment, provided that the Includible Compensation is paid by the later of 2 %2 months after the Participant's Severance from Employment or the end of the calendar year that contains the date of such Participant's Severance from Employment. In addition, pursuant to Section 1.457-4(d)(1) of the Income Tax Regulations, Includible Compensation will include payments made to an individual who does not currently perform services for the Employer by reason of qualified military service (as defined in Code Section 414(u)(5)) to the extent those payments do not exceed the amount the individual would have received if the individual had continued to perform services for the Employer rather This specimen plan is intended to assist you and your counsel in adopting a governmental 457 plan. Modifications may be required to meet your plan's particular objectives. (10/11) 2 0 than enter qualified military service. Includible Compensation will not include Employee pick- up contributions described in Code Section 414(h)(2). 1.13 "Independent Contractor" means any person to whom Compensation from the Employer is payable for services rendered pursuant to one or more written or oral contracts, if such person is not a common-law employee. 1.14 "In -Plan Roth Rollover" means a rollover contribution to the Plan that consists of a distribution from an Elective Deferral Account, a 457(b) Rollover Account or a non-457(b) Rollover Account under the Plan that the Participant rolls over to the Participant's In -Plan Roth 457(b) Rollover Account in the Plan, in accordance with Code Section 402A(c)(4). 1.15 "Investment Product" means group or individual annuity contracts or such other investment arrangements issued by or offered through the Provider and used to hold assets of the Plan. 1.16 "Normal Retirement Age" means the age as elected by the Employer in the Adoption Agreement that is used for the Special 457 Catch-up Contribution election under Section 3.2. The Employer is not permitted to have more than one Normal Retirement Age for each Participant under all plans under Code Section 457(b) that it (together with any other entity required to be aggregated with the Employer under Code Section 414(b), (c), (m) or (o)) sponsors. 1.17 "Participant" means any 10 individual who has entered into a Participation Agreement to make Deferrals under the Plan or has previously made Deferrals under the Plan and who has not yet received a distribution of his entire Participant Account under the Plan. As appropriate, a Participant means a Beneficiary or an alternate payee as defined in Code Section 414(p)(8). 1.18 "Participant Account" means the following accounts established for the Participant and maintained by the Administrator for each Participant, including any earnings and losses attributable thereon: (a) Elective Deferral Account, (b) Roth 457(b) Contributions Account, (c) 457(b) Rollover Account, (d) Non-457(b) Rollover Account, (e) Roth 457(b) Rollover Account, (f) Roth Non-457(b) Rollover Account, (g) Rollover of In -Plan Roth Non-457(b) Rollover Account; and (h) In -Plan Roth 457(b) Rollover Account. 1.19 "Participation Agreement" means an agreement, which meets the requirements of Section 2.4, entered into between an Eligible Individual and the Employer pursuant to which an This specimen plan is intended to assist you and your counsel in adopting a governmental 457 plan. Modifications may be required to meet your plan's particular objectives. (10/11) 3 Eligible Individual agrees to defer Elective Deferrals and/or Roth 457(b) Contributions to the Plan and thus to become a Participant. 1.20 "Plan" means the name of the Plan as indicated in the Adoption Agreement. 1.21 "Plan Year" means the Plan's 12-consecutive month accounting year as elected by the Employer in the Adoption Agreement. 1.22 "Provider" means ING Life Insurance and Annuity Company and/or ReliaStar Life Insurance Company or such other provider entity as the Employer may approve. 1.23 "Rollover Contribution" means, if so elected by the Employer in the Adoption Agreement, contributions made by a Participant (or, if applicable, Eligible Individual) of "eligible rollover distributions" in accordance with Code Section 402(c)(4). 1.24 "Roth 457(b) Contributions" means, if so elected by the Employer in the Adoption Agreement, contributions that are: (a) made by the Employer to the Plan pursuant to a Participation Agreement entered into by a Participant, which qualifies as a "designated Roth contribution" within the meaning of Code Section 402A; (b) irrevocably designated by the Participant at the time of the cash or deferred election as a Roth 457(b) Contribution that is being made in lieu of all or a portion of the Elective Deferrals the Participant is otherwise eligible to make under the Plan; and (c) treated by the Employer as includible in the Participant's income at the time the Participant would have received that amount in cash if the Participant had not made a cash or deferred election. 1.25 "Severance from Employment" means the date on which the Employee dies, retires or otherwise has a severance from employment with the Employer, as determined by the Administrator. 1.26 "Special Section 457 Catch-up Contributions" means the catch-up contribution for a Participant in the three consecutive years prior to the year in which the Participant reaches Normal Retirement Age, as permitted under Code Section 457(b)(3) and pursuant to Section 3.2. 1.27 "Unforeseeable Emergency" means a financial hardship of the Participant or Beneficiary resulting from: (a) An illness or accident of: (1) the Participant or the Beneficiary (2) the spouse of the Participant or Beneficiary, or (3) the dependent of the Participant or Beneficiary; This specimen plan is intended to assist you and your counsel in adopting a governmental 457 plan. Modifications may be required to meet your plan's particular objectives. (10/11) 0 (b) Loss of the Participant's or Beneficiary's property due to casualty; or (c) Similar extraordinary and unforeseeable circumstances arising as a result of events beyond the control of the Participant or Beneficiary. In addition, if elected by the Employer in the Adoption Agreement, an Unforeseeable Emergency means a severe financial hardship of the Participant resulting from an illness or accident of a primary Beneficiary designated by the Participant under the Plan. A determination of an Unforeseeable Emergency will be based on each Participant's and Beneficiary's specific facts and circumstances. ARTICLE II PARTICIPATION 2.1 Eligibility Each Eligible Individual will be a Participant in the Plan when he satisfies the eligibility requirements specified by the Employer in the Adoption Agreement and has executed a Participation Agreement. 2.2 Determination of Eligibility and Effective Date of Participation (a) The Administrator will determine whether an Eligible Individual has satisfied the eligibility requirements specified by the Employer in the Adoption Agreement based upon information furnished by the Employer. Such determination will be conclusive and binding and the criteria for such determination will be applied uniformly to all Participants. (b) The Participant will provide investment direction for contributions made to an Investment Product on such forms as may be required by the Provider. 2.3 Termination of Eligibility In the event a Participant will go from a classification of an Eligible Individual to a non -Eligible Individual, such Participant will not be able to make Deferrals to the Plan until he is again reclassified as an Eligible Individual. The Participant Account of such inactive Participant will continue to be allocated any attributable earnings and losses based on the investment direction supplied by the Participant. This specimen plan is intended to assist you and your counsel in adopting a governmental 457 plan. Modifications may be required to meet your plan's particular objectives. (10/11) 5 2.4 Participation Agreements (a) In order to participate in the Plan, a Participant must complete a Participation Agreement with the Employer and file such Participation Agreement in a manner and method determined by the Administrator. The Participation Agreement will specify: (1) The amount (expressed either as a dollar amount or as a percentage) of the Participant's Compensation which the Participant agrees to make as Deferrals, subject to the limitations of Article III; and (2) The date as of which Deferrals pursuant to the Participation Agreement will begin. (b) A Participant may make Deferrals payable in the calendar month during which the Eligible Individual first becomes a Participant if the Participation Agreement providing for such Deferrals is entered into before the first day of the month in which the Compensation is paid or becomes available. (c) Notwithstanding subsection (b), a new Employee who is also an Eligible Individual may become a Participant and make Deferrals payable in the calendar month during which he first becomes an Employee if a Participation Agreement providing for the Deferrals is entered into on or before the first day on which he performs services for the Employer. (d) A Participant may, by amendment of a Participation Agreement or by any manner as the Administrator may prescribe, do any of the following: (1) change the specification of the investment for any contributions to a Participant Account under an Investment Product; or (2) change prospectively the amount of Deferrals. An amendment to the Participation Agreement will be effective as early as administratively practicable, but not earlier than the first day of the following calendar month in which the Compensation is paid or made available. 2.5 Information Provided by the Employee Each Eligible Individual enrolling in the Plan should provide to the Administrator at the time of initial enrollment, and later if there are any changes, any information necessary for the Administrator to administer the Plan, including, without limitation, whether he is a participant in any other eligible plan under Code Section 457(b). 2.6 Contributions Made Promptly All contributions under the Plan will be transferred to the applicable Investment Product within a period that is not longer than is reasonable for the proper administration of the Participant Accounts. For purposes of this requirement, Deferrals under the Plan by a Participant must be This specimen plan is intended to assist you and your counsel in adopting a governmental 457 plan. Modifications may be required to meet your plan's particular objectives. (10/11) transferred to the Investment Product within 15 business days following the month in which these amounts would otherwise have been paid to the Participant. 2.7 Leave of Absence Unless an election is otherwise revised, if an Employee is absent from work by leave of absence, Deferrals under the Plan will continue to the extent that Compensation continues. ARTICLE III CONTRIBUTIONS AND LIMITATIONS 3.1 Deferrals (a) Except as provided in Section 3.2 and 3.3 and subject to any applicable law or under any applicable collective bargaining agreement, the maximum amount of Deferrals which may be made by a Participant in any taxable year will not exceed the lesser of (1) the applicable dollar amount provided under Code Section 457(b)(2) (adjusted for cost of living under Code Section 457(e)(15)) or (2) 100% of the Participant's Includible Compensation. (b) If elected by the Employer in the Adoption Agreement, a Participant may elect to make Deferrals from accumulated sick pay, accumulated vacation pay and back pay, provided the Participant enters into a Participation Agreement pursuant to Section 2.4 to make such Deferrals before the amounts would otherwise be paid or made available. A Participant who is a former Employee may make Deferrals from accumulated sick pay, vacation pay and back pay, provided that the Participant enters into a Participation Agreement pursuant to Section 2.4 prior to the first day of the calendar month to make such Deferrals before the amounts would otherwise be paid or made available, provided that such amounts are payable within the later of 2 1/2 months after the Participant's Severance from Employment or the end of the calendar year that includes the date of the Participant's Severance from Employment. 3.2 Special 457 Catch -Up Contributions (a) In any one or more of a Participant's last three calendar years ending before the year in which the Participant attains Normal Retirement Age, as defined by the Employer in the Adoption Agreement, the Participant may elect to make Deferrals in an amount not exceeding the lesser of (1) twice the dollar amount permitted as a general deferral under Section 3.1 or (2) the sum of the maximum deferral permitted under Section 3.1 for the current tax year and as much of the applicable deferral limit under Code Section 457(b)(2) in prior years before the current tax year that had not previously been used ("underutilized amount"). For purposes of this Section, a prior year will be taken into account only if such year began after December 31, 1978, and the Participant was eligible to participate in the Plan during all or a portion of the prior year. A Participant may only make this election under this subsection once with respect to an plan p Y under Code Section 457(b) of the Employer. This specimen plan is intended to assist you and your counsel in adopting a governmental 457 plan. Modifications may be required to meet your plan's particular objectives. (10/11) 7 (b) In determining a Participant's underutilized amount, the Plan will take into consideration: (1) Prior to 2002, if a Participant made Deferrals to the Plan and deferrals to any other plan under Code Section 457(b), salary reduction contributions made to plans under Code Section 401(k), plans under Code Section 403(b), simplified employee pension (SARSEP) plans under Code Section 402(h)(1), simple retirement accounts under Code Section 408(p), and amounts deferred under any plan for which a deduction is allowed because of a contribution to an organization described in Code Section 501(c)(18), such deferrals to the other plans will be taken into account in determining a Participant's underutilized amount under Code Section 457(b)(2). In addition, Includible Compensation will be limited to the limitation in effect in the calendar year in which the deferrals were made. If such deferrals cumulatively exceed the then -applicable dollar amount in Code Section 457(b)(2) in the year that such amounts were deferred, then there will be no underutilized amount for that year. (2) To the extent that the Employer did not maintain a plan under Code Section 457(b), no underutilized limitation is available to a Participant for that prior year. (3) After 2001, only deferrals to plans under Code Section 457(b) will be taken into account for purposes of determining the underutilized amount. (4) Age 50 Plus Catch -Up Contributions will not be taken into account for purposes of determining a Participant's underutilized amount. 3.3 Age 50 Plus Catch -Up Contributions If elected by the Employer in the Adoption Agreement, a Participant who has attained age 50 before the close of the calendar year may elect Age 50 Plus Catch-up Contributions. Such contributions are not subject to the limitations of Code Section 457(b). The maximum dollar amount of the Age 50 Plus Catch-up Contributions for a calendar year adjusted for cost of living under Code Section 414(v)(2)(C). 3.4 Maximum Amount of Catch -Up Contributions Any catch-up contributions made by a Participant pursuant to Section 3.2 or Section 3.3 may not exceed the greater of (a) the amount that the Participant is eligible to make as Deferrals under Section 3.2 or (b) the amount that the Participant is eligible to make as Deferrals under Section 3.3. 3.5 Participant Covered by More than one 457(b) Plan If a Participant is or has been a participant in one or more other plans under Code Section 457(b) in the same calendar year, then the Plan and all such other plans will be considered as one plan for purposes of applying the limitations of this Article III. For this purpose, the Administrator This specimen plan is intended to assist you and your counsel in adopting a governmental 457 plan. Modifications may be required to meet your plan's particular objectives. (10/11) 0 will take into account any other such plan of the Employer under Code Section 457(b) and, to the extent the Participant provides the Administrator with sufficient information concerning his participation, any such other plans under Code Section 457(b) in which the individual participated in the same calendar year. 3.6 Excess Deferrals (a) In the event that the limit on Deferrals is exceeded pursuant to this Article III, the Administrator will direct the Provider as to the proper correction method permissible under applicable law, including calculation of any earnings or losses and the proper tax reporting with respect to such distributions as soon as administratively practicable after the Administrator determines that the amount is an excess deferral. (b) A Participant who participates in the Plan and another 457(b) plan of another employer will be responsible for complying with the deferral limits of this Article III. In the event of an excess amount, the Participant will notify the Administrator so that the excess may be distributed as soon as practicable after the Administrator determines that the amount is an excess deferral. 3.7 Transfers from Other Plans under Code Section 457(b) (a) If elected by the Employer in the Adoption Agreement, the Plan will accept transfers of amounts previously deferred under another plan under Code Section 457(b) maintained by another employer as defined in Code Section 457(e)(1)(A). (b) A transfer under subsection (a) will only be permitted if: (1) the transferring plan provides for the transfer of such amounts, and (2) the Participant has a benefit equal to the amount immediately after the transfer to least equal to the amount under the Plan immediately before the transfer. (c) The Administrator may require such documentation from the transferring plan as . g it deems necessary to effectuate the transfer in accordance with Section 1.457-10(b) of the Income Tax Regulations and to confirm that the transferring plan is an eligible government plan as defined in Section 1.457-2(f) of the Income Tax Regulations. The amount so transferred will be credited to the appropriate account under the Participant Account and will be held accounted for, administered and otherwise treated in the same manner as amounts as held in the transferor plan, except that the transferred amounts will not be taken into consideration for purposes of Code Section 457(b)(2) for the year of transfer. This specimen plan is intended to assist you and your counsel in adopting a governmental 457 plan, Modifications may be required to meet your plan's particular objectives. (10/I 1) 9 n 3.8 Rollovers to the Plan (a) The Employer may elect in the Adoption Agreement to permit an Eligible Individual, whether a Participant at the time, to rollover amounts that are considered eligible rollover distributions as defined in Code Section 402(c)(4) to the Plan from an eligible retirement plan, as defined in Code Section 402(c)(8)(B). (b) Amounts (other than designated Roth contributions as defined in Code Section 402A) rolled over from another Code Section 457(b) plan maintained by an employer defined in Code Section 457(e)(1)(A) will be allocated to the Participant's 457(b) Rollover Account. Amounts (other than designated Roth contributions as defined in Code Section 402A) rolled over from an eligible retirement plan that is not a Code Section 457(b) plan will be allocated to the Participant's Non-457(b) Rollover Account. (c) Designated Roth contributions as defined in Code Section 402A rolled over from another Code Section 457(b) plan maintained by an employer as defined in Code Section 457(e)(1)(A) will be allocated to the Participant's Roth 457(b) Rollover Account. Designated Roth contributions as defined in Code Section 402A rolled over from an eligible retirement plan that is not a Code Section 457(b) plan will be allocated to the Participant's Roth Non-457(b) Rollover Account. (d) Designated Roth contributions relating to in -plan rollovers under Code Section 402A(c)(4) rolled over from an eligible retirement plan that is not a Code Section 457(b) plan will be allocated to the Participant's Rollover of In -Plan Roth Non-457(b) Rollover Account. (e) Amounts attributable to In -Plan Rollovers will be allocated to an In -Plan Roth 457(b) Rollover Account. In -Plan Roth Rollover Contributions will be subject to the Plan rules related to Roth 457(b) Contributions. 3.9 Investments Subject to Section 5.9, amounts contributed to the Plan will be invested in an Investment Product. Participants will direct the investment of their Participant Accounts among the investment options available under the Investment Product. Contributions will be allocated to a Participant Account in accordance with this Article III and earnings and losses attributable to such contributions will be allocated to such Participant Account. If any provision of an Investment Product agreement is not consistent with the Plan provisions, the terms of the Plan will control. 