Agenda Packet_2023-09-19 - Laserfiche WebLink

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EXHIBIT 2: PROCEDURES FOR COMPLYING WITH FUND COMPANY MARKET TIMING AND EXCESSIVE TRADING This EE hi bit 2 shal apply .o any Recordkeepi rig Servic es Sc had u le under the Master Services Agreement PROCEDURES FOR COMPLYING WITH FUND COMPANY MARKET TIMING AN I) EXCESSIVE TRADING PH LIC I ES The prospectuses, policies and or procedures of certain fund companies require retirement plan providers offering their fund(s) to agree to restrict marl at timiin andolor excessive trading "prohibited trading") in their funds. The following procedures describe ho- - e wil comply with fund compLany instructions designed -o prevent or mini•nize prohibited trading. Various fund companies instruct intermediaries to perform standardized trade monitoring while others perform their own periodic monitoring and request trading reports when they suspect that an individual is engaging in prohibited trading. If an individual's trading activity is determined to constitute prohibited trading, as defined tyy the applicable fund company, the individual will be notified that a trading restriction vAll be implemented if prohibited trading does not cease. (Some funds may require that trading restrictions be implemented immediately without warning, in which case notice of the restriction will be provided to the individual and plan, if applicable). If the individual continues to engage in prohibited trading, the individual wiill be restricted from making transfers into the identified fund(s) for a specified time period, as determined by the apoicable fund company. Individuals are always permitted to make transfers out of the ide ntified fund(s) to other available investment options.. When the fund company's restriction period has been met, the individual will automatically be allowed to resume transfers into the identified funds). Additionally, tf prohibited trading persists, the fund company may reject all trades initiated bey the plan, including) trades. of inrdividualswho have not engaged in prohibited trading. Mote: certain plan sponsors have or may elect to implement plan level restrictions to prevent or minimize individual prohibited trading. To the extent that such procedures are effective, we may not receive requests for information from the fund companies or requests to implement the restrictions described above. D112-222 City i y ounce - 19 — 22 9/19/2023