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SPARK Institute Best Practices for 403(b) and Related Retirement Plans Information Sharing Version 1.04 - August 2015

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1) Best Practices for 403(b) and Related Retirement Plans Information Sharing - Minimum and Comprehensive Data Elements Version 1.04 Updated on July 31, 2015 Effective as of August 17, 2015 SHAPING AMERICA’S RETIREMENT

2) Best Practices for 403(b) and Related Retirement Plans Information Sharing Minimum and Comprehensive Data Elements1 Version 1.04 (Updated on – July 31, 2015) General Information A. Purpose and Scope These “Best Practices” set forth: 1. The data elements for information sharing between 403(b) plan employers or employer representatives and vendors. The data to be shared applies to 403(b) plans as well as any associated plans including 401(a), 401(k), 457(b) governmental, etc. that are sponsored by the same employer. 2. A basic file convention layout. 3. The frequency of data transmissions. 4. An approach for sharing and transmitting data on a transaction or daily basis when agreed upon by both the sending and receiving parties. The document does not define best practices for: the methods of data transmission (see Section B below), or 1099 distributions. The Best Practices were developed for purposes of facilitating compliance with the final regulations by identifying the specific data elements necessary to coordinate plan administration. Additionally, the Best Practices are offered with a view to facilitating uniform expectations among 403(b) vendors and employers who will be engaged in data sharing and to facilitate efficient information technology design and development. The Best Practices represent the views of The SPARK Institute only and are not intended as the sole or exclusive means of effecting 403(b) data sharing. The information is intended to facilitate adherence to regulations requiring information sharing between vendors, but it does not replace the need for providers to determine the amount that the participant is eligible to take 1 These data sharing best practices identify both (a) the minimum data sharing elements required to support a plan that has adopted the model language published in Rev. Proc. 2007-71, and (b) the additional data sharing elements that an employer and vendor may agree to share to support plan features in addition to those addressed by the model language (e.g., employer contributions or Roth features). i SHAPING AMERICA’S RETIREMENT

3) as a distribution. To determine distribution amounts, a number of factors, including the defaulted loan amount, vesting and product rules and riders for each vendor, would need to be considered. B. Data Security, Privacy and Transmission - Issues regarding data security and privacy are beyond the scope of the Best Practices. Such issues are company specific and vary based on each companies own policies, procedures, resources and capabilities. The SPARK Institute has not established any standards on these matters, except with respect to data transmission. The preferred Best Practices standard for data transmission is "secure FTP-PGP." We recognize that other transmission methods are available but the preferred method was determined to be the one that is likely to be acceptable to most affected parties. Additionally, The SPARK Institute does not consider using a combination of electronic and paper based transmission of data to be an acceptable means of adhering to the Best Practices. We encourage all companies that are attempting to adhere to the Best Practices to transmit data electronically only and not to use a combination of electronic and paper based transmissions as a matter of course. Electronic transmission is necessary in order to leverage the full benefits and efficiencies of the Best Practices.2 Overview This document originally consisted of four parts. However, as explained below, Part III has been moved to a separate document. Part I – Identifies conventions in formatting and providing data that applies to all of the data elements identified in the Best Practices. Part II – Identifies and describes the data elements. Generally, each data element description (1) identifies the data element (field) name, (2) identifies the field’s maximum length, (3) identifies the data format (e.g., alphanumeric), (4) provides an example, (5) identifies whether the data field is required for plans with minimum features, required for plans with additional features, or is “conditional” based on certain circumstances, and (6) provides additional explanatory comments. Additionally, this Part identifies the core participant account data needed to administer Hardships and Loans. Part III – This Part, which covered census and remittance processing practices, has been removed from this document and published as a separate document entitled “Best Practices for Multiple Vendor Plans Remittance and Census Data Elements.” The document is available on The SPARK Institute website at http://www.sparkinstitute.org/comments-and-materials.php. In order to minimize confusion among the Companies that are already using the Data Elements Best 2 The foregoing applies to transmission of data among vendors. The use of electronic communication with participants is governed by applicable IRS and DOL rules. See Treas. Reg. § 1.401(a)-21; DOL Reg. § 2510.104b-1. ii SHAPING AMERICA’S RETIREMENT

4) Practices, the Parts in this document have not been renumbered and will continue to be referred to by their previous Part designations. Part IV – Describes the data standards for distributions. While not every distribution made by a vendor is required to be reported under the 403(b) plan regulation, a number of SPARK Institute members reported that some employers or their representatives have asked for this information. In addition to loans and hardship withdrawals, other distribution types including contract exchanges, in-service withdrawals, rollovers, deaths, disability, required minimum distributions, QDROs and separation from service are supported. Summary of Version 1.04 Updated on February 14, 2011 This update to Version 1.04 reflects certain industry developments that occurred since it was originally published in June 2009. Additionally, the update incorporates answers to certain questions that had been posted on The SPARK Institute website. The update does not change the file structure or format, except in connection with Part II, Section G, Fields 3 and 5 (previously “filler” fields) relating to Loan Amount Available Data. We note that anyone using the previously released Version 1.04 may continue to do so without making any programming change as a result of this update. In order to facilitate the continued use of the prior version, this update was not assigned a new version number (i.e., 1.05) which would have required all users to reprogram their systems to adjust the affected header record field. More specifically, this update includes the following: 1. Establishes that the best practice for data transmission is on a weekly basis (instead of monthly) in response to plan needs and industry requests for more up to date data for use in monitoring plan activity and approving transactions. 2. Establishes approaches for transmitting daily file updates as either a full file refresh or a partial file refresh (“Daily Delta Files”) when the affected parties specifically agree. 3. Incorporates clarifications and updates in response to questions we received from the 403(b) plan community and previously answered on The SPARK Institute website, i.e., Questions 55 (over 99 loans), 58 (inception to date), 61 and 62 (distribution amounts), 63 (Vendor Source ID), 70 (HEART distributions), 72 (Defaulted loans), 78 and 79 (Term Date and Product ID), 81 (Daily Delta Files), 86 (whole numbers), and 89 (Gross Amount). 4. Identifies each field within each record by number in order to make it easier to reference and locate them. Please note that the field numbers are for reference purposes only and do not require any changes. Summary of Version 1.04 Updated on July 31, 2015 This latest 1.04 version incorporates content from the 403(b) Plans Information Sharing Data Elements Questions & Answers (listed separately on The SPARK Institute web site) to ensure that the Best Practices are updated with the most recent technical information. In addition, certain terms and definitions were clarified to improve data consistency and common understanding among users. iii SHAPING AMERICA’S RETIREMENT

5) No changes were made to the file format itself (and as a result, the format version was not changed). Rather, the purpose of the revision is to provide more specificity concerning the data to be shared between providers to assist users who are newly adopting the Best Practices, or as a reference for existing users. Every version of the Best Practices includes a Version Control Log that identifies the changes that have been made between versions. Please see Appendix B. Effective Date - In order to facilitate an effective transition, this update will become effective on August 17, 2015 (as updated and clarified on July 31, 2015). Additionally, as of August 17, 2015 any and all prior versions of the Best Practices (i.e., Version 1.03 and all earlier versions) will be considered obsolete. * * * * * The SPARK Institute may release revised versions of the Best Practices periodically. Anyone with questions about this version should contact info@sparkinstitute.org. THIS MATERIAL HAS NOT BEEN REVIEWED, APPROVED, OR AUTHORIZED BY THE DEPARTMENT OF LABOR, THE TREASURY DEPARTMENT OR THE INTERNAL REVENUE SERVICE AS MEETING THE REQUIREMENTS OF ANY APPLICABLE RULES OR REGULATIONS. THE SPARK INSTITUTE DOES NOT PROVIDE LEGAL ADVICE. USERS OF THIS MATERIAL SHOULD CONSULT WITH THEIR LEGAL COUNSEL BEFORE USING IT. iv SHAPING AMERICA’S RETIREMENT

6) TABLE OF CONTENTS PART I - File Layout Conventions for Data Sharing Between Vendors and Employers or Employer Representatives (Aggregators)..................................1 A. B. C. D. General File Layout Conventions ...........................................................................................1 Identification of Record Types ...............................................................................................5 SPARK Institute File Header for All Data Files.....................................................................6 SPARK Institute File Trailer for All Data Files .....................................................................7 PART II - Data Sharing Elements for Vendor File Account Point-in-Time Detail Records to be Shared with Employers or Employer Representatives ........................8 A. B. C. D. E. F. G. Basic Account Data.................................................................................................................8 Deferral Limit Monitoring / 415 Limit Monitoring Data .....................................................16 Required Minimum Distribution Data ..................................................................................17 Hardship Amount Available Data.........................................................................................18 Employer Contribution Restriction Grandfathering Data ....................................................21 Non-Emergency Withdrawal Data (In Service Withdrawals) ..............................................22 Loan Amount Available Data ...............................................................................................23 PART III - Intentionally Omitted. PART IV - Data Sharing Elements for Employer or Employer Representative (Aggregator) Distributions Made by Vendors.............................................32 A. Distributions Made by Vendors Data ...................................................................................34 Appendix A - Version Control Log ............................................................................................36 Appendix B - Summary of Prior Version Changes...................................................................45 Schedule I – Best Practices for 403(b) Plans Information Sharing .........................................46 v SHAPING AMERICA’S RETIREMENT