3.10 Protection of Persons Who Serve In a Uniformed Service (a) An Employee whose employment is interrupted by qualified military service under Code Section 414(u) or who is on a leave of absence for qualified military service under Code Section 414(u) may elect to make additional Deferrals upon resumption of employment This specimen plan is intended to assist you and your counsel in adopting a governmental 457 plan. Modifications may be required to meet your plan's particular objectives. (10/11) 10 with the Employer equal to the maximum Deferrals that the Employee could have elected during that period if the Employee's employment with the Employer had continued (at the same level of Compensation) without the interruption or leave, reduced by the Deferrals, if any, actually made for the Employee during the period of the interruption or leave. Except to the extent provided under Code Section 414(u), this right applies for five years following the resumption of employment (or, if sooner, for a period equal to three times the period of the interruption or leave). (b) In the case of a Participant who dies while performing qualified military service (as defined in Code Section 414(u)), the Beneficiaries are entitled to any additional benefits (other than Deferrals relating to the period of qualified military service) provided under the Plan had the Participant resumed employment and then had a Severance from Employment on account of death. ARTICLE IV BENEFIT DISTRBUTIONS 4.1 Distributions Under the Plan (a) A Participant Elective Deferral Account, Roth 457(b) Contributions Account or In -Plan Roth 457(b) Rollover Account may not be paid to a Participant (or, if applicable, the Beneficiary) until one of the following events has occurred: (1) upon the Participant's Severance from Employment; (2) the calendar year in which the Participant attains age 70 Y2; (3) an Unforeseeable Emergency, within the meaning of and subject to Section 4.6, if elected by the Employer in the Adoption Agreement; or (4) the election of a small balance distribution within the meaning of and subject to Section 4.7, if elected by the Employer in the Adoption Agreement. (b) A Participant may choose to receive a distribution from his 457(b) Rollover Account, Non-457(b) Rollover Account, Roth 457(b) Rollover Account, Rollover of In -Plan Roth Non-457(b) Rollover Account and Roth Non-457(b) Rollover Account at the time elected by the Employer in the Adoption Agreement. (c) An Independent Contractor will be considered to have a Severance from Employment upon the expirat16 ion of all of the contracts under which services are performed for the Employer, if the expiration constitutes a good faith and complete termination of the contractual relationship. An expiration of such contractual relationship will not be considered to be a good faith and complete termination if the Employer anticipates a renewal of such contractual relationship or the Independent Contractor becomes an Employee. 4.2 Distributions from a Roth 457(b) Contributions Account, a Roth 457(b) Rollover Account, a Roth Non-457(b) Rollover Account, a Rollover of In -Plan Roth Non-457(b) Rollover This specimen plan is intended to assist you and your counsel in adopting a governmental 457 plan. Modifications may be required to meet your plan's particular objectives. (10/11) 0 Account and an In -Plan Roth 457(b) Rollover Account, will be tax-free for federal income tax purposes if: (1) The distribution meets the requirements of Section 4.1(a); (2) The amounts are held fora 5-year holding period, measured from the first year that the initial Roth 457(b) Contribution was made on behalf of the Participant to a Roth 457(b) Contributions Account, and (3) The distribution is due to a Participant's attainment of age 591/2, death, or in the event of the Participant's becoming Disabled. 4.3 Determination of Benefits Payable to a Participant (a) Upon attainment of a distributable event described in Section 4.1, but in no event later than the requirement to commence minimum distribution payments in accordance with Code Section 401(a)(9) and the Income Tax Regulations thereunder, a Participant may elect a benefit distribution option to which benefits will be paid. (b) pUpon a Participant's application for benefits, the Administrator will direct the distribution of a Participant Account in accordance with this Section 4.2. (c)A Participant may choose a benefit distribution option as elected by the Employer in the Adoption Agreement. In the event a Participant fails to make an election as to a benefit distribution option, any benefit payable to such Participant will be distributed as elected by the Employer in the Adoption Agreement. The terms of any annuity contract purchased and distributed by the Plan to a Participant will comply with the requirements of the Plan. 4.4 Determination of Benefits Upon Death (a) pUpon the death of a Participant, the Administrator will direct that the deceased Participant's Participant Account, be distributed to the Beneficiary in accordance with the provisions of this Section. (b) The designation of a Beneficiary will be made on a form satisfactory to the Administrator. A Participant or Beneficiary may at any time revoke his designation of a Beneficiary or change his Beneficiary by filing written notice of such revocation or change with g . the Administrator. In the event no valid designation of Beneficiary exists at the time of the Participant's or Beneficiary's death, the death benefit will be payable to the Participant's or Beneficiary's estate. (c) The Administrator may require such proper proof of death and such evidence of the right of an person to receive payment of the value of the Participant Account of a deceased g YParticipant or Beneficiary, as the Administrator may deem appropriate. The Administrator's determination of death and of the right of any person to receive payment will be conclusive. This specimen plan is intended to assist you and your counsel in adopting a governmental 457 plan. Modifications may be required to meet your plan's particular objectives. (10/11) 12 (d) Death benefits payable to a Beneficiary will be made in a form as selected by the Beneficiary in accordance with the available options as elected by the Employer in the Adoption Agreement. In the event a Beneficiary fails to make an election as to a benefit distribution option, any benefit payable to such Beneficiary will be distributed in accordance with Code Section 401(a)(9). The terms of any annuity contract purchased and distributed by the Plan to a Beneficiary will comply with the requirements of the Plan. 4.5 Minimum Distributions. (a) All distributions under the Plan will comply with the minimum distribution requirements of Code Section 401(a)(9) and the Income Tax Regulations. ((b) Notwithstanding the foregoing, a Participant or Beneficiary who would have been required to receive required minimum distributions for 2009 but for the enactment of Code Section 401(a)(9)(H) ("2009 RMDs"), and who would have satisfied that requirement by receiving distributions that are (1) equal to the 2009 RMDs or (2) one or more payments in a series of substantially equal distributions (that include the 2009 RMDs) made at least annually and expected to last for the life (or life expectancy) of the Participant, the joint lives (or joint life expectancy) of the Participant and the Participant's Beneficiary, or for a period of at least 10 years ("Extended 2009 RMDs"), will not receive those distributions for 2009 unless the Participant or Beneficiary chooses to receive such distributions. Participants and Beneficiaries described in the preceding sentence will be given the opportunity to elect to receive the distributions described in the preceding sentence. (c) In addition, notwithstanding. Section 4.8, 2009 RMDs and Extended 2009 RMDs will be treated as eligible rollover distributions as defined in Code Section 402(c)(4). 4.6 Unforeseeable Emergency withdrawals (a) If elected by the Employer in the Adoption Agreement, a Participant or Beneficiary may request an Unforeseeable Emergency withdrawal subject to the following requirements: (1) The request for an Unforeseeable Emergency withdrawal will be determined by the Administrator based on the Participant's or Beneficiary's relevant facts and circumstances. (2) The request for an Unforeseeable Emergency may be made only to the extent that such emergency is or may not be relieved through: • reimbursement or compensation from insurance or otherwise; • liquidation of the Participant's or Beneficiary's assets, to the extent the liquidation of such assets would not itself cause severe financial hardship; or This specimen plan is intended to assist you and your counsel in adopting a governmental 457 plan. Modifications may be required to meet your plan's particular objectives. (10/1 l ) 13 • cessation of the Participant's Deferrals to the Plan. (3) Distributions due to an Unforeseeable Emergency must be limited to the amount reasonably necessary to satisfy the emergency need (which may include any amounts necessary to pay federal, state, or local income taxes or penalties reasonably anticipated to result from the distribution). (b) A Participant or Beneficiary may request an Unforeseeable Emergency withdrawal by submitting that request in writing on the Plan's approved form to the Administrator, who will review and approve the request. If the request is denied, a request for review of the determination may be made in writing to such entity as the Administrator may designate, provided that such entity has accepted the designation. If the review of the determination fails to confirm a claim of Unforeseeable Emergency, an appeal may be made to the appellate committee established by the Administrator in writing. If at any time a request of an Unforeseeable Emergency withdrawal is approved, the Employer may thereupon direct the Provider to distribute so much of the Participant Account as is necessary to provide the amount approved to meet the Unforeseeable Emergency, as determined by the Administrator. (c) Unforeseeable Emergency withdrawals will be made in accordance with the procedures established by the applicable Provider's Investment Products. 4.7 Small Balance Distribution If elected by the Employer in the Adoption Agreement and upon proper written request, a Participant may elect to receive a small balance distribution, payable in a lump sum, if the Participant's Deferral Account value is $5,000 or less, and the Participant has not made Deferrals to the Plan for a period of two years before distribution. A Participant may take a small balance distribution under this Section only once while a Participant under the Plan. 4.8 Rollovers From The Plan (a) Notwithstanding any provision of the Plan to the contrary, a Participant, a surviving spouse who is the designated Beneficiary of the Participant or a spouse or former spouse who is the alternate payee will be permitted to elect to have any eligible rollover distribution as defined in Code Section 402(c)(4) paid directly to an eligible retirement plan as defined in as defined in Code Section 402(c)(8)(B) or to a Roth IRA established under Code Section 408A specified by the Participant. The Participant will, in the time and manner prescribed by the Administrator, specify the amount to be rolled over and the eligible retirement plan to receive such rollover. Any portion of a distribution which is not rolled over will be distributed directly to the Participant. This specimen plan is intended to assist you and your counsel in adopting a governmental 457 plan. Modifications may be required to meet your plan's particular objectives. (10/11) 14 (b) Anon -spousal Beneficiary may elect to roll over death benefits amounts in accordance with Code Section 402(c)(11) provided that: (1) such amounts are rolled over to an inherited IRA via a direct trustee -to -trustee transfer; (2) such election is made by December 31 of the year following the year of the Participant's death; and (3) the rolled over amounts are eligible rollover distributions as defined in Code Section 402(c)(4). 4.9 Permissive Service Credit Transfers (a) If a Participant is also a participant in a tax qualified defined benefit governmental plan (as defined in Code Section 414(d)) that provides for the acceptance of plan -to -plan transfers with respect to the Participant, then the Participant may elect to have any portion of his Participant Account transferred to the defined benefit governmental plan in accordance with Code Section 457(e)(17). A transfer under this Section may be made before the Participant has had a Severance from Employment. (b) A transfer may be made under subsection (a) only if the transfer is either for the purchase of permissive service credit (as defined in Code Section 415(n)(3)(A)) under the receiving defined benefit governmental plan or a repayment to which Code Section 415 does not apply by reason of Code Section 415(k)(3). 4.10 Transfers to Other Plans under Code Section 457(b) Upon Severance From Employment (a) Upon a Participant's Severance from Employment, a Participant may elect to have all or a portion of the Participant Account transferred to the plan under Code Section 457(b) of an employer defined in Code Section 457(e)(1)(A). Such amounts will be transferred at the Participant's election, provided: (1 } The plan under Code Section 457(b) to which the Participant's benefit is being transferred provides for the acceptance of such amounts; (2) The Participant or Beneficiary has a benefit equal to the amount immediately after the transfer to least equal to the amount under the Plan immediately before the transfer; and (3) In the case of a transfer made on behalf of a Participant, such individual has had a Severance from Employment with the Employer and is performing services for the employer maintaining the receiving plan. This specimen plan is intended to assist you and your counsel in adopting a governmental 457 plan. Modifications may be required to meet your plan's particular objectives. (10/1 I ) (b) Upon the transfer of amounts under subsection (a), the Plan's liability to pay benefits to the Participant or Beneficiary under the Plan will be discharged to the extent of the amount so transferred on behalf of the Participant or Beneficiary. The Administrator may require such documentation from the receiving plan as it deems appropriate or necessary to q comply with this Section or effectuate the transfer pursuant to Section 1.457-10(b) of the Income Tax Regulations. If Roth 457(b) Contributions are transferred, the receiving plan must permit Designated Roth contributions as defined in Code Section 402A. 4.11 Loans to Participants (a) If elected by the Employer in the Adoption Agreement, a Participant may receive a loan from his Elective Deferral Account, 457(b) Rollover Account and non-457(b) Rollover Account. Such loans may also be subject to the requirements of the Investment Product. (b) For purposes of this Section, all plans of the Employer will be considered one plan in accordance with Code Section 72(p) and Income Tax Regulations thereunder, and the balance of all loans under any plan of the Employer under which the Participant participates must be ag gregated in determining the maximum loan available under subsection (d). (c) The Provider may, in accordance with the Administrator's direction, make loans to Participants under the following circumstances: (1) loans will be made available to all Participants on a reasonably equivalent basis; (2) loans will bear a reasonable rate of interest, (3) loans will- be adequately secured; and (4) will provide for periodic repayment over a reasonable q y period of time. (d) No loan made pursuant to this Section will exceed the lesser of: 1 $50,000 reduced by the excess (if any) of the highest outstanding balance of loans from the Plan to the Participant during the one-year period ending on the day before the date on which such loan is made, over the outstanding balance of loans from the Plan to the Participant on the date on which such loan was made, or (2) one-half (1/2) of the Participant Account. For purposes of this Section, any loan from any other plan maintained by the Employer will be treated as if it were a loan made from the Plan, and the Participants vested interest under any such other plan will be considered a vested interest under this Plan; provided, however, that the provisions of this paragraph will not be applied so as to allow the amount of a loan to exceed the p p g amount that would otherwise be permitted in the absence of this paragraph. (e) Loans will provide for level amortization with payments to be made not less frequently than quarterly over a period not to exceed five (5) years. However, loans used to acquire any dwelling unit which, within a reasonable time, is to be used (determined at the time the loan is made) as a principal residence of the Participant will, provide for periodic repayment This specimen plan is intended to assist you and your counsel in adopting a governmental 457 plan. Modifications may be required to meet your plan's particular objectives. (10/11) 16 over a reasonable period to be determined by the Administrator of time that may exceed five (5) years. Notwithstanding the foregoing, in the event a Participant enters the uniformed services of the United States and retains reemployment rights under law, repayments will be suspended and interest will cease to accrue during the period of leave and the period of repayment will be extended by the number of months of leave in the uniformed services. In the event a Participant is on an Employer approved, bona fide leave of absence without payments may pay, loan aY Y ments be suspended (but interest will continue to accrue) for the period of leave but not to exceed one year; however, the loan must be repaid by the original loan repayment date. (f) An assignment or pledge of any portion of a Participant's interest in the Plan will be treated as a loan under this Section. (g) Any security interest held by the Plan by reason of an outstanding loan to the Participant will be taken into account in determining the amount of the death benefit or single lump -sum payment. 4.12 Distributions from Governmental Plans for Health and Long Term Care. If elected by the Employer in the Adoption Agreement and pursuant to Code Section 457(a)(3), annual distributions of up to $3,000 from the Plan that would other be taxable, are excludable for income tax purposes if the following conditions are satisfied: (1) the distribution is used to pay for qualified health insurance premiums (accident, health insurance or long term care) for an eligible public safety officer, or spouse or dependent of the public safety officer, (2) the public safety officer is separated from service due to disability or attainment of the age which the Participant has the right to retire and receive unreduced retirement benefits from the Employer's basic pension plan, and (3) the distributions are paid directly to the insurer or to the administrator of a self -insured plan. ARTICLE V ADMINISTRATION 5.1 Powers and Responsibilities of the Employer (a) The Employer will have full power to interpret and construe the Plan in a manner consistent with its terms and the provisions of Code Section 457, including the applicable Income Tax Regulations and to establish practices and procedures conforming to those provisions. In all such cases, the Employer's determination will be final and conclusive upon all persons. It is recognized that unusual circumstances may occur and questions may arise that are not specifically covered by any provision of the Plan, and the Employer will have the right to resolve all such questions. Notwithstanding the above, the Employer's power and responsibility under the Plan will not extend to, nor have any control over, those responsibilities and duties of the Provider. This specimen plan is intended to assist you and your counsel in adopting a governmental 457 plan. Modifications may be required to meet your plan's particular objectives. (10/11) 17 (b) The Employer will be empowered to appoint and remove the Administrator from time to time as it deems necessary for the proper administration of the Plan to assure that the Plan is being operated for the exclusive benefit of the Participants and their Beneficiaries in accordance with the terms of the Plan and the Code. (c) The Employer will periodically review the performance of any person to whom duties have been delegated or allocated by it under the provisions of this Plan or pursuant to procedures established hereunder. This requirement may be satisfied by formal periodic review by the Employer or by a qualified person specifically designated by the Employer, through day- to-day conduct and evaluation, or through other appropriate ways. 5.2 Designation of Administrative Authority The Employer may appoint a committee ("Committee") of one or more persons to serve as the Administrator and to discharge the Administrator's responsibilities under the Plan. The Employer may remove a Committee member for any reason by giving such member ten (10) days written notice and may thereafter fill any vacancy thus created. If the Employer does not appoint a Committee to administer the Plan, the Employer will be the Administrator. 5.3 Allocation and Delegation of Responsibilities If more than one person is appointed as Administrator, the responsibilities of each Administrator may be specified by the Employer and accepted in writing by each Administrator. In the event that the Employer makes no such delegation, the Administrators may allocate the responsibilities among themselves, in which event the Administrators will notify the Employer in writing of such action and specify the responsibilities of each Administrator. 