HomeMy WebLinkAbout4.11 Agreement ICMA-RC or
19 82 STAFF REPORT CITY CLERK
CITY COUNCIL File #600-30
DATE: January 20, 2015
TO: Honorable Mayor and City Councilmembers
FROM: Christopher L. Foss, City Manager "
SUBJECT: Approval of Agreement with ICMA-RC to Administer the Ci Y's Deferred
Compensation Plan
Prepared by Colleen Tribby, Director of Administrative Services
EXECUTIVE SUMMARY:
The City Council will consider a contract renewal with International City Management
Association Retirement Corporation (ICMA-RC) to administer its deferred compensation plan.
FINANCIAL IMPACT:
Approval of the contract will have no financial impact to City funds. Applicable fees are paid from
employee contributions held in trust.
RECOMMENDATION:
Staff recommends that the City Council adopt the Resolution Authorizing the City Manager to
Execute a Contract Renewal With International City Management Association Retirement
Corporation to Provide Third Party Administrator Services for the City's Deferred Compensation
Plan.
Reviewed By
Assistant City Manager
DESCRIPTION:
Since August 1988, the City has contracted with International City Management Association
Retirement Corporation (ICMA-RC) to provide administrative services of the City's deferred
compensation plans (401(a) and 457 plans). In addition to investment advisory, ICMA-RC's
range of services includes account maintenance, account recordkeeping, investment and tax
reporting, transaction processing, benefit disbursement, and asset management.
Page 1 of 2 ITEM NO. 4.11
The current agreement between the City and ICMA-RC was amended in February of 2011, with
a five-year contract term and administration fees of 0.15% per year of the amount of plan assets
invested.
With the City Council's approval, the City Manager will execute a new contract with ICMA-RC
(Attachment 2) that will effective for seven years (ending in January 2022), and which eliminates
the 0.15% annual fee after the first two years.
In October 2014, a representative of ICMA-RC presented to the City of Dublin Employee
Committee the terms of the proposed agreement, and discussed the various member benefits
that the contract provides for, including financial planning, estate planning, pre-retirement
planning, on-line enrollment, and self-directed accounts. The Employee Committee
recommended that the City proceed with the new seven-year mutually exclusive agreement.
NOTICING REQUIREMENTS/PUBLIC OUTREACH:
None.
ATTACHMENTS: 1. Resolution authorizing the City Manager to Execute a Contract
Renewal with International City Management Association Retirement
Corporation to provide Third Party Administrator Services for the
City's Deferred Compensation
2. Administrative Services Agreement with ICMA-RC
Page 2 of 2
RESOLUTION NO. XX - 15
A RESOLUTION OF THE CITY COUNCIL
OF THE CITY OF DUBLIN
* * * * * * * * * * *
AUTHORIZING THE CITY MANAGER TO EXECUTE A CONTRACT RENEWAL WITH
INTERNATIONAL CITY MANAGEMENT ASSOCIATION RETIREMENT CORPORATION TO
PROVIDE THIRD PARTY ADMINISTRATOR SERVICES FOR THE CITY'S DEFERRED
COMPENSATION PLAN
WHEREAS, On August 22, 1988 the City Council of the City of Dublin adopted Resolution
116-88 Establishing a Deferred Compensation Plan to be administered by the International City
Management Association Retirement Corporation (ICMA-RC); and
WHEREAS, the current agreement between ICMA-RC and the City of Dublin was
amended on February 14, 2011; and
WHEREAS, the City of Dublin has affirmed the continued need to contract with a third
party for administrative services of the City's deferred Compensation Plan;
WHEREAS, the City of Dublin desires that the investment of funds held under its deferred
compensation plan continue to be administered ICMA-RC under a new contract that provides for
a reduction to the City's administration fee and a seven year contract term.
NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Dublin
hereby authorizes the City Manager to execute a contract agreement with ICMA-RC for Third
Party Administrator Services.
PASSED, APPROVED AND ADOPTED this 20th day of January, 2015, by the following
vote:
AYES:
NOES:
ABSENT:
ABSTAIN:
Mayor
ATTEST:
City Clerk
ATTACHMENT 1
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ADMINISTRATIVE SERVICES AGREEMENT
Between
ICMA Retirement Corporation
and
City of Dublin
Type: 457
Account#: 302959
Type: 401
Account#: 106040
GS/RS
Plan numbers 302959, 106040
ADMINISTRATIVE SERVICES AGREEMENT
This Administrative Services Agreement("Agreement"),made as of the day
of ,2014 (herein referred to as the"Inception Date"), between the International
City Management Association Retirement Corporation("ICMA-RC"), a nonprofit
corporation organized and existing under the laws of the State of Delaware, and the City
of Dublin ("Employer"), a City organized and existing under the laws of the State of
California with an office at 100 Civic Plaza,Dublin, California 94568.