7) PART I File Layout Conventions for Data Sharing Between Vendors and Employers or Employer Representatives (Aggregators) This update establishes that the best practice for data transmission is on a weekly basis (instead of monthly) in response to plan needs and industry requests for more up to date data for use in monitoring plan activity and approving transactions. Feedback from SPARK Institute members and others in the 403(b) plans community has identified the need among many industry providers and plan sponsors for information to be provided on a timelier basis to facilitate transaction processing. Parties that adopt a weekly transmission schedule would not be expected to also exchange monthly files. Please note that the “as of” date of any file that is transmitted is specified by the “Valuation Date” in file Header field (Part I, Section C, Field 8). The affected parties should agree upon the appropriate Valuation Dates for data transmissions, including whether transmission as of a month-end or year-end is needed. Additionally, please note Sections A, 8 and 9 below that describe a “Daily Delta File” transmission option that can be used in conjunction with the weekly transmissions as the affected parties agree. A. General File Layout Conventions 1. The extract file (including the Header and Trailer records) should be an ASCII file that is pipe “|” delimited, with no spaces between the data element and pipe at either end. For more information regarding pipe delimited files, please refer to the discussion of “Coding PIPE Delimited Data” on The SPARK Institute’s website located here http://www.sparkinstitute.org/comments-and-materials.php. Examples are shown for when the data field has a value to be reported and when the first field is NULL because no data is being reported. 2. The file will be variable length. All data elements should be reported on a single line (variable length record) for each account reported. 3. In order to maintain file layout consistency, all fields, including NULL fields, must be provided. Note that within Part II, Section G. Loan Amount Available, multiple outstanding (active or deemed /defaulted) or paid off loans during the prior 12 months, would be reported as recurring loan components (one set of loan components for each outstanding (active or deemed/defaulted loan) or paid off loan during the prior 12 months) within a single Account record, rather than repeating loan records for the same Account. For those vendors unable to supply detailed loan information for each outstanding (active or deemed/defaulted) or paid off loan during the prior 12 months, a single set of loan component data can be reported in which information has been summarized for all outstanding (active or deemed/defaulted) or paid off loans during the prior 12 months. If there have been no outstanding (active or deemed/defaulted) or paid off loans during the last 12 months, no loan component data is reported and in this case, no NULL fields are needed because the loan component data is at the end of the record. A “Method of Reporting Loan Data” of “M” and a “Number of Sets of Loan Component Data” = “0” would signify that no loan component data is reported. 4. Hardship and Loans Data for surrendered or closed contacts (e.g. the participant is terminated from the plan and all account value has been distributed) should be included The hardship and loan sections of Part II should still reflect key items such as the HOLB (Highest Outstanding Loan Balance 12 months component or the summary data within 1 SHAPING AMERICA’S RETIREMENT

8) the component) and date of last hardship. The vendor should continue to send Part II records as long as the HOLB is greater than zero or the last hardship distribution date is less than or equal to 12 months from the date of reporting (i.e., if either condition is true). 5. Sending Participant Data records for an account with a zero balance should occur if any of the following conditions are met: a. A new account is set-up and the participant has not funded the account through a payroll contribution. The Investment Provider should include these records in their file. b. An active account is fully surrendered and no defaulted loans are outstanding. The investment Providers should continue to report the record for a rolling 12 months. c. An active account is fully surrendered that had a hardship or loan. The investment Providers should continue to report the record for a rolling 12 months. d. Additionally, if the fully surrendered account had a defaulted loan, report this record, including the defaulted loan information, for as long as administratively possible beyond the rolling 12 months after the account was surrendered. Note: Some plans do not allow a participant who has defaulted on a loan to take another loan. 6. When sending a file that contains no activity, for example a Part II (as agreed to by Investment Providers) or Part IV file that had no transactions in the prior reporting period, the sender should send an empty file that contains the Header and Trailer records without any detail records. The file should be sent according to the agreed upon frequency between the Investment Providers. 7. File name: The file name is a combination of: a. Vendor Name/Employer Name - Text. b. Aggregator - Text. c. Frequency - One character. d. Frequency Values: A = Annually, B = Bi-Weekly, D = Daily, M = Monthly, Q = Quarterly, S = Semi-Annually, T = Semi-Monthly, W = Weekly and X = Daily Delta. e. Record type - Two characters. Record Type Values: 01 = Account, 02 = Distributions, 12 = Both Account, and Distribution data. f. Date and Time - YYMMDD_HHMMSS g. File name extension - “.TXT” A Vendor is the Investment Provider, a.k.a. “IP”. An “Aggregator” is a firm responsible for consolidating the Vendor reported data associated with a Plan on behalf of the Employer. The Aggregator may also act as the Administrator of the Plan on behalf of the Employer. Some Vendors may also provide Aggregator services. Third Party Administrators (TPAs) may also provide Aggregator services. A date/time stamp is important in case replacement files are created. Example: A file sent by “Vendor Name” to “Aggregator” as a weekly file for Part I data on December 31, 2010 should be named: “Vendor Name_Aggregator_W_01_101231_110503.TXT” 2 SHAPING AMERICA’S RETIREMENT

9) The above naming protocols should be used for both Part II and IV file submissions. While most firms that compress files have been using a TXT.zip and not TXT.gz, there are many formats that can be used and it is ultimately up to the affected parties to decide what they will provide and accept. 8. “Daily Delta File” defined: A Daily Delta File is a file transmission where daily records are sent whenever any of the transactions identified below are executed for an account. These files should contain a full record refresh of all Part II data for participants with the specified transaction activity. The transactions that are included in the list below are those that could have a material impact on the availability of loans and hardships. A Daily Delta File can also be sent when other transactions are executed for an account as an optional extension of the Daily Delta File process. Daily Delta Files should only be used by parties that submit a full file refresh on at least a weekly basis according to the best practices under this updated Version 1.04. Daily Delta Files should be used and formatted as follows: a. A Daily Delta File should be used to transmit information whenever any of the following transaction is executed for an account: i. Loan initiation ii. Loan default iii. Loan payoff (total loan repayment) iv. Withdrawal (including Hardship) v. Lump sum contribution (e.g., rollover, contract exchange, etc.). Note: This does not include ordinary plan contributions. vi. Reversal of any of the above transactions. b. The format of a Daily Delta File will be exactly the same as a file sent on any other basis. Note: The file name changes to indicate a frequency of “X” for Daily Delta File. c. If Part IV records are included with Daily Delta Files, they should only include the transaction(s) processed on the day the file is sent. d. Daily Delta Files should only be used to update existing accounts from the last weekly full file refresh. The Daily Delta File process should not be used to establish or set up new participant accounts. e. Recipients of a Daily Delta File should identify the account(s) for which an update is received and replace all Part II data on record with the updated data. 9. All files other than a Daily Delta File are to be sent as a total replacement of the information sharing data sent in any prior transmission. 10. When sending data, all non-variable fields should be reported. TEXT or Alpha-numeric fields without values should default to null and numeric fields should default to zero (either 0 or 0.00 depending of field length definition). NULL fields should contain no values/spaces between delimiters. A NULL value is reported as two delimiters with no embedded spaces, as follows: || Although values or nulls are required in the Loan Summary section, do NOT report loan component fields with null values between delimiters when the method of loan data is ‘M’ and the number of sets of loan components is zero. The loan components are variable data fields and are only required when the method of reporting loan data is ‘C’. 11. Every "required" field must be reported with a valid value as indicated in the 3 SHAPING AMERICA’S RETIREMENT

10) "Comments" column of the Best Practices document. For example, the default value for "required" currency fields is "0.00". 12. All date fields should be formatted as CCYYMMDD. All “Required” date fields must be reported. Any “Optional” date field may contain a valid date or be NULL (two delimiters with no embedded space) indicating that the date is not available. 13. Any “Required” TEXT field cannot be reported as NULL. All text fields should be all uppercase. 14. Any “Optional” TEXT field can be reported as a valid value or be NULL (two delimiters with no embedded space) indicating that the date is not available. 15. Although certain fields are generally considered “Optional” under the Best Practices, we note that some Aggregators may request some optional fields to be populated under their service arrangements. For example, a TPA that tracks state approved products may request Field 1 (“Contract Certificate Issue Date”) in Part II, Section E and Field 5 (“Product ID”) in Part II, Section G to be populated. This will need to be worked out between the Aggregator and each vendor at the start of the data sharing arrangement. 16. All numeric fields that have fractional numbers included should have an explicit decimal point. For example, if the format for an amount field is “11.2” it means 8 significant digits to the left of an explicit decimal point and two digits to the right of the decimal point; in total occupying at most 11 positions. Reported amounts or values that are less than the maximum length of a field do not require leading zeros. Numeric fields are intended to be variable length and leading zeros are unnecessary. Whether or not leading zeros will be accepted by an Aggregator will depend on the Aggregator. We note, however, that certain numeric fields should be fixed length (e.g. dates and social security number). Examples of acceptable numeric values include: |0.00| |0| |0.01| |1.00| |1.23| |12345678.12| || (valid only when a numeric field is optional) Examples of unacceptable numeric values include: || (invalid; when a numeric field is required, it cannot be reported as NULL) |.| |1| |.0| |0.| |.00| |00.| 4 SHAPING AMERICA’S RETIREMENT

11) |0.0| |1.234| |12345678901.45| In addition Numeric fields should be right justified. 17. All amount fields in Parts II represent the latest available data and therefore are positive amounts; no sign is necessary. Even though a Distribution Amount may be represented as a negative number in the vendor’s administrative system (because it is a withdrawal), positive numbers should be used when reporting the Distribution Amount unless a reversal of a previously processed Distribution is being reported. A distribution that has been reversed would be reported with a leading negative sign (e.g. |-12345.67|). The negative sign will take up a reportable position so the maximum amount of a distribution reversal would be |-9999999.99Any “Required” numeric field must be reported; 0.00 is the default value and will be treated as the reported amount. Any “Optional” numeric field may contain a numeric, including 0.00 or be NULL (two delimiters with no embedded space) indicating that the field is not available. If you have any questions regarding formatting please refer to the document “How to Code PIPE Delimited Data” available here http://www.sparkinstitute.org/comments-and-materials.php. B. Identification of Record Types 1. Each file will contain at least one SPARK Institute Header and one SPARK Trailer record. Detail records will appear between the SPARK Institute Header and Trailer records. The SPARK Institute Header contains a “Data Type” field which identifies the data following the SPARK Institute Header as: 01- Account data 02- “Distributions Made” data 2. There can be multiple SPARK Institute Header, Detail and SPARK Institute Trailer records on a single transmitted file; an example follows: Basic Account Data a. SPARK Header for Vendor 1’s data of Data Type “01” (Account) from Sender A b. SPARK formatted (Account) Detail records for Vendor 1 c. SPARK Trailer for Vendor 1’s (Account) data Distributions Made Data d. SPARK Header for Vendor 1’s data of Data Type “02” (Distributions Made) from Sender A e. SPARK formatted (Distributions Made) Detail records for Vendor 1 f. SPARK Trailer for Vendor 1’s (Distributions Made) data 3. There is no requirement to send both “Account” and “Distributions Made” data in the same file. The Account data is necessary to allow Employers or Employer representatives (Aggregator/Administrator) to make decisions about Hardship and/or Loan requests. The “Distributions Made” data may be required by certain Employers who want to be aware of Distributions Made to their plan participants; however, 5 SHAPING AMERICA’S RETIREMENT