5.4 Powers and Duties of the Administrator The primary responsibility of the Administrator is to administer the Plan for the benefit of the Participants and their Beneficiaries, subject to the specific terms of the Plan. The Administrator will administer the Plan in accordance with its terms and will have the power and discretion to construe the terms of the Plan and determine all questions arising in connection with the administration, interpretation, and application of the Plan. Any such determination by the Administrator will be conclusive and binding upon all persons. The Administrator may establish procedures, correct any defect, supply any information, or reconcile any inconsistency in such manner and to such extent as will be deemed necessary or advisable to carry out the purpose of the Plan• provided, however, that any procedure, discretionary act, interpretation or construction will be done in a nondiscriminatory manner based upon uniform principles consistently applied and will be consistent with the intent that the Plan will continue to be deemed a qualified plan under the terms of Code Section 457, and will comply with the terms of all Income Tax Regulations issued pursuant thereto. The Administrator will have all powers necessary or appropriate to accomplish his duties under this Plan. The Administrator will be charged with the duties of the general administration of the Plan, including, but not limited to, the following: This specimen plan is intended to assist you and your counsel in adopting a governmental 457 plan. Modifications may be required to meet your plan's particular objectives. (10/11) W (a) the discretion to determine all questions relating to the eligibility of Employees and Independent Contractors to participate or remain a Participant hereunder and to receive benefits under the Plan; (b) determine the amounts to be contributed to each Participant Account; (c) to authorize and direct the Provider with respect to all disbursements to which a Participant is entitled under the Plan; (d) to maintain all necessary records for the administration of the Plan; (e) to maintain practices and procedures necessary to administer the Plan as are consistent with the terms hereof; (0 to determine the type of any Investment Product to be purchased from the Provider; and 4 (g) to assist any Participant regarding his rights, benefits, or elections available under the Plan. 5.5 Records and Reports The Administrator will keep a record of all actions taken and will keep all other books of accounts, records, and other data that may be necessary for proper administration of the Plan and will be responsible for supplying all information and reports to the Internal Revenue Service, Participants, Beneficiaries and others as required by law. 5.6 Appointment of Advisors The Administrator may appoint/employ such agents, attorneys, actuaries, accountants, auditors, investment counsel, and clerical assistants, and other persons as the Administrator deems necessary or desirable in connection with the administration of this Plan. 5.7 Information from the Employer To enable the Administrator to perform his functions, the Employer will supply the necessary information to the Administrator on a timely basis regarding the Participants under the Plan, including but not limited to Compensation, date of hire, date of death, Severance from Employment, and such other pertinent facts and data as the Administrator may require. The Administrator may rely upon such information as is supplied by the Employer and will have no duty or responsibility to verify such information. This specimen plan is intended to assist you and your counsel in adopting a governmental 457 plan. Modifications may be required to meet your plan's particular objectives. (10/11) U 5.8 Payment of Expenses All expenses of administration will be paid by the Employer. Such expenses will include any expenses incident to the functioning of the Administrator, including, but not limited to, fees of accountants, counsel, and other specialists and their agents, and other costs of administering the Plan. 5.9 Discontinuance of Provider Notwithstanding Section 3.9, if any Provider ceases to be eligible to receive Deferrals under the Plan, the Employer may direct that both existing amounts under Participant Accounts that were invested with such Provider and any future contributions be transferred to the Investment Products of those Providers which are currently approved to receive Deferrals under the Plan. ARTICLE VI AMENDMENT AND TERMINATION 6.1 Amendment (a) The Employer will have the right at any time to amend this Plan subject to the limitations of this Section. Any such amendment will become effective as provided therein upon its execution. (b) No amendment to the Plan will be effective if it authorizes or permits any part of the Investment Product (other than such part as is required to pay taxes and administration expenses) to be used for or diverted to any purpose other than for the exclusive benefit of Participants or Beneficiaries; or causes any reduction in the amount credited to the account of any Participant or Beneficiary; or causes or permits any portion of the Investment Product to revert to or become property of the Employer. 6.2 Termination (a) The Employer will have the right at any time to terminate the Plan by resolution of its governing board. In addition, the Employer must deliver written notice of discontinuance of the Investment Product to the Provider. (b) Upon the full termination of the Plan, the Employer will direct the distribution of the assets to Participants and Beneficiaries in a manner which is consistent with and satisfies the provisions of Article IV as soon as administratively practicable after termination of the Plan. This specimen plan is intended to assist you and your counsel in adopting a governmental 457 plan. Modifications may be required to meet your plan's particular objectives. (10/11) 20 6.3 Transfer of Entire Plan Assets to Another Eligible Plan Within the Same State Subject to this Section, the Employer may direct the transfer of all assets of the Plan to another plan under Code Section 457(e)(1)(A) and that is located in the same state, provided that the requirements of Code Section 457(b) and Section 1.457(b)-10 (b)(3) of the Income Tax Regulations are satisfied. If Roth 457(b) Contributions are transferred, the receiving plan must permit Designated Roth contributions as defined in Code Section 402A. ARTICLE VII MISCELLANEOUS 7.1 Assets For Exclusive Benefit Of Participants And Beneficiaries All amounts in the Participant Accounts under this Plan, all property and rights which may be purchased with such amounts and all income attributable to such amounts, property or rights will be held in trust (or a custodial account or annuity contract described in Code Section 401(f)) for the exclusive benefit of Participants and their Beneficiaries. All such amounts will not be subject to the claims of the Employer's general creditors. 7.2 Participant Rights This Plan will not be deemed to constitute a contract between the Employer and any Participant or to be a consideration or an inducement for the employment of any Participant, Employee, or Independent Contractor. Nothing contained in this Plan will be deemed to give any Participant, Employee, or Independent Contractor the right to be retained in the service of the Employer or to interfere with the right of the Employer to discharge any Participant, Employee or Independent Contractor at any time regardless of the effect which such discharge will have upon him as a Participant in this Plan. 7.3 Alienation Subj ect to applicable state law (and Code Section 401(g) if the Investment Product consists of an annuity contract) and except as provided in Section 7.4, no benefit which will be payable to any person (including a Participant or his Beneficiary) will be subject in any manner to anticipation, alienation, sale, transfer, assignment, pledge, encumbrance, or charge, and any attempt to anticipate, alienate, sell, transfer, assign, pledge, encumber, or charge the same will be void; and no such benefit will in an manner be liable for, or subject to, the debts, contracts, liabilities, y � engagements, or torts of any such person, nor will be subject to attachment or legal process for or against such person, and the same will not be recognized except to such extent as may be required by law. This specimen plan is intended to assist you and your counsel in adopting a governmental 457 plan. Modifications may be required to meet your plan's particular objectives. (10/11) 21 7.4 Recognition of Approved Domestic Relations Orders Notwithstanding Section 7.3, if a judgment, decree or order (including approval of a property settlement agreement) that relates to the provision of child support, alimony payments, or the marital property rights of a spouse or former spouse, child, or other dependent of a Participant is made pursuant to the domestic relations law of any State ("domestic relations order") and Code Section 414(p), then the amount of the Participant Account will be paid in the manner and to the person or persons so directed in the domestic relations order. Such payment will be made without regard to whether the Participant is eligible for a distribution of benefits under the Plan. The Administrator will establish reasonable procedures for determining the status of any such decree or order and for effectuating distribution pursuant to the domestic relations order. 7.5 IRS Levy Notwithstanding Section 7.3, if a Participant or Beneficiary is entitled to a distribution in accordance with Section 5, the Administrator may pay from a Participant's or Beneficiary's Account the amount that the Administrator finds is lawfully demanded under a levy issued by the Internal Revenue Service with respect to that Participant or Beneficiary or is sought to be collected by the United States Government under a judgment resulting from an unpaid tax assessment against the Participant or Beneficiary. 7.6 Distribution for Minor Beneficiary or Incompetent If a Participant or Beneficiary entitled to receive any benefits hereunder is a minor or is adjudged to be legally incapable of giving valid receipt and discharge for such benefits, or is deemed so by the Administrator, benefits will be paid to such person as the Administrator may designate for the benefit of such Participant or Beneficiary. Such payments shall be considered a payment to such Participant or Beneficiary and shall, to the extent made, be deemed a complete discharge of any liability for such payments under the Plan. 7.7 Mistaken Contributions If any contribution (or any portion of a contribution) is made to the Plan by a good faith mistake of fact, then within one year after the payment of the contribution, and upon receipt in good order of a proper request approved by the Administrator, the amount of the mistaken contribution (adjusted for any income or loss in value, if any, allocable thereto) will be returned directly to the Participant or, to the extent required or permitted by the Administrator, to the Employer. 7.8 Procedure When Di stributee Cannot Be Located The Administrator shall make all reasonable attempts to determine the identity and address of a Participant or Beneficiary entitled to benefits under the Plan. For this purpose, a reasonable attempt means (a) the mailing by certified mail of a notice to the last known address shown on the Employer's or the Administrator's records, (b) notification sent to the Social Security Administration or the Pension Benefit Guaranty Corporation (under their program to identify This specimen plan is intended to assist you and your counsel in adopting a governmental 457 plan. Modifications may be required to meet your plan's particular objectives. (10/1 l ) 22 payees under retirement plans), and (c) the payee has not responded within 6 months. If the Administrator is unable to locate such a person entitled to benefits hereunder, or if there has been no claim made for such benefits, the funding vehicle shall continue to hold the benefits due such person. 7.9 Governing Law The Plan will be construed, administered and enforced according to the Code and the laws of the state in which the Employer has its principal place of business. 7.10 Headings Headings of the Plan have been inserted for convenience of reference only and are to be ignored in any construction of the provisions hereof. 7.11 Gender Pronouns used in the Plan in the masculine or feminine gender include both genders unless the context clearly indicates otherwise. 0 2011 ING North America Insurance Corporation. This specimen plan is intended to assist you and your counsel in adopting a governmental 457 plan. Modifications may be required to meet your plan's particular objectives. (10/11) 23 I�Ff7z I I ING SPECIMEN ADMINISTRATIVE SERVICES AGREEMENT This specimen is representative of the Agreement ING requires in order to administer and record keep a retirement plan. ,The specific terms of each Agreement is customized to the retirement plan and the product, seryices and investment options ING proposes to make available to your retirement program. The content of the Agreement is subject to mutual agreement. Key to shaded language: + Gray shading — Data/fields must be completed. + Yellow/Green shading -- This language may or may not apply. Include only as required by RFP. OMNI Govl ASA ( I T' {.�_;; •i',i`j��1Tr• .i:. 1,J_ wl:�ri\'_:a;!'s_._ _ _ _ _-_i•C,t'r11•_ TABLE OF CONTENTS i RECITALS ................................................................................................................ 1 SECTION1 SERVICES................................................................................................... 2 1.01 Good Order.......................................................................................................... 2 1.02 Allocation of Contractor Responsibilities........................................................... 2 1.03 Scope of Services................................................................................................ 2 1.04 Administrative Requirements ............. :................................................................ 2 1.05 Selection of Investment Options......................................................................... 2 1.06 Investment Provider Minimum Standards.......................................................... 2 1.07 Modification to Investment Options ............................................. 6..................... 3 1.08 Limits Imposed by the Underlying Funds........................................................... 3 1.09 Limits Imposed by the Contractor on Frequent Transfers ................................. 3 1.10 Access to Investment Advice............................................................................. 3 1.11 Access to Self Directed Brokerage Accounts .................................................... 3 SECTION 2 PARTICIPANT INFORMATION............................................................ 4 2.01 Provision of Certain Participant Information...................................................... 4 2.02 Changes in Deferral or Contribution Information; New Participant Deferral or Contribution Information.................................................................... 6 e so 4 SECTION3 COMPENSATION...................................................................................... 4 3.01 Contractor's Compensation................................................................................. 4 3.02 Factors Influencing Agreement........................................................................... 3.03 Compensation Paid to Sales Professionals.................................................. 0....... 5 3.04 Float................................................................................................................5 3.05 Transaction Processing........................................................................................ 6 SECTION4 TERM........................................................................................................... 6 4.01 Term................................................................................................................ 6 4.02 Termination......................................................................................................... 7 SECTION5 GENERAL................................................................................................... 7 5.01 Circumstances Excusing Performance................................................................ 7 5.02 5.03 5.04 5.05 5.06 5.07 5.08 5.09 5.10 5.11 5.12 5.13 BusinessRecovery.............................................................................................. 7 Ownershipof Records.................................................................................. a ...... 8 PartiesBound...................................................................................................... 8 ApplicableLaw...............................................................................................sees 8 Severability......................................................................................................... 8 Acknowledgement............................................................................................... 8 Notices................................................................................................................ 9 Copiesof Agreement......................................................................................... 10 Headings........................................................................................... 0 ................10 IndependentContractor.....................................................................................10 Contractor Primary Contact.............................................................................. 10 Licen r 'v 0. 5.14 Subcontracting...................................................................................................10 5.15 Contract Assignability...................................................................................... 010 5.16 Licenses and Permits.........................................................................................11 5.17 Conflict of Interest............................................................................................11 5.18 Improper Consideration.................................................................................... 11 5.19 Indemnification.................................................................................................11 5.20 Insurance...........................................................................................................11 5.21 Right to Monitor................................................................................................12 5.22 Confidentiality..................................................................................................12 SCHEDULE A: SCOPE OF CONTRACTORS SERVICES.........................................13 APPENDIX I TO SCHEDULE A: ENROLLMENT SERVICES..................................19 APPENDIX II TO SCHEDULE A: CONTRIBUTION RATE SERVICES .................. 23 APPENDIX III TO SCHEDULE A: PAYROLL FEEDBACK FILE ............................ 25 APPENDIX IV TO SCHEDULE A: UNFORESEEABLE EMERGENCY WITHDRAWAL -REVIEW AND APPROVAL REQUIREMENTS............ 27 APPENDIX V TO SCHEDULE A: DOMESTIC RELATION ORDER - REVIEW AND APPROVAL REQUIREMENTS ........................................... 29 SCHEDULE B: LOAN PROGRAM................................................................................ 32 SCHEDULE C: ADMINISTRATIVE REQUIREMENTS ......... .................................... 38 SCHEDULED: PLAN INVESTMENT OPTIONS........................................................ 39 SCHEDULE E: INVESTMENT PROVIDER MINIMUM STANDARDS DISCLOSURE STATEMENT............................................................. 40 SCHEDULE F: ING EXCESSIVE TRADING POLICY ................................................ 42 SCHEDULE G: GENERAL COMPENSATION PROVISIONS ................................... 44 SCHEDULE H: ILIAC' S POLICY FOR CORRECTION OF INADVERTENT PROCESSING ERRORS..................................................................... 46 SCHEDULE I: AUTHORIZED PLAN SPONSOR REPRESENTATIVES ................... 48 SCHEDULE J: CONTRACTOR'S PRIMARY CONTACT .......................................... 49 SCHEDULE K: LICENSED REPRESENTATIVES...................................................... 