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Northern Trust

Daily Valuation

Operating Guidelines

US Version

Daily Valuation Operating Guidelines June 2009

Notice This document is for general descriptive and informational purposes only No warranty of any kind express or implied is made hereby or contained herein concerning any equipment or service described or referenced herein or any other equipment or service offered or to be offered by The Northern Trust Company or its affiliates While this document describes some of the intended capabilities of Northern Trust Daily Valuation Operating Guidelines no warranty or guarantee is made or implied hereby as to the actual operational characteristics and performance of Northern Trust Daily Valuation Operating Guidelines Trademark Notices Northern Trust and the Northern Trust anchor logo are registered trademarks of Northern Trust Corporation Copyright copy 2009 by The Northern Trust Company 50 S La Salle Street Chicago IL 60675 3126306000 This publication or any part thereof may not be reproduced or transmitted in any form or by any means electronic or mechanical including photocopying recording storage in an information retrieval system or otherwise without prior written permission of The Northern Trust Company

2


TABLE OF CONTENTS General Information

Daily Valuation Terminology 5 Account Structure 7 Holidays 8

Legal Direction Letters 9

Investment Options Separately Managed Portfolios 11 Mutual and Collective Funds 13 Company Stock Accounting 15 Company Stock In-Kind 17 Company Stock ESOP Pass-Through Dividends 18 Guaranteed Insurance Contracts and Fixed Income Funds 19 Self-Directed Brokerage Accounts 20 Target Maturity Lifestyle Funds 22

Pricing Pricing Overview Calculation Approaches 23 Mutual Fund Accounting 26 Unit Trust Approach Accounting Procedures for Daily SNAV Calculation 25 Valuation and Processing Materiality Guidelines 28

Daily Valuation Workflow of the Daily Environment 31 Reporting 33 Fee and Expense Accruals 35

Role of the Recordkeeper Expectations for Recordkeepers Processing in a Daily Valuation Environment 36 Trade Communication 37 Participant Activity 38 Recordkeeping Connectivity 40 Reconciliation 42 Proxies 43

ImplementationPlan Changes Transition 44 Manager Hiring and Termination 45

Appendix 1 ndash Sample SNAV Calculations 46

Appendix 2 ndash Materiality Flow Chart 47

Appendix 3 ndash The Daily Valuation Process Flow Chart 48

3


INTRODUCTION All Daily Valuation clientspartners should be aware of the operating procedures and requirements for Northern Trustrsquos Daily Valuation product On a daily basis transactions are processed records are updated and funds are invested or divested Some standardization is necessary in order to provide these services to our clients in a timely consistent manner at a reasonable cost The enclosed guidelines provide details on the standard procedures and requirements Any questions regarding the material contained in the guidelines booklet should be directed to your Relationship Manager or Recordkeeping Relationship Group Consultant If other persons within your organization require a copy of this booklet additional copies are available These guidelines will be updated and distributed periodically Please review them carefully The continued use of the Daily Valuation product constitutes your acknowledgement that the Guidelines will govern the manner in which Northern Trust provides the service

4


DAILY VALUATION TERMINOLOGY

Term Definition

DTC Depository Trust Company ndash a central securities certificate depository through which members effect security deliveries between each other via computerized bookkeeping entries thereby reducing the physical movement of stock certificates

DWAC DepositWithdrawal At Custodian ndash A method by which stock certificates are delivered electronically

DCCampS

Defined Contribution Clearance and Settlement ndash standardizes centralizes and automates the processing of defined contribution mutual fund transactions using the enhanced capabilities of National Securities Clearing Corporationrsquos (NSCC) Fund SERV Networking and the Mutual Fund Profile systems Mutual funds banks brokerdealers trustees and third party administrators or recordkeepers can take advantage of more efficient processing that reduces operating costs and supports volume growth

Derivatives A security whose price is dependent upon or derived from one or more underlying assets The derivative itself is merely a contract between two or more parties Its value is determined by fluctuations in the underlying asset The most common underlying assets include stocks bonds commodities currencies interest rates and market indexes Most derivatives are characterized by high leverage

EGTRRA Economic Growth amp Tax Relief Reconciliation Act of 2001 ndash A series of laws passed in 2001 which changed some of the tax code relative to benefit plans

Fund Company Sponsor of a registered mutual fund

Futures Contract It is a legally binding agreement to buy or sell a set quantity or grade of a given commodity in a designated future month at a price agreed upon today by the buyer and seller Therefore it is possible to lock in at a given price The party that agrees to purchase has opened a long position whereas the party who has agreed to sell has opened a short position

GIC Guaranteed Investment Contract offered by one party generally an insurance company Traditional ndash Actual contracts owned by the party Synthetic ndash Ownership of the fund is determined by the value of the collateral

Investment Option Options available within a retirement plan including but not limited to mutual funds company stock and insurance contracts

Mark-to-Market A mark-to-market is an arithmetic procedure that debits or credits the margin account daily The procedure changes the balance of the margin account by the sum of the dollar change in value of open contracts resulting from price movements that occurred during the last trading session The daily mark for the buyer (long position) will be equal and opposite each day to the mark-to-market for the seller (short position)

5


NAV Net Asset Value ndash the value of a mutual fund share determined by

deducting the fundrsquos liabilities from the total assets of the portfolio and dividing this amount by the number of shares outstanding

Northern Trust Passportreg

Northern Trustrsquos suite of applications which empower the user with online transactional and financial information management tools to meet the userrsquos daily need for global custody master trust investment retirement and treasury management services

NSCC National Securities Clearing Corporation ndash a leading provider of centralized clearance settlement and information services to the mutual fund industry

Participant Unit Unit held on the trust system representing a portion of ownership in an investment option

SNAV Synthetic Net Asset Value ndash the value of a participant unit determined by adding income accruals and deducting liabilities from the market value of an asset portfolio or a one-line asset (usually a mutual or collective fund) and dividing this amount by the number of participant units outstanding

STIF Short Term Investment Fund ndash a fund consisting of highly liquid and readily marketable interest-bearing securities

Trade Date (T) The date on which a transaction is executed

T + 1 (23) Refers to the settlement period of a transaction Trade + 1 Day Trade + 2 Days Trade + 3 Days

Transfer Agent Responsible for Maintaining individual records of shareholders Re-registration of shares Disbursing or reinvesting dividends and capital gain distributions and Communicating confirmed prices

6


ACCOUNT STRUCTURE Northern Trust establishes an account for each investment option (mutual fund or separately managed portfolio) An investment option may consist of one trust account or several trust accounts that are consolidated to create a pooled investment fund A clearing account facilitates cash transactions outside the valued investment options This account holds contributions before the participant allocation and distributions until they are paid to participants When transactions flow in and out of the clearing account the appropriate transaction category (contributions rollovers transfers etc) is maintained for reconciliation and audit trail purposes Monies that remain in the clearing account are invested in a short-term investment vehicle A delegation letter addresses the allocation of the STIF earned income Common uses of this income are to offset recordkeeping adjustments to offset expenses or to allocate to participants annually A loan account is used to represent the outstanding principal value of participant loans Its value can be consolidated with other accounts for periodic reporting to represent the total plans market value Both Northern Trust and the recordkeeper reconcile this account on a daily or monthly basis as dictated by the recordkeeper or client

7


HOLIDAYS Northern Trust provides asset valuations on all days in which the New York Stock Exchange (ldquoNYSErdquo) is open On holidays in which the NYSE is closed no valuation services will be performed These holidays are traditionally New Yearrsquos Day Martin Luther King Day Washingtonrsquos Birthday Good Friday Memorial Day Independence Day Labor Day Thanksgiving Day and Christmas Day If the holiday falls on a weekend no valuation will be provided on the day the holiday is observed by the NYSE These NYSE holidays are as follows for 2009-2011 2009 2010 2011 New Yearrsquos Day January 1 January 1 January 3 Martin Luther King Day January 19 January 19 January 17 Washingtonrsquos Birthday February 16 February 16 February 21 Good Friday April 10 April 2 April 22 Memorial Day May 25 May 31 May 30 Independence Day July 3 July 5 July 4 Labor Day September 7 September 6 September 5 Thanksgiving Day November 26 November 25 November 24 Christmas Day December 25 December 24 December 26 On Federal Reserve System (ldquoFedrdquo) holidays when the NYSE is open Northern Trust will provide daily valuation on worldwide securities The Fed holidays for 2009 - 2011 are listed below 2009 2010 2011 Columbus Day October 10 October 11 October 10 Veterans Day November 11 November 11 November 11 Standard procedures are followed in updating portfolio valuations and transmitting prices at the end of the day When the Fed is closed for the above holidays wire transfers trade settlement income posting and participant activity are not processed Participant dollars and units are included in the next business days valuation Due to this holiday process Northern Trust and the recordkeeping system units are not in balance until the following business day

8


DIRECTION LETTERS For all current and new daily valuation relationships Northern Trust reviews the trustcustody agreement to ensure the language is appropriate for the account structure and information flow Any needed modifications are negotiated with the client In addition to possible trustcustody agreement modifications the following direction letters are required and must be executed prior to the effective date of daily valuation