12) “Distributions Made” data is not required to make decisions about Hardship or Loan requests unless specified by the Plan. 4. When Vendors share files for more than one employer (or more than one plan for the same employer) and account data is being supplied in one file, only one Header and Trailer record should be used (i.e., do not send a Header and Trailer for each Employer (or individual employer plans) within the file). The same protocol applies to the “Distributions Made” data. (Note: The Best Practices anticipate vendors sending data on a single file that pertains to many plans. The standards identified a file naming convention to identify the Vendor (or Employer or Aggregator) and the date/time the file was created (see Part I, Section A4). Within the detail records on the file, the plan identity must be specified as either the Aggregator Plan ID or the Employer Plan ID if no aggregator has been selected) For each account detail record within the Header and Trailer record the following conditions should exist: a. The SPARK Institute Best Practices version number (e.g., 1.04) identified in each data type should be the same across all data types. b. The cash valuation dates reported within the account detail records should be the same as the Header throughout the record. c. A participant should only be listed once under the same employee account number and Vendor Plan ID. Samples of File and Data sharing file formats are available on The SPARK Institute website at http://www.sparkinstitute.org/comments-and-materials.php. 5. All Header and data records should be followed by a CR-LF (Carriage Return – Line Feed). Data for each participant should be sent on a separate line. This is typically automatically generated by the FTP process. (Note: The file format is not a fixed length and there is no end of record marker. The record lengths is variable and the last field can be identified by counting the number of delimiters. Typically most vendors will use a CR LF to start the next row of data.) C. SPARK Institute File Header for All Data Files - Every Vendor and Employer Data File should contain a file Header with the following information and layout. No. Field Max Length Data Type Example Required for all Plans Comments 1 Header 6 Text SPARKH Required Constant value: SPARKH. 2 Data Type 2 Numeric 01, 02, 03, 04 Required Identifies the type of data which follows until a SPARK Institute Trailer record appears 01-Account Data 02-Distributions Data. 6 SHAPING AMERICA’S RETIREMENT

13) No. Max Length Field 3 Data Source 4 File Creation Date/Time 5 30 15 Contact 40 40 Data Type Example Text For Vendor: Vendor ABC For Employer: ER_XYZ School District For Aggregator: Aggregator_AnyCoName Required for all Plans Required Comments Identifies the data source as the Vendor (Investment Provider), Employer or Aggregator. Required Format: CCYYMMDDHHMMSS (time is in Military format 120000 for noon, 190000 for 7:00pm). Text Free-form J.Smith1-222-333-4444 x123 Optional Identifies an individual and phone number if there are questions about the content of the file. Text Free-form ABC Firm as Aggregator for Vendors D, E and F in School District Z. Optional Identifies sender name and role (i.e., Aggregator or Vendor). Text 20081001-110503 6 Sender 7 SPARK Institute 403(b) Data Elements Version No. 4 Text 1.04 Required SPARK Institute Best Practices version number in which the data is formatted. 8 Valuation Date 8 Date Format CCYYMMDD Required Indicates the Valuation date of data provided in layout. D. SPARK Institute File Trailer for All Data Files – Every Vendor and Employer Data File should contain a file Trailer identifying the number of records within the file and record type, including the Header and the Trailer records. No. Field Max Length Data Type Example Required for all Plans 1 Trailer 7 Text SPARKTR Required Constant value SPARKTR. Required Total number of ALL records INCLUDING Header and Trailer records. Format 99999999, right justified, spaces filled with zeros. 2 Record Count 8 Numeric 00045678 Comments 7 SHAPING AMERICA’S RETIREMENT

14) No. Field Max Length Data Type Example Required for all Plans 3 Filler 65 Text Blank Null Comments Spaces, reserved for future use. 8 SHAPING AMERICA’S RETIREMENT

15) PART II Data Sharing Elements for Vendor File Account Point-in-Time Detail Records to be Shared with Employers or Employer Representatives Generally, the Best Practices anticipate the transmission of a full data file under Part II. However, affected parties can agree among themselves to transmit and accept partial Part II files as change only files in addition to one full Part II weekly file. Please refer to Part I, Sections A, 8 and 9 regarding such "Daily Delta Files." (Note: for all Cash Value fields, the amount reported in these fields should include the cumulative amount of money into and out of the specific investment source(s) and the associated earnings on those source(s).) A. Basic Account Data No. Field Max Length Data Type Example Required for Plans with Minimum Features Required for Plans with Additional Features Comments Conditional, if no Aggregator has been assigned and the Employer has multiple Plans Identifies the Employer. The Employer EIN is used to tie multiple Plans of the same Employer together when there is no Aggregator involved. If there are multiple Employer EINs associated with the same Plan(s) of that Employer, the Employer must specify which EIN to associate with all of their Plans. 1 Employer EIN 10 Alphanumeric AB-1234567 Conditional, if no Aggregator has been assigned and the Employer has multiple Plans 2 Vendor EIN 10 Alphanumeric CD-7654321 Required Required Identifies the Vendor (I.P.) 3 Vendor Source Name 20 Text Varies Required Required Identity of the Vendor associated with the Account. Varies Optional, required if an Aggregator has been selected by the Employer to consolidate data of all vendors associated with the Employer’s plan participants Optional, required if an Aggregator has been selected by the Employer to consolidate data of all vendors associated with the Employer’s plan participants 4 Aggregator Source Name 20 Alphanumeric Identity of Aggregator, if any, supplying the fields. NULL if no Aggregator has been selected by the Employer. 9 SHAPING AMERICA’S RETIREMENT

16) No. Field Max Length Data Type Example Required for Plans with Minimum Features 5 Vendor Source ID 20 Alphanumeric Varies Optional 6 7 8 Aggregator Plan ID Vendor Plan ID Employer Plan ID 20 20 20 Alphanumeric Alphanumeric Alphanumeric Varies Varies AB1234567001 Conditional, required if an Aggregator has been selected by the Employer Required Conditional, required if no Aggregator has been selected Required for Plans with Additional Features Optional Conditional, required if an Aggregator has been selected by the Employer Required Conditional, required if no Aggregator has been selected Comments The identifier used by the Aggregator (if any) to identify the Vendor. The identifier used by the Aggregator (if any) to identify the Plan or to differentiate locations or divisions within a plan. Must be provided if the Employer Plan ID is NULL. Each Aggregator should provide the Aggregator Plan ID to the Vendor that will transmit the data. The identifier used by the Vendor to identify the Plan. May be the same as the Aggregator Plan ID if that vendor also serves as the Aggregator for the plan. . The Employer Plan ID uniquely identifies the Plan as defined by the Employer. Suggested format is Employer’s EIN plus a sequential number to differentiate multiple plans of the same Employer. 10 SHAPING AMERICA’S RETIREMENT

17) No. Field Max Length Data Type Example Required for Plans with Minimum Features Required for Plans with Additional Features Comments Employee specific account/contract number at the Vendor. This is the Participant’s contract or account number at the Vendor level. 9 Employee Account Number 25 Alphanumeric Varies Conditional if multiple accounts within the same Plan Conditional if multiple accounts within the same Plan Participants may have more than one account or contract with the same Vendor. This field is needed in order to properly reflect the account values at the contract level. A participant should not be listed more than once with the same Employee Account Number and Vendor Plan ID. 10 Employee SSN 9 Numeric 123456789 Required Required The participant’s social security number will be used to identify the participant. 11 Employee ID 20 Alphanumeric Varies Optional Optional Employee identification found on the Employer records; default to SSN if employer does not use a unique ID. 12 Employee First Name 35 Text Varies Required Required For research purposes only. Will be used in the event of a record rejecting. 13 Employee Last Name 35 Text Varies Required Required For research purposes only. Will be used in the event of a record rejecting. Required A default value, such as “19000101” or “19010101”, is necessary if the date of birth is not available. Aggregators must be advised of default values to ensure the default is not mistaken as a valid date of birth. 14 Date of Birth 8 Date Format CCYYMMDD Required 11 SHAPING AMERICA’S RETIREMENT

18) No. Field Max Length Data Type Example Required for Plans with Minimum Features Required for Plans with Additional Features Comments Identifies all account Cash Values as either Gross or Net. It is understood that some vendors may not have vesting schedule information so all Cash Values should reflect the total of vested and unvested amounts. (Treat as if all amounts are 100% vested). G or N Assume that Cash Value 3 Type 15 1 Alphanumeric Vested=40K Unvested=10K Outstanding loans = 20K GROSS = 40K+10K=50 K Required NET = 50K20K=30K Required If a Vendor is reporting Gross Cash Values, then the Cash Values reported will include 100% of vested and unvested amounts plus all outstanding and/or defaulted loans. Outstanding/defaulted loans are not netted out of Gross Cash Value. If a Vendor is reporting Net Cash Value, then the Cash Values reported will include 100% of vested and unvested amounts but will not include outstanding or defaulted loans. Gross Cash Value = Net Cash Value + Outstanding/defaulted loan principal and interest 3 All Cash Value fields are either Gross or Net. [The seven cash value fields (i.e., Employer Cash Value, EE Deferral Cash Value, Rollover EE Pre-Tax Cash Value, Rollover EE Post-Tax Cash Value, Rollover Roth Cash Value, EE Post-Tax Cash Value, Roth Cash Value) in Part II, Section A of the current version of the Best Practices (Version 1.04) should add up to the total cash value of the participant's account (either Gross or Net, as specified). Please note that the "403(b)(7) Employer Cash Value" would not be included in the calculation above because a different calculation applies under 403(b)(7) rules. Please see Schedule I of this document for examples regarding reporting 12 loan amount available data. SHAPING AMERICA’S RETIREMENT