50 ADMINISTRATIVE SERVICES AGREEMENT This Agreement is made and entered into this day of% , by and between 'l Sp Qr;, (the Plan Sponsor) on behalf of the (the 45? Plan ), the 4�Q1 Flan le (the "401(a) Plan'`), (unless specified otherwise, cps ecfive referred to herein as the "Plan"). ING Life Insurance and Annuity Company ("ILIAC"), a corporation organized and existing under the laws of the State of Connecticut and ING Financial Advisers, LLC a limited liability company organized and existing under the laws of the State of Delaware and registered as a broker -dealer under the federal securities laws (the "Broker -Dealer"). ILIAC and the Broker -Dealer are hereinafter collectively called the "Contractor". This Agreement is separate and apart from any other contract issued to the Plan, including any group annuity contract or funding agreement issued to the Plan Sponsor by ILIAC. RECITALS WHEREAS, the Plan Sponsor has selected certain investment products offered or otherwise made available by or through ILIAC or the Broker -Dealer, respectively, for the investment of the Plan's assets (the "Program"); and WHEREAS, the Plan Sponsor further wishes to engage the Contractor as an administrative service provider to facilitate the administration of the Plan by providing services that shall include without limitation, accounting for deferrals or contributions, disbursement of funds, withholding of taxes, investment education, retirement counseling, investment of assets in the appropriate Plan investment options and proper recordkeeping of participant accounts; and WHEREAS, the Contractor wishes to provide such administrative services to the Plan. NOW, THEREFORE, in consideration of the mutual promises contained herein, the parties do hereby agree as follows: Section 1. Services 1.01 Good Order: The Contractor and the Plan Sponsor acknowledge that for purposes of this Agreement "Good Order" is defined as the receipt at the Contractor's designated location of a transaction request, instructions or data that is complete, accurate and in an acceptable format, and which do not require the Contractor to apply any research or discretionary judgment. To qualify as current business day instructions, a transaction request, instructions or data sent electronically, by telephone, facsimile or mail must be received by us no later than the close of the New York Stock Exchange ("NYSE") (typically 4:00 p.m. ET). If the Contractor receives a transaction request, instructions or data in Good Order after the close of the NYSE, the Contractor will process the data or request on the next business day that the NYSE is open. 1.02 Allocation of Contractor Responsibilities: The Broker -Dealer or other broker - dealers with which ING Financial Advisers, LLC has a selling agreement shall service or perform all marketing communications, enrollment and securities transactions settlement and processing functions assigned to the Contractor. ILIAC shall perform all other responsibilities assigned to the Contractor, including Plan and participant recordkeepng. 1.03 Scope, of Services: The Contractor agrees to provide the Plan with the services listed on Schedule A for the term of this Agreement. Brice offered pdrsuant 10 the Plan's Ioa p will be subeco the terms specified in Schedule 1.04 Administrative Requirements: The Contractor agrees to comply with the requirements set forth on Schedule 0 in the performance of this Agreement. The Contractor and the Plan Sponsor will review these administrative requirements periodically and make adjustments as necessary and mutually agreed. 1.05 Selection of Investment Options: The Plan Sponsor acknowledges that it is responsible for choosing the investment options to be made available to participants under the Plan. The Contractor agrees to provide Plan participants with a selection of investment options as specified in Schedule D. 1.06 Investment Provider Minimum Standards: Subject to the minimum standards set forth in Schedule , the Contractor will provide its administrative services in connection with the Plan Sponsor's selection of investment products to fund the Plan. 1.07 Modification to Investment Options: The addition or removal of any investment option to the Plan must be mutually agreed to by the Contractor and the Plan Sponsor and will be made in accordance with a mutually agreed upon schedule for implementing the change. (1) Subject to mutual agreement between the parties to add an investment option; (i) The Plan Sponsor may direct the Contractor to add an investment option from the range of investment products the Contract currently offers, and that are currently available in the Program, upon forty- five (45) days written notice of the proposed change. The Plan Sponsor may direct the Contractor to add an investment option that the Contract does not currently offer or an investment option that the Contractor currently offers but is not currently available in the Program, upon at least ninety (90) days written notice of the proposed change. Any investment option additions made pursuant to this Subsection 1.07(1)(ii) will be made in accordance with the Contractor's scheduled quarterly fund updates. (2) The Contractor reserves the right to reject any new investment option that imposes short-term trading (redemption) fees on participant accounts. (3) To the extent an existing investment option imposes short-term trading (redemption) fees on Participant accounts, the Contractor reserves the right to discontinue offering the investment option or to deduct any such short- term trading (redemption) fees from participant accounts. 1.08 Limits Im osed by Underlying Funds: The Plan Sponsor understands and acknowledges that orders for the purchase of fund shares may be subject to acceptance by the fund. The Contractor reserves the right to reject, without prior notice, any allocation of payments to the variable investment products, including the NAV Funds, if the Contractor's purchase order for the corresponding fund is not acceptable by the fund for any reason. 1.09 Limits Imposed b Contractor on Fre uent Transfers: The Plan Sponsor understands and acknowledges that the investment products offered or otherwise made available by or through the Contractor are not designed to serve as vehicles for frequent trading in response to short-term fluctuations in the market. Such frequent trading can disrupt management of a fund and raise its expenses. This in turn can have an adverse effect on fund performance. Accordingly, the Plan Sponsor agrees to adhere to the Contractor's current Excessive Trading Policy, as set forth in S h *'.T, (the "Excessive Trading Policy"). The Contractor reserves the right to modify the Excessive Trading Policy in whole or in part at any time and without prior notice, depending on the needs of the underlying fund(s), the best interest of contract owners and fund investors, and/or state or federal regulatory rPrn i i rPm PntQ Section 2. Participant Information 2.01 Provision of Certain Participant Information: The Plan Sponsor or its authorized representative shall facilitate the transmission to the Contractor of all current Plan participant level records including, but not limited to: name; address; social security number; active or terminated employment status; loan information; and deferral amount information. The Contractor shall be able to rely on the information provided by the Plan Sponsor. we are not responsible for any errors, omissions or other inaccuracies in the data you or an unaffiliated third party, including without limitation, prior service providers furnish us. Over the term of this Agreement, the Contractor and the Plan Sponsor will develop procedures for the Plan Sponsor to notify the Contractor of changes in employment status and, to the extent the Plan Sponsor has knowledge of the death of any participant, the Plan Sponsor will notify the Contractor of such death. The Plan Sponsor shall provide such information on a timely basis and use its best efforts to assure the accuracy and completeness of all information provided to the Contractor. 2.02 Changes in Deferral or Contribution Information: New Participant Deferral or Contribution Information: The Contractor and the Plan Sponsor will develop procedures to coordinate the processing pf (i) changes in deferral or contribution amount information and (ii) initial deferral or contribution information pertaining to participants joining the Plan on or after the date the Contractor commences the provision of services under this Agreement. Section 3. Compensation Alternative one: Retirement Choice with Fixed Plus III 3.01 Contractor's Compensation: The Contractor's services under the Agreement are rendered in connection with the Plan Sponsor's selection of certain investment products offered by or through the Contractor. The revenues paid to the Contractor from such investment products shall constitute one source of compensation for the services rendered under this Agreement. In addition, an administrative service fee will be assessed quarterly and calculated across all funds, !%pig the stability of principal option. This fee is not assessed on assets held in the Self Directed Brokerage Account. The fee will be deducted from the participant's money sources in the sequence elected by the Plan Sponsor for participant -initiated withdrawals in Schedule A. The Contractor's overall revenue requirement is ,, _:-� ".; '% ("revenue required"). Therefore, the Contractor will assess an asset based fee of No M%, assuming the Contractor receives the revenue required from the investment products offered by or through the Contractor. The Contractor reserves the right to increase the asset based fee if plan characteristics change from what was originally assumed. Additional transactional fees and charges may apply for optional services such as loans, investment advisory services and Self Directed Brokerage Account. 3.02 Factors Influencing Agreement: connectio h it5re Any fees, products and services rendered in o he C t i Nth exclusive (or one of ) provider of investment products and administrative services to the Plan during the Term of this Agreement and any subsequent renewal periods (as described in Section 4.01). The addition of any other provider or providers to the Plan during the Term of this Agreement and any subsequent renewal periods or changes in the Plan document may impact any fees, products and services under this Agreement. This Agreement and fees are contingent.on the Plan provisions in effect on the date of this Agreement. Any amendment to the Plan may impact this Agreement and fees. The Plan Sponsor understands and acknowledges that the compensation to the Contractor is subject to the certain general provisions, as set forth in Schedule (the "General Compensation Provisions"). The Contractor reserves the right to modify the General Compensation Provisions in whole or in part at any time and without prior notice, depending on the needs of the underlying fund(s), the best interest of contract owners and fund investors, and/or state or federal regulatory requirements. 3.03 Compensation Paid to Sales Professionals: The Contractor shall pay sales professionals a fixed trailer compensation of .% based on the total Plan assets. The compensation paid to sales professionals will be derived exclusively from the Contractor's revenue, defined in Schedule G. Sales professionals may also be eligible for additional expense reimbursement. Compensation may also be paid at the time of participant election of an annuitization distribution option and will be disclosed to the participant at the time the distribution option is elected. 3.04 Float.- ILIAC and its affiliated companies (collectively referred to as "ING" for purposes of this Section 3 ) earn income in the form of bank service credits on contributions awaiting investment and on payments awaiting distribution from the bank accounts that ING maintains (or "float"). The bank service credits are applied against the bank service fees that apply to the bank accounts that ING maintains and may not be redeemed for cash. Specifically, the bank accounts have been established to receive and hold for a reasonable time: • contributions or other amounts to be invested in your retirement Plan, or • amounts redeemed to pay a distribution or disbursement from your Plan. ING will receive income in the form of bank service credits (as described below) and offset such credits against bank service fees that are charged to ING for the use of such bank accounts and for services provided by the banks for processing receipts or disbursements. Float Generated by Contributions: ING uses a bank account to receive and hold contributions or other Plan deposit amounts to be invested. Contributions or other deposit amounts are held until authorized instructions are received in Good Order. Income in the form of bank service credits are earned on the bank account during any waiting period for authorize tru F ri tru io recei d ' rder, 5 contributions or other deposit amounts will be invested on that business day. For authorized instructions received in Good Order after the close of the New York Stock Exchange, contributions or other deposit amounts will be processed on the next business day. Float Generated by Distributions: ING receives income in the form of bank service credits in connection with distributions or disbursements that ING pays on the Plan's behalf. The bank service credits accrue during the period beginning when an amount is redeemed from the Plan's investment to fund a distribution or disbursement check and ending when the check is presented for payment. Additionally, from time to time, ING may receive money market like rates of return on other deposit or short term investment products in which distributions may be held until such time as the check is presented for payment. 3.05 Transaction Processing: ILIAC seeks to avoid transaction processing errors to the greatest extent possible, but inadvertent errors do occur from time to time. when a transaction processing error for which ILIAC is directly responsible occurs, ILIAC will attempt to correct the error as soon as reasonably practicable after identification of the error. Once all necessary information has been gathered, ILIAC will promptly take corrective action to put the Plan and its Participants in a position financially equivalent to the position they would have been in if the ILIAC processing error had not occurred. ILIAC processes your Plan's investment instructions on an "omnibus" or aggregated basis. If ILIAC's correction of an ILIAC processing error results in a loss to your Plan or its Participants, ILIAC will absorb the loss. If any gain results in connection with the correction of an ILIAC processing error, ILIAC will net any such gain against other losses absorbed by ILIAC and retain any resulting net gain as a component of its compensation for transaction processing services, including its agreement to make Plan and Participant accounts whole for losses resulting from ILIAC processing errors. For more information on our error correction policy, please refer to ING Life Insurance and Annuity Company's Policy for Correction of Processing Errors ("ILIAC Policy"), which is included in Schedule H. The ILIAC Policy and any updates to the ILIAC Policy are posted in the Sponsor Disclosure section of Sponsor web. Section 4. Term 4.01 Term: This Agreement shall commence on the Effective Date and continue for an initial term of F -X years. Unless either Plan Sponsor or Contractor provides written notice of intent to terminate this Agreement at least ninety (90) calendar days before the end of the initial term, the Agreement shall automatically renew thereafter for subsequent one-year terms; provided, however, that either Plan Sponsor or Contractor may terminate the Agreement as of the last day of any such one-yeax by 'din n no ' of jcjermi io e (90) 6 calendar days prior to the effective date of the termination. The Plan Sponsor and Contractor may mutually agree in writing to an earlier termination. This Agreement may be amended in writing if agreed to by both parties. 4.02 Termination: Notwithstanding Section 4.01, either party may terminate this Agreement at any time upon written notice "for cause". For this purpose, "for cause" shall mean: (1) failure of the other party to comply substantially with this Agreement and attached schedules hereto which, when called to the attention of the other party in writing has not been corrected within thirty (30) days; (2) the fraud or embezzlement on the part of the other party or provider of investment advice; (3) if the other party ceases to conduct business in the normal course, becomes insolvent, .makes a general assignment for the benefit of creditors, suffers or permits the appointment of a receiver for its business or assets, or avails itself of, or becomes subject to any proceeding under the Federal Bankruptcy Act or any other statute of any state relating to insolvency or the protection of the rights of creditors; (4) failure of the other party to pay any fees under this Agreement; or (5) if pursuant to Section -1.07 the Plan Sponsor requests the addition or removal of an investment option under the Plans, that is reasonably anticipated by the Contractor to result in a reduction in revenues under the Plans and no mutual agreement is reached between the parties on the recoupment of such lost revenues, the Contractor shall have the right to terminate this Agreement. Section 5. General 5.01 Circumstances Excusing, Performance: Neither the Plan Sponsor nor the Contractor shall be liable to the other for any delays or damages or any failure to act due, occasioned, or caused by reason of restrictions imposed by any government or government agency, acts of God, strikes, labor disputes, action of the elements, or causes beyond the control of the parties affected thereby. 5.02 Business Recovery Plan: The Contractor acknowledges that it has a Business Recovery Plan in place for its computer environment, specifying steps to be taken in the event of a disaster. The plan is built around a worst -case scenario involving loss of the facility or loss of access to the facility. It is also adaptable to less severe disasters. Generally, there are three phases to the Contractor's Business Recovery Plan: • Immediate response, damage assessment and critical notifications • Environmental and operation restoration • Operational readiness, testing and business resumption. A critical part of this plan is the Contractor's System Recovery Plan, which itself has three components: Hardware: the Contractor maintains a primary data center to support it mainframe applications and a portion of its mid -range and Intel based distributed environment. The Contractor has contracted with an outside vendor to provide hot site recovery capabiliti r t a me ' cas of site 1 el f . he v dor 7 maintains equipment that the Contractor will use to restore its applications in case of emergency. In addition, the Contractor has several data centers located throughout the U.S. with mid -range and distributed equipment to lessen the risk from any one site. On -site generators and UPS systems provide continuous power to the Contractor's facilities. A fully redundant wide area network connects all of the data centers in the U.S. as well as to the hot site vendor facility. Application software: the Contractor secures program libraries, to tape cartridges weekly, storing them in both on -site and off -site vaults. Production data: the Contractor's system and database files are backed up periodically, many on a daily basis, to tape cartridges stored in both on -site and off - site vaults. The Contractor's internal auditors have reviewed its disaster recovery procedures. Portions of the plan are tested on an annual basis. 5.03 Ownership of Records: The Contractor agrees that all computer tapes, discs, programs and any records generated by the Contractor under this Agreement shall be the property of the Plan. In the event of the termination of this Agreement, the Contractor shall provide all electronic and/or written data records to the Plan's designated representative or to a new contractor in an agreed upon format at no cost and within 180 days of written notice of intent to terminate this Agreement. 5.04 Parties Bound: This Agreement and the provisions thereof shall be binding upon the respective parties and shall inure to the benefit of the same. 5.05 Applicable Law: This Agreement shall be construed in accordance with the laws of '�A'f.a.,r = r :21 s •1 f•.. A•.�. p. �l'1 q.i�l •# .�J � �H rd'v...qq.l v t}r.. •Z_.� 4+ 'r � eft i. �;! �f, ��•ti ���'t t �1' 1. p�,{..1 � �ti c•..=':. the Y _: of_:��.` :? :y'.:'; The Contractor and the Plan Sponsor shall comply with all state and federal laws and regulations applicable to the services to be performed. 5.06 Severability: If any provision of this Agreement shall be found to be illegal or invalid for any reason, the illegality or invalidity shall not affect the remaining parts of this Agreement and the remainder of this Agreement shall be construed and enforced as if said illegal or invalid provision had never been inserted herein. Neither party shall be required to perform any services under this Agreement which would violate any law, regulation or ruling. 