Delegation Northern Trust takes direction from the recordkeeper to process daily cash flows and participant transactions These responsibilities must be delegated by the appropriate committee or other fiduciary as defined by the trustcustody agreement by a letter of delegation The delegation letter cannot be finalized until the trustcustody agreement is finalized The trust account structure in the daily valuation environment includes a clearing account to facilitate cash flows The timing of contributions and distributions results in STIF interest posting to the clearing account Uses of the interest earned in the clearing account include the following 1) offset plan expenses 2) allocate back to the investment funds or 3) recordkeeping adjustments If the client chooses to allow any of these uses Northern requires that the delegation letter identify these uses Employer Securities Liquidity To allow for daily transactions to be processed a small percentage of the company stock investment option is usually held in a short-term investment vehicle A letter that directs Northern with respect to the appropriate percentage of liquidity to be maintained must be executed Also Northern Trust can make special arrangements for same-day settlement of company stock sales to help manage liquidity shortages To utilize this facility this language must be incorporated into the standing letter of direction GIC and Mutual Funds Liquidity A liquidity level should be maintained for insurance contract funds and mutual funds that do not honor after-hours trades A letter that directs Northern Trust with respect to the appropriate level of liquidity to be maintained must be executed Separately Managed - Multiple Manager Liquidity When multiple managers are used within a single investment option a process must be in place to provide for daily transactions The client is expected to direct the cash re-balancing among the investment manager portfolios or to provide a standing letter of direction

Self Directed Brokerage Accounts When a determination is made by the client that a Self-Directed Brokerage Account will be offered as an Investment Fund a trust amendment will need to be executed unless necessary language is included in the original trust document Additional agreements including Participant Agreements and Account Applications need to be executed based on the recordkeeper and their broker relationships

9


Expense Accrual Direction Northern Trust requires the client to provide an Expense Accrual Direction form to set up expense accruals in each of the investment options The client is responsible for notifying Northern Trust when expenses change in order for Northern to adjust the accruals accordingly This notification should be accomplished by submitting a newly completed and executed Expense Accrual Direction form See Fees and Expense Accruals section of this document for additional details

Re-balancing If Northern Trust is required to process the re-balancing transactions related to a ldquocustomrdquo fund of funds lifestyle fund or multiple manager pool a letter of direction must be on file to instruct the timing and frequency of these asset reallocations Specimen copies of the above direction lettersagreements can be obtained from your Relationship Manager

10


Investment Options

SEPARATELY MANAGED PORTFOLIOS General Description A Separately Managed Account or SMA is an investment account custodied and serviced by Northern Trust The fund is comprised of individual securities including equities bonds futures and swaps which are all selected and managed by the investment manager per the mandate of their fund

Trade Communication Investment managers are able to electronically communicate trades to Northern Trust in various ways including DTC IID TradesAffirming Managers and DTC IID TradesNon-Affirming Managers The only acceptable non-electronic trade communication method is by facsimile Trade information relayed through these formats will be included in the valuation on T+1 if the trades are sent on trade date and affirmed by 200 PM CT on T+1 In order for a trade to be included in any given business dayrsquos valuation the trade must be affirmed by 200 PM CT on that day Trades affirmed after 200 PM CT on any given day will be included in the next dayrsquos valuation For specific guidelines on trade communication please consult with your Northern Trust Relationship Manager

Liquidity In order for Northern Trust to accommodate daily valuation trade orders clients should review the guidelines currently in place with their investment managers to ensure that sufficient cash will be available A portion of the fund should be held in STIF to meet liquidity needs If Northern Trust is responsible for monitoring the liquidity the plan sponsor needs to complete the appropriate liquidity letter (see Section II ndash Legal Direction Letters) prior to the beginning of the daily valuation process If the separately managed fund does not have sufficient liquidity all non-trade transactions may be delayed until liquidity is available Any market value fluctuations during this delay will impact all fund participants and every participant experiences the risk

11


Proxy Voting Unless the plan sponsor has chosen otherwise all voting proxies are forwarded to the investment manager for appropriate action In an effort to ensure timely receipt of the proxy and information materials Northern Trust has engaged 3rd party vendors for the processing of voting instructions for securities traded in all markets It is the responsibility of the investment manager to submit the proxy voting instructions to the applicable vendor within the appropriate timeframe

Pricing Northern Trust uses independent third party vendors (primary and secondary) to assign daily prices for all assets held in the trust For a complete list of Northern Trust worldwide pricing sources contact your Relationship Manager Domestic equities are priced using the NYSE closing price where applicable When manual intervention is required Northern Trust uses various financial references to obtain prices including Bloomberg and the National Quotation Bureau (source of market maker information) If a price is not available through these sources Northern Trust will default to either the most recent price or the purchase price (if it is a new security) The investment manager may be contacted to locate a pricing source when Northern Trust has exhausted all its pricing source options In these cases Northern Trust shall be entitled to rely upon the pricing source identified by the investment manager

12


MUTUAL AND COLLECTIVE FUNDS General Description A Mutual fund and Collective fund are professionally managed types of collective investment schemes that pools money from many investors and invests it in stocks bonds short-term money market instruments andor other securities

Trade Settlement Northern Trust is notified of trades via transmission (with facsimile as a backup) by the recordkeeper Each night buy or sell trade orders are communicated to the appropriate fund company by the recordkeeper Each trade represents the net participant activity for the fund Once notified Northern will settle the trades

bull Wires for purchases are sent out assuming sufficient funds bull Redemption wires must be initiated to Northern Trust by 1000 AM CT

Northern Trustrsquos standard settlement process is to net settle (only one wire sent or received) with each fund company per client Liquidity Every mutualcollective fund company in the daily valuation environment must be able to exchange information with Northern Trust and the recordkeeper to maintain liquidity as follows 1 The fund must have the capability to receive trade orders in dollars from the recordkeeper after the close

of the markets on trade date The fund must agree to honor these trades at that days price

2 The fund must be able to settle all trades on T+1 All redemption orders must be settled by initiating a wire to Northern Trust by 1000 AM CT Northern Trust will settle all purchase orders by initiating a wire to the fund by 1200 PM CT on T+1

A fund company is legally permitted to honor the trade date price but delay settlement for up to three business days if the fund does not have sufficient liquidity to meet a days redemption This will not become known until the day after the recordkeeper has updated participant account balances and will cause a liquidity shortage for Northern Trust in settling purchases in the other funds on T+1 In this scenario the recordkeeper has processed participant transactions under the standard assumption that the trust would obtain next day settlement Therefore the recordkeeper shows participants sharing in the earnings regardless of actual investment timeframes at the mutual fund The market value impact of the T+3 settlement is allocated to all participants in the receiving fund(s) when the purchases of other funds are settled Plan sponsors should ensure that plan participants are notified of the possibility of three-day settlement and its impact on earnings allocation In any case in which a fund does not have sufficient liquidity to meet redemptions Northern Trust reserves the right to delay completing the processing of participant activity until sufficient liquidity is available

13


Pricing Northern Trust receives fund prices each day that the NYSE is open If applicable Northern Trust uses the prices reported to the National Association of Securities Dealers (NASDAQ) for newspaper reporting For all funds that do not report prices to NASDAQ Northern Trust receives prices from the fundrsquos transfer agentfund accounting areas The deadline for receipt of this information via facsimile transmission or hotline number is 530 PM CT Northern Trust contracts with a backup (secondary) pricing vendor for all funds held in trust This vendor conducts an independent price gathering operation and delivers a backup pricing file to Northern by 730 PM CT In the event that Northern Trust or the backup pricing vendor does not receive a price and the contacts at the fund company are not available prices are retrieved from secondary pricing sources such as Bloomberg or Reuters If Northern has been unable to obtain a price from any source by 800 PM CT the fundrsquos prior dayrsquos price is used Northern Trust reserves the right to extend the 800 PM CT deadline if it is deemed appropriate Operating Procedures Reconcilement Each day Northern Trust reconciles the accountrsquos share position to the balance at the fund company Therefore the fund company needs to provide Northern Trust with access to holdings and transaction information on a daily basis by 900 AM CT Income and Capital Gains Mutual fund dividends are included in the valuation as of ex-dividend date or as soon as the information becomes available from the mutual fund transfer agent If this information is available on ex-date Northern Trust calculates the dividend paymentreinvestment by applying the dividend rate on the ex-date-1 holdings This amount is included in the calculation of the ex-date NAV Income and capital gains are automatically reinvested in the daily valuation environment The income and capital gains are reinvested at the appropriate mutual fund NAV as dictated by the specific fund prospectus Northern Trust works with fund organizations and other sources to obtain the income announcement information The expected deadline for receipt of this information via facsimile or transmission is 530 PM CT If the information is not available by 800 PM CT the income will be incorporated into the following business days valuation or upon receipt of the information whichever occurs first

14


COMPANY STOCK General Description A Company stock investment option (ldquoCSIOrdquo) can be valued either in a unitized or a share accounting environment The processes surrounding the two different methodologies are significantly different and are described separately below Unitization of CSIO A CSIO is often unitized in order to facilitate frequent transfers into and out of the CSIO Unitization is necessary to provide liquidity for daily transactions executed at the CSIO closing NAV as well as to allow fees andor income to be included in the calculation of the CSIO NAV The recordkeeping system reflects recordkeeping units that are allocated to a participantrsquos plan account with a balance in the CSIO rather than an allocation of actual shares of stock For tax purposes the original cost basis must be maintained on the recordkeeping system to ensure the participant receives correct tax information regardless of whether a distribution is taken in cash or in shares Liquidity To provide liquidity for daily transactions a small portion of the CSIO is typically held in cash which is invested in Northern Trustrsquos collective STIF When a CSIO is either converted to daily valuation or due to plan design changes participants are allowed to reallocate CSIO balances that had previously been required to be held in the CSIO a higher level of liquidity may be needed during the first few weeks of daily valuation as the CSIO may experience large volumes of participant transfers Northern Trust places stock trades based on participant activity using the guidelines dictated by the client in the Employer Securities Liquidity standing direction letter (see Section II for documentation requirements) In accordance with these guidelines Northern Trust seeks to maintain the cash position of the CSIO within a ldquotargetrdquo range set by the client The cash is used to fund daily participant activity On days when there is a net inflow to the CSIO the cash position increases and stock is purchased if and when the level of cash exceeds the designated target range On days when there is a net outflow from the CSIO the cash position decreases and Northern Trust sells company stock if and when the level of cash falls below the designated target range When directed Northern Trusts Investment Services Group attempts to provide special arrangements to sell company stock with same-day settlement if participants draw their balances out of the fund unexpectedly (see Section II for documentation requirements) If the client chooses same-day settlement the broker may require the commission to be higher than regular settlement The company stock standing direction letter must be completed before Northern Trust will place trades on a same-day settlement basis If the CSIO does not have sufficient liquidity all non-trade transactions (recordkeeper directed cash flows expenses etc) may be delayed until cash is available Any market value fluctuations during the delay will impact all fund participants and every participant experiences the risk The client should be aware that maintaining a cash position might cause the performance of the fund to differ from the actual performance of the shares of the underlying stock Additional rdquotracking errorrdquo (positive or negative) may result from the fact that participant transactions on a given day are generally processed by the recordkeeper using that dayrsquos SNAV while actual trades within the CSIO may depending on liquidity levels take place on a different date and potentially at different prices that were used to calculate the SNAV