19) No. Field Max Length Data Type Example Required for Plans with Minimum Features Required for Plans with Additional Features Comments The market value of the Participant’s account containing Employer Contributions. Market value is defined as the value of the account as of the end of the reporting period. 16 Employer Cash Value 11.2 Numeric 12345678.12 Does not apply, submit as 0.00 Required for Plans with employer contributions For an account containing both Employee and Employer contributions for a Retirement plan, which cannot distinguish a separate value by money sources, the reported value should be combined into the more restrictive money source. If none of the plan's contribution sources are more restrictive than others for the same plan, then the entire value should be reported in the 403(b) (7) Employer Cash Value field. If no value, submit as 0.00. 13 SHAPING AMERICA’S RETIREMENT

20) No. Field Max Length Data Type Example Required for Plans with Minimum Features Required for Plans with Additional Features Comments The market value of the Participant’s account containing Employee PreTax or Salary Deferral Contributions. 17 EE Deferral Cash Value 11.2 Numeric 12345678.12 Required Required For an account containing both Employee and Employer contributions for a 403(b) or other related retirement plan, which cannot distinguish a separate value by money sources, the reported value should be combined into the more restrictive money source. If none of the plan’s contribution sources are more restrictive than others for the same plan, then the entire value should be reported in the Employer Cash Value field. If no value, submit as 0.00. The market value of the Participant’s account containing Rollover Employee Pre-Tax or Salary Deferral Monies. 18 Rollover EE Pre-Tax Cash Value 11.2 Numeric 12345678.12 Required for Plans that allow rollover amounts Required for Plans that allow rollover amounts This does not include Roth 403(b) or other related retirement rollovers that can be tracked with Rollover Roth Cash Value. If no value, submit as 0.00. 19 Rollover EE Post-Tax Cash Value 11.2 Numeric 12345678.12 Required for Plans that allow rollover amounts Required for Plans that allow rollover amounts The market value of the Participant’s account containing the Rollover Employee Post-Tax monies. If no value, submit as 0.00. 14 SHAPING AMERICA’S RETIREMENT

21) No. 20 21 Field Rollover Roth Cash Value EE Post-Tax Cash Value Max Length 11.2 11.2 Data Type Numeric Numeric Example Required for Plans with Minimum Features Required for Plans with Additional Features 12345678.12 Required for Plans that allow rollover amounts Required for Plans that allow rollover amounts 12345678.12 Required for Plans with EE Post-Tax contributions Required for Plans with EE Post-Tax contributions Roth Cash Value 22 23 (Originally named “Roth 403(b) Cash Value”) Date of First Roth Contribution 11.2 Numeric 8 Date Format 12345678.12 Does not apply, submit as 0.00 Required for Plans with Roth features CCYYMMDD Does not apply, create as Null Required for Plans with Roth features Comments The market value of the Participant’s account containing Rollover Roth monies. If no value, submit as 0.00. The market value of the Participant’s account containing Employee Post-Tax Contributions. If no value, submit as 0.00. The market value of the Participant’s account containing Roth Contributions, excluding any Roth Rollover amounts which are reported separately in the Roth Rollover Cash Value field., The amount reported in this field should include the cumulative amount of money into and out of the specific investment source(s) and the associated earnings on those source(s). If no value, submit as 0.00. The date of the first Roth Contribution. 15 SHAPING AMERICA’S RETIREMENT

22) No. Field Max Length Data Type Example Required for Plans with Minimum Features Required for Plans with Additional Features Comments Due to regulatory requirements for more stringent distribution restriction handling: 403(b)(7) Employer Cash Value 24 11.2 Numeric 12345678.12 (Originally named “403(b)(7) Cash Value”) Conditional, required if Account Type = “008” (reflecting both 403(b)(1) and 403(b)(7) account Conditional, required if Account Type = “008” (reflecting both 403(b)(1) and 403(b)(7) account Represents the 403(b)(7) portion of the Employer Cash Value for a combination account --- OR --The Employer dollars that were part of a prior exchange from a 403(b)(7) to a 403(b)(1) account. Note that the 403(b)(7) Employer Cash Value amount should be excluded when determining the total cash value for the account, as this amount is already included in the Employer Cash Value field. For any Type of Account other than “008” the “403(b)(7) Employer Cash Value” should reflect a default value of “0.00”. If no value, submit as 0.00. 25 26 Cash Value Date Type of Account 8 3 Date Format Text CCYYMMDD 001, 007, 008, 009, 01a, 01k 457 Required Required Required Required The Date of Valuation of all Cash Value fields provided within this file. It represents the "as of" date for all cash values transmitted on the file. 001 = 403(b)(1) 007 = 403(b)(7) 008 = Both 403(b)(1) and (7) 009 = 403(b)(9) 01a = 401a 01k = 401k 457 = 457 (including both 457(b) and 457(f) plans) Non-403(b) plan information should be provided only in instances where such other plan is related to a 403(b) plan of a common employer. 16 SHAPING AMERICA’S RETIREMENT

23) B. Deferral Limit Monitoring / 415 Limit Monitoring Data No. 1 Field Year-to-Date EE Contributions Max Length 11.2 Data Type Example Numeric 12345678.12 Required for Plans with Minimum Features Required Required for Plans with Additional Features Required Comments The amount of the Participant’s contributions, (Employee Pre-Tax and Roth) year to date. This is needed for 402g limit monitoring. If no value, submit as 0.00. 2 Year-to-Date ER Contributions 11.2 Numeric 12345678.12 Conditional, if Employer makes contributions Conditional, if Employer makes contributions The amount of the Employer’s contributions, year to date, needed for 415 limit monitoring. If no value, submit as 0.00. 3 Account Inception-toDate EE Contributions 11.2 Numeric 12345678.12 Optional Optional The amount of the Participant’s contributions, (Employee Pre-Tax and Roth) since account inception, for calculation of 15 Year Catch-Up. This value is the gross contributions – not reduced for distributions, charges or other items. If no value, submit as 0.00 4 Account Inception-toDate 15 Year Catch-Up Contributions 11.2 Numeric 12345678.12 Optional Optional The total of all 15 Year Catch-Up contributions (Employee Pre-Tax and Roth) submitted since account inception. (Includes current year deferrals reclassified as Catch-Up. This value is the gross contributions – not reduced for distributions, charges or other items. If no value, submit as 0.00 17 SHAPING AMERICA’S RETIREMENT

24) C. Required Minimum Distribution Data No. Field Max Length Data Type Example Required for Plans with Minimum Features Required for Plans with Additional Features Comments The value of the Participant’s account, containing Employee Pre-Tax or Voluntary Contributions, as of 12/31/1986. 1 12/31/86 Cash Value – EE 11.2 Numeric 12345678.12 Does not apply as no RMD coordination is required across vendors. Submit as 0.00 Required for Plans seeking to coordinate minimum required distributions. This value is a subset and should be included in the total EE deferral cash value (Part II A – field 17). For an account containing both Employee and Employer contributions for a 403(b) or other related retirement plan, which cannot distinguish a separate value by money sources, the reported value should be combined into the more restrictive money source. If no value, submit as 0.00. The value of the Participant’s account, containing Employer Contributions, as of 12/31/1986. 2 12/31/86 Cash Value – ER 11.2 Numeric 12345678.12 Does not apply as no RMD coordination is required across vendors. Default entry is 0.00 Required for Plans seeking to coordinate minimum required distributions. Default entry is 0.00 This value is a subset and should be included in the total Employer Cash Value (Part II, A – field 16). For an account containing both Employee and Employer contributions for a 403(b) or other related retirement plan, which cannot distinguish a separate value by money sources, the reported value should be combined into the more restrictive money source. If no value, submit as 0.00. 18 SHAPING AMERICA’S RETIREMENT

25) D. Hardship Amount Available Data - Provide calculated hardship amount available or components, if hardship withdrawals are allowed under the plan. Hardship information reported in this section should be limited to those which have been taken within the last rolling 12 months. (Note: If no Hardships are permitted under the Plan, the best practice is to enter M in the Method of Reporting Hardship Amount Available Data field and 0.00 in the Total Hardship Amount Available field). No. Field Max Length Data Type Example Required for Plans with Minimum Features Required for Plans with Additional Features Comments The method of reporting Hardship Amount Available data. Method of Reporting Hardship Amount Available Data 1 1 Alphanumeric M or C Required Required M = Maximum hardship available reported. Note that if reporting M, each component field must still be reported as “0.00”, to maintain integrity of the record format. C = Hardship components are reported. Total Hardship Amount Available 2 11.2 Numeric 12345678. 12 Conditional, Required if a) b) c) d) are not supplied Conditional, Required if a) b) c) d) are not supplied The value of the Participant’s account available for withdrawal on account of a hardship. This amount is calculated by adding (a) 12-31-88 Cash Value-EE (field 6) (b) 12-31-88 Cash Value-ER (field 7) (c) post 12-31-88 EE contributions and subtracting (field 8) (d) post 12-31-88 4 withdrawals (field 9) If no value, submit as 0.00. 4 In the event the plan allows additional sources to be available for hardship withdrawals, these amounts can be reported in two ways: The first method is to report the aggregate amount in the “Total Hardship Amount Available” field. The reporting party can calculate this amount as necessary to address the specific needs of each plan. The second method is to add the additional source amounts to one of the components a – c (found in fields 6-8 above) 19 provided that doing so produces the correct result. SHAPING AMERICA’S RETIREMENT