5.07 Acknowledgment: The Plan Sponsor acknowledges that: (a) the Contractor is performing non -discretionary, ministerial administrative services at the direction of the Plan and it's authorized representatives; (b) the Plan Sponsor and its authorized representatives have sole authority for making all benefit determinations. The Plan Sponsor may delegate the day- to-day administration of initial benefit determinations to the Contractor as in ' ted ' ed 8 (c) the Plan Sponsor and its authorized representative have the sole authority for the review and final disposition of a Plan Participant's appeal of any benefit determination made by the Contractor under the Plan; (d) the Contractor does not directly provide any investment advice to the Plan Sponsor with respect to the Plan's assets; (e) in performing services under this Agreement, the Contractor is entitled to rely on any information the Plan Sponsor, or its authorized representatives identified in Schedule or the Plan participants provide. The Contractor has a reasonable duty to inquire as to the authenticity or the accuracy of such information or the actual authority of such person to provide it; and (fl The Plan Sponsor will promptly provide to the Contractor any proposed amendments to the Plan for review and comment by the Contractor at least 90 days prior to the proposed amendment effective date. (g) ILIAC Error. ILIAC's responsibility with respect to providing the services is limited to correcting errors, within a reasonable time, which result from its computer system malfunctions, its staff errors or are otherwise caused by ILIAC's negligent acts. ILIAC shall make a good faith effort to correct any such error as soon as reasonably practicable after identification of the error when such correction is reasonably necessary and practical under the circumstances. For more information on our error correction policy, please refer to ING Life Insurance and Annuity Company's policy for Correction of Processing Errors ("ILIAC Policy"), which is included in Schedule L. The ILIAC Policy and any updates to the ILIAC Policy are also posted in the Sponsor Disclosure section of Sponsor Web. (h) Plan Sponsor Error. ILIAC will attempt to correct, at Plan Sponsor's expense, processing errors resulting from Plan Sponsor, or Plan Sponsor's representative, or otherwise caused by the negligent acts of Plan Sponsor; provided that Plan Sponsor promptly notifies ILIAC of such error and furnishes all data to ILIAC reasonably necessary to make such corrections. Plan Sponsor shall pay ILIAC its reasonable expenses incurred in making such corrections 5.08 Notices: Each parry will promptly provide the other with notice and copy of any attempts to levy or attach amounts held under the Plan and/or any litigation affecting the Plan of which it becomes aware and/or any notices or demands to be given under this Agreement. All such notices, demands or other communications hereunder shall be in writing and duly provided if sent certified mail, return receipt requested, addressed to the party to be notified or upon whom a demand is being made, at the addresses set forth in this Agreement or such other place as either party shall from time to time designate in writing. The date of service of a notice or demand shall be the receipt date on any certified mail receipt Notices to the Contractor shall be sent to: ING Life Insurance and Annuity Company Attn: Associate General Counsel Legal ]Department, C IS One Orange Way Windsor, CT 06095 Notices to the Plan Sponsor shall be sent to: 5.09 Copies of Agreement: This Agreement may be executed in any number of counterpart copies, each of which when fully executed shall be considered as an original. 5.10 Headin s: Headings are for convenience of reference only. Headings do not limit or expand the scope of the text and are not intended to emphasize any portion thereof. 5.11 Independent Contractor: The Contractor is associated with the Plan Sponsor only for the purposes and to the extent specified in this Agreement, with respect to the performance of the contracted services pursuant to this Agreement, the Contractor shall have the sole right to supervise, manage, operate, control and direct performance of the details incident to its duties under this Agreement. 5.12 Contractor Primary Contact: The Contractor designates certain individual(s) to serve as the primary point of contact for the Agreement. These individuals are identified in �i�dule J. 5.13 Licensed Representative: The Contractor agrees to provide licensed representatives to perform enrollment and education services, and to assist participants with account balance inquiries,_ investment selection changes, interfund transfers or exchanges, and transaction initiation. These individuals are identified in Schedule K. 5.14 Subcontracting: The Contractor may enter into subcontracting agreements for work contemplated under the Agreement. Any subcontractor shall be subject to the same terms and conditions as the Contractor. The Contractor shall be fully responsible for the performance of any subcontractor. 5.15 Contract Assig_nablity: Without the prior written consent of the Plan Sponsor, the Agreement is not assignable by the Contractor either in whole or in part. 5.16 Licenses and Permits: The Contractor shall ensure that it has all necessary licenses and permits required by the laws of federal, state, and municipal laws, ordinances, rules and regulations. The Contractor shall maintain these licenses and permits in effect for the duration of this Agreement. The Contractor will notify the Plan Sponsor immediately of loss or suspension of any such licenses and permits. Failure to maintain a required license or permit may result in immediate termination of this Agreement. 5.17 Conflict of Interest: The Contractor shall make all reasonable efforts to ensure that no conflict of interest exists between its officers, employees, agents or subcontractors and the Plan Sponsor. The Contractor shall make a reasonable effort to prevent employees, consultants, or members of governing bodies from using their positions for purposes that are, or give the appearance of being, motivated by a desire for private gain for themselves or others such as those with whom they have family, business, or other ties. 5.18 Improper Consideration: The Contractor shall not offer or be forced to provide (either directly or through an intermediary) any improper consideration such as, but not limited to, cash, discounts, services, the provision of travel or entertainment, or any items of value to any officer, employee, group of employees, or agent of the Plan Sponsor in an attempt to secure favorable treatment or consideration. 5.19 Indemnification: The Contractor agrees to indemnify and hold the Plan Sponsor, its officers, employees and agents harmless from any loss, liability, claim, suit or judgment resulting from work or acts done or omitted by the Contractor's officers, employees or agents in carrying out the Contractor's responsibilities as set forth in this Agreement to the proportionate extent that it results from the negligence or wrongdoing of the Contractor or any of its officers, employees or agents. The Contractor agreements to indemnify shall not extend to any injury or damage which results from the Contractor's reliance on information transmitted by the Plan Sponsor. The Plan Sponsor agrees to indemnify and hold the Contractor, its officers, employees and agents harmless from any loss, liability, claim, suit or judgment resulting from work or acts done or omitted by the Plan Sponsor's officers, employees or agents in carrying out the Plan Sponsor's responsibilities as set forth in this Agreement to the proportionate extent that it results from the negligence or wrongdoing of the Plan Sponsor or any of its officers, employees or agents. 5.20 Insurance: During the term of this Agreement, the Contractor shall maintain Comprehensive General Liability insurance with limits of not less than one million dollars, as well as automotive and Workers' Compensation insurance policies. Also, the Contractor shall maintain Professional Liability in the amount of not less than five million dollars. A Certificate of Insurance evidencing said coverage shall be provided prior to commencement of performance of this Agreement. Throughout the term of this Agreement, the Contractor shall provide upon request an updated Certificate of Insurance upon expiration of the current Certificate. 5.21 Right to Monitor: The Plan Sponsor or any appointee thereof, shall have the right to review and audit all records, books, documents, and other pertinent items as requested, and shall have the right to monitor the performance of the Contractor in the delivery of services provided under this Agreement. Full cooperation shall be given by the Contractor in the implementation, and in any auditing or monitoring conducted. 5.22 Confidentiality: The Contractor acknowledges that all information made available by the Plan Sponsor about its employees shall be considered confidential. The Contractor agrees that it will not distribute, disclose or release to any third party any such confidential information except as may be necessary to the performance of services hereunder either during or at any time after the term of the Agreement, upon the prior written approval of the Plan Sponsor or as otherwise required by law. IN WITNESS WHEREOF, the parties hereto have caused this Agreement (including all referenced and attached Schedules and Appendices) to be executed by their respective officers thereunto duly authorized as of the day and year first above written. By: Printed Name: ING LIFE INSURANCE AND ANNUITY COMPANY By: Printed Name: Title: Title: ING FINANCIAL ADVISERS, LLC By: Printed Name: Title: Schedule A: Scope of Contractor Services The Contractor agrees to provide the Plan with the services listed within this Schedule for the term of this Agreement. For purposes of this Schedule, all references to "participant" are intended to apply equally to all account holders under the Plan. This includes participants, beneficiaries and alternate payees. 1. The one-time preparation and implementation of a Plan -specific product and service conversion or transition schedule which shall include notice to all Plan participants. 2. The initial installation of overall Plan records and individual Plan participant records. 3. To assist the Plan Sponsor and its legal counsel, the Contractor will provide a specimen governmenta1457(b) and/or 401(a) plan document upon your request. As a specimen plan, you and your legal counsel may modify the document(s) to reflect your Plan design needs. 4. The development of Plan enrollment materials. 5. Conducting introductory on -site education and enrollment meetings for employees. 6. Ongoing allocation of Plan contributions to individual participant accounts, and reconciliation of Plan and participant activity on a daily basis. 7. Contractor will perform one test per month beginning in October through December on each participant account per Plan covered by this Agreement for the limit on elective deferrals pursuant to Code section 402(g) and/or 457(e)(15) and on the annual additions limit in accordance with Code section 415(c), if applicable. If the Plan Sponsor sponsors more than one plan, the Contractor will not aggregate the Plan covered by this Agreement with any other plan for testing purposes. 8. Ongoing maintenance of participant beneficiary designations under the Plan based upon mutually agreed upon procedures which shall be reflected in the Plan document. Participants may designate a beneficiary via the Contractor's participant internet site or by speaking with a customer service representative via a toll free telephone line. Community property Edit This optional feature of the online beneficiary maintenance service will take into account community property laws applicable in the Participant's resident state at the time that he or she is making a beneficiary designation. When this service has been elected, the Contractor's online beneficiary maintenance service will require any participant who has identified themselves as being married or in a registered domestic partnership or a civil union and who does not designate a person identified as his or her spouse or domestic partner as a primary beneficiary for at least the percentage prescribed under the community property laws to complete and submit a paper benef d atio ❑ The Plan Sponsor elects to utilize the Contractor's Community Property Edit feature as described above. 9. Ongoing maintenance, recordkeeping of individual participant account records and processing in a timely manner of all transactions permitted under the Plan as authorized or approved by the Plan Sponsor. Any delegation of the Plan Sponsor's role of authorizing or approving transactions under the Plan to the Contractor will be as directed later within this Schedule or other written instrument between the parties. Such direction shall not be construed as delegating Contractor discretion with respect to such decision. 10. Ongoing generation of periodic Plan activity reports for Plan Sponsor use, as mutually agreed upon, to be made available through a secure website. 11. Ongoing provision of necessary tax forms on a timely basis to participants who received taxable distributions during the previous year. 12. Ongoing provision of employee enrollment and education services, including the provision of communication packages which includes the necessary information for employees to enroll and make investment choices. 13. Establish and maintain an electronic interface with the Plan Sponsor for participant enrollment information (including automatic enrollments) and changes to the participant's contribution amount or rate, as provided in Appendix I, II and III to Schedule A. 14. Access to customer service representatives via a toll free telephone line to respond to to Plan participant inquiries, provide information about participants' accounts and investment options, enroll an employee into the Plan and to distribute administrative forms. 4 15. Access to an automated voice response system via toll free telephone lines, through which participants may obtain updated account and investment information and initiate transactions permitted under the Plan. 16. Access to an internet site, through which participants may obtain updated account and investment information, and initiate transactions permitted under the Plan including enrollment or electing a new contribution amount or rate under the Plan and requesting forms for initiating certain transactions as permitted under the Plan. 17. Money Source Withdrawal Sequence A withdrawal or liquidation sequence for money sources available to fund a withdrawal from the must be identified. The default sequence for a governmental 457(b) plan is shown below — if no change is made, this is the withdrawal sequence that will apply to participant withdrawals under the Plan. Employee Elective Deferrals Rollovers from another 457 Plan Rollovers from a 401 or 403(b) Plan or IRA Designated Roth Roth Rollovers from another 457 Plan Roth Rollovers from a 401 or 403(b) Plan In Plan Roth Rollover Rollover of In Plan Roth Rollover from a 401 or 403(b) Plan Other (Please specify) 18. Incoming Rollovers / Transfers Authorization Ongoing review and processing of participant -initiated incoming rollover or transfer requests, on behalf of the Plan Sponsor, shall be based on mutually acceptable procedures for the review, and processing of these types of requests. Incoming rollover and transfer requests determined to be in Good Order will be processed on the same business day as the assets are received by the Contractor. At the Plan Sponsor's direction, participants who have had a request denied shall be given the opportunity to appeal to the Plan Sponsor for review and final disposition of the determination. 19. Unforeseeable Emergency withdrawal Authorization Ongoing review and processing of participant unforeseeable emergency withdrawal requests on behalf of the Plan Sponsor, based on the standard for the review, qualification and processing of these withdrawals as provided in Appendix IV to Schedule A. The Contractor will make a determination (approval and/or denial) within 5 business days of receipt of the request, and supporting documentation, in Good Order. If the request approved, the request will be processed as of the date of favorable determination; with payment being mailed or made available electronically through ACH. 20. Automatic Contribution Reinstatement As the Plan requires a contribution suspension period for Participants who take an unforeseeable emergency withdrawal, the Contractor will automatically reinstate the Participants' deferral election in effect prior to the withdrawal, unless you elect out of this service. A notification will be sent to the Participant of the reinstatement. (Note: The Plan Sponsor cannot elect out of this service if the Plan utilizes the Contractor's Automatic Contribution Increase Service.) ❑ The Plan elects not to utilize the Contractor's Automatic Contribution Reinstatement Service (check required to elect out of service). Note: The Contractor will notify participants when the suspension period expires, but will not automatically reinstate the deferral election. 21. Permissible Withdrawal Authorization This paragraph pertains to the following participant -initiated withdrawals and/or transfers from a Participant account as permitted under the Plan (check all that apply): ❑ In -Service Withdrawal for Governmental 457(b) Plans (aka deminimus withdrawal) ❑ Purchase of Governmental Defined Benefit Plan Service Credit Normal Retirement Age — ident� the age level to allow withdrawal ❑ Age Based Withdrawal — identify the age level to allow withdrawal Ongoing review and processing of participant -initiated withdrawal or transfer requests, on behalf of the Plan Sponsor, shall be based on mutually acceptable procedures for the review and processing of these types of requests. Withdrawal or transfer requests are processed as of the date received in Good Order, with payment being mailed or made available electronically through ACH. At the Plan Sponsor's direction, participants who have had a request denied shall be given the opportunity to appeal to the Plan Sponsor for a review and final disposition of the determination. 22. Domestic Relations Order Administration Ongoing review and processing of Domestic Relations Orders (DRO) on behalf of the Plan Sponsor, based on the standard for the review, qualification and processing of DROs as provided in Appendix V to Schedule A. 23. The Contractor will make a determination within S business days of receipt of the domestic relations order in Good Order. If. the request approved, the request will be processed as of the date of favorable determination; with confirmation being mailed. If the domestic relations order is not received in good order, the Contractor will work with the respective parties until the order is presented in Good Order. Benefit Payment Authorization _ Ongoing review and processing of participant -initiated benefit payment requests (including annuity payments and death benefits) due to participant's separation from service or o o an or, a on t e able 6 procedures for the review, qualification and processing of these requests. The Plan Sponsor is responsible for providing the Contractor with any and all participant termination data in the mutually agreed upon electronic format, within a reasonable time period following the participant's separation from service or death. The Contractor may not make the applicable benefit payment request transaction and/or paperwork available to the participant until the termination data is received from the Plan Sponsor in Good Order. Benefit payment requests are processed as of the date received in Good Order; with payment being mailed or made available electronically through ACH. At the Plan Sponsor's direction, participants who have had a request denied shall be given the opportunity to appeal to the Plan Sponsor for a review and final disposition of the determination. 24. Access to counseling by licensed agents or representatives for Plan participants, who are retiring or otherwise requesting a benefit payment from the Plan, based on mutually acceptable standards. 25. Ongoing processing of Required Minimum Distributions ("RMD") in accordance with the rules of Code Section 401(a)(9) for eligible Plan participants and their beneficiaries as follows: a. Participants: In the absence of an affirmative election or instructions received in Good Order from the Participant on an annual basis for receiving the RMD, the Contractor is directed by the Plan Sponsor, to calculate and distribute the RMD amount. The Contractor shall calculate the RMD in the following manner. i. For Participants with either (1) no beneficiary, (2) a non -spouse beneficiary, (3) a spouse beneficiary without a date of birth, or (4) a non -individual beneficiary (e.g., charitable organization), calculate the current year RMD by dividing the account balance on 12/31 of the prior year by the distribution period under the Uniform Lifetime Table using the Participant's age on 12/31 of the current year. 11. For Participants with a spouse beneficiary more than 10 years younger than the Participant, calculate the current year RMD by dividing the account balance on 12/31 of the prior year by the combined life expectancy factor under the Joint and Last Survivor Table using the ages of the Participant and the spouse beneficiary on 12/31 of the current year. iii. For Participants who are at least 70-1 /2 years of age in a calendar year and have separated from service with their employer, any distribution requested will first be reduced by the applicable RMD for the distribution calendar year. b. Beneficiary(ies): In the absence of an affirmative election or instructions re%d i m en ci (ies th sor irec 7 the Contractor to calculate the RMD amount in accordance with Code Section 401(a)(9) provided the Contractor has received in Good Order proper notification of the Participant's death and complete beneficiary(ies) information (including the complete name and address of the beneficiary(ies)). In situations where the life expectancy rules are not available for the calculation of the RMD either because the Contractor has not received the requisite information by the date for issuing RMD payments or the beneficiary is not entitled to receive RMD under the life expectancy rules, the Plan Sponsor directs the Contractor to apply the five- year payout rule and force out a lump sum by December 3 1 " of the fifth year following the year of the Participant's death. The Plan Sponsor acknowledges that the Contractor shall not be responsible for any tax penalties or excise taxes the Plan Sponsor, Plan Participants, or beneficiaries may incur as a result of the Contractor's failure to calculate and distribute the RMD amount where the failure is due to the Plan Sponsor's, the Plan Participant's or the beneficiaries' failure to provide the required information in a timely manner. 