15


EXAMPLE On Day 1 there is a net inflow to the CSIO causing the level of cash to exceed the relevant target On Day 2 shares are purchased to bring the liquidity level back to the target range All of the Day 1 participant transactions are processed using the Day 1 SNAV for the CSIO The shares are actually purchased on Day 2 when the market price of the underlying stock may be higher or lower than it was on Day 1 and used in the calculation of the DAY 1 SNAV Overtime this type of discrepancy may cause a tracking error Any shortfall (or surplus) resulting from differences between the price used for recordkeeping purposes and the actual price for which the CSIO purchases or sells company stock will be ldquoabsorbedrdquo within the CSIO and will impact all participants in the CSIO Accordingly the differential between the performance of the CSIO and that of the underlying stock should be monitored by the client so appropriate action can be taken if the client determines that the ldquotracking errorrdquo is excessive Share Accounting for CSIO Share accounting of a CSIO can be used to reflect participant holdings as actual shares of the underlying security Share accounting does not require any standing liquidity No fees andor income can be accrued as part of the daily valuation but must instead be allocated to the participants via a transaction on the recordkeeping system The transaction prices used to execute requested activity may more closely reflect the actual trade experience in the market A key difference from unitization is the existence of different transaction prices for buys and sells processed on the recordkeeping system for the same valuation point These prices will also differ from the final market valuation which will continue to use the NYSE close of that night Company stock share accounting is a specialized process at both the recordkeeper and trusteecustodian Northern can only offer this methodology after detailed consultation with a recordkeeper that has this capability Whether using unitization or share accounting the following items apply to the processing for all CSIOs Proxy Voting To facilitate the proxy tabulation for CSIOs Northern Trust provides the record date share position and total CSIO market value to the recordkeeper Northern Trust will work with the client and their tabulating agent to determine the necessary deadlines for the cut-off date for tabulation results and the timing of when the trust vote must be submitted Pricing For further details on security pricing refer to the pricing policy defined in the Separately Managed Accounts section

16


Operating Procedures In-Kind Contributions If the plan allows for in-kind contributions of company stock Northern Trust will collect the shares from the transfer agent on contribution date + 1 The recordkeeper notifies the client Northern Trust and the transfer agent of the exact share contribution amount On contribution date Northern Trust receives the shares from the transfer agent and deposits them to the CSIO In-Kind Distributions If the plan allows for in-kind distributions of company stock to participants Northern Trust must remove the net shares to be distributed from the CSIO upon direction from the recordkeeper The shares are moved to the clearing account or other holding account until actual distribution to the transfer agent or broker takes place There are two primary methods by which shares can be distributed to participants as noted below and are dependant upon what level of detail is provided by the recordkeeper and to what entity the information is sent

1 DTC direct ndash The recordkeeper provides all relevant details to Northern Trust pertaining to the in-kind distributions Northern Trust completes the process by having the shares sent directly to the participants brokersdealers DTC account

2 DWAC (DRS) ndash The record keeper provides aggregated in-kind distribution amounts to Northern Trust and at the same time the record keeper also provides participant level relevant details of the shares to either the transfer agent or Northern Trust Whichever entity receives the participant level details is responsible for entering the information into the DRS system The transfer agent will still be responsible for generating statements to the participants with positions on record

17


ESOP Dividend Pass-Through Some plan sponsors may want to take advantage of the expanded ESOP dividend deduction rules under EGTRRA These plan sponsors may give participants in a company stock investment option (CSIO) the choice to receive their dividend in cash or to re-invest it in the company stock Plan sponsors must determine the frequency of payment to participants who elect to receive their dividend in cash (a ldquopass-throughrdquo) Generally these payments are made either quarterly or annually The process for each is detailed below

bull Annual payment options for plans with quarterly dividends and annual pass-through payments bull Option 1 ndash Earnings allocated to all participants in all funds

minus Cash for dividend payments is transferred to the clearing account at the time of the dividend payment

minus Earnings on the payments as well as other earnings in the clearing account are distributed per client direction (eg allocated to all plan funds used to pay fees etc)

minus Participants receive a check for the dividend amounts along with a 1099-DIV tax form

bull Option 2 ndash Earnings allocated to all CSIO participants minus Separate clearing account established to hold these funds until they are paid minus Earnings are swept from the ESOP clearing account to the CSIO at any client-directed

frequency (monthly quarterly and annually) minus Participants receive a check for the dividend amounts along with a 1099-DIV tax form

bull Option 3 ndash Earnings allocated to participants who elected a payment

minus Pass-through payments are transferred from the CSIO to the ESOP dividend account which is a separate fund on the recordkeeping system (typically a money market fund)

minus A daily NAV is calculated for this fund minus Annually the dividend amounts are transferred to the clearing account for payment to

participants Checks are produced based on the benefit payments file received from the recordkeeper

minus Annually the earnings from the ESOP dividend account are transferred by participant to the CSIO


bull Quarterly Payment Process bull Dividend payments are transferred to the clearing account on payable date bull Checks are produced based on the benefit payments file received from the recordkeeper and sent to

participants along with the 1099-DIV tax form

18


GUARANTEED INSURANCE CONTRACTS AND FIXED INCOME FUNDS General Description A Guaranteed Insurance Contract or GIC is a contract between an insurance company and a corporate profit-sharing or pension plan that guarantees a specific rate of return on the invested capital over the life of the contract which is commonly anywhere from 30 days up to 5 years Although the insurance company takes all market credit and interest rate risks on the investment portfolio it can profit if its return exceeds the guaranteed amount Only the insurance company backs the guarantee not any governmental agency so if the insurer fails it is possible that there could be a default on the contract A Fixed Income refers to any type of investment that yields a regular or fixed return Trade Communication To facilitate timely processing in the daily environment Northern Trust should receive notification of new contracts added to the fund and notification of modifications to current asset indicative data (eg rate changes gross to net) at least 48 hours prior to the effective date of the change All other trade activity including transfers for synthetic GICs need to be communicated to Northern at least 24 hours prior to the effective date of the change Liquidity Clients should review the liquidity guidelines currently in place with their investment managers to ensure that sufficient cash will be available in the Daily Valuation environment Also all insurance contracts should be reviewed before the onset of daily valuation to ensure that the contract(s) are benefit responsive and that liquidity can be raised in anticipation of participant withdrawals GICWrapper Annual Process On an annual basis Northern Trust balances the Synthetic GIC contracts market value back to the assets that wrap each contract Northern Trust then takes the total value of the synthetic GICs and compares that value to the value of the assets that are wrapping the contract If there is a difference Northern Trust will increase or decrease the value in the wrapper account to bring the two values in line When the procedure is complete the value of the synthetic GICs will tie to the wrapper account Operating Procedures Reconciliation Northern Trust reconciles its position to the balance at the contract carrier within five business days of receipt of the monthly contract statement The statement should be available within ten business days after month end to facilitate this timely balancing function Any necessary adjustments of the trust holdings to the statement occurs on the actual date and is not backdated to the statement date

19


SELF-DIRECTED BROKERAGE ACCOUNTS (SDAs) General Description Northern Trust in conjunction with the recordkeeper and brokerage institution offers a Self-Directed Brokerage Account (SDA) to plan sponsors of qualified defined contribution plans SDAs allow plan participants to transfer a portion of their qualified retirement plan balance to a brokerage account Participants act as their own investment manager and can purchase a wide range of securities diversifying beyond the core funds It is up to the client to set any limitations with the broker as to what options are available to participants to be able to trade as noted in the restrictions below The participants are responsible for monitoring and transferring any balances between the SDA and the core funds Investment Choices The SDA option allows participants access to a full range of investment choices including 1 Equity securities traded on major US exchanges including but not limited to

bull NYSE bull American Stock Exchange bull NASDAQ

2 Mutual funds 3 Permissible fixed income investments shall include

bull Investments issued or guaranteed by the US government or its agencies (T-Bills T-Bonds T-Notes GNMAs FNMAs FHLMCs)

bull Corporate Bonds bull Commercial Paper bull Certificates of Deposit (if DTC eligible)

Investment Restrictions The following investment choices may be restricted in the SDA option in which Northern Trust Company is the directed trustee

bull Annuities bull Life Insurance Policies bull Futures bull Currencies bull Precious Metals bull Employer Stock bull Limited Partnerships bull Options bull Real Estate

20


SELF-DIRECTED BROKERAGE ACCOUNTS (SDAs) Investment Restrictions - continued Participants cannot place short sells or trade on margin Northern Trust reserves the right to impose additional restrictions as deemed appropriate Interfaces The availability of an SDA investment option assumes the establishment of several electronic links between the recordkeeper trustee and brokerage firm in order to facilitate volume processing These include links from bull Recordkeeper to Broker

bull Send instructions for new accounts to be opened bull Send cash movement transactions to be executed

bull Broker to Recordkeeper bull Send new brokerage account numbers bull Send account values for updating IVR and Website

bull Trustee to Broker bull Execute wire transfers to broker

bull Broker to Trustee bull Send daily trade price and position information bull Execute wire transfers to Trustee

bull Recordkeeper to Trustee bull Send instructions for wires out and set up wire expects