RECITALS
Employer acts as public plan sponsor of a retirement plan("Plan"), and in that
capacity,has responsibility to obtain administrative services and investment alternatives
for the Plan;
VantageTrust is a group trust established and maintained in accordance with New
Hampshire Revised Statutes Annotated section 391:1 and Internal Revenue Service
Revenue Ruling 81-100, 198 1-1 C.B. 326,which provides for the commingled
investment of retirement funds held by various state and local governmental units for
their employees;
ICMA-RC acts as investment adviser to VantageTrust Company, LLC,the
Trustee of VantageTrust;
ICMA-RC has designed, and VantageTrust offers, a series of separate funds (the
"Funds") for the investment of plan assets as referenced in VantageTrust's principal
disclosure document, "Making Sound Investment Decisions: A Retirement Investment
Guide" and the accompanying VantageTrust Fund Fees and Expenses document
("Retirement Investment Guide").
The Funds are available only to public employers and only through VantageTrust
and ICMA-RC.
In addition to serving as investment adviser to VantageTrust, ICMA-RC provides
a range of services to public employers for the operation of employee retirement plans
including, but not limited to, communications concerning investment alternatives,
account maintenance, account recordkeeping, investment and tax reporting,transaction
processing,benefit disbursement, and asset management.
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Plan numbers 302959, 106040
AGREEMENTS
I. Appointment of ICMA-RC
Employer hereby appoints ICMA-RC as Administrator of the Plan to perform all
nondiscretionary functions necessary for the administration of the Plan. The functions to
be performed by ICMA-RC shall be those set forth in Exhibit A to this Agreement.
2. Adoption of Trust
Employer has adopted the Declaration of Trust of VantageTrust Company and agrees to
the commingled investment of assets of the Plan within VantageTrust. Employer agrees
that the investment,management, and distribution of amounts deposited in VantageTrust
shall be subject to the Declaration of Trust, as it may be amended from time to time and
shall also be subject to terms and conditions set forth in disclosure documents (such as
the Retirement Investment Guide or Employer Bulletins) as those terms and conditions
may be adjusted from time to time.
3. ExclusivL Agreement
Employer agrees that for the initial or succeeding term of this Agreement specified in
Section 10, so long as ICMA-RC continues to perform in all material respects the
services to be performed by it under this Agreement,Employer shall not obtain plan
administration from anyone other than ICMA-RC. Employer acknowledges that ICMA-
RC has agreed to the compensation to be paid to ICMA-RC under this Agreement in the
expectation that ICMA-RC will be able to offset costs allocable to performing this
Agreement with revenues arising from Employer's exclusive use of ICMA-RC at the
rates provided herein throughout the initial or succeeding term.
4. Employer Duty to Furnish Information
Employer agrees to furnish to ICMA-RC on a timely basis such information as is
necessary for ICMA-RC to carry out its responsibilities as Administrator of the Plan,
including information needed to allocate individual participant accounts to Funds in
VantageTrust, and information as to the employment status of participants, and
participant ages, addresses, and other identifying information(including tax identification
numbers).Employer also agrees that it will notify ICMA-RC in a timely manner
regarding changes in staff as it relates to various roles. This is to be completed through
the online EZLink employer contact options.ICMA-RC shall be entitled to rely upon the
accuracy of any information that is furnished to it by a responsible official of the
Employer or any information relating to an individual participant or beneficiary that is
furnished by such participant or beneficiary, and ICMA-RC shall not be responsible for
any error arising from its reliance on such information. ICMA-RC will provide reports,
statements and account information to the Employer through EZLink,the online plan
administrative tool.
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Plan numbers 302959, 106040
Employer is required to send in contributions through EZLink,the online plan
administration tool provided by ICMA-RC. Alternative electronic methods may be
allowed,but must be approved by ICMA-RC for use. Contributions may not be sent
through paper submittal documents.