26. Ongoing facilitation of communications between the Contractor, the Plan Sponsor and the Plan participants based on mutually acceptable guidelines. �!n Name Appendix I tcedle A Enr irient erv+ es Eligibility Tracking Service: With this service the Contractor will evaluate eligibility for the Plan Sponsor's employees based on the Plan's definition of eligibility and entry dates and establish an electronic interface with the Plan Sponsor for transmission of enrollment / contribution rate information. An employee will be notified of his eligibility, including information on how to enroll, once all requirements are completed as outlined in the Plan document. A non - enrolled employee will receive reminder notice of his eligibility, including information on how to enroll, on each anniversary of his eligibility date. Plan Sponsor understands and acknowledges that the Contractor in providing this service is not exercising any discretion and is therefore not acting as a fiduciary when providing this administrative service. The Plan Sponsor is ultimately responsible for final determination of eligibility for Plan participation. ❑ The Plan elects the Contractor's Eligibility Tracking Service (please check) Plan Sponsor responsibilities In addition to providing timely and accurate information for this service, the Plan Sponsor will be responsible for the following: • Upon transition of the Plan to this service, Plan Sponsor will provide the Contractor with anniversary year-to-date and Plan year-to-date hours for all employees through the Effective Date of this Agreement. Subsequent submission of hours will be required on a pay period -to -date basis. • Phan Sponsor will notify Contractor of all rehired employees so that the employee status can be reflected properly on the Contractor's system. • Plan Sponsor will submit to ING census data for eligibility tracking for all employees with each payroll. If census data is not submitted with each payroll, the Contractor will not provide this service. Therefore, the Plan Sponsor will be responsible for tracking eligibility until such time as census data is submitted with each payroll. • Should a participant make a deferral election through a means other than the Contractor's customer service representative, voice response system or internet site, it will be the Plan Sponsor responsibility to update its payroll system based upon the participant's election in accordance with applicable Code requirements and regulations governing the effective date of deferral elections to the Plan. Automatic Enrollment Service: This service allows the Plan Sponsor to adopt an automatic enrollment feature and to establish an electronic interface with the Contractor for acceptance of enrollment / contribution rate information. Plan Sponsor acknowledges its responsibility for ensuring that the Automatic Contribution Arrangement (automatic enrollment) complies with their state laws in regards to wage withholding. The payroll withholding laws of the Plan Sponsor's state should be reviewed prior to implementation of this program to determine if deductions without an employee's written consent are permitted. El The Plan elects the Contractor's Automatic Enrollment Service (please check) Notices to all eligible participants: Plan Sponsor understands that initial and annual notices are required to be provided to participants regarding their elections in accordance with applicable regulations. Initial Notice Requirements: For plans with an Eligible Automatic Contribution Arrangement (EACA) or other Automatic Contribution Arrangement (ACA) provision, as defined under PPA and related regulations, each newly eligible employee must receive the initial notice no earlier than 90 days before the employee's eligibility date, and no later than the employee's eligibility date. Annual Notice Requirements: For plans with an EACA or ACA provision, each eligible employee must receive the annual notice no less than 30 days before the start of each plan year. Notification Service: The Contractor provides a notification service to assist the Plan Sponsor with complying with the requirements noted above. The initial notices provide participants an explanation of the respective feature and may include the following: the percentage of employees' pay to be contributed to the Plan, the investment option(s) available, the default investment if an employee chooses not to enroll and select an investment option. The notice will also advise employees of their right to revoke the automatic withholding and their rights to increase, decrease or stop contributions and instructions on how to do so. Annual notices are required to be provided to participants who have been automatically enrolled and remain in that status and have not changed their initial contribution amount and/or default investment option. The "notices" will remind Participants of their deferral amounts and of their right to increase, decrease or stop these contributions, also including the procedure to do so. The Contractor will automatically provide both the initial and annual notices for plans that select the Contractor's Eligibility Tracking, Automatic Enrollment and/or Automatic Contribution Increase Services. Initial Contribution Amount: Participants will be automatically enrolled in the Plan, unless the participant opts out, with • _t L. ;,�-•.:^/c: ' -•'y' �i .'3., _t i;�:�: lL. •:. , :: ••. �• .1,. `t C'i'.; � :.?7 )..! • � �.}:•i}•�}�c�f�. �+r.{�`_':�M1�`i-;: < i�`.�= s-.ice`:; t.. _s Ft�,�. t�}:. S'i.-'�:,+..wrz� :i? '•°'•.f: ;��;y �:.. ,�O an Initial contribution amount of :;i:��. _ ; ,; ,�;Z. `_�:.. >>. -, Default Investment Arrangement - Please select one of the following options for the Plan's default investment option with respect to the Automatic Enrollment Service. Plan Sponsor understands that it has the fiduciary responsibility to choose the appropriate "default" investment option, and therefore, may choose from any of the investment options available under the Plan. ING.SoWon Port fol o funds Permissible Withdrawals: If allowed under the Plan, an employee who was automatically enrolled may request a return of his/her defaulted deferrals (as adjusted for gain or loss) within 90 days of the da the first defaulted elective deferral was deducted from the employee's pay. Attributable matching contributions must be forfeited. The Plan Sponsor understands the applicable IRS regulations for automatic contribution arrangements only allow permissible withdrawals of defaulted elective deferrals under plans where the automatic contribution arrangements meet the EACA requirements. Please choose one of the following: [:] A. Yes, the Plan will allow for permissible withdrawals. ❑ B. No, the Plan will not allow for permissible withdrawals. Automatic Contribution Increase Service This service will increase a participant's deferral amount based on a uniform schedule. Note: The Automatic Contribution Increase service is only available if the Plan Sponsor elects to also utilize the Contractor's Automatic Enrollment Service. ❑ The Plan Sponsor elects to utilize the Contactor's Automatic Contribution Increase service in accordance with the following criteria (please check) F-1 Dollar -based Increase elective deferral amount of $ x amount by $Y . subject to a maximum Participants to be subject to the automatic contribution increase service are (choose one option): ❑ All new Participants enrolled between and Fal (mm dd) (mm dd) Automatically enrolled Participants only -- subject to the following grace period: ❑ No grace period EJ 365 day grace period f Contribution Source for Automatic Contribution Increase: ❑ Employee elective deferral contributions ❑ Employee voluntary contributionsr � El Other (describe) The first automatic increase will take place the first day of the Plan year following the year of initial participation, subject to the grace period election above. For example, if the plan year started 1/1/2010 and the Participant was enrolled on 1/1/2010, the first automatic contribution will increase on 1 /1 /2011, assuming a 365 day grace period is elected. Participants will be notified 14 day prior to the increase. Enrollment Kit Requirements An enrollment kit must be provided to each eligible participant prior to enrollment (including automatic enrollment) into the Plan. The kit must include, but is not limited to the following: investment option fact sheets for each of the available investment options, fund performance, participant disclosure booklet and information on how a participant can access their account to make account changes. An adequate supply of Enrollment Kits will be provided to the Plan Sponsor by the Contractor whenever requested of the Plan Sponsor. The Contractor will generate a periodic report whenever employees have been identified as being eligible but not yet participating in the Plan. Included on the report will be those employees eligible to be automatically enrolled into the Plan, if the automatic enrollment service is utilized by the Plan. You must identify an individual to receive notification of when the report is available. The purpose of this report is to identify those employees who must receive an enrollment kit. It is understood and acknowledged by the Plan Sponsor and Contractor that the individual designated below is responsible for the distribution of enrollment kits to the employees identified on the report. Please indicate who should be notified when the report is available. Select one. ❑ Licensed Representative Name: Telephone: E-mail: In the event that the identified individual is removed or replaced, the Contractor is responsible for notifying the Plan Sponsor immediately in writing. F-1 Plan Sponsor Name: Telephone: E-mail: In the event that the identified individual is removed or replaced, the Plan Sponsor is responsible for notifying the Contractor immediately in writing. ppecix to Scedue Contiiouto n:R.at S rvWc8 Contribution Rate Change Service: This service allows participants to make contribution rate changes via the L;ontracior-s Participant internet site or by speaking with a customer service representative of the Contractor. Please note it is your responsibility -to notify the Contractor of terminated employees. Contribution rate changes are allowed in fractional percentages. This service supports the older worker catch-up contribution elections (if available under the Plan). other types of catch-up or make-up contribution options available under the Plan are supported by the service. Cn Plan Sponsor acknowledges that it is its responsibility for ensuring that the Contribution Rate Change Service complies with their state laws_ in regards to wage withholding. The payroll withholding laws of the Plan Sponsor's state should be reviewed prior to implementation of this program to determine if deductions, and/or contribution rate changes, without an employee's written consent are permitted. The service includes increases, decreases, stops and restarts, either based on participant direction, or as directed by the Plan as a result of loans or unforeseeable emergency withdrawals t El The Plan Sponsor elects to utilize the Contactor's Contribution Rate Change service and Participant Directed Contribution Rate Escalator service (described below) in accordance with the following criteria (please check). Minimum and Maximum Contribution Schedule: Pursuant to the Plan document, indicate the minimum and maximum contribution amount or rate a participant can elect. If applicable, indicate the maximum total contribution percentage allowed i El Dollar -based Employee elective deferral contributions Minimum Employee voluntary contributions Minimum Other (describe) Minimum $ . k 1VMaximum $ {x Maximum $ ` Maximum Participant Directed Contribution Rate Escalator Service This service allows participants to elect automatic increases in deferral rates via the Contractor's Participant internet site or by speaking with a customer service representative of the Contractor. Participant will indicate the frequency and amount of the contribution rate increase. The Contractor will send a reminder to the Participant 30 days prior to the automatic increase. Restrictions and Limitations: • This service is only available if the Plan Sponsor elects to utilize the Contractor's Contribution Rate Change Service. • This service does not apply to catch-up contribution elections. • If there is a conflict between a Participant's Contribution Rate Escalator service and the contribution limits applicable to the Plan, the Participant's contribution rate escalator election will be cancelled. • The Participant's contribution rate escalator election will be cancelled if participant submits a contribution rate change election pursuant to the Contribution Rate Change Service above. �Appendixl�T to Schedule A: P'ayxoll `ebck Fide Payroll Feedback File If the Plan Sponsor has elected the Eligibility Tracking service, Automatic Enrollment service, the Contribution Rate Change service or offers loans, the Contractor will provide a periodic payroll feedback file through an automated process. It is the responsibility of the Plan Sponsor to update its payroll. system based upon the data contained in the payroll feedback file in accordance with applicable Code requirements and regulations governing the effective date of deferral elections to the Plan. The payroll feedback file is a .csv format file which can be uploaded to most payroll systems. As an alternative, a payroll feedback report in a .pdf format can be printed and used for manual entry into a payroll system. Electronic File Delivery: Please select one of the following delivery types (required): ❑ Email: Contractor will send files in an encrypted format (access information will be provided). Please provide one or more email addresses: 0 LK FTP (File Transfer Protocol): Contractor will send files via FTP. the FTP delivery address, ID and password: FTP Delivery Address: ftp:// Please provide FTP ID: FTP Password: Sponsor Web/Archive: Plan Sponsor will obtain reporting data through the Contractor's plan sponsor internet site. The Contractor will send the periodic electronic payroll feedback file based on the information selected above until a change is provided, in writing, by the Plan Sponsor. Reporting Frequency: The Contractor will provide the automated contribution rate reporting data on the frequency that best meets the needs of the Plan Sponsor. t.Z Telephone: E-mail: In the event that any identified individual is removed or replaced, the Plan Sponsor is responsible for noting the Contractor immediately in writing. =:+ Appendix IV to Schedule A: Unforeseeable Emergency Withdrawal Review and Approval Requirements The Contractor is responsible for the ongoing review and processing of participant unforeseeable emergency withdrawal requests on behalf of the Plan Sponsor. The Contractor's process is based on the following procedures for the review, qualification and processing of these withdrawals under 457(b) deferred compensation plans. To request an unforeseeable emergency withdrawal, a participant must complete the relevant paperwork and provide the appropriate documentation to support the request. The Contractor will review the request to determine whether it satisfies the IRS and Plan requirements for an unforeseeable emergency. Specifically, an unforeseeable emergency means extraordinary and unforeseeable circumstances arising as a result of events beyond the control of the participant including: • severe financial hardship of the participant resulting from an illness or accident of a participant, the participant's spouse or of a participant's dependent (as defined in Code Section 152(a))*; • loss of the participant's property due to casualty (including the need to rebuild a home following damage to a home not otherwise covered by homeowner's insurance); or • other similar extraordinary and unforeseeable circumstances arising as a result of events beyond the control of the participant. *Effective in 2007, the Pension Protection Act of 2006 expanded this definition to include the participant's designated primary beneficiary. In its evaluation, The Contractor will limit the withdrawal to the amount reasonably necessary to satisfy the emergency need, which may include any amounts necessary to pay Federal, state, or local income taxes or penalties reasonably anticipated to result from the distribution. In addition, a withdrawal shall be allowed only to the extent that such emergency is or may not be relieved through: 1) reimbursement or compensation from insurance or otherwise; 2) liquidation of the participant's assets, to the extent the liquidation of such assets would not itself cause severe financial hardship; or 3) cessation of the participant's deferrals under the Plan. The determination of whether a request qualifies as an unforeseeable emergency will be based on all the facts and circumstances of the participant's specific situation. While it is a subjective decision, the Contractor's process incorporates three underlying principles: consistent application of the IRS rules to similar situations; decisions must be reasonable and not arbitrary; and when there is a close call, we err on the conservative side. The Contractor takes this review process very seriously and understands the importance of consistently administering the IRS and Plan requirements. The Contractor recognizes that failure to do so, and thus treating the Plan Eike a savings account, can result in adverse tax consequences to the participant and to the Plan. Withdrawal requests will be reviewed in a timely manner. For requests which are approved, The will rocess the withdrawal as of the date of the a royal. (27 F�� I n participant, who has had a withdrawal request denied because of insufficient documentation, can resubmit his or her request to the Contractor for re -review with all applicable documentation, L Appendix V to Schedule A: Domestic Relation Order Review and Approval Requirements The Contractor is responsible for the ongoing review and processing of Domestic Relations Orders (DRO) on behalf of the Plan Sponsor. The Contractor's process is based on the following procedures for the review, qualification and processing of DROs which if followed as specified below shall constitute a valid Plan Sponsor direction to process the DRO. Definition of a Domestic Relations Order A Domestic Relations Order ("DRO" or "Order") is a court order, judgment, or decree issued under a state's domestic relations law that recognizes the right of a spouse, former spouse, child, or other dependent of a Participant in an employee benefit plan to receive all or part of the Participant's benefit in the plan. A Qualified Domestic Relations Order ("QDRO") is a DRO that has met the specific requirements mandated by federal law and the provisions of the Plan as determined by the Plan Administrator or its designee. A QDRO requires a qualified plan to pay all or any part of a Participant's benefits to an Alternate Payee. An Alternate Payee is a spouse, former spouse, or dependent of the Participant who is entitled to a portion of the Participant's benefits. Requirements for QDRO For a domestic relations order to meet the Contractor's good order processing standards and for the DRO to be qualified and considered a QDRO, the order must comply with the following requirements. In addition, certain state rules may be imposed on domestic relations orders by statute. I . The order must be an original or a court -certified copy of the original, signed by the judge or clerk of the court. A fax or a photocopy cannot be accepted as they are not in compliance with the Contractor's good order standards. 2. The order must create or recognize the existence of an alternate payee's right to, or assign to an alternate payee the right to, receive all or a portion of the benefits payable with respect to a participant under the plan. 3. The order must constitute a j udgment, decree or order (including approval of a property settlement agreement) that relates to provisions of child support, alimony payments or marital property rights to a spouse, former spouse, child or other dependent of a participant, and is made pursuant to a state domestic relations law (including a community property law). 4. The order must clearly and unambiguously name each plan to which the order applies. 5. The order must clearly specify the name and last known mailing address of the participant and each alternate payee covered by the order. (if the alternate payee is a minor or is legally incompetent, the order must include the name and address of the alternate payee's legal representative.) The order should identify the social security number (or tax identification number) and date of birth of the participant and each alternate payee covered by.the order. If State or local law prevents the inclusion of such information in the court order, this data must be provided to the Contractor, in writing, by the party that drafts the court order, in order for good order processing standards to be met. b. The order must be specific with respect to the dollar amount or percentage of the participant's benefits to be paid by the plan to each alternate payee or the manner in which the amount or percentage is to be determined. The calculation of this amount must be very clear and not subject to interpretation. If the amount ordered to be paid to the alternate payee's account is at all ambiguous, then the order cannot be accepted. 