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PROCEDURES FOR COMPLYING WITH FUND COMPANY MARKET TIMING AND EXCESSIVE TRADING POLICIES <br />The prospectuses, policies and/or procedures of certain fund companies require retirement plan providers offering their fund(s) to <br />agree to restrict market timing and /or excessive trading ( "prohibited trading ") in their funds. The following procedures describe <br />how we, as your recordkeeper, will comply with fund company instructions designed to prevent or minimize prohibited trading. <br />Various fund companies instruct intermediaries to perform standardized trade monitoring while others perform their own periodic <br />monitoring and request trading reports when they suspect that an individual is engaging in prohibited trading. If an individual's <br />trading activity is determined to constitute prohibited trading, as defined by the applicable fund company, the individual will be <br />notified that a trading restriction will be implemented if prohibited trading does not cease. (Some funds may require that trading <br />restrictions be implemented immediately without warning, in which case notice of the restriction will be provided to the individual <br />and plan, if applicable). If the individual continues to engage in prohibited trading, the individual will be restricted from making <br />transfers into the identified fund(s) for a specified time period, as determined by the applicable fund company. Individuals are <br />always permitted to make transfers out of the identified fund(s) to other available investment options. When the fund company's <br />restriction period has been met, the individual will automatically be allowed to resume transfers into the identified fund(s). <br />Additionally, if prohibited trading persists, the fund company may reject all trades initiated by the plan, including trades of <br />individuals who have not engaged in prohibited trading. <br />Note: certain plan sponsors have or may elect to implement plan level restrictions to prevent or minimize individual prohibited <br />trading. To the extent that such procedures are effective, we may not receive requests for information from the fund companies <br />or requests to implement the restrictions described above. <br />10/16/07 <br />