To the extent Employer selects third-party funds that do not have fund profile
information provided to ICMA-RC through our electronic data feeds from external
sources (such as Morningstar)or third party fund providers,the Employer is responsible
for providing to ICMA-RC timely fund investment updates for disclosure to Plan
participants. Such updates may be provided to ICMA-RC through the Employer's
investment consultant or other designated representative.
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Failure to provide timely fund profile update information, including the source of the
information,may result in a lack of fund information for participants, as ICMA-RC will
remove outdated fund profile information from the systems that provide fund information
to Plan participants.
5. Certain Representations and Warranties
ICMA-RC represents and warrants to Employer that:
(a) ICMA-RC is a non-profit corporation with full power and authority to
enter into this Agreement and to perform its obligations under this
Agreement. The ability of ICMA-RC to serve as investment adviser to
VantageTrust is dependent upon the continued willingness of
VantageTrust for ICMA-RC to serve in that capacity.
(b) ICMA-RC is an investment adviser registered as such with the U.S.
Securities and Exchange Commission under the Investment Advisers Act
of 1940, as amended.
(c)(i) ICMA-RC shall maintain and administer the Plan in accordance with the
requirements for eligible deferred compensation plans under Section 457
of the Internal Revenue Code and other applicable federal law;provided,
however,that ICMA-RC shall not be responsible for the eligible status of
the Plan in the event that the Employer directs ICMA-RC to administer the
Plan or disburse assets in a manner inconsistent with the requirements of
Section 457 or otherwise causes the Plan not to be carried out in
accordance with its terms. Further, in the event that the Employer uses its
own customized plan document,ICMA-RC shall not be responsible for
the eligible status of the Plan to the extent affected by terms in the
Employer's plan document that differ from those in ICMA-RC's standard
plan document. ICMA-RC shall not be responsible for monitoring state or
local law or for administering the Plan in compliance with local or state
requirements unless Employer notifies ICMA-RC of any such local or
state requirements.
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Plan numbers 302959, 106040
(c)(ii) ICMA-RC shall maintain and administer the Plan in accordance with the
requirements for plans which satisfy the qualification requirements of
Section 401 of the Internal Revenue Code and other applicable federal
law;provided,however, ICMA-RC shall not be responsible for the
qualified status of the Plan in the event that the Employer directs ICMA-
RC to administer the Plan or disburse assets in a manner inconsistent with
the requirements of Section 401 or otherwise causes the Plan not to be
carried out in accordance with its terms;provided, further,that if the plan
document used by the Employer contains terms that differ from the terms
of ICMA-RC's standardized plan document, ICMA-RC shall not be
responsible for the qualified status of the Plan to the extent affected by the
differing terms in the Employer's plan document. ICMA-RC shall not be
responsible for monitoring state or local law or for administering the Plan
in compliance with local or state requirements unless Employer notifies
ICMA-RC of any such local or state requirements.
Employer represents and warrants to ICMA-RC that:
(d) Employer is organized in the form and manner recited in the opening
paragraph of this Agreement with full power and authority to enter into
and perform its obligations under this Agreement and to act for the Plan
and participants in the manner contemplated in this Agreement. Execution,
delivery, and performance of this Agreement will not conflict with any
law,rule, regulation or contract by which the Employer is bound or to
which it is a party.
(e) Employer understands and agrees that ICMA-RC's sole function under
this Agreement is to act as recordkeeper and to provide administrative,
investment or other services at the direction of Plan participants,the
Employer, its agents or designees in accordance with the terms of this
Agreement. Under the terms of this Agreement, ICMA-RC does not
render investment advice, is not the Plan Administrator or Plan Sponsor as
those terms are defined under applicable federal, state, or local law, and
does not provide legal,tax or accounting advice with respect to the
creation, adoption or operation of the Plan and its related trust. ICMA-RC
does not perform any service under this Agreement that might cause
ICMA-RC to be treated as a"fiduciary"of the Plan under applicable law.
(f) Employer acknowledges and agrees that ICMA-RC does not assume any
responsibility with respect to the selection or retention of the Plan's j
investment options. Employer shall have exclusive responsibility for the
Plan's investment options, including the selection of the applicable mutual
fund share class. Where applicable,Employer understands that the VT
Retirement Income Advantage Fund is an investment option for the Plan
and that the fund invests in a separate account available through a group
variable annuity contract. By entering into this Agreement,Employer
acknowledges that it has received the Important Considerations document
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Plan numbers 302959, 106040
and the Retirement Investment Guide and that it has read the information
therein concerning the VT Retirement Income Advantage Fund.