7. The order must specify the exact date when the account should be valued which should be a day the New York Stock Exchange (NYSE) is open. If the date provided is a date when the NYSE was not open, the Contractor will process the request, if received in good order, as of the preceding business date the NYSE is open. 8. The order must provide that the calculation of the amount of the participant's benefit to which the alternate payee is entitled to be readily calculable and according to records currently available to the Contractor. Pursuant to this requirement, the Contractor will not accept ,any order that requires calculations prior to the time the Contractor began providing services to the plan, unless the actual financial records necessary to make such calculation on a non -discretionary basis are provided to the Contractor. 9. If earnings prior to the effective date are also to be segregated on behalf of the alternate payee, the attorney representing the participant must provide the actual financial records necessary to make such calculation on a non -discretionary basis, if such records are not available to the Contractor. 10. If the order specifies a dollar amount to be paid to the alternate payee, such amount may not exceed the participant's vested balance in the plan. Amounts payable to an alternate payee shall be distributed proportionately from the participant's account with the Contractor. Account values fluctuate with market conditions. If the dollar amount specified is above the current balance, the request may be rejected. when establishing the alternate payee's account, the Contractor shall first redeem amounts pro rata from all investment options other than non -core investment options (e.g., life insurance, self directed brokerage account, certificate of deposit, etc.), if applicable, held in the participant's account, and shall redeem amounts fr on- 'nvestm en oEEpti if pl' ble, ly ' s ry to 0 obtain the amount consistent with this Order. 11. A plan may specify a date as of which QDROs are allowed under the plan (such as orders dated after a specified date, e.g., January 1, 2002). Court orders which pre- date the allowance of QDROs under the plan may not be accepted. 12. The order must not require the plan to provide any type or form of benefit or any option, not otherwise provided under the plan. 13. The order must not require the plan to provide increased benefits (determined on the basis of actuarial value). 14. The order must not require any payment of benefits to an alternate payee that are required to be paid to another alternate payee under another order previously determined to be a QDRO. 15. The order must not require the plan to pay benefits in the form of a qualified joint and survivor annuity for the lives of the alternate payee or his/her subsequent spouse. 16. The order must - provide for tax treatment of the account other than as required under federal law and regulations. If the order meets all of the approval requirements listed above, it will be given effect and the Contractor will send notification of approval to the involved parties and their counsel. If the order fails to meet one or more of the approval requirements listed above, it will be rejected. A letter notifying the involved parties -of the rejection will be mailed, together with an explanation. Administrative Hold on Participant's Account When the Contractor receives a signed domestic relations order (DRO), or is notified that a. legal action is pending in which a DRO will be sought, the Contractor will place an administrative hold on the participant's affected plan account(s) pending the determination of the qualified status of the DRO. During this period, the participant will be restricted from taking a distribution or loan until the QDRO has been processed. PPanIe eaw o� Prgrt Terms of Contractor's Loan Program. ("Loan Program"): This Loan Program is only available to the extent that the Plan Sponsor has established an automated contribution remittance process that is acceptable to the Contractor. where a Plan remits contributions from multiple payroll locations, this Loan Program will only be available to participants at payroll locations that have established an automated contribution method acceptable to the Contractor. • Types of Loans Permitted —select all that apply. [:] General Purpose F-1 Residential • Maximum number of loans that may be outstanding at any time. General Purpose 1' Residential 2. Total (regardless of type of loan) • Minimum Loan Amount - Wicate the minimum loan amount pursuant to this Loan Program $ . Maximum Loan Amount - the maximum amount of a loan made pursuant to this Loan Program shall be an amount which, when added to the outstanding balance of any other loans to the participant from the Plan and any other qualified plan of the Employer, does not exceed the lesser of; (i) $50,000 reduced by the excess (if any) of a) the highest outstanding balance of loans from the Plan to the participant during the one year period ending on the day before the date on which such loan is made, less b) the outstanding balance of loans from the Plan to the participant on the date on which such loan was made, or (h) one-half (1/2) of the present value of the non -forfeitable accrued benefit of the participant under the Plan. • For purposes of this limit, all plans of the Employer shall be considered one plan, to the extent required by Section 72 of the Internal Revenue Code, and the balance of all loans under any plan of the Employer under which the individual participates must be aggregated in determining the maximum loan available from the Plan. The Employer will be responsible for confirming the accuracy of the loan amount available for participant and has an outstanding loan balance with an Employer sponsored plan that is not administered by ING. • All assets under the participant's Account with the Contractor will be considered in determining the maximum loan amount available. • Loan fee shall be deducted from the participant's total account balance before determining the maximum loan amount available. • Loan Interest Rate -- the interest rate used for loans from your Plan must be commensurate with interest rates currently charged by persons in the business of lending money for loans which would be made under similar circumstances. The Contractor will set the loan interest rate on the first business day of each calendar month following the month in which a change in the loan interest rate index occurs. Changes to the loan rate will be applicable to loans issued on or after the first business day of the month following the month in which the rate is changed. The index for establishing the loan interest rate for the Plan is as follows. Select one of the following options : EJ Moody's Corporate Bond Yield Average -- Monthly Average Corporates, as published by Moody's Investors Service, Inc. on the last business day of each month. The following adjustment factor is to be added to the indexed interest rate for loans issued under the Plan. Select one of the following options. [:] No adjustment EJ 0.5% (one-half percent) [:] 1.0% (one percent) EJ 1.5% (one and one-half percent) ❑ 2% (two percent) El 2.5% (two and one-half percent) ❑ Other (specify)* * Subject to the Contractor's underwriting review and approval. • Loan Repayment Frequency - The loan repayment frequency will be used to amortize the loan- and calculate loan repayments. The loan repayment frequency will be determined by the payroll frequency. Check all that apply. If more than one frequency is checked, indicate the payroll location name or number to which the frequency applies. Frequency E] Weekly EJ Bi-weekly Semi -Monthly Monthly Annually Location Name or Number (list all that apply) • Loan Repayment Following Separation from Service —Are participants that have separated from service permitted to continue loan repayments? ❑ Yes —Plan Sponsor understands and agrees to the conditions noted below. ❑ No Conditions: 1. Must be permitted under the Plan document. 2. Plan Sponsor is responsible for providing the Contractor with any and all participant termination data in a mutually agreed upon electronic format. 3. Loan repayments for participants that have separated from service will be made via ACH Debit to the participant's bank account. 4. Should the participant take a full distribution of his or her account balance, the outstanding loan will be automatically defaulted. Prepayment - Prepayment of the full loan amount will be allowed at any time, without penalty. Partial loan prepayments are not permitted. • Maximum loan repayment period Internal Revenue Code section 72(p) requires a plan loan be repaid in full no later than 5 years from the date of the loan (except for a loan used to acquire a principal residence of the plan participant). Accordingly, it may be necessary to provide for a loan repayment term that is less than 60 months in order to meet the Code section 72(p) requirement (e.g., 57 or 58 months, etc.). General Purpose (maximum of 57 months.) Residential (maximum of 360 months.) • Investment of Loan Repayments - Loan repayments will be allocated in accordance with the participant's current contribution investment allocation instructions on the date a loan repayment is received in good order. • Loan Default Restrictions - If the participant defaults on any loan under the Plan, the participant shall not be allowed to initiate another loan of that type under the Plan until the defaulted amount is repaid. • Loan Fee - The Contractor shall charge a one-time fee to the Participant at the time of loan for services rendered under this Loan Program, in the amount of $100 per loan. Money Source Withdrawal Sequence — A withdrawal or liquidation sequence for money sources available to fund a loan from the be identified. Omit from the sequence the money -sources) not available to fund a loan. The. default sequence for a governmenta1957(b) plan is shown below — if no change is made, this is the withdrawal sequence that will apply to loans issued under the Plan. lst Employee Elective Deferrals 2nd Rollovers from another 457 Plan 3rd Rollovers from a 401 or 403(b) Plan or IRA Other (Please specify) • Fund withdrawal Sequence — money will be withdrawn from participant investment options on a pro-rata basis. Fixed Plus III Account restrictions may apply. • Spousal Consent -- indicate if spousal consent is required for loans from the Plan El Yes No • Loan Authorization — indicate who will be responsible for authorizing loan disbursements. Select one of the following options: El Authorized Plan Sponsor representative 0 the Contractor, based on the loan provisions of the Internal Revenue Code Section 72(p), corresponding regulations and terms of the Loan Program as identified in this Schedule. • Paperless Loan Processing — This service allows Plan participants to initiate general purpose loans online through a secure website or through a toll -free customer service line and receive a check directly from the Contractor without completing loan request paperwork. The loan provisions (Promissory Note and Truth and Lending Disclosure) are included on the check remittance. By endorsing the check, the participant accepts the terms of the loan. Paperless loan processing service is not available if the Plan requires additional qualifying criteria for loans (e.g., hardships or unforeseeable emergency) or if the Plan requires spousal consent for loan requests. This service is not available for residential loan requests. ❑ Plan Sponsor elects to utilize the Contractor's paperless loan processing service. • Loan Default Monitoring — where the Contractor is recordkeeping loans under the Plan, the Contractor will perform loan default monitoring as described herein. The loan default process will occur on the next to last business day of each month. This schedule allows us to effectively monitor and take .action on loans that risk default. The Plan Sponsor agrees that the Plan document shall identify the Grace Period as the last business day of the calendar quarter following the calendar quarter in which the loan repayment was due. You also agree to have the Contractor actively monitor and alert participants of potential loan defaults and defaulted loans. • Trust Requirement - Loans extended under this Loan Program will be held in trust by ING National Trust. Plan Sponsor Responsibilities: • Ensure the Plan document and any applicable state/local law allows for loans to be administered in accordance with the terms of this Loan Program. • The Plan Sponsor will inform the Contractor of the any change to the provisions of the Loan Program (and thus the criteria for approving loans under the Plan) as identified in this Schedule. • Establish payroll deduction of loan repayment amount for each participant with an approved loan. • Remit loan repayment amounts via the payroll submission tool being utilized by the Plan Sponsor on behalf of each active participant with an approved loan. The data provided is to include the loan identifier and repayment amount. • Notify the Contractor via the payroll submission tool being utilized by the Plan Sponsor of any participant with an outstanding loan who begins a leave of absence, either bona fide (for a period of not more than one year) or due to uniformed service (military duty) and for whom suspension of loan repayments will apply. The data provided is to include the type of leave, the start date and the end date. Contractor Responsibilities: • The Contractor will set the interest rate to apply to loans issued under the Plan. Such rate will be determined monthly for new loans. A loan will be processed using the rate in effect when the loan request package is sent to the Participant. The loan request package and interest rate will be valid for a maximum of 30 days. The Contractor will reset the loan interest rate as indicated in the Loan Interest Rate section above. The rate will apply for the duration of the loan. • Process loans from a participant's account in accordance with the terms of the Loan Program and the loan request package. • Deduct the loan amount from the participant's account based on the Money Source Withdrawal Sequence selected above, on a Oro-rata basis across all current investment options within the participants account or such other method as agreed upon between Contractor and the participant. • Generate reports, including a Loan Amortization Report, to be made available to the Plan Sponsor through a secure website. If the Plan Sponsor has elected to utilize the Contractor's plan sponsor reporting by payroll location service, the Loan Amortization Report will be segregated by payroll location. • Furnish participants with quarterly account statements, reflecting loan activity since the prior statement date. • Provide the Plan Sponsor with the loan repayment amount for each participant loan as determined by the level amortization calculation applicable to the amount of the loan, the repayment frequency, and selected repayment period. Loan repayment amounts will be provided through an automated periodic payroll feedback file as described in Appendix III to Schedule A. Loans can be re -amortized only upon written direction from the Plan Sponsor and only if there has been a change in the borrower's payroll frequency or status. Outstanding loans cannot be refinanced. • Upon notice from Plan Sponsor that a participant with an outstanding loan is on a qualifying leave of absence, loan repayments may be suspended for the maximum period permitted under IRS rules. Currently, IRS rules permit loan repayments to be suspended in the following circumstances: • A participant on a bona fide leave may suspend payments for up to one year if the pay received by the participant during this period is less than the amount of the installment payments required under the terms of the loan. However, the loan must still be repaid by the end of the loan term (i.e., the period of suspension will be less than one year if the loan was within one year of the final payment due date when the leave began). • A participant on a leave of absence due to performance of the uniformed services (as described under Internal Revenue Code Section 414(u)), may elect to suspend loan repayments for the period of uniformed service. In this situation, upon the participant's return from uniformed service, the loan repayment period will be extended by a period equal to the length of the uniformed service. The Contractor will monitor loan repayments and perform default processing if there is an outstanding balance after the scheduled loan maturity date or there is more than one scheduled loan repayment not received by the end of the Grace Period. Should this occur, the entire loan will be in default. Each month, we will generate a warning notification to any participant who has missed more than one loan repayment during the previous quarter or has an outstanding balance after the scheduled loan maturity date. The nolkOftormKOWes e inJ!lNations c uss im aacmergand the date on which the loan will be defaulted unless a repayment is promptly received. At the same time, we will generate a series of loan reports as noted below to be made available to the Plan Sponsor through a secure website. If the Plan Sponsor has elected to utilize the Contractor's plan sponsor reporting by payroll location service, these following reports will be segregated by payroll location. 1. Missed First Loan Payment Report — reflects loans with a first payment due during the current or previous month and have not had any loan payments applied. 2. Delinquent Loans Report — reflects loans that had any missing payments during the current month. 3. Loans Past Maturity Report — reflects loans that had a loan payoff/maturity date during the current month but have an outstanding loan balance. 4. Deemed/Offset Loans Report — reflects loans that were deemed or offset due to not being paid by the grace period applicable to the Plan. On the last business day of the calendar quarter we will default any loan in which the grace period expires that day. A confirmation statement will be sent to participants for whom a loan default is processed. • Compute and withhold federal and state income taxes, as required by law, for loan defaults or withdrawals from the Plan in order to repay outstanding loan amounts in full, in accordance with the Internal Revenue Code and applicable guidance. The Contractor will forward, within the applicable time limit, the appropriate information return reflecting the amount of the defaulted loan disbursement and taxes withheld to the appropriate taxing authority and to the participant. k Schedule C: Administrative Requirements For purposes of this Schedule, all references to "participant" are intended to apply equally to all account holders under the Plan. This includes participants, beneficiaries and alternate payees. 1. Participant account statements and Plan Sponsor reports shall reflect accurate information with regard to contributions, allocations, earnings and withdrawals. 2. Under normal circumstances and unless otherwise authorized by the Plan Sponsor; participant quarterly statements shall be mailed within 15 days of the end of a calendar quarter. 3. Information on payout options, including a notice which satisfies the requirements of Internal Revenue Code Section 442(f), will be made available to participants through the internet or a toll free telephone number. Additionally, upon a terminated Participant's request, a licensed representative will provide to the Participant education and assistance on the available payout options. 4. Contributions determined to be in Good Order on any day that the New York Stock Exchange is open (a "Business Day"), and exchange, prior to the close of the e, shall be applied to the appropriate account on that day' g s close of business of the New York Stock Exchange. Contributions received at any other time will be applied to the appropriate account on the next succeeding Business Day. Written confirmation of receipt and deposit will be provided to the Plan Sponsor or its designee by mail. The Contractor shall notify the Plan Sponsor or its designee by telephone within two business days of discovery of transactions received not in Good Order. If after 5 business days, transactions remain not in Good Order, the Contractor will require the Plan Sponsor to provide written consent for the Contractor to continue holding the amount of the contributions related to the not in Good Order transactions in a non - interest bearing suspense account. If after 14 business days, the transactions remain not in Good Order, the amount of the contributions received not in Good Order will be refunded to the Plan Sponsor. 