Reporting The brokerage institution provides participant account reporting including the preparation and mailing of trade confirmations and account statements Participant Statements produced by the recordkeeper include the aggregate balance in the SDA investment option Special arrangements can be made to accommodate 5500 integration Please contact your Relationship Manager for further information

21


Target Maturity Lifestyle Funds

General Description There are two major types of asset allocation funds target maturity funds (often called lifecycle funds) and target risk funds (often referred to as lifestyle or balanced funds) Lifecycle fundsrsquo asset allocations evolve over time while lifestyle funds typically have long-term fixed strategic asset allocations

Customized Lifestyle Options A customized lifestyle investment option is composed of multiple collective andor mutual fund holdings The recordkeeper is responsible for summing the trade orders for each fund across the investment option and communicating those trades to both Northern Trust and the fund manager In addition the recordkeeper must electronically communicate to Northern Trust the participant activity by type for each investment option and the net proportional buy or sell of each fund across all investment options As determined by the client Northern Trust or another agent is responsible for monitoring the percentage of the overall investment option invested into each fund At some predetermined frequency (eg monthly quarterly) Northern Trust or the agent compares current allocations to the desired percentage mixes When the allocations fall outside the predetermined tolerances the responsible party communicates the realigning net trade orders directly to the fund company or to the recordkeeper for inclusion in that nightrsquos trade communication to the appropriate fund company

Lifestyle Target Risk Fund Examples bull Conservative bull Moderate bull Aggressive

Glidepath for Lifecycle funds Lifestyle or Target Risk funds have a pre-set mix of assets and a clear investment objective This objective theoretically does not ever change Lifecycle or Target Maturity funds have a floating mix of assets and a clear investment objective based on the expected retirement date of the individual investor The goal behind the creation of lifecycle funds is to allow participants to invest in a single plan option which will invest the participants assets based on their expected year of retirement and associated market risk through-out that period of time A participant retiring in the year 2050 should be investing primarily in equities and as that year approaches more and more of the assets should be invested in more stable fund options A glidepath is created by the manager of these fund options perhaps an entity assigned by the client to monitor and adjust yearly or by the fund manager of the fund Lifecycle Target Maturity Fund Examples

bull Retirement Income bull 2015 bull 2020 bull 2030

22


PRICING OVERVIEW The internal pricing group at Northern Trust is responsible for pricing all assets held in trust Northern Trust contracts with independent third party vendors to provide security prices The pricing group supports these efforts by performing certain reasonability checks by utilizing alternative sources for difficult to price securities and by researching pricing exceptions Security Pricing Methods Northern Trust uses independent third party vendors (primary and secondary) to assign daily prices for all assets held in the trust For further details on security pricing refer to the pricing policy defined in the Separately Managed Accounts section For further details on pricing mutual and collective funds refer to the pricing policy defined in the Mutual and Collective Funds section

Price Reliability Northern Trust recognizes the importance of providing quality market price information and constantly reviews existing vendors and outside sources As a result of this ongoing effort each days valuation is based upon the best information Northern is able to obtain within the applicable time constraints Due to the large number of mutual funds and other securities that must be priced it is impossible for Northern Trust to independently verify the accuracy of every price obtained from the vendors and sources we utilize Northern shall not be responsible for pricing errors made by outside sources Additionally valuations will not be recalculated based on additional information supplied by investment managers after the fact

PRICE CALCULATION APPROACHES Two approaches are available for valuing investment options in the daily environment TrustMarket Value (SNAV) approach or Mutual Fund (NAV) approach The impact to the total value of the participant account is the same using either valuation approach The following table summarizes some of the differencesrequirements of the two valuation approaches TrustMarket

Value Approach Mutual Fund

Approach Can be used with individual mutualcommingled fund Y Y Can accrue daily income as part of account balance Y N Can accrue daily fees Y N Can utilize multiple managers Y N Dividends can be itemized on participant statements Y Y NAVs equal fund price N Y Adjustments can be made without funding Y N Manager fund can be changed without rk event Y N

23


Mutual Fund Approach (NAV) This approach can be used only for single-line mutualcommingled fund investment options The initial NAV is established equal to the mutualcommingled fund closing price On strike date the total market value of the investment option is divided by the closing mutualcommingled fund price to calculate the number of participant units to be allocated by the recordkeeper to participant accounts With each dayrsquos activity using that same methodology the mutualcommingled fund units will remain exactly equal to the recordkeeping units When an ex-dividend date occurs the value of the accrual is used to purchase additional participant units of the fund using the ex-date NAV In this valuation method the funds market value remains constant with the exception of market gainslosses and participant activity While participant units increase the NAV decreases in value on ex-date The additional units purchased for the dividend would then be allocated by the recordkeeper across all participant accounts In using this approach participant statements can reflect the additional dividend unit allocation as a separate line item Plan expenses cannot be allocated on a daily basis to participants when using this approach

24


TrustMarket Value Approach ( SNAV) The initial trust calculated SNAV is established at a predetermined price (ie 100 1000 or 10000) On strike date the total market value of the investment option is divided by the predetermined price to calculate the initial number of participant units to be allocated by the recordkeeper to participant accounts All dividend andor capital gain activity is reflected in the market appreciationdepreciation values on the participant statement The Trust Market Value approach also allows flexibility to allocate additional participant units on ex-date Please refer to page 3-5 for a discussion of dividend allocations The Trust Market Value approach must be used when

bull a daily income accrual is included as part of the valuation (for some recordkeeping systems) bull plan expenses are included as part of the fund valuation or bull the account is separately managed for a specific trust or bull multiple fund managers are consolidated in an investment option

Traditionally Northern Trust uses the TrustMarket Value approach in valuing investment fund accounts In a daily valued environment participant records reflect ownership in an investment option (company stock GICs mutual fund separately managed portfolio) via participant units or shares The recordkeeping system maintains transaction detail and associates participant units with every appropriate transaction Participant units are associated to contributions loan repayments rollovers distributions loan issuance transfers etc Every day the markets are open a unit value is calculated that incorporates market experience earnings and expenses The value is applied to participant units which determines the participantrsquos market value of each investment option The following example illustrates the unit accounting process On February 1 a participant makes an initial contribution of $20000 The current investment election for this participant is 100 allocated to the equity fund The unit value for the equity option is $1200 On the recordkeeping system the participant will reflect a February 1 contribution transaction with value of $20000 and 16667 (200 divide12) participant units The number of participant units for this transaction will never change However the price will fluctuate every market day to represent market experience On the following market day the price for the equity option is $1300 The market value for 16667 participant units is now $21667 representing an unrealized gain of $1667 on the original investment of $20000 When the participant makes an additional contribution on the next payroll cycle (215) the price for 215 is $1350 The following occurs

UNITS SNAV MARKET VALUE

Beginning balance 16667 $1300 $21667

Updated MVSNAV 16667 $1350 $22500

Contributions 14815 $1350 $20000

Ending balance 31482 $1350 $42500

25


ACCOUNTING PROCEDURES FOR DAILY SNAV CALCULATION TrustMarket Value Approach (SNAV) The valuation module divides the portfolios net market value by the outstanding number of participant units The units are updated automatically each day based on participant activity The shareholder equity is made up of several components They are as follows

a) Participant admissions b) Participant withdrawals c) Net income earned d) Receivables and payables e) Unrealized gainslosses f) Realized gainslosses

Company StockESOP Valuation (CSIO) In order to facilitate daily valuation a CSIO must be unitized Unitization is necessary to provide liquidity for daily transactions as well as allowing fees to be accrued into the value of the CSIO The recordkeeping system reflects recordkeeping units that a participant owns in the CSIO instead of actual shares For tax purposes the original cost basis must be maintained on the recordkeeping system to ensure the participant receives correct taxation regardless of whether a distribution is taken in cash or in shares Dividend Income There are three methods to allocate dividend income to the participants in company stock funds Based on client direction one of the following processes is used

1 Including the dividend in the SNAV calculation The accrued dividend is included in the portfolio value

and participant unit SNAV for the company stock fund On ex-dividend date an accrual is calculated and added to the market value of the stock fund which offsets the stock pricersquos downward adjustment In this method the participant units remain constant Excluding normal market gains or losses the trust calculated SNAV stays constant as a result of the dividend Using this method participant statements do not reflect the dividends which are instead incorporated into the fundrsquos market appreciationdepreciation

2 Allocating additional participant units On ex-date the value of the accrual is used to purchase additional participant units of the stock fund using the ex-date (excluding accrual amount) SNAV The funds market value remains constant (with the exception of normal market gains or losses and participant elected activity) while participant units increase As a result of this the SNAV decreases in value proportional to the decrease in price The additional units purchased for the dividend are allocated by the recordkeeper across all participant accounts based upon relative unit holdings With this method participant statements will reflect the dividends separate from the fundrsquos market appreciationdepreciation

3 Dividend Pass-Through (ESOP ONLY) Plans may also allow participants the option of receiving the company stock dividend in cash instead of reallocating it back to the fund If this option is elected the dividend is paid directly to the participants at the frequency the client deems appropriate The dividend received on payable date is transferred from the company stock account to a clearing account pending distribution to the participants

Upon actual payment of the dividend and in accordance with the desired level of liquidity additional shares of the company stock may be purchased

26


Guaranteed Insurance Contract (GIC) amp Fixed Income Mutual Funds Valuation For GICs and fixed income mutual funds a SNAV is calculated that incorporates both the accrued daily income on all contracts or funds as well as the current dayrsquos prices for any fixed income funds or securities held in the portfolio