(g) Employer acknowledges that certain such services to be performed by
ICMA-RC under this Agreement may be performed by an affiliate or
agent of ICMA-RC pursuant to one or more other contractual
arrangements or relationships, and that ICMA-RC reserves the right to
change vendors with which it has contracted to provide services in
connection with this Agreement without prior notice to Employer.
(h) Employer acknowledges that it has received ICMA-RC's Fee Disclosure
Statement,prepared in substantial conformance with ERISA regulations
regarding the disclosure of fees to plan sponsors.
(i) Employer approves the use of its Plan in ICMA-RC external media,
publications and materials. Examples include press releases
announcements and inclusion of the general plan information in request
for proposal responses.
6. Participation in Certain Proceedings
The Employer hereby authorizes ICMA-RC to act as agent,to appear on its behalf, and to
join the Employer as a necessary party in all legal proceedings involving the garnishment
of benefits or the transfer of benefits pursuant to the divorce or separation of participants
in the Plan. Unless Employer notifies ICMA-RC otherwise,Employer consents to the
disbursement by ICMA-RC of benefits that have been garnished or transferred to a
former spouse, current spouse, or child pursuant to a domestic relations order or child
support order.
7. Compensation and Payment
(a) Plan Administration Fee. For years one (1) and two (2) of this j
Agreement,the amount to be paid for plan administration services under
this Agreement shall be 0.15%per annum of the amount of Plan assets
invested in VantageTrust. Such fee shall be computed based on average
daily net Plan assets in VantageTrust.
For years three(3)through seven (7) of this Agreement,the amount to be
paid for plan administration services under this Agreement shall be 0.00%
per annum of the amount of Plan assets invested in VantageTrust. ICMA-
RC's compensation under this Agreement shall be as set forth in
subsection (c)below.
(b) Mutual Fund Services Fee. There is an annual charge of 0.00%assessed
against average daily net Plan assets invested in VantageTrust's Trust
Series funds,which are a group of funds each of which invests
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Plan numbers 302959, 106040
substantially all of its assets in a third-party mutual fund not affiliated with
ICMA-RC. .
(c) Compensation for Management Services to VantageTrust,
Compensation for Advisory and other Services to The Vantagepoint
Funds and Payments from Third-Party Mutual Funds. Employer
acknowledges that, in addition to amounts payable under this Agreement,
ICMA-RC receives fees from VantageTrust for investment advisory
services and plan and participant services furnished to VantageTrust.
Employer further acknowledges that certain wholly owned subsidiaries of
ICMA-RC receive compensation for advisory and other services furnished
to The Vantagepoint Funds,which serve as the underlying portfolios of a
number of Funds offered through VantageTrust. For a VantageTrust Fund
that invests substantially all of its assets in a third-party mutual fund not
affiliated with ICMA-RC, ICMA-RC or its wholly owned subsidiary
receives payments from the third-party mutual fund families or their
service providers in the form of 12b-1 fees, service fees, compensation for
sub-accounting and other services provided based on assets in the
underlying third-party mutual fund. These fees are described in the
Retirement Investment Guide and ICMA-RC's fee disclosure statement.
In addition,to the extent that third party mutual funds are included in the
investment line-up for the Plan, ICMA-RC receives administrative fees
from its third party mutual fund settlement and clearing agent for
providing administrative and other services based on assets invested in
third party mutual funds; such administrative fees come from payments
made by third party mutual funds to the settlement and clearing agent.
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(d) Redemption Fees. Redemption fees imposed by outside mutual funds in
which Plan assets are invested are collected and paid to the mutual fund by
ICMA-RC. ICMA-RC remits 100%of redemption fees back to the
specific mutual fund to which redemption fees apply. These redemption
fees and the individual mutual fund's policy with respect to redemption
fees are specified in the prospectus for the individual mutual fund and
referenced in the Retirement Investment Guide.
(e) Payment Procedures.All payments to ICMA-RC pursuant to this Section
7 shall be made from Plan assets held by VantageTrust or received from
third party mutual funds or their service providers in connection with Plan
assets invested in such third party mutual funds,to the extent not paid by
the Employer. The amount of Plan assets held through VantageTrust shall
be adjusted by VantageTrust as required to reflect any such payments as
are made from Plan assets invested in VantageTrust. In the event that the
Employer agrees to pay amounts owed pursuant to this Section 7 directly,
any amounts unpaid and outstanding after 30 days of invoice to the
Employer shall be withdrawn from Plan assets held by VantageTrust.