5. A calendar year-end report shall be delivered to the Plan Sponsor, by h .'f of the following year. The custom Plan Review book includes Plan -specific data on plan assets, participant counts and average balances, contribution and distribution activities, service utilization along with fund performance and Scorecard information. Industry benchmarking is available to help you compare your Plan to other comparable plans in the industry. Schedule D: Plan Investment Options The Contractor agrees to provide Plan participants with a selection of investment options as shown below. The Plan Sponsor acknowledges that it has chosen these investment options to be made available to participants under the Plan. The Plan Sponsor acknowledges receipt and has reviewed the prospectuses for each identified investment option. Plan sponsor should consider the investment objectives, risks, and charges and expenses of the investment options carefully before choosing to make these options available to participants under the Plan. Fund prospectuses containing this and other information can be obtained by contacting your local representative. Please read the information carefully before signing this Agreement. You may also visit our website at www.jMgMtkgMXv1ans.co „misr�onsor to view your Plan -on-line. Schedule E Investment Provider Minimum Standards Disclosure -Statement The following items summarize the minimum administrative requirements required in order for the Contractor to transact with an investment provider on the Plan's behalf: l . Prising Deadlines: The investment provider must furnish the Contractor with confirmed net asset value information as of the close of trading (generally 4:00 p.m., Eastern Time) on the New York Stock Exchange ("Close of Trading") on each business day that the New York Stock Exchange is open for business ("Business Day") or at such other time as the net asset value of the fund is calculated, as disclosed in the relevant then current prospectus(es) in a format that includes (I*) the fund's name and the change from the last calculated net asset value, (ii) dividend and capital gains information as it arises. Such information shall be provided to the Contractor by 6:30 p.m. Eastern Time. "Net" means after all management, service and administrative expenses are deducted. 2. Priciniz Error Reimbursements: The investment provider shall agree to hold the Plan harmless for any amounts erroneously credited to participant accounts due to (1*) an incorrect calculation of the fund's daily net asset value ("NAV"), dividend rate, or capital gains distribution rate or (ii) incorrect or late reporting of the daily net asset value, dividend rate, or capital gains distribution rate of a fund, by reimbursing the Contractor, on the Plan's behalf. In addition, the fund shall be liable to the Contractor for systems and out of pocket costs incurred by the Contractor in making the Plan's or the participant's account whole, if such costs or expenses are a result of the fund's failure to provide timely or correct net asset values, dividend and capital gains or financial information and if such information is not corrected by 4:00 p.m. Eastern Time of the next Business Day after releasing such incorrect information provided the incorrect NAV as well as the correct NAV for each day that the error occurred is provided. If a mistake is caused in supplying such information, which results in a reconciliation with incorrect information, the amount required to make a Plan's or a Participant's account whole shall be borne by the investment provider providing the incorrect information, regardless of when the error is corrected. 3. Sales Literature: The investment provider will provide to the Contractor at least one com lete co of all pros ectuses statements of additional P - EE 4 1 information, annual and semiannual reports and proxy statements, other related documents, and all amendments or supplements to any of the above documents that relate to the fund promptly after the fling of such document with the SEC or other regulatory authorities. The investment provider agrees to provide to the Contractor, in electronic format, performance updates and portfolio updates for the fund within 10 business days after the end of each calendar quarter. 4. Advertising: Advertising and literature with respect to the fund prepared by the Contractor for use in marketing shares of the fund to the Plan shall be submitted to the investment provider for review and approval before such material is used with the Plan. The investment provider shall advise the Contractor in writing within three (3) Business Days of receipt of such materials of its approval or disapproval of such materials. 5. Expense Reimbursement: The investment provider shall make available for reimbursement certain out-of-pocket expenses the Contractor incurs in connection with providing shareholder services to the Plan. These expenses include actual postage paid by the Contractor in connection with mailing updated prospectuses, supplements and financial reports to participants, and all costs incurred by the Contractor associated with proxies for the fund, including proxy preparation, group authorization letters, programming for tabulation and necessary materials (including postage). b. Excessive Trading: The investment provider shall use its best efforts and shall reasonably cooperate with the Contractor to generally prevent any market timing and frequent trading activity under the Plan. See the ING "Excessive Trading" Policy, Schedule F. Schedule F: ING Excessive Trading Policy The ING family of insurance companies ("ING"), as providers of multi -fund variable insurance and retirement products, has adopted this Excessive Trading Policy to respond to the demands of the various fund families which make their funds available through our variable insurance and retirement products to restrict excessive fund trading activity and to ensure compliance with Section 22c-2 of the Investment Company Act of 1940, as amended. ING's current definition of Excessive Trading and our policy with respect to such trading activity is outlined below. 1. ING actively monitors fund transfer and reallocation activity within its variable insurance and retirement products to identify Excessive Trading. ING currently defines Excessive Trading as: a. More than one purchase and sale of the same fund (including money market funds) within a 60 calendar day period (hereinafter, a purchase and sale of the same fund is referred to as a "round-trip"). This means two or more round -trips involving the same fund within a 60 calendar day period would meet ING's definition of Excessive Trading; or b.. Six round -trips within a twelve month period. The following transactions are excluded when determining whether trading activity is excessive: a. Purchases or sales of shares related to non -fund transfers (for example, new purchase payments, withdrawals and loans); b. Transfers associated with scheduled dollar cost averaging, scheduled rebalancing or scheduled asset allocation programs; c. Purchases and sales of fund shares in the amount of $5,000 or less; d. Purchases and sales of funds that affirmatively permit short-term trading in their fund shares, and movement between such funds and a money market fund; and e. Transactions initiated by a member of the ING family of insurance companies. 2. If ING determines that an individual has made a purchase of a fund within 60 days of a prior round-trip involving the same fund, ING will send them a letter warning that another sale of that same fund within 60 days of the beginning of the prior round-trip will be deemed to be Excessive Trading and result in a six month suspension of their ability to initiate fund transfers or reallocations through the Internet, facsimile, Voice Response Unit (VRU), telephone calls to the ING Customer Service Center, or other electronic trading medium that ING may make available from time to time ("Electronic Trading Privileges"). Likewise, if ING determines that an individual has made five round -trips within a twelve month period, ING will send them a letter warning that another purchase and sale of that same fund within twelve months of the initial purchase in the first round-trip in the prior twelve month period will be deemed to be Excessive Trading and result in a six month suspension of their Electronic Trading Privileges. According to the needs of the various business units, a copy of the warning letters may at e s tyl , to ers 2 ate fund transfers or reallocations, the agent/registered representative or investment adviser for that individual. A copy of the warning letters and details of the individual's trading activity may also be sent to the fund whose shares were involved in the trading activity. 3. If ING determines that an individual has used one or more of its products to engage in Excessive Trading, ING will send a second letter to the individual. This letter will state that the individual's Electronic Trading Privileges have been suspended for a period of six months. Consequently, all fund transfers or reallocations, not just those which involve the fund whose shares were involved in the Excessive Trading activity, will then have to be initiated by providing written instructions to ING via regular U.S. mail. During the six month suspension period, electronic "inquiry only" privileges will be permitted where and when possible. A copy of the letter restricting future transfer and reallocation activity to regular U.S. mail and details of the individual's trading activity may also be sent to the fund whose shares were involved in the Excessive Trading activity. 4. Following the six month suspension period during which no additional Excessive Trading is identified, Electronic Trading Privileges may again be restored. ING will continue to monitor the fund transfer and reallocation activity, and any future Excessive Trading will result in an indefinite suspension of the Electronic Trading Privileges. Excessive Trading activity during the six month suspension period will also result in an indefinite suspension of the Electronic Trading Privileges. 5. ING reserves the right to limit fund trading or reallocation privileges with respect to any individual, with or without prior notice, if ING determines that the individual's trading activity is disruptive, regardless of whether the individual's trading activity falls within the definition of Excessive Trading set forth above. Also, ING's failure to send or an individual's failure to receive any warning letter or other notice contemplated under this Policy will not prevent ING from suspending that individual's Electronic Trading Privileges or taking any other action provided for in this Policy. 6. Each fund available through ING's variable insurance and retirement products, either by prospectus or stated policy, has adopted or may adopt its own excessive/frequent trading policy. ING reserves the right, without prior notice, to implement restrictions and/or block future purchases of a fund by an individual who the fund has identified as violating its excessive/frequent trading policy. All such restrictions and/or blocking of future fund purchases will be done in accordance with the directions ING receives from the fund. I, Wit. , Schedule G: General Compensation Provisions 1. Direct and Indirect Compensation: This Schedule describes compensation received by the Contractor for services rendered to the Plan and Plan participants, including fees and revenue derived from both direct and indirect sources. Direct Compensation includes compensation paid directly by Plan Sponsor or the Plan to the Contractor for plan recordkeeping and administrative services including certain transaction fees that are charged directly to participant accounts. Indirect Compensation includes compensation from sources other than direct fees that the Contractor may collect from third parties, including revenue derived from service arrangements with mutual funds, revenue sharing and other indirect compensation that may be generated in servicing the Plan. 2. Assumptions: As provided in Section 1 of the Agreement, the Contractor has agreed to perform certain services. Based on the assumptions outlined in the Agreement, the Contractor agrees to supply the Services for the compensation specified in Section 3.01 of the Agreement, as supplemented by any additional compensation or transaction fees as specified within Schedule B with respect to administration of loans under the Plan and with respect to Investment Advisory Services and/or Self Directed Brokerage Account, as specified in a separately executed agreement(s). 3. Fund Specific Revenue: Indirect compensation received by the Contractor represents revenue from investment companies based on the investment of assets held in the Plan pursuant to agreements between the applicable investment companies and the Contractor. They represent fees payable from such investment companies for shareholder services, sub -transfer agency services, or pursuant to a 12b-1 plan adopted by such investment companies. In the case of investment options of ILIAC affiliates or former affiliates, Contractor compensation represents revenue assumptions made by the Contractor's defined contribution business for purposes of product pricing. Gross revenues from such investment options generally include payments for investment management and for certain administrative services. Pricing assumptions are derived from gross fund revenues, less the internally transferred costs of fund management and administration. The pricing assumptions for certain investment options of ILIAC affiliates or former affiliates reflect the approximate weighted average of the net fund revenues of each portfolio within a given ILIAC fund complex. 4 . Changes in Investment ti ons : -- - 0 p To the extent the Contractor's compensation is derived in whole or in part from revenue from the Plan Sponsor's selection of certain investment products offered by or through the Contractor, the Contractor reserves the right to amend the Agreement, including this Schedule, in the event such revenue is reduced by a change in the investment products or options available under the Plan. Schedule H ILIAC's Policy For Correction of Inadvertent Processing Errors As your Plan's administrative service provider, ING Life Insurance and Annuity Company ("ILIAC") has agreed to process transaction orders received in good order prior to market close from the plan and plan participants accurately and on a timely basis. We seek to avoid transaction processing errors to the greatest extent possible, but inadvertent errors do occur from time to time. Inadvertent processing errors are exclusively defined as incorrect or untimely processing by ILIAC employees of transactions that are received in good order. Inadvertent processing errors do not include errors made by plan sponsors or third parties. ILIAC will correct any identified inadvertent processing error caused by ILIAC (an "ILIAC inadvertent processing error") as soon as practicable, typically no later than five (5) business days after ILIAC has identified sufficient information to correct the error. ILIAC represents that in no event will ILIAC exercise discretionary authority or control over the correction of inadvertent processing errors in order to maximize gain or correct such error for ILIAC's own benefit or interest. Once an ILIAC inadvertent processing error has been identified, we promptly take corrective action to put the plan and its participants in a position financially equivalent to the position they would have been in if the processing error had not occurred. This means that ILIAC will make the plan whole for any loss to a plan resulting from correcting an ILIAC processing error. If any gain to a plan results in connection with a corrected transaction, ILIAC will keep that gain. The following examples illustrate the effect of the policy: • When a plan participant directs that a certain dollar amount be contributed to his or her plan account, ILIAC credits the number of investment units that dollar amount will purchase to the participant's account on Day 1, the day the contribution is processed. The number of units is based on the unit's dollar value on Day 1, as set by the investment fund and communicated to ILIAC after market close. If an inadvertent error occurs, and ILIAC does not process the contribution until Day 2, ILIAC will determine the number of units that should have been credited on Day 1, using Day 1's unit price. If, on Day 2, the unit price has gone up, the dollar amount of the contribution will not be enough to cover the number of units the participant should have received. ILIAC will make up the difference such that the participant receives the number of units he or she would have received on Day 1 and ILIAC will absorb the loss. The participant is not charged for any additional cost. However, if, on Day 2, the unit price has gone down, the amount of the contribution would purchase more units on Day 2 than it would have purchased on Day 1. In that circumstance, the participant will receive the number of units he or she would have received on Day 1 had the transaction been processed and ILIAC will keep the excess as part of its overall fee for services under the contract. Regardless of whether there is a gain or a loss, the participant receives the benefit of what he or she requested. When a plan participant makes a withdrawal request of a certain dollar amount from his or her account, ILIAC liquidates or sells the number of investment units needed in order to make the distribution. Thus, on Day 1, ILIAC typically would sell or liquidate investment units in the participant's investment fund at Day 1's price to make the distribution. If, due to an ILIAC inadvertent processing Error, ILIAC processes the instructions a day late, ILIAC will make sure that the participant receives the dollar amount he/she requested. ILIAC will sell or liquidate the same number of units that would have been sold on Day 1 had the transaction been accomplished on Day 1. If the unit price has declined, liquidated units will have a lower value on Day 2 than they had on Day 1, which means that ILIAC must make up the difference so that the participant receives the requested amount in full. In doing so, ILIAC will incur a loss, which it absorbs. On the other hand, if the market has gone up and the units have increased in value, ILIAC will sell the same number of units as it would have sold on Day 1, but the sales amount will be higher than the requested withdrawal. ILIAC will keep the excess as part of its overall fee. In either circumstance, the participant receives the benefit of what he or she requested and bears no additional cost. ILIAC tracks the net financial experience of ILIA.C's Correction Account and the effect of the corrections for each affected plan on an annual basis and will make that information available in accordance with ERISA Section 408(b)(2). Any gains kept by ILIAC constitutes additional compensation for the services provided by ILIAC under its contract and ILIAC will report it in accordance with ERISA Section 408(b)(2)• By executing an administrative services agreement with ILIAC, you are authorizing ILIAC's application of the error correction policy as described above to your Plan in connection with the plan administrative services that ILIAC will provide. You have the right to terminate ILIAC's services in accordance with the terms of the administrative services agreement. S6heu1e : Authorized Plan Sponsor Representative The Contractor is hereby authorized to act upon the directions, instructions, and any information provided by any of the Authorized Plan Sponsor Representatives listed below. These signatures will be accepted until the Contractor is notified of a change in writing. The following person(s) have the authority under the Plan to provide direction to the Contractor with respect to administration of the Plan including any benefit sensitive financial transactions permitted under the Plan and requests for contribution refunds. In the event that a Plan Sponsor Representative is removed or replaced, the Contractor must be notified immediately in writing - please contact the Contractor's designated Plan Manager to request the applicable administrative form to complete. I. ( Name (please type or print) Agency, Division or Location Name and Code (if applicable) Authorized Plan Sponsor Representatives Signature 2. 1 Name (please type or print) Agency, Division or Location Name and Code (if applicable) Authorized Plan Sponsor Representatives Signature 1 j Name (please type or print) Agency, Division or Location Name and Code (if applicable) Authorized Plan Sponsor Representatives Signature 4. 1 Name (please type or print) Agency, Division or Location Name and Code (if applicable) Authorized Plan Sponsor Representatives Signature Title Title Title Title Schedule K: Contractor's Primary Contact The Contractor designates the following individual(s) to serve as its primary point of contact to the Plan Sponsor with respect to this Agreement. n. fg�:taxrie Plan Manager ING Life Insurance and Annuity Company One Orange Way Windsor, CT 06095 Aine Rolubi""A lo.14Wk —j71— Schedule K: Licensed Representatives The Contractor designates the following individual(s) to serve as its Iicensed representatives with respect to this Agreement. Licensed representatives are designated as one of the following: Agent, including Career Agent --- Appointed with ING Life Insurance and Annuity Company, registered representative of ING Financial Partners, Inc. and receives commission based compensation. Broker — (Non ING FA Only) — Appointed with ING Life Insurance and Annuity Company, but affiliated with a broker -dealer other than ING Financial Partners, Inc. and receives commission based compensation. Salaried Enroller -- ING Life Insurance and Annuity Company employees who will not receive commission based salary and are registered representatives of ING Financial Partners, Inc. F-1 Agent [:] Broker F Salaried Enroller Representative Name Broker Dealer Affiliation Last 4 Digits SSN Office Code Rep # % Participation (Lac. Code Agent Broker F-1 Salaried Enroller Representative Name Broker Dealer Affiliation Office Code Agent Rep # Broker Representative Name Broker Dealer Affiliation Last 4 Digits SSN % Participation (Loc. Code Salaried Enroller Last 4 Digits SSN Office Code Rep # % Participation _ Loc. Code )