1 Income Accruals ndash Where appropriate a daily income accrual is incorporated into each SNAV

calculation For weekends and holidays a multiple rate is incorporated in the next or previous market dayrsquos valuation based on investment manager direction These accruals are calculated using a 360 or 365-day calendar depending upon the asset type or terms of the contract

2 Reinvestment ndash The income accruals are realized and reinvested monthly for both GICs and mutual funds with daily accrual rates

Separately Managed Portfolio Valuation The valuation of separately managed portfolios uses the same methodology of the other funds while accounting for multiple assets and asset types Please reference the pricing section of the Operating Guidelines for details on pricing sources and methodologies for the various instruments listed below 1 Equities ndash All corporate actions (Splits Spin-offs Ex-dividends etc) are processed on ex-date No

participant units will be allocated for corporate actions

2 Bonds and Mortgage Backed Securities ndash A daily income accrual is calculated using the carrying value multiplied by the stated interest rate for each security when applicable paydowns will be posted on payable date

3 Short Term Securities ndash Northern Trust does not accrue for short-term securities These securities are priced daily using market or automated matrix pricing

A sample SNAV calculation is included as Appendix 1

27


VALUATION AND PROCESSING MATERIALITY GUIDELINES Purpose and Scope In the event that a valuation or processing error occurs these Guidelines provide standards for (i) the steps to be taken to determine what errors are ldquomaterialrdquo and what if any actions are required to rectify the error and (ii) the circumstances under which Northern Trust will or will not have responsibility for the costs and expenses of correcting the error Analysis of Error If Northern Trust discovers an error Northern will determine the amount of the error and perform a calculation to determine the ldquoerror percentagerdquo The amount of an error related to a SNAV calculation is determined by calculating the difference between the incorrect SNAV and the correct SNAV then calculating the error percentage by dividing the difference by the correct SNAV The amount of an error that is related to a processing error is determined by calculating the difference between the actual result of the processing activity and the result assuming the processing activity had occurred correctly This amount is divided by the current market value of the account to determine the error percentage Primary Materiality Standard If the impact of an error is less than one tenth of one percent (1) of the correct value the difference is not considered material and no further action will be taken

28


Materiality Analysis When an error is discovered it will first be defined as either a valuation or processing error A processing error is an error that is caused by the failure to complete a transaction properly and results in a financial impact to the trust or participant(s) Examples of a processing error are a trade is executed late a purchase is executed instead of a sale or the wrong number of sharesdollars is traded A valuation error is an incorrect valuation of a portfolio which in a unitized account results in an incorrect SNAV For example an inaccurate price incorrect accrual or an inappropriate posting of units may result in a valuation error Valuation errors are often corrected by applying the correct information eg posting the correct dividend accrual and then if material having the recordkeeper make appropriate unit adjustments where possible For a valuation error the following process is followed

Level 1 bull If the error percentage is less than one-tenth of one percent (1)

bull The error is not considered material bull Northern will not notify the Client or the Recordkeeper

NOTE If Northern Trust is required to default to the backup sources to calculate the NAV the defaulted prices are considered acceptable The one-tenth of one percent materiality limit is applied using the defaulted SNAV

bull If the error percentage is equal to or greater than 1 bull Northern will notify the Client and Recordkeeper of the correct SNAV bull The Recordkeeper will perform the Level 2 analysis

Level 2 The Recordkeeper will perform a participant-level analysis to determine which if any participant accounts were impacted by +- $20 bull For each participant distribution involving an overpayment of $20 or more

bull Northern will notify the Recordkeeper and the Client of the total amount of the impact This impact is then analyzed as a processing error (see page 4-7) using the total amount of the error as compared to the total value of the affected fund(s)

bull For each participant distribution involving an underpayment of $20 or more

bull The Recordkeeper will instruct Northern via regular methods to issue an additional check to each participant representing the amount of the underpayment

bull Northern will issue and distribute the checks bull Northern will notify the Client of the total amount of the additional payments bull Northern will reimburse the fund for the amount of the error attributable to its actions only as

specified in the following section (ldquoResponsibilityrdquo)

bull The Recordkeeper will restate participant balances for a processing error that results in a loss of value where the error percentage is equal to or greater than 1

bull Northern will notify the Client and Recordkeeper of the amount of the error bull The Level 2 analysis will not be performed bull The Recordkeeper will restate participant balances bull Northern will reimburse the fund for the amount of the error attributable to its actions only as specified in

the following section (ldquoResponsibilityrdquo)

29


Responsibility Northern Trustrsquos financial responsibility for SNAV or other processing errors is limited to situations where (i) Northern caused the error and (ii) the error is ldquomaterialrdquo under these Guidelines In the event a Northern Trust error causes incorrect increases in some participant balances and incorrect decreases in others Northern will not have responsibility to reimburse the fund to avoid reallocating participant balances Northern does not assume financial responsibility based on materiality policies or guidelines established by recordkeepers or other parties to the extent they differ from these Guidelines Northern will have no responsibility for correction of an error arising from the actions or inaction of other parties In particular Northern will have no responsibility for errors resulting from a change in a SNAV that is caused by the unavailability or change in information or in the event that a price corporate action dividend etc was not timely reported to Northern from any of its sources Northern will not have responsibility if the performance of its duties is prevented or delayed by circumstances beyond its reasonable control including but not limited to work stoppages fires riots equipment utility or transmission failures acts of omissions of investment fund managers third party pricing sources or other similar occurrences Northern will differentiate between a correction of an error resulting from Northern Trustrsquos actions and a change in a SNAV that is caused by the unavailability or change in information If a price corporate action dividend etc was not reported to the Northern from any of itrsquos ldquonormalrdquo sources ie ldquobest available informationrdquo Northern will use its best efforts and therefore will not be responsible for restating SNAVrsquos or funding possible losses A Materiality Flow Chart is included as Appendix 2

30


WORKFLOW OF THE DAILY ENVIRONMENT The following describes the normal workflow of a daily inter-fund transfer from the recordkeeping system to the investment fund valuation module The flow begins from the originating point of a participant calling the toll-free number or using the Internet and ends with the communication of SNAVs back to the recordkeeper on the following business day All times mentioned below are in central time (CT) and assume regular NYSE trading hours Please refer to your Recordkeeper for actual trading times for your plan as some plans andor recordkeepers may use an earlier deadline than the NYSE trading hours Day One Communication of Participant Activity

Friday 301 PM ndash Monday 300 PM Plan participants initiate a transfer between investment options via phone or internet bull A participating employee of company XYZ directs the movement of $100 from Fund A to Fund B bull The recordkeeping system maintains the information ($100 transfer from Fund A to Fund B) for the end

of day batch processing

Monday 500 PM bull Northern Trusts valuation system is updated with current days prices accrual rates and dividend

information (as applicable) If fund information is received after 500 PM all subsequent times will be adjusted accordingly

bull Monday - Between 500 PM and 645 PM Northern Trust provides the Recordkeeper with all SNAVs and accrual dollars (for company stock only) for the investment funds GICs and company stock funds (Note SNAV includes processing of participant activity from the previous business day)

bull The recordkeeping system posts that dayrsquos SNAV processes participant activity and updates participant balances

Monday 900 PM - Tuesday 700 AM bull Plan and fund level information (dollar amounts and corresponding units to be boughtsold) is

communicated by the recordkeeping system to the investment fund managers (Monday 800 PM or later as managers permit) and Northern Trust (Tuesday 700 AM)

31


Day Two Northern Trust Internal Processing

Tuesday 1000 AM bull Northern Trust verifies adequate liquidity and then posts participant transactions

Tuesday 1100 AM bull Wires for each applicable investment fund are created and executed

Tuesday 100 PM bull Aggregate participant and trade activity is loaded to the valuation system for each clientrsquos plan by fund

by category

Tuesday 500 PM bull Northern Trusts valuation system is updated with current days investment transactions prices accrual

rates and dividend information (as applicable) If fund information is received after 500 PM all subsequent times will be adjusted accordingly

Tuesday - Between 500 and 645 PM bull Northern Trust provides the Recordkeeper with all SNAVs and accrual dollars (for company stock only)

for the investment funds GICs and company stock funds (Note SNAV includes processing of participant activity from the previous business day)

bull The recordkeeping system posts the SNAV processes participant activity and updates participant balances

Tuesday 900 PM - Wednesday 700 AM bull Plan and fund level information (dollar amounts and corresponding units to be boughtsold) is

communicated by the recordkeeping system to the investment fund managers (Tuesday 800 PM or later as managers permit) and Northern Trust (Wednesday 700 AM)

Wednesday 700 AM bull Investment fund information processed on the DV Module on Tuesday (sent by the Recordkeeper

Monday night) is available online via the Northern Trust Passportreg Reporting System on Wednesday at 700 AM

A flow chart of the daily valuation process is included as Appendix 3

32


REPORTING Northern Trust provides flexibility in reporting of daily valuation plans Reports are available for any full-day period of time (daily weekly monthly etc) online through Northern Trust Passportrsquosreg Reporting System which is updated daily with all activity Monthly trust statements are available through Passport as well and are available on the 5th business day of the each month Annual statements are produced on CD-ROM but hardcopy reports can be be made available upon request along with other daily and monthly reports The reporting templates available are listed below Northern Trust provides a userrsquos guide for these templates Clients who obtain information online have the ability to export the underlying data and do further customization using their own software or work with a Northern Trust specialist to design customized reports Standard Package

Asset Detail Asset Summary Capital Change Detail Change in Book and Market Value Change in Cash Value Foreign Exchange GainLoss Detail Foreign Exchange GainLoss Summary Foreign Exchange Rates to Base Currency Funding and Disbursement Detail Funding and Disbursement Summary Income and Expense Detail Income and Expense Summary Investment Transaction Detail Investment Transaction Summary Pending Transaction Detail