26) No. 3 Field Latest Hardship Distribution Type 4 Latest Hardship Distribution Date 5 Latest Hardship Distribution Amount 6 Hardship Component a) 12/31/88 Cash Value – EE Max Length 2 8 11.2 11.2 Data Type Alphanumeric Date Format Numeric Numeric Example D or HP CCYYMM DD 12345678. 12 12345678. 12 Required for Plans with Minimum Features Required for Plans with Additional Features Comments Required; if Hardships are not allowed or not taken, enter “NO” The reason for the most recent Hardship Withdrawal C = Casualty Loss D = Disability F = Funeral HP = Home Purchase M = Medical NO = No Hardship taken in the last 12 months PF = Prevent Foreclosure T = Tuition O = Other U = Unknown Required if a Hardship Withdrawal has been taken Required if a Hardship Withdrawal has been taken The date of the most recent Hardship Withdrawal taken so the employer can implement 6 month deferral suspension. Where the participant has made multiple hardship requests, the Employer can determine if any have been distributed and reflected in the Total Hardship Amount Available figure. If no Hardship has been taken in the last 12 months, then report as NULL. Required if a Hardship Withdrawal has been taken Required if a Hardship Withdrawal has been taken Required; if Hardships are not allowed or not taken, enter “NO” Required if reporting C (in field 1 above); Conditional if reporting M Required if reporting C (in field 1 above); Conditional if reporting M The amount of the most recent Hardship Withdrawal taken. If no value, submit as 0.00. The value of the Participant’s account, containing Employee Pre-Tax or Voluntary Contributions, as of 12/31/1988. For an account containing both Employee and Employer contributions for a 403(b) or other related retirement plan, which cannot distinguish a separate value by money sources, the reported value should be combined into the more restrictive money source. If no value, submit as 0.00. If no Hardships are permitted under the plan, enter 0.00. 20 SHAPING AMERICA’S RETIREMENT

27) No. Field Max Length Data Type Example Required for Plans with Minimum Features Required for Plans with Additional Features Comments The value of the Participant’s account, containing Employer Contributions, as of 12/31/1988. 7 Hardship Component b) 12/31/88 Cash Value – ER 11.2 Numeric 12345678. 12 Required if reporting C ; Conditional if reporting M Required if reporting C; Conditional if reporting M For an account containing both Employee and Employer contributions for a 403(b) or other related retirement plan, which cannot distinguish a separate value by money sources, the reported value should be combined into the more restrictive money source. If no value, submit as 0.00. If no Hardships are permitted under the plan, enter 0.00. 8 9 Hardship Component c) Post 12/31/88 Contributions – EE Hardship Component d) Post 12/31/88 Withdrawals The value of the Participant’s post 12/31/88 Employee contributions. 11.2 11.2 Numeric Numeric 12345678. 12 12345678. 12 Required if reporting C; Conditional if reporting M Required if reporting C; Conditional if reporting M Required if reporting C; Conditional if reporting M Required if reporting C; Conditional if reporting M If no value, submit as 0.00. If no Hardships are permitted under the plan, enter 0.00. The value of the Participant’s post 12/31/88 withdrawals. Include only if above components (a, b, c) have not been reduced by these withdrawals. If no value, submit as 0.00. If no Hardships are permitted under the plan, enter 0.00. 21 SHAPING AMERICA’S RETIREMENT

28) E. Employer Contribution Restriction Grandfathering Data (for 403(b)(1) Annuity Contracts Only) No. 1 Field Contract Certificate Issue Date Max Length 8 Data Type Date Format Example CCYYMMDD Required for Plans with Minimum Features Does not apply, Blank Required for Plans with Additional Features Required for 403(b)(1) Plans with Employer contributions Comments The final 403(b) regulations require that Employer contributions not be distributable until severance from employment or prior to the occurrence of some event, such as after a fixed number of years, the attainment of a stated age, or disability. The new rule does not apply to contracts issued by an insurance company before 01/01/2009, so this issue date is needed in connection with plans that did not impose restrictions on distribution of Employer contributions that were at least as stringent as the new rule. 22 SHAPING AMERICA’S RETIREMENT

29) F. Non-Emergency Withdrawal Data (In Service Withdrawals) No. Field Max Length Data Type Example Required for Plans with Minimum Features Required for Plans with Additional Features Comments For 403(b) 1 annuity contracts, the value of the Participant’s account containing Employee Pre Tax, or Voluntary Contributions, as of 12/31/88, reduced by all post 12/31/88 distributions, if applicable.(. 1 In Service Available Cash Value For 403(b)1 and 403(b)7 contracts, any money available for In Service distributions should be added to the In Service Available Cash Value reported regardless if it is Employer or Employee money. 11.2 Numeric 12345678. 12 Required Required All grandfathered 12/31/88 balances (403(b)1 contracts) or money available for In Service distribution (403(b)1 and 403(b)7 contracts) should be reported if possible and used prior to taking a hardship distribution. If the account does not have any sources of assets available for an in service withdrawal, then the In Service Available Cash Value field should be reported as "0.00". 23 SHAPING AMERICA’S RETIREMENT

30) G. Loan Amount Available Data Note – Examples that illustrate the Best Practices methodology are available at the end of this document THE EXAMPLES WERE DEVELOPED BY THE SPARK INSTITUTE PROJECT TEAM AND ARE INTENDED SOLELY AS ILLUSTRATIONS OF HOW THE BEST PRACTICES ARE INTENDED TO OPERATE. THE EXAMPLES HAVE NOT BEEN REVIEWED, APPROVED, OR AUTHORIZED BY THE DEPARTMENT OF LABOR, TREASURY DEPARTMENT OR THE INTERNAL REVENUE SERVICE AS MEETING THE REQUIREMENTS OF ANY APPLICABLE RULES OR REGULATIONS. THE SPARK INSTITUTE DOES NOT PROVIDE LEGAL ADVICE. USERS OF THIS MATERIAL SHOULD CONSULT WITH THEIR LEGAL COUNSEL REGARDING THE APPLICABILITY OF THE EXAMPLES TO THEIR PARTICULAR SITUATIONS. The following guidelines should be followed in connection with providing the loan amount available data. The Best Practice is to provide loan data for all loans with activity or an outstanding balance in the prior 12 months. Additionally it is the best practice to include component data if it is available, regardless of how old the activity is. Provide calculated “Maximum Loan Amount Eligible at this Vendor” (“MLAE-Vendor”), subject to all IRS (IRC Section 72(p)) and Vendor Product restrictions, if any, without reducing this amount for any outstanding active or defaulted loans. If there have been any outstanding active, defaulted or paid off loans reported during the prior 12 months, then loan data must be reported for all of the loans within the Loan Component data fields, on either a detailed, loan-byloan basis or as a “SUMMARY” of all loans (active, defaulted, offset and/or paid off) during the prior 12 months. The Aggregator (or Employer if self-administering loans) should perform the calculations necessary across all vendors to determine the “Maximum Loan Amount Available-Plan” (“MLAA-Plan”). A vendor’s product restrictions may reduce this amount for accounts at that particular vendor. Loan Status Definitions Set forth below are guidelines for reporting the status of certain loans using the codes under Best Practices. However, some vendors may choose to report certain situations differently (e.g., one vendor may report an Offset Defaulted/Deemed Loan as "defaulted" while another vendor may report the same loan situation as "paid"). Please note that employment status does not impact or change loan status definitions. “A” - Active Use this code when all of the following conditions are satisfied. 1. The participant who has a loan is a participant in the plan. 2. The participant has an outstanding loan balance in the prior 12 months and is currently in the repayment phase. 24 SHAPING AMERICA’S RETIREMENT

31) 3. The participant has not died. 4. The plan has not terminated. “P” - Paid Use this code when all of the following conditions are satisfied. 1-1. An “active” loan has been fully repaid and the terms of the loan agreement have been satisfied. 1-2. The participant is a participant in the plan. 1-3. The repaid loan currently has a zero loan balance. 1-4. The loan was repaid within the last 12 rolling months. 1-5. The plan has not terminated. (Note: A paid loan should be reported for a minimum of 12 months after the loan is repaid.) OR Use this code when all of the following conditions are satisfied. 2-1. A loan that was previously considered deemed distributed is paid off in full. (assumes funding vehicle allows for repayment after tax) 2-2. The repaid deemed distributed loan currently has a zero loan balance. 2-3. The deemed distributed loan was repaid within the last 12 rolling months. (Note: A repaid deemed distributed loan should be reported for a minimum of 12 months after the loan is repaid.) “D” – Defaulted Use this code when in any of the following situations. 1. A scheduled loan payment remains past due at the end of the calendar quarter following the quarter in which the payment was originally due unless the plan has a different grace period or requirement. 2. The plan is terminated. 3. The participant retires or otherwise severs employment and does not either repay the loan in full or continue to make payments following the separation from employment. 4. The participant dies. 5. A default occurs under the terms of the loan agreement. 6. An amount remains unpaid at the end of the loan term. Additionally, it should be noted that Part II data is intended to be used to report a defaulted loan as long as the defaulted loans has an outstanding balance. Part IV data is only reported for a rolling 12 months. Defaulted loans also include all of the following situations that should be reported as “D” – Defaulted. A. Deemed Distributed A-1. The participant fails to abide by the terms of the loan agreement. A-2. The participant is not eligible for a plan distribution (e.g., an active participant under age 59 1/2). Please note that rules may vary by plan. 25 SHAPING AMERICA’S RETIREMENT

32) B. Active Deemed Distributed B-1. Conditions for Deemed Distribution under A immediately above are satisfied; B-2. The participant resumes payment of the loan; and B-3. The loan has an outstanding balance. C. Partial Offset of Defaulted/Deemed Loan C-1. The participant fails to abide by the terms of the loan agreement; C-2. The participant is eligible to receive all or part of their account as a distribution, even though a distribution does not necessarily occur (see conditions for defaulted loan above); C-3. The participant is no longer considered an active participant in the plan and the plan does not prohibit distributions upon separation from service; C-4. The offset occurred within the last 12 rolling months; and C-5. The offset loan balance is greater than zero. (Note: An offset loan should be reported for a minimum of 12 months after the loan is offset.) Special situations involving limited data available – Whenever there has been an outstanding, defaulted (including deemed distributable, offset) or paid loan during the prior 12 months loan component data fields must be reported. While the best practice is to report each loan separately, The SPARK Institute project team recognized that some vendors may be unable to separately report each outstanding, defaulted (offset) and paid-off loan. In this case, the loan data can be summarized and reported within the first (and only) set of loan component data fields, using default values as follows: 1. Number of Sets of Loan Component Data Reported = 1 2. Vendor Loan Number = “SUMMARY” (This will inform the Aggregator that the loan component data represents a summary of multiple loans, instead of a single loan.) 3. Loan Initiation Date = date of the most recently issued loan. 4. Loan Status = If any loan is defaulted (offset) during the prior 12 months, enter “D”, if all loans have been paid off during the prior 12 months, enter “P”, otherwise, enter “A”. 5. Loan Type Indicator = Enter “G” (General) unless it is known that at least one of the loans (Active, Defaulted (offset) or Paid Off) is Residential, in which case, enter “R”. 6. Original Loan Amount = total of the original loan amounts for all outstanding and/or defaulted loans. 7. Remaining Loan Balance = total remaining balances of all outstanding and/or defaulted ((offset) during the prior 12 months) loans. 8. Remaining Balance Date = Cash Value date of the account with regards to the loan balance. 9. Highest Outstanding Balance-12 Months = Aggregated sum of the highest outstanding loan balances for all outstanding, defaulted (offset) and paid off loans during the prior 12 months. Special situations involving vendors with more than 99 loans – If there are more than 99 loans and the loan reporting method is “C” for loan components, loans 1-98 should be reported as usual. For loans 99 and above, the loan data should be summarized and reported in loan number 99. Example: If a participant has 105 loans to be reported, report 1-98 individually and 99-105 as a summary in the 99th loan. 26 SHAPING AMERICA’S RETIREMENT