The compensation and payment set forth in this Section 7 are contingent upon the
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Plan numbers 302959 106040
Employer's use of ICMA-RC's EZLink system for contribution processing and
submitting contribution funds by ACH or wire transfer on a consistent basis over the
term of this Agreement.
The compensation and payment in this Section 7 will take effect in the calendar
quarter following receipt of one fully executed copy of this Administrative Services
Agreement based upon the following schedule:
• Agreement received by February 20—Effective April
• Agreement received by May 20—Effective July
• Agreement received by August 20—Effective October
• Agreement received by November 20—Effective January
Employer further acknowledges and agrees that compensation and payment under this
Agreement shall be subject to re-negotiation in the event that the Employer chooses
to implement additional funds not on ICMA-RC's mutual fund platform.
8. Contribution Remittance
Employer understands that amounts invested through VantageTrust are to be remitted
directly to VantageTrust in accordance with instructions provided to Employer by ICMA-
RC and are not to be remitted to ICMA-RC. In the event that any check or wire transfer is
incorrectly labeled or transferred to ICMA-RC, ICMA-RC may return it to Employer
with proper instructions.
9. Indemnification
ICMA-RC shall not be responsible for any acts or omissions of any person with respect
to the Plan or its related trust, other than ICMA-RC in connection with the administration
or operation of the Plan. Employer shall indemnify ICMA-RC against, and hold ICMA-
RC harmless from, any and all loss, damage,penalty, liability, cost, and expense,
including without limitation,reasonable attorney's fees,that may be incurred by, imposed
upon, or asserted against ICMA-RC by reason of any claim,regulatory proceeding, or
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litigation arising from any act done or omitted to be done by any individual or person
with respect to the Plan or its related trust, excepting only any and all loss, damage,
penalty, liability, cost or expense resulting from ICMA-RC's negligence, bad faith, or
willful misconduct.
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10. Term
This Agreement shall be in effect and commence on the date all parties have signed and
executed this Agreement ("Inception Date"). The term of this Agreement will commence
on the Inception Date and extend seven (7) years from that date. This Agreement will be
renewed automatically for each succeeding year unless written notice of termination is
provided by either party to the other no less than 60 days before the end of such
Agreement year. The Employer understands and agrees that, in the event the Employer
terminates this Agreement (or replaces the VT PLUS Fund as an investment option in its
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Plan numbers 302959, 106040
investment line-u p), ICMA-RC retains full discretion to release Plan assets invested in
the VT PLUS Fund in an orderly manner over a period of up to 12 months from the date
ICMA-RC receives written notification from the Employer that it has made a final and
binding selection of a replacement for ICMA-RC as administrator of the Plan (or a
replacement investment option for the VT PLUS Fund).
11. Amendments and Adiustments
(a) This Agreement may be amended by written instrument signed by the parties.
(b)ICMA-RC may amend this agreement by providing 60 days' advance written
notice to the Employer prior to the effective date of such proposed amendment.
Such amendment shall become effective unless, within the 60-day notice period,
the Employer notifies ICMA-RC in writing that it objects to such amendment.
(c) The parties agree that enhancements may be made to administrative and
operations services under this Agreement. The Employer will be notified of
enhancements through the Employer Bulletin, quarterly statements, electronic
messages or special mailings. Likewise, if there are any reductions in fees, these
will be announced through the Employer Bulletin, quarterly statement, electronic
or special mailing.
12. Notices
All notices required to be delivered under this Agreement shall be in writing and shall be
delivered, mailed, e-mailed or faxed to the location of the relevant parry set forth below
or to such other address or to the attention of such other persons as such party may
hereafter specify by notice to the other parry.
ICMA-RC: Legal Department, ICMA Retirement Corporation, 777
North Capitol Street,N.E., Suite 600, Washington,D.C., 20002-4240
Facsimile; (202) 962-4601
Employer: at the office set forth in the first paragraph hereof, or to any
other address, facsimile number or e-mail address designated by the
Employer to receive the same by written notice similarly given.
Each such notice, request or other communication shall be effective: (i) if given by
facsimile, when transmitted to the applicable facsimile number and there is appropriate
confirmation of receipt; (ii) if given by mail or e-mail, upon transmission to the
designated address with no indication that such address is invalid or incorrect; or (iii) if
given by any other means,when actually delivered at the aforesaid address.