Online only

Allocation Overview Cash Activity Detail Cash Balance Report Manager Mix Top 10 Equity Holdings

33


FAS157 Reporting FAS 157 which is effective for fiscal years beginning after Nov 15 2007 creates a single definition of fair value for financial reporting The new rules associated with FAS 157 state that valuation techniques consistent with the market approach income approach andor cost approach should be used to estimate fair value Selection of a valuation technique or multiple valuation techniques depends on the nature of the asset or liability being valued as well as the availability of data

5500 Reporting Internal Revenue Service (IRS)Department of Labor (DOL) regulations require that administrators and sponsors of qualified employee benefit plans file form 5500 annually for each master trust or investment pool as well as for each plan The 10 supplemental schedules provided by Northern Trust are designed to facilitate these filings These templates are available to clients on CD-Rom on-line or hardcopy The templates provided via Northern Trustrsquos Management Reporting platform are

Current Value of Assets and Liabilities Schedule of Realized Gains and Losses Summary of Gains and Losses Reportable 5 Transaction Schedule Schedule of Acquisitions and Dispositions Schedule of Assets Held for Investment Purposes Schedule C Income Reconciliation Schedule Schedule H Transfer Reconciliation Schedule

34


FEE AND EXPENSE ACCRUALS Expense Accrual Directions The client must direct Northern Trust whether or not to accrue for plan fees and expenses using the authorized Expense Accrual Direction form The client should complete the initial form prior to the date Northern is expected to begin NAV calculations The client must provide to Northern Trust a new Expense Accrual Direction form any time expenses are modified or structural changes occur

The client must complete and provide forms based on the specific requirements detailed on the forms Forms that do not comply with all requirements will be returned to the client for modification New or modified accruals will only be established after Northern receives a properly completed form

Types of Fees Expenses for fees are generally comprised of a combination of fixed fees and basis point fees The explanation of the two types of fees the method of payment and accruals based on investment structure are as follows

1 Fixed Fee ndash is a predetermined dollar amount That amount is applicable to a single specific account or

multiple accounts If the fee is applicable to the entire trust Northern Trust allocates the fee across all of the investment options on a pro-rata basis The pro-ration is reset quarterly

2 Basis Point Fee ndash is a fee determined by applying a basis point charge to the assets of an account If the plan sponsor or investment manager chooses to accrue fees as a basis point percentage of the assets Northern Trust applies those basis point percentages to the prior dayrsquos market value to arrive at that dayrsquos fee

Methods of Payment 1 Monthly Transfer ndash Each month the amount of the expense (fee) accrual may be transferred from the

investment option to the clearing account In this case Northern Trust transfers the prior monthrsquos accrual on the 1st business day and returns the accruals to zero These amounts remain in the clearing account until invoices are received for the fees to be paid

2 Payment Directly from the Funds ndash Expenses are accrued on a daily basis and the amount of the accrual remains in the account Invoices are paid directly from the investment options to which they pertain When an invoice is paid the amount of the accrual is reduced by the amount of the invoice If the amount of an invoice does not equal the amount accrued for the period based on the clientrsquos Expense Accrual Direction form the account may be impacted by this difference

35


EXPECTATIONS FOR RECORDKEEPERS PROCESSING IN A DAILY VALUATION ENVIRONMENT

In order for Northern Trust to provide our daily valuation services the following requirements must be met by the planrsquos recordkeeper These are in place so that the quality of service that clients receive is not diminished by inconsistencies in processing between different service providers Failure of a recordkeeper to adhere to these expectations may have an impact on service andor result in additional valuation fees charged by Northern Trust Northern Trust shall not be responsible for any delays losses claims or expenses that arise as a result of a recordkeeperrsquos failure to meet the expectations listed below Unit Accounting ndash The recordkeeper must utilize unit or share accounting in each of the funds within the plan and operate with the Northern Trust using daily SNAV or NAV prices and unitsshares Plan Balancing ndash The recordkeeper must supply ending unit positions by fund (including the loan fund) to the Northern Trust on a daily basis Northern Trust balances the plan to the participant records on a daily basis The recordkeeper must balance the participant records to the number of units provided on the daily price file Failure to complete the balancing procedure may affect the integrity of the valuation Electronic Interface ndash The recordkeeper must program electronic data transmission (EDT) files in agreed upon formats The files include daily pricing files daily participant transaction files and periodic benefit payment files These files are necessary to ensure the quality and accuracy of Northern Trustrsquos processing After Hours Trade Initiation ndash Where applicable the recordkeeper must establish after-hours trading agreements with the fund companies and communicate the trade amounts to them on a nightly basis Northern Trust subsequently settles these trades based on participant transaction information from the recordkeeper Plan Accounting ndash The recordkeeper must complete any plan level accounting for master trust relationships for plans within a daily valuation environment Additional Capabilities The following items are not requirements by Northern Trust to be able to complete daily processing or to be able to work with Northern Trust in a daily valuation environment However these additional processes where applicable do create more efficiencies and eliminate manual intervention Fee Processing Rebalancing Trades Interest Processing Reconciliation ndash See page 6-7

36


Trade Communication Mutual and Collective Funds Northern Trust is informed of trades via transmission with fax backup by the recordkeeper Each night buy or sell trade orders are communicated to the appropriate fund company by the recordkeeper Each trade represents the net participant activity for a given investment option For example Participant Transactions

a Recordkeeper

communicates to the Fund A transfer agent a buy order of $350 using 415

trade price and 416 settlement

Initiated April 15 Fund A Fund B Participant Contributions $100 $50 Sponsor Contributions 100 50 New Loan Issuances (50) - Transfers 200 (200) a $350 b $(100)

b Recordkeeper communicates to the Fund B transfer agent a sell order of $100 using 415 trade price and

416 settlement On April 16 Northern Trust is informed of these trades and settles them bull The wire for the purchase is sent out assuming sufficient funds and bull the redemption wire must be initiated to Northern Trust by 1000 AM CT Company Stock Trades Please refer to the investment alternatives section for information on company stock trades NSCC Trading Trading may be available through DCCampS a service to standardize centralize and automate the processing of defined contribution mutual fund transactions utilizing the capabilities of NSCCrsquos existing FundSERV Networking and Mutual Fund Profile systems DCCampS reduces the time costs and risks associated with defined contribution mutual fund transactions

Recordkeepers accept purchase and redemption orders from plan participants Participant-level information orders and balances are maintained by the recordkeeper Mutual funds calculate the daily NAV per share and send the final audited prices daily accrual rates and dividend information to NSCC NSCC makes those NAVs and related information available to the recordkeeper and Northern Trust via Mutual Fund Profile Service

The recordkeeper updates the individual participant accounts on their recordkeeping system and calculates orders for each mutual fund The recordkeepers then send NSCC the orders via the FundSERV Service

Following format and file edits NSCC makes orders available to mutual funds Northern Trust also receives a copy of these orders Upon receipt mutual funds return confirmed and rejected orders to NSCCrsquos system

The recordkeepers and Northern Trust receive a daily file from NSCC with all confirmedrejected trades All confirmed transactions are set up for settlement at NSCC On the morning of T+1 NSCC provides Northern Trust and funds with a net settlement figure and a summary of purchases and redemptions On T+1 NSCC makes a single net settlement debit or credit via Fed funds to Northern Trust and each fund

37


Participant Activity Northern Trust is informed of participant activity via electronic transmission (with facsimile backup) from the recordkeeper All participant activity is calculated by the recordkeeper on trade date and netted by fund to provide trade orders to investment fund managers Northern is able to accept trade information by through two options

1 Detailed breakdown by account the type of activity that comprises the trade communicated by the recordkeeper Example would be transfers before tax contributions loans etc

2 Aggregated trade amount by account therefore not including any details that would be

Included in option one This option would apply specifically to plans in which Northern Trust would not custody the entire plan assets

Payroll Contributions and Loan Repayments After the recordkeeper completes the payroll process it confirms with the client the exact amount of contributions and loan repayments to be wired to Northern Trust The client initiates the wire for the exact amount of the contribution and loan repayments (as successfully processed by the recordkeeper) to Northern Trust on T+1 by 1100 AM CT Wires are received into the clearing account and transferred into the investment funds on the same day Loan repayment principal flows through the loan account to adjust the loan asset and then flow into the investment funds on the same day Cash flows received in the trust are often wired out on the same-day for investment therefore receipt of the contribution wires is crucial to avoid overdrafts If the client indicates the wire will not be sent Northern Trust will be entitled to reimbursement for lost use of funds and further reserves the right to recall the associated trades Northern Trust shall not be responsible for any resulting market impact to participants recordkeeping charges or any other expenses resulting from the clientrsquos failure to timely wire funds to Northern Trust If unidentified funds are received the funds will be held in the clearing account until the recordkeeper has updated participant records and provided investment direction to Northern Through the clearing account reconciliation process all issues regarding unidentified funds will be resolved Please refer to the Investment Alternatives section for a discussion of in-kind contributions for company stock Rollovers and Loan Repayment Checks The client or recordkeeper forwards the checks to Northern Trust for deposit into the clearing account or into the clientrsquos lockbox The checks must be received by Northern Trust before 1100 AM CT the day the recordkeeper updates the records The recordkeeper provides directions to transfer the rollover and loan repayment check amounts out of the clearing account and into the investment fund options If a check is deposited and does not reconcile with information provided by the recordkeeper Northern Trust contacts the recordkeeper for direction If a check is returned for insufficient funds Northern Trust notifies the recordkeeper who initiates the appropriate reversal of participant activity