33) No. Field Max Length Data Type Example Required for Plans with Minimum Features Required for Plans with Additional Features Comments The method of reporting Loan data. M = the Maximum Loan Amount Eligible at this vendor will be reported as there have been no loans (Active, Defaulted (offset) or Paid Off) during the prior 12 months. 1 Method of Reporting Loan Data 1 Alphanumeric M or C Required Required C = Loan components data will be reported because there has been at least one loan (Active, Defaulted (offset) or Paid Off) during the prior 12 months. Although it is preferred to report loan component data for each loan separately, the data format allows a Vendor to summarize loan component data for all loans into a single set of loan components. If no Loans are permitted under the Plan, enter M and default values for other fields 27 SHAPING AMERICA’S RETIREMENT

34) No. Field Max Length Data Type Example Required for Plans with Minimum Features Required for Plans with Additional Features Comments Data Aggregators may use the Maximum Loan Amount Eligible –Vendor (MLAE) amounts in place of the reported cash value amounts to calculate the Maximum Loan Amount Available (MALA). The Maximum Loan Amount Eligible – Vendor (MLAE) should take into consideration all IRS (IRC Section 72(p)) and Vendor product rules. A Vendor may have more restrictive product rules in place which may result in a lower available loan amount than IRC Section 72(p) permits. 2 Maximum Loan Amount EligibleVendor 11.2 Numeric 12345678.12 Required Required Do not reduce the MLAE amount for outstanding loan balanced (active and defaulted loans). The Vendor must always include the remaining loan balance amounts reported in the loan component fields for all Active and Defaulted loans when calculating the MLAE-Vendor amount. The MLAE – Vendor amount should never exceed the IRC Section 72(p) maximum loan limit of $50,000. If the participant is not eligible for a loan and does not have any outstanding Active or Defaulted loans the MLAE – Vendor amount should be submitted as $0.00 . 3 Separation from Service Date 8 Date Format CCYYMMDD Optional Optional The date the participant separated from service. NOTE: This field was previously a filler field from prior versions of the Best Practices and has been leveraged for a new purpose so as to minimize changes to the file format. 28 SHAPING AMERICA’S RETIREMENT

35) No. 4 Field Number of Loans Outstanding Max Length 2 Data Type Numeric Example 2 or 10 Required for Plans with Minimum Features Required Required for Plans with Additional Features Required Comments Number of Outstanding “Active” and “Defaulted” Loans . If none, submit a 0. If there are any Outstanding (or Defaulted) Loans, then this field must be greater than 0 and less than 100. The product name/ identification used by the Investment Provider. The coding/decoding of the values should be provided by the Investment Provider. 5 6 Product ID Loan Default Indicator 11 1 Alphanumeric Alphanumeric CreativePro Y or N Optional Required Optional Required NOTE: This field was previously a filler field from prior versions of the Best Practices and has been leveraged for a new purpose so as to minimize changes to the file format. This field has changed from Numeric 11.2 to Alphanumeric 11. For loans or contracts issued after 01/01/2004, indicate whether there is currently an outstanding defaulted Loan for the account. If Number of Loans Outstanding is 0, enter “N” If the Method of Reporting is M, then submit 0 to indicate that no loan component data will follow. 7 Number of Sets of Loan Component Data Reported 2 Numeric 02 Required if Reporting Method is C Required if Reporting Method is C If the Method of Reporting is C, this value represents the number of sets of Loan component data which follow. Note that a number of loans can be summarized and reported in a single set of Loan component data, in which case, enter “1”. If the Method of Reporting is C, this number must be greater than 0 and not more than 99. 29 SHAPING AMERICA’S RETIREMENT

36) No. Field Max Length Data Type Example Required for Plans with Minimum Features Required for Plans with Additional Features Comments Loan Number as defined by the Vendor. Vendor Loan Number 5 Component 8 9 Loan Initiation Date 3 Component Loan Status 3 Component 10 11 Loan Type Indicator 63 Component 20 8 1 1 Text Date Format Text Text Varies Conditional, Required if Method of Reporting is “C” Conditional, Required if Method of Reporting is “C” CCYYMMDD Conditional, Required if Method of Reporting is “C” Conditional, Required if Method of Reporting is “C” A, P or D G or R Conditional, Required if Method of Reporting is “C” Conditional, Required if Method of Reporting is “C” Conditional, Required if Method of Reporting is “C” Conditional, Required if Method of Reporting is “C” If loan data has been summarized for all loans (Active, Defaulted (offset) and/or Paid Off), then enter “SUMMARY” to let Aggregators know that only one set of loan components are reported for multiple loans. Original Date the loan was taken on this account. If “SUMMARY” loan data is reported, enter the date of the most recently issued loan. Status of loan as last reported from the Investment Provider. (A) Active, (P) Paid or (D) Defaulted. Paid or “offset” loans must be reported for 12 months following the paid-off or offset date. If SUMMARY loan data is reported, enter as follows: enter “D” If any loan is defaulted, or offset in the last 12 months, enter “P”, if all loans have been paid off in the last 12 months, otherwise enter “A”. (G) General or (R) Residential. If SUMMARY loan data is reported enter as follows: Enter “G” unless it is known that at least one of the active or defaulted, offset or paid off in the last 12 months loans (if any) is Residential, in which case, enter “R”. 5 If Loan Component data is reported, then all loan component fields should repeat for every Outstanding (Active and/or Defaulted) loan and any Loan Paid Off or offset in the last 12 months. 3 If Loan Component data is reported, then all loan component fields should repeat for every Outstanding (Active 30 and/or Defaulted) loan and any Loan Paid Off or offset in the last 12 months. SHAPING AMERICA’S RETIREMENT

37) No. Field Original Loan Amount 3 Component 12 Max Length 11.2 Data Type Numeric Example Required for Plans with Minimum Features Required for Plans with Additional Features 12345678.12 Conditional, Required if Method of Reporting is “C” Conditional, Required if Method of Reporting is “C” Comments Amount initially taken. If SUMMARY loan data is reported, enter the total of the original loan amounts for all outstanding and/or defaulted, offset or paid off loans in the last 12 months. Current loan balance (principal and interest). Remaining Loan Balance 3 Component 13 11.2 Numeric 12345678.12 Conditional, Required if Method of Reporting is “C” Conditional, Required if Method of Reporting is “C” The principal and all outstanding interest as of the valuation date should be included in the amount reported. Interest or fees that may be charged in the future should NOT be included If SUMMARY loan data is reported, enter the total remaining balances (principal and interest) of all outstanding and/or defaulted loans. Remaining Balance 14 3 Date Component 8 Date Format CCYYMMDD Conditional, Required if Method of Reporting is “C” Conditional, Required if Method of Reporting is “C” Cash Value Date of account with regards to loan data. The highest outstanding balance of the loan over the past 12 month period. 15 Highest Outstanding Loan Balance-12 Months 3 Component 3 11.2 Numeric 12345678.12 Conditional, Required if Method of Reporting is “C” Conditional, Required if Method of Reporting is “C” If SUMMARY loan data is reported, enter the aggregated sum of the highest outstanding loan balances for all outstanding, defaulted, offset or paid off loans during the last 12 months. If Loan Component data is reported, then all loan component fields should repeat for every Outstanding (Active 31 and/or Defaulted) loan and any Loan Paid Off or offset in the last 12 months. SHAPING AMERICA’S RETIREMENT

38) PART III Data Sharing Elements for Employer or Employer Representative (Aggregator) Census and/or Remittance Detail Records to be shared with Vendors Part III has been removed from the Data Elements Best Practices document as part of the changes made in Version 1.04. The Census and Remittance Best Practices are addressed in a new document entitled “Best Practices for Multiple Vendor Plans Remittance and Census Data Elements.” The document is available on The SPARK Institute website at the following address: http://www.sparkinstitute.org/comments-and-materials.php 32 SHAPING AMERICA’S RETIREMENT

39) PART IV Data Sharing Elements for Employer or Employer Representative (Aggregator) Distributions Made by Vendors 1. Information reported under this Part IV should be for a rolling 12 months period (i.e., the 12 months prior to the Valuation Date (Business Process Date) on the Header record). 2. For Part IV data, each distribution should be reported separately, including multiple distributions for the same participant. For example, a participant that received three In Service Withdrawals in one day should be reported with three distinct distribution detail records. Similarly, if a distribution was processed and reversed within the same reporting period, the vendor has two options based on the provider and aggregator’s preferences and capabilities. One is to report both the original distribution and its reversal. The alternative is to report neither as the net effect is that the distribution did not occur in the reporting period. 3. Distribution Reason Codes are only required for Hardship Distributions. distributions the Distribution Reason Code should be reported as NULL. For all other 4. The following transactions types should not be included in Part IV: a. Return of Contributions b. Excess Deferrals c. Account Fees (for example, account-based charges such as a $25 annual account fee, asset-based charges such as a 25 basis points fund level wrap fee, and TPA fees that are deducted directly from an account). d. . 5. The following commonly used transaction types can be included in Part IV and classified as follows: a. Participant Annuitization should be classified as a Distribution Type ‘06’ - Separation of Service. b. Service Credits if agreed to by the aggregator, vendors and plan sponsor, should be Distribution Type ‘03’ - In Service Withdrawal. c. Intra-plan transfers between providers of the same employer should be classified as a Distribution Type ‘01’ - (Contract) Exchange. d. For Plan to plan transfers, the more common Distribution Types that may be used are "01" Contract Exchange; "03" In Service Withdrawal and "06" Separation from Service. If the reporting party has an established practice for how it classifies plan to plan transfers, it should notify the receiving party. 6. If vendor providing data does not have enough detail to break out QDROs and RMDs then use the following, otherwise provide the detail for each item as a separate Distribution Type. a. Qualified Domestic Relations Orders would be classified as a Distribution Type ‘03’ - In Service Withdrawal. b. Required Minimum Distributions would be classified as a Distribution Type ‘06’ Separation of Service. 33 SHAPING AMERICA’S RETIREMENT