13. Complete Agreement
This Agreement shall constitute the complete and full understanding and sole agreement
between ICMA-RC and Employer relating to the object of this Agreement and correctly
9
Plan numbers 302959, 106040
sets forth the complete rights, duties and obligations of each party to the other as of its
date.This Agreement supersedes all written and oral agreements, communications or
negotiations among the parties.Any prior agreements,promises,negotiations or
representations,verbal or otherwise,not expressly set forth in this Agreement are of no
force and effect.
14. Titles
The headings of Sections of this Agreement and the headings for each of the attached
schedules are for convenience only and do not define or limit the contents thereof.
15. Incorporation of Schedules
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All Schedules (and any subsequent amendments thereto), attached hereto, and referenced
herein, are hereby incorporated within this Agreement as if set forth fully herein.
16. Governing Law
This Agreement shall be governed by and construed in accordance with the laws of the
State of California, applicable to contracts made in that jurisdiction without reference to
its conflicts of laws provisions.
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Plan numbers 302959, 106040
In Witness Whereof,the parties hereto certify that they have read and understand this
Agreement and all Schedules attached hereto and have caused this Agreement to be
executed by their duly authorized officers as of the Inception Date first above written.
CITY OF DUBLIN
By Date
Signature
Name and Title (Please Print)
INTERNATIONAL CITY MANAGEMENT ASSOCIATION
RETIREMENT CORPORATION
By t
An j ela C.Montez
Assistant Corporate Secretary
Please return fully executed contract to: New Business Services
ICMA-RC j
777 North Capitol Street NE
Suite 600
Washington DC 20002-4240
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Plan numbers 302959, 106040
Exhibit A
Administrative Services
The administrative services to be performed by ICMA-RC under this Agreement shall be
as follows:
(a) Participant enrollment services, including providing a welcome package
and enrollment kit containing instructions and notices necessary to
implement the Plan's administration. Employees will enroll online or
through a paper form. ICMA-RC will provide an enrollment link through
the general ICMA-RC web site as appropriate.. Employer will also make
available the online enrollment link in their Intranet site or via email to
new employees. Employer can also enroll employees through EZLink.
(b) Establishment of participant accounts for each employee participating in the
Plan for whom ICMA-RC receives appropriate enrollment instructions.
ICMA-RC is not responsible for determining if such Plan participants are
eligible under the terms of the Plan.
(c) Allocation in accordance with participant directions received in good
order of individual participant accounts to investment funds offered under
the Plan.
(d) Maintenance of individual accounts for participants reflecting amounts
deferred, income, gain or loss credited, and amounts distributed as
benefits.
(e) Maintenance of records for all participants for whom participant accounts
have been established. These files shall include enrollment instructions
(provided to ICMA-RC through Account Access,EZLink or form),
beneficiary designation instructions and all other and documents concerning
each participant's account.Provision of periodic reports to the Employer
through EZLink Participants will have access to account information
through Investor Services,Voice Response System, Account Access and k
through quarterly statements that can be delivered electronically through
Account Access or by postal service.
(17 Communication to participants of information regarding their rights and
elections under the Plan.
(g) Making available Investor Services Representatives through a toll-free
telephone number from 8:30 a.m.to 9:00 p.m.Eastern Time,Monday
through Friday(excluding holidays and days on which the securities
markets or ICMA-RC are closed for business(including emergency
closings),to assist participants.
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Plan numbers 302959, 106040
(h) Distribution of benefits as agent for the Employer in accordance with
terms of the Plan. Participants who have separated from service can
request distributions through Account Access or via form.
(i) Upon approval by the Employer that a domestic relations order is an
acceptable qualified domestic relations order under the terms of the Plan,
ICMA-RC will establish a separate account record for the alternate payee
and provide for the investment and distribution of assets held there under.
(j) Loans may be made available on the terms specified in the Loan Guidelines,
if loans are adopted by the Employer. Participants can request loans through
Investor Services or Account Access.
(k) Guided Pathways—Participant Advice and Guidance may be made
available through a third party vendor on the terms specified on ICMA-
RC's website.
(1) ICMA-RC will determine appropriate delivery method(electronic and/or
print) for plan sponsor/participant communications and education based on
a number of factors (audience, effectiveness, etc.).
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