38


Transfers Participants may be allowed the flexibility of daily transfers via their request on a recordkeepers voice response or online system All participant requests received on any market day and completed by market close (or earlier as defined by the client) are processed by the recordkeeper using that nights closing SNAV or NAV Northern Trust processes daily transfer elections on T+1 upon the direction by the recordkeeper It is expected that all transfer activity nets to zero across the investment options Loan Issuance New loan issuances flow from the investment fund options through the loan account to adjust the loan asset and into the clearing account the same day Loan proceeds remain in the clearing account until loan checks are issued based on the recordkeeperrsquos direction Northern Trust does not hold the individual employee promissory notes rather a master note is established to aggregate all outstanding loans Plan Payments Termination distributions in-service withdrawals and hardship withdrawals (as applicable by plan) flow from the investment options into the clearing account the same day Distribution monies remain in the clearing account until checks are issued based on the recordkeeperrsquos direction Northern Trust as directed by the client or recordkeeper provides the tax filing for the payments Northern Trustrsquos standard is to receive instructions for every installment payment to ensure accuracy of trust and participant records Participant distribution and withdrawal activities are coordinated between the recordkeeper and Northern Trust to facilitate the processing of payments by the established year-end cut-off date For more information on check issuance please refer to Northern Trustrsquos Benefit Payments Service Description Forfeitures Forfeitures are accounted for in one of two methods 1 Moved to clearing account The dollars are deposited directly into the clearing account based on the

recordkeeperrsquos direction The forfeiture amounts remain in the clearing account until the recordkeeper andor client provide further direction

2 Held in a separate account Upon payment of the final distribution (or earlier as directed by the client) units for forfeited funds are transferred into a separate account on the recordkeeping system typically referred to as Mr Forfeiture As funds move in and out this account acts like a normal participant account

39


RECORDKEEPING CONNECTIVITY Electronic Files The delivery of timely information is critical between recordkeeping and trust systems To facilitate the processing of activity Northern Trust requires the automated exchange of information in these three methods

1 Daily Price Feed This data file is sent from Northern Trust to the recordkeeper each night It details the NAV or SNAV of each investment fund and other pertinent investment information The data is automatically transmitted to the recordkeepers on a same-day basis by 645 PM CT

2 Daily Participant Activity Feed The Daily Participant Activity File capability enables recordkeepers to communicate net daily participant activity to Northern Trust Northern Trust then processes and settles all net participant transactions The file must be delivered prior to 700 AM CT on T+1 Because required identification fields secure each transmission transactions are posted automatically to Northern Trusts system without manual intervention such as re-keying data The daily participant file allows for automated cash movements including wires checks and transfers to Northern Trust banking accounts

All Northern Trust interface methods utilize a secure environment and all information is validated before posting to the receiving system Northern Trust representatives work with the recordkeeper in setting up and testing new communication links

3 Benefit Payment Feed (where applicable) The benefit payment file allows a system-to-system transmission of information detailing lump sum loan and installment distributions to participants With this information the Northern Trust Benefit Payments Division processes and distributes payments according to the following schedule Day 1 ndash File sent to Northern Trust Day 2 ndash Checks produced dated Day 3 Wires (special request only) sent Day 3 ndash Checks mailed to participants The benefit payment file can be utilized as frequently as distributions are permitted (monthly weekly or daily)

40


Holiday Considerations There are three types of holidays to be considered Fed holidays when the NYSE is open Fed holidays when the NYSE is closed and NYSE holidays when Fed is open

Federal holidays when NYSE is open This can happen up to twice a year Veterans Day and Columbus Day On these days the NYSE is open for trading but not for settlement because the Fed is closed Therefore recordkeepers should only communicate the participant activity file to Northern Trust The benefit payments feed should not be sent on that day When preparing the participant activity file recordkeepers should report all transactions with the trade date of the participant activity and the settlement date of the day after the holiday Northern Trust transmits the daily price feed to the recordkeeper in the usual manner and timeframe However the participant activity is not settled until the following business day The result is that units remain constant the price will change based on unrealized gainloss for the day

Federal holidays when NYSE is closed This can happen up to eight times a year New Years Day Martin Luther King Day Washingtonrsquos Birthday Memorial Day Independence Day Labor Day Thanksgiving Day and Christmas Day On these days both the Fed and the NYSE are closed There should be no electronic transmission of information between recordkeepers and Northern Trust The activity from the previous business day should be transmitted to Northern Trust on the first business day after the holiday

NYSE closed when Federal is open This can happen at least once per year Good Friday On this day no trading or settlement occurs therefore Northern Trust will not produce or transmit the daily price file A participant activity file is not expected for that day Recordkeepers may send the benefit payments file on this day or they may elect to send it on the following business day The activity from the previous business day can be transmitted to Northern Trust the morning of Good Friday or the business day following the holiday Note These market schedules are applicable to US plans only Any foreign domiciled plans would need to follow market calendars based on the country or origin or other related calendars

41


RECONCILIATION Trust Reconciliation Northern Trust reconciles aggregated outstanding units by investment option daily with the recordkeeping system Additionally the recordkeeper must balance the participant records to the number of units provided on the daily price file If differences arise Northern Trust works with the recordkeeper on the appropriate resolution

Clearing Account Reconciliation The following allocation of responsibilities shall apply with respect to the ongoing support of the clearing account bull Client

bull Assumes ultimate responsibility for the reconciliation of the clearing account bull Reconciles and resolve outstanding debitscredits related to expenses and earnings

bull Recordkeeper bull Reconciles and resolve outstanding debitscredits for transactions except those related to expenses

and earnings which are tracked by the client bull Provides Northern with proper direction to initiate transactions to occur within the clearing account

as well as between the clearing account and other accounts within the trust bull Provides Northern with proper direction to initiate any transactions required to clear unresolved

debitscredits or other balances in the clearing account bull Contact Northern for needed support in the resolution of specific open reconciliation items

bull Northern Trust bull Obtains the appropriate documentation and direction with respect to transactions to be processed in

the clearing account bull Processes transactions timely and accurately bull Processes transactions and provide reports to facilitate the reconciliation process bull Responds to inquiries from the client andor the recordkeeper related to the reconciliation of the

clearing account

42


PROXIES To facilitate the proxy tabulation for company stock funds Northern Trust provides the total market value and cash holdings to the recordkeeper for each company stock account as of record date The recordkeeper then sends individual participant information to the tabulating vendor For more information on proxies please refer to the investment alternatives section

REDEMPTION FEES Redemption fees are charged to participants so as to discourage the practice of market timing or international fund arbitraging These fees set by either the investment manager or the plan sponsor are calculated by the recordkeeper and deducted from a participantrsquos redemption request based upon dollars that have not been in the fund for a predefined time frame (eg 30 days as determined by the recordkeeper) The deducted amounts are initially moved from the investment funds to the clearing account at the direction of the recordkeeper At further direction from the recordkeeper the redemption fees are either returned to the client investment option or wired directly to the investment manager to reimburse the fund for the transaction costs and market impact of the redemption

43


TRANSITION Northern Trust assigns a transition coordinator to facilitate the movement of assets from the prior trustee Based on the situation adequate lead-time will be needed to ensure a smooth asset transition The prior trustee must provide preliminary statements before the transition date and certified statements through the transition date to complete the transition of assets Northern must be informed of the accounting basis (cash versus accrual-income and fees trade versus settlement date) of the statements to allow all assets and liabilities to be appropriately included in the valuation When a transition is occurring from a daily valuation environment the prior trustee or the client must provide certified positions on the transition date for each investment option before Northern Trust will strike a valuation and supply the prices to the recordkeeper In addition the prior trustee needs to provide information (asset lists trades cash flows etc) needed to run parallel processing for a specified period of time prior to the conversion All assets must be balanced against outside records (fund managers etc) before conversion Northern Trust provides the prior trustee with the appropriate format and timing of the information exchange during the parallel period All appropriate documentation needed for accurate valuation should be provided by the plan sponsor prior to the first price calculation These include liquidity letters and fee accrual information For plans that convert on non-plan year end dates Northern Trust must receive 5500 reports that document the ending ERISA cost by security as of the close of business on the final valuation date It is expected that Northern Trust will receive these reports within 60 days of transition

44


MANAGER HIRING AND TERMINATION Manager Hiring When a manager is hired the following information must be provided to Northern Trust

bull Effective date account will be funded bull Funding method (cash or securities) bull Funding direction bull Securities lending participation bull Manager information

bull Name bull Address bull Contact name and phone number bull Reporting recipients names and addresses bull Security information bull Fee schedule bull Index Benchmark

The above information should be given to Northern Trust at least 15 business days before the effective date This allows for appropriate set-up and notification to be completed before trading begins In the event securities will be transferred from an existing manager written sign-off by each new and terminated manager will be required before a price will be calculated Manager Termination When a manager is to be terminated Northern Trust should be notified at least 15 business days prior to the effective date The following information should be provided in the notification bull Effective date of termination bull Terminated manager name bull Termination methodology (liquidate vs security transfer new vs current manager to assume asset

responsibility) Northern Trust Global Investors (NTGI) can assist in handling the liquidation of the terminated managers

ortfolio p

45


APPENDIX 1 SAMPLE SNAV CALCULATIONS

1 - GIC EXAMPLE

(A) (B) (A)+(B) Market Value Asset Accumulated Accrual Total Market Value Principal 300000000 490946 300490946 Constitution 300000000 312244 300312244 Allstate 1 100000000 159768 100159768 Allstate 2 100000000 177060 100177060 Life of Virginia 140000000 174809 140174809 Hartford 299670438 472461 300142899 FHLMC 80015250 133333 80148583 COLTV STIF 1423677042 3668605 1427345647 TOTALS 2743362730 5589226 2748951956 Total Units Outstanding = 2740735562 SNAV = NET MARKET VALUE = 2748951956 UNITS OUTSTANDING 2740735562 = 10029979 2 - NONGIC EXAMPLE Day One Market Value of Securities 2431691550 Accrued Income 2289215 Accrued Expenses (904782) Net Market Value 2433075983 SNAV = Net Market Value 2433075983 = 10513192 Units Outstanding 2314307620 Day Two Market Value of Securities 2445449969 Investment Securities Sold 43703539 Investment Securities Purchased (51825000) Accrued Income 2311928