40) 7. Distribution amounts are reported as gross amounts and as positive numbers. The only exception is the reversal of a distribution that should be reported as a negative number. For example, a $45,000 distribution should be reported as 45000.00. 8. The distribution data to be included applies to 403(b) plans as well as any associated plans including 401(a), 401(k), 457, etc. Reminder: The Valuation Date (Business Process Date) should be used when determining which distributions should be reported in the rolling 12 months or other reporting period. The Trade Date should not be used for reporting this information. 34 SHAPING AMERICA’S RETIREMENT

41) A. Distributions Made by Vendors Data No. 1 Field Aggregator Plan ID Max Length 20 Data Type Alphanumeric 2 Employer Plan ID 20 Alphanumeric 3 Vendor Plan ID 20 Employee SSN 9 Numeric Required/ Optional Comments Varies Conditional, Required if Employer Plan ID is not present The identifier used by the Aggregator (if any) to identify the Plan. AB1234567001 Conditional, Required if Aggregator Plan ID is not present Plan ID used by the Employer to uniquely identify the Plan. May be the same as the Aggregator Plan ID. Optional at discretion of Vendor The Plan ID used by the vendor to identify the Plan. Alphanumeric 4 Example 5 6 Employee Account Number Vendor Transaction Number 25 20 Alphanumeric Alphanumeric 123456789 Varies G0001200832 Required Conditional, if multiple Accounts within the same Plan Optional, at discretion of Vendor Employee specific account/ contract number at the Vendor. This is the Participant’s contract or account number at the Vendor level. Participants may have more than one account or contract with the same Vendor. This field is needed in order to properly reflect the account values at the contract level. A unique identifier of this Distribution transaction at the Vendor’s discretion. 7 Distribution Type 2 Numeric 02 Required Type of Distribution Made 01 – (Contract) Exchange 02 – Hardship Withdrawal, (including HEART withdrawals) 03 – In Service Withdrawal 04 – Loan 05 – Rollover 06 – Separation from Service 07 – Death 08 – Disability 09 – Required Minimum Distribution (RMD) 10 – Qualified Domestic Relations Order (QDRO) 8 Distribution Date 8 Date Format CCYYMMDD Required Trade date of the distribution. 35 SHAPING AMERICA’S RETIREMENT

42) No. Field Max Length Data Type Example Required/ Optional Comments The Gross amount of the Distribution made. (Amount prior to any fees, charges or taxes.) 9 Distribution Amount 11.2 Numeric 5000.00 or -5000.00 Required Reversals of distributions are identified by a negative (-) sign that precedes the leading digit of the distribution amount. If no value submit as 0.00 10 Distribution Reason 2 Alphanumeric HP Conditionally Required when Distribution Type = ‘02’ The reason for this distribution C = Casualty Loss D = Disability F = Funeral HP = Home Purchase M = Medical PF = Prevent Foreclosure T = Tuition O = Other U = Unknown If a Specific Distribution Reason is not known and Distribution Type = Hardship - ‘02’, submit as ‘U’ Null Value for any other Distribution Type other than Hardship - ‘02’ 11 Vendor Source ID 20 Alphanumeric Varies Optional The identifier used by the Aggregator (if any) to identify the Vendor. 36 SHAPING AMERICA’S RETIREMENT

43) APPENDIX A To The Best Practices for 403(b) and Related Plans Information Sharing Version 1.04 (Updated on July 31, 2015) VERSION CONTROL LOG Version Description Date Published Page Reference 1.00 Initial version 05/7/08 n/a 1.01 Version including DTCC specific fields and protocols 07/10/08 n/a 1.02 Technical corrections and DTCC related changes Description of Revisions Revisions related to: 1) DTCC planned information sharing services 2) Cosmetic and mechanical corrections. Revisions related to: 1) DTCC postponement of information sharing services. 2) Revisions and clarifications in response to questions from vendors/TPA’s, as identified below. 10/29/08 Version 1.01 pages affected: ii, iii, iv, 1, 2,3,5,6,22,29, 30, Exhibit A Removed references to DTCC data fields, Header/Trailer records and processing. Page 4 Updated SPARK Institute Best Practices version number. Page 8 Clarification of GROSS vs. NET Cash Value Type. Page 10 Clarification that separate reporting of 403(b)(7) Cash Value is only for account type “008” (combined 403(b)(1) and 403(b)(7) plans). Page 11 Addition of Account Type “009” for church plans. Page 14 Clarification of Hardship reporting. 37 SHAPING AMERICA’S RETIREMENT

44) Version Description Date Published Page Reference Pages 18-23 Description of Revisions Section G: Loan Data 1) Clarification to reporting Loan Data 2) Reporting Loans in SUMMARY format 3) Two data fields originally defined are now identified as Filler1 and Filler2 as the data they represent will be available within the loan component data fields. “Filler” data elements reported as “NULL” have been specified to maintain the original file format. Page 24 Header record for Part III data. Data Type = 04-Remittance-Census Data. Page 25 Correct format of Payroll Date. Pages 26, 28 Clarify use of Marital Status on Census and Remittance-Census Data. Page 27 Correct Header record for Part III Remittance data, Data Type = 03-Census Data. Page 29 Correct Employee Account Number to 25 characters. Page 30 Addition of “Vendor Source ID” data element to Part IV “Distributions Made” data. Pages 31-32 1.03 Technical corrections Addition of Appendix A - Version Control Log. Revisions and clarifications in response to questions from vendors/TPAs, as identified below. A few cosmetic changes to properly capitalize data field names were also made but not listed below. 12/05/08 Page iii Summary of version 1.03 changes. Page 4 Record type 04 is both Remittance and Census data. Page 4 Updated SPARK Institute Best Practices version number. Page 7 Clarification that the Vendor Plan ID may be the same as the Aggregator Plan ID if that vendor also serves as the Aggregator for the plan. 38 SHAPING AMERICA’S RETIREMENT

45) Version Description Date Published Page Reference Description of Revisions Page 10 Renamed Roth 403(b) Cash Value to Roth Cash Value and clarified usage. Page 10 Cosmetic change; substituted “Post-Tax” for “After tax” in “required for” columns. Page 10 Renamed 403(b)(7) Cash Value to 403(b)(7) Employer Cash Value and clarified its usage. Noted that this field is excluded when calculating the total cash value of the account (since the amount is already included in the Employer Cash Value field). Page 14 Inserted clarification that Hardship information reported is limited to hardships taken within the last 12 months. Page 21 Clarification as to how the “Date of the Last Loan Distributed” can be determined from the most recent of the Loan Initiation dates reported within the Loan component data. Page 24 Clarification that Data Type = “04” contains Remittance and Census data. Revisions and clarifications in response to questions from vendors/TPAs, as identified below. 1.04 Technical Corrections 06/30/09 Title Page Cosmetic changes to properly capitalize data field names were also made but not listed below, Part IV changes as well. Made change to title to add Related Retirement Plans. Page i Deleted Background section and modified Overview. Referenced Removal of Part III. Page ii Added Summary of Version 1.04 changes. Page iii Reordered the Version Summaries from most recent to older. Page iv Modified Table of Contents to Remove Part III and reflect pages of current changes. 39 SHAPING AMERICA’S RETIREMENT

46) Version Description Date Published Page Reference Description of Revisions Added definition around Surrendered or Closed Contracts. Page 1 Added Clarification of Participant data with zero balances. Added description about sending files with no activity. Page 2 Addition of parameters and standards around file naming conventions. Page 3 Added clarification to reversal process. Provided clarification of record type identification process. Page 4 Added comments about when Vendors are sharing data for more than one employer. Page 5 Added information about data records stating each should be provided on a separate line. Renamed the constant value for Header field on the Header record. Page 6 Updated Best Practices version number. Added additional field to end of Header Record for Valuation Date. Page 7 Renamed the constant value for the Trailer field on the Trailer record. Renamed Employer Account # to Employee Account Number. Page 9 Clarified that the Employee Account Number should be unique per Plan. Pages 11,15, 17, 18 Cosmetic changes; added “other related retirement” in the comments sections. Page 13 Cosmetic changes; capitalized values for 01A and 01K in comments section for Type of Account. Page 18 Added Component (a) to comments section for what to include in Hardship Component d) Post 12/31/88 Withdrawals. 40 SHAPING AMERICA’S RETIREMENT

47) Version Description Date Published Page Reference Description of Revisions Renamed the 12/31/88 Cash Value – EE to In Service Available Cash Value. Page 20 Added clarification around the field to include any money available for In Service distribution prior to taking a hardship. Section G: Loan Data Pages 21, 22 Added Loan Status definition to provide additional clarification around how each should be populated. Provided clarifications around Defaulted Loans. Page 23 Pages 24,25 Cosmetic changes including references to Deemed distributable and offset loans. Corrected the Maximum Loan Amount EligibleVendor comments to remove overriding logic for frequency and Loan restrictions. Added Maximum Loan Eligible Cap comment. Pages 26, 27 Cosmetic changes; added offset language and last 12 months language in comments sections. Page 28 Provided clarification in comments section for Remaining Balance Date Component. Page 29 Reference the Removal of Part III to a separate Best Practices document. Added a Summary of the additional transactions type included in Part IV and classification of existing transaction types. Page 30 Specified the rolling 12 months requirement for the data to be sent. Added comment about how Part IV distribution data should be reported separately. 41 SHAPING AMERICA’S RETIREMENT