Accrued Expenses (947865) Net Market Value 2438692571 SNAV = Net Market Value 2438692571 = 10506012 Units Outstanding 2321235213

Change in Participant Units - 2321235213 - 2314307620 6927593 7282979 Day Two Admission = 6927593 10513 Day One SNAV

46


APPENDIX 2

MATERIALITY FLOW CHART

gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error

gt 110 Participant+- $20

STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3

Voice ResponseSysteminternet

RecordkeepingSystem

Northern TrustCash Processing

Mutual FundCompanies

Northern TrustMutual FundProcessing

Northern TrustValuation System

Trades in SeparateAccounts

Open Market ampMutual Fund

Prices

WiresSettlements Day 212pm

Trade Communications

Day 212am

Day 1 Prior to 630 pm

Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm

Day 2 5pmDay 2 SNAV645pm


Day 1 SNAV

645 pm

Client Payroll

Payroll WireDay 2 12pm

Net Payroll Amount

THE DAILY VALUATIONPROCESS

RecordkeepingSystem

ParticipantCalls

Day 1 = Post DateDay 2 = Post Date +1

All times are CT

PayrollFeedDay-5 Edit Process

ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation

Employer Securities Liquidity

GIC and Mutual Funds Liquidity

Separately Managed - Multiple Manager Liquidity

Self Directed Brokerage Accounts

Expense Accrual Direction

Re-balancing

Investment Options

SEPARATELY MANAGED PORTFOLIOS

General Description

Trade Communication

Liquidity

Pricing

MUTUAL AND COLLECTIVE FUNDS

General Description

Trade Settlement

Liquidity

Pricing

Operating Procedures

Reconcilement

Income and Capital Gains

COMPANY STOCK

General Description

Proxy Voting

Pricing

In-Kind Contributions

In-Kind Distributions

ESOP Dividend Pass-Through

GUARANTEED INSURANCE CONTRACTS AND FIXED INCOME FUNDS

General Description

Trade Communication

Liquidity

GICWrapper Annual Process


Reconciliation

SELF-DIRECTED BROKERAGE ACCOUNTS (SDAs)

General Description

Investment Choices

Investment Restrictions


Investment Restrictions - continued

Interfaces

General Description

Customized Lifestyle Options

Lifestyle Target Risk Fund Examples

Glidepath for Lifecycle funds

Lifecycle Target Maturity Fund Examples

PRICING OVERVIEW

Security Pricing Methods

Price Reliability

PRICE CALCULATION APPROACHES

Mutual Fund Approach (NAV)

TrustMarket Value Approach ( SNAV)

ACCOUNTING PROCEDURES FOR DAILY SNAV CALCULATION

Company StockESOP Valuation (CSIO)

Guaranteed Insurance Contract (GIC) amp Fixed Income Mutual Funds Valuation

Separately Managed Portfolio Valuation

VALUATION AND PROCESSING MATERIALITY GUIDELINES

Purpose and Scope

Analysis of Error

Primary Materiality Standard

Materiality Analysis

Level 1

Level 2

Responsibility

WORKFLOW OF THE DAILY ENVIRONMENT

Day One

Communication of Participant Activity

Friday 301 PM ndash Monday 300 PM

Monday 500 PM

Monday 900 PM - Tuesday 700 AM

Day Two

Northern Trust Internal Processing

Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM

Tuesday - Between 500 and 645 PM

Tuesday 900 PM - Wednesday 700 AM

Wednesday 700 AM

REPORTING

Standard Package

Online only

FEE AND EXPENSE ACCRUALS

Expense Accrual Directions

Types of Fees

Methods of Payment

EXPECTATIONS FOR RECORDKEEPERS PROCESSING

IN A DAILY VALUATION ENVIRONMENT

Mutual and Collective Funds

Company Stock Trades

NSCC Trading

Payroll Contributions and Loan Repayments

Rollovers and Loan Repayment Checks

Transfers

Loan Issuance

Plan Payments

Forfeitures

RECORDKEEPING CONNECTIVITY

Electronic Files

1 Daily Price Feed

2 Daily Participant Activity Feed

3 Benefit Payment Feed (where applicable)

Holiday Considerations

Federal holidays when NYSE is open

Federal holidays when NYSE is closed

NYSE closed when Federal is open

Note These market schedules are applicable to US plans only Any foreign domiciled plans would need to follow market calendars based on the country or origin or other related calendarsRECONCILIATION

Trust Reconciliation

Clearing Account Reconciliation

TRANSITION

MANAGER HIRING AND TERMINATION

Manager Hiring

Manager Termination

APPENDIX 1

SAMPLE SNAV CALCULATIONS



Notice This document is for general descriptive and informational purposes only No warranty of any kind express or implied is made hereby or contained herein concerning any equipment or service described or referenced herein or any other equipment or service offered or to be offered by The Northern Trust Company or its affiliates While this document describes some of the intended capabilities of Northern Trust Daily Valuation Operating Guidelines no warranty or guarantee is made or implied hereby as to the actual operational characteristics and performance of Northern Trust Daily Valuation Operating Guidelines Trademark Notices Northern Trust and the Northern Trust anchor logo are registered trademarks of Northern Trust Corporation Copyright copy 2009 by The Northern Trust Company 50 S La Salle Street Chicago IL 60675 3126306000 This publication or any part thereof may not be reproduced or transmitted in any form or by any means electronic or mechanical including photocopying recording storage in an information retrieval system or otherwise without prior written permission of The Northern Trust Company

2













3



4



Term Definition



DCCampS









5













6



7



8





9




10


Investment Options




11




12









13



14



15



16





17

















18



19









20









21








22







23



24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1















3



4



Term Definition



DCCampS









5













6



7



8





9




10


Investment Options




11




12









13



14



15



16





17

















18



19









20









21








22







23



24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1





4



Term Definition



DCCampS









5













6



7



8





9




10


Investment Options




11




12









13



14



15



16





17

















18



19









20









21








22







23



24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1





Term Definition



DCCampS









5













6



7



8





9




10


Investment Options




11




12









13



14



15



16





17

















18



19









20









21








22







23



24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1















6



7



8





9




10


Investment Options




11




12









13



14



15



16





17

















18



19









20









21








22







23



24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1





7



8





9




10


Investment Options




11




12









13



14



15



16





17

















18



19









20









21








22







23



24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1





8





9




10


Investment Options




11




12









13



14



15



16





17

















18



19









20









21








22







23



24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1







9




10


Investment Options




11




12









13



14



15



16





17

















18



19









20









21








22







23



24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1






10


Investment Options




11




12









13



14



15



16





17

















18



19









20









21








22







23



24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1




Investment Options




11




12









13



14



15



16





17

















18



19









20









21








22







23



24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1






12









13



14



15



16





17

















18



19









20









21








22







23



24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1











13



14



15



16





17

















18



19









20









21








22







23



24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1





14



15



16





17

















18



19









20









21








22







23



24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1





15



16





17

















18



19









20









21








22







23



24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1





16





17

















18



19









20









21








22







23



24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1







17

















18



19









20









21








22







23



24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1



















18



19









20









21








22







23



24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1





19









20









21








22







23



24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1











20









21








22







23



24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1











21








22







23



24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1










22







23



24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1









23



24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1





24







Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1









Updated MVSNAV 16667 $1350 $22500


Ending balance 31482 $1350 $42500

25










26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1












26











27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1













27



28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1





28
















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1


















29



30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1





30











31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1













31






by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1








by category











32




Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1






Online only


33





34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1







34











35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1













35




36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1






36



a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1





a Recordkeeper










37







38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1









38





39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1







39







40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1









40






41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1








41











clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1













clearing account

42




43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1






43



44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1





44







ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1









ortfolio p

45



1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1





1 - GIC EXAMPLE




46


APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1




APPENDIX 2


gt $20 - impact

Valuation Yes

gt $20 + impact

NoProcessing lt $20

Yes

No

Error identified

Valuationor

Processing Error


STOPSTOP

STOP

Aggregate Impact of

corrections

Impactgt 110

STOP

Fund Trust STOP

Unit Adjustments

47


48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1




48

APPENDIX 3


RecordkeepingSystem







Prices



Day 212am


Day 1 until 3pm

Day 2 12am

Day 2 11am

Day 2 8am

Day 2 3pm

Day 2 2pm



Day 1 SNAV

645 pm

Client Payroll


Net Payroll Amount


RecordkeepingSystem

ParticipantCalls


All times are CT


ACCOUNT STRUCTURE

HOLIDAYS

DIRECTION LETTERS

Delegation






Re-balancing

Investment Options


General Description

Trade Communication

Liquidity

Pricing


General Description

Trade Settlement

Liquidity

Pricing


Reconcilement


COMPANY STOCK

General Description

Proxy Voting

Pricing





General Description

Trade Communication

Liquidity



Reconciliation


General Description

Investment Choices




Interfaces

General Description





PRICING OVERVIEW


Price Reliability









Purpose and Scope

Analysis of Error



Level 1

Level 2

Responsibility


Day One



Monday 500 PM


Day Two


Tuesday 1000 AM

Tuesday 1100 AM

Tuesday 100 PM

Tuesday 500 PM



Wednesday 700 AM

REPORTING

Standard Package

Online only



Types of Fees

Methods of Payment





NSCC Trading



Transfers

Loan Issuance

Plan Payments

Forfeitures


Electronic Files

1 Daily Price Feed










TRANSITION


Manager Hiring

Manager Termination

APPENDIX 1



northern trust daily valuation operating guidelines … northern trust daily valuation operating...

Documents