48) Version Description Date Published Page Reference Description of Revisions Addition of Transaction codes for the Distribution Type field in the comments section. Pages 31-32 Specified that the distribution date should be the trade date of the distribution in comments section. Modified the Comments section for Distribution Reason. 1.04 Updated Feb. 14, 2011 Updates related to file transmission frequency, Daily Delta Files and technical corrections/ clarifications Feb. 14, 2011 Title Page Cosmetic changes and added updated version and release dates. Page i Updated general information. Page ii Added Summary of Version 1.04 Update, including making weekly file feeds the industry standard and introducing the “Daily Delta” file sharing method. Page iii Added reference to move of Prior Version Changes to a new Appendix B. Updated Effective Date. Page v Added Appendix B to Table of Contents. Page 1 Added note that this update establishes that the best practice for data transmission has changed from monthly to weekly. Added reference to “Daily Delta” file. Pages 2-3 Added: - Clarifications from Q&A - Added file naming value for Daily Delta files - Defined Daily Delta file process Page 4 Added reference to populating certain “Optional” fields. Page 6 Began identifying each field within each record with a number for reference purposes. Pages 14-15 Changed case of codes for Type of Account from 01A to 01a and 01K to 01k. Added clarification to contribution fields that these are gross contributions not net (from Q&A). Page 23 Added clarification from Q&A for vendors with more than 99 outstanding loans. Page 25 Changed Filler 1 to Separation from Service Date (#3) as outlined in prior Q&A. 42 SHAPING AMERICA’S RETIREMENT

49) Version Description Date Published Page Reference Description of Revisions Page 26 Changed Filler 2 to Product ID (#5) and format from 11.2 numeric to 11 Alphanumeric as outlined in prior Q&A. Page 31 Added point 7 in response to a prior Q&A. Pages 32-33 Added clarification to comments for Distribution Type and Distribution Amount from prior Q&A. Page 34 Page 41 1.04 Updated ________ Updates related to the incorporation of Q&A Information into the 1.04 Format Added updated version and release dates. Added Appendix B – Summary of Prior Version Changes. Added clarifications from Q&A regarding associated plans of the employer and 1099’s Date TBD Page i Modified paragraph to clarify providers’ responsibilities regarding allowable distributions Page ii Added clarifications from Q&A regarding data transmission security Page iii Added clarifications from Q&A regarding Version Control Log Updated The SPARK Institute contact information Page iv Page v Updated Table of Contents to include Schedule I Page 1 1. and 2.In General File Layout Conventions, inserted additional information from the Q&A on how to code a pipe delimited file Page 2 Page 2-3 Page 3 4. Added “should be included.” 5.b. Clarification of what represents a fully surrendered active account. 7. Inserted information from the Q&A to clarify acceptable file extensions. 8.d. Incorporated clarifying comments related to new participant accounts 10. Inserted information from the Q&A clarifying how to report fields without values 11. New paragraph. Inserted information from the Q&A clarifying required fields 13. Removed conflicting directions in the document 14. Inserted information from the Q&A clarifying how to report a Null Optional field, Page 4 15 Modified language concerning the requirement to populate optional fields 16. Inserted information from the Q&A concerning how to report values that are less than maximum length with additional examples of valid and invalid values 43 SHAPING AMERICA’S RETIREMENT

50) Page 5 17. Inserted information from the Q&A clarifying the use of numeric characters for distribution amounts. B. 2. Added paragraph headers for clarification purposes 4. Added Note. Inserted information from the Q&A regarding file submission standards Page 6 Part II Introduction Page 8 Page 9 5. Added Note. Inserted information from the Q&A clarifying separation of participant records in the file. Rewording to clarify Part II full file frequency requirement. Added Note. Information about Cash Values originally in the multiple fields but moved to introduction to make it more visible. Incorporated Q&A into field description comments for field 6 aggregator plan id.. Page 10 Incorporated Q&A into field description comments for field 14 date of birth. Page 11 Incorporated Q&A into field description comments for field 15 cash value type. Page 11 Incorporated Q&A into footnote related to field 15 cash value type. Page 12 Incorporated Q&A into field description comments for field 16 employer cash value. Page 13 Page 13-14 Page 15 Page 15 Incorporated Q&A into field description comments for field 17 ee deferral cash value. Incorporated Q&A into field description comments for fields 18 through 22, cash value types. Incorporated Q&A into field description comments for field 24 403(b)(7) employer cash value. Incorporated Q&A into field description comments for field 25 cash value date. Page 15 Incorporated Q&A into field description comments for field 26 type of account. Page 17 Fields 1 & 2 - 12/31/86 Cash Value – EE and ER: Added clarification from Q&A Page 17 Page 18 Page 18 Page 19 Page 19-20 Page 22 Modified Reporting Requirement for Plans with Minimum Features to clean up inconsistency Moved note about use of “M” reporting method from field 1 to Introduction to improve visibility of direction to users Field 2 - Total Hardship Amount Available: Added references to specific fields to improve definitions New Footnote added to incorporate Q&A info. Field 4 – Latest Hardship Distribution Date: confirmed reporting period for hardships Fields 4 – 9 – Hardship Information • Modified Required Field status for purpose of improving clarity • Added comment about data input if hardships are not permitted under the plan Field 1 – In Service Available Cash Value : Modified comment to incorporate Q&A info 44 SHAPING AMERICA’S RETIREMENT

51) 1. 23 - 30 Incorporated ‘Loan Examples’ into the Best Practices document, removing reference to examples held separately on the SPARK Institute website. 2. 27 30 32 32 32 32 32 33 33 Pages 46-53 Pages 49-52 Page 53 Incorporated Q&A into field descriptions and comments. Field 2: Additional clarification added regarding calculation of Maximum Loan Amount Eligible per Vendor Field 13: Updated definition of Remaining Loan Balance Component 2. updated to add Q&A information regarding how to report multiple distributions and reversals for Part IV. 4c. updated to add Q&A information regarding definition of account fees. 4d. Removed Item regarding Service Credits as it is now covered under Item 5b Clarified Item 5b to include service credits if agreed to by receiving party. Added clarification and definition to 5c and 5d from the Q&A regarding Intra-plan transfers, Exchanges, Plan-to-Plan transfers, In Service Withdrawals, and Separation of Service distribution types and reporting. Clarified item 7 to include that distribution amounts are to be reported as Gross Added a new Item 8. Inserted Q&A information to define what plan types should be included Part IV distribution data. Incorporated Schedule I – Examples for Reporting Loan Amount Available Data Schedule I pulled from existing document on SPARK Institute website and inserted in the Best Practices document to provide clarification for plan vendors reporting MLAE as well as aggregator calculation of MLAA Removed specific dates and replaced with mmddyyyy and year number to reference point in time for examples 2-5 in Schedule I Added Clarification from Q & A For Reporting Maximum Loan Amount Eligible Vendor field Copyright © 2007- 2011, The SPARK Institute, Inc. 45 SHAPING AMERICA’S RETIREMENT

52) APPENDIX B To The Best Practices for 403(b) and Related Plans Information Sharing Version 1.04 (Updated on July 31, 2015) SUMMARY OF PRIOR VERSION CHANGES Version 1.04 Changes (Released June 30, 2009) - This latest 1.04 version incorporates content from the 403(b) Plans Information Sharing Data Elements Questions & Answers (listed separately on The SPARK Institute web site) to ensure that the Best Practices are updated with the most recent technical information. In addition, certain terms and definitions were clarified to improve data consistency and common understanding among users Version 1.04 Changes (Released June 30, 2009) - In response to questions that were raised regarding the labeling of the “Distribution Types and Reasons” fields, The SPARK Institute determined that it was necessary to recognize additional Distribution Types and clarify the Distribution Reasons. Accordingly, Version 1.04 of the Best Practices added four additional Distribution Types: Deaths, QDROs, Disability and RMD (Required Minimum Distribution). Additionally, The SPARK Institute took the opportunity to insert text relating to the rolling 12 months rule (for all distribution data) that previously was not expressly stated for Part IV data. Part III was removed. Several other minor clarifications to Part II and IV were made in response to questions. The changes are identified in the Version Control Log. Version 1.03 Changes - In response to additional questions that have been raised relating to the labeling of the “Rollover Roth Cash Value” and “Roth 403(b) Cash Value” fields, The SPARK Institute determined that it was necessary to rename the field previously called “Roth 403(b) Cash Value” to “Roth Cash Value” and clarify its definition. Clarification has also been made by renaming the “403(b)(7) Cash Value” field to “403(b)(7) Employer Cash Value” and revising the description and pointing out that this field is a subset of the “Employer Cash Value” field and should be excluded when determining the overall cash value of the account. The file structure for Part II of the guidelines remains unchanged. Additionally, The SPARK Institute inserted text relating to the rolling 12 months rule (for reporting Hardship Data) that was inadvertently omitted in Part II, Section D. A few other minor clarifications were included in response to industry Q&As. See the Version Control Log. Version 1.02 Changes - On May 7, 2008, The SPARK Institute released the initial version of the Best Practices and on July 10, 2008 an updated version was released to include data fields and approaches in order to accommodate a planned DTCC information sharing service and several other corrections. As vendors started making system changes, The SPARK Institute received a number of questions requesting clarifications regarding the intended use and values of the data elements. The SPARK Institute established a panel of member companies to review and respond to the questions and created a website in order to broadly communicate the questions and answers. Version 1.02 was released to reflect changes that the panel considered necessary or beneficial as a result of the questions we received, and to remove DTCC specific items. A Version Control Log was added as Appendix A. Examples regarding the intended methodology for vendor reported loan data are available on The SPARK Institute website (see Part II, Section G herein). 46 SHAPING AMERICA’S RETIREMENT

53) SCHEDULE I Best Practices for 403(b) Plans Information Sharing EXAMPLES FOR REPORTING LOAN AMOUNT AVAILABLE DATA Note – These examples, and any updates are posted on The SPARK Institute website under the 403(b) Plans Materials Section of the Comments and Materials page, which is located at the following web address. Any updates or revisions will be posted on the website as necessary. http://www.sparkinstitute.org/comments-and-materials.php The following guidelines should be followed in connection with providing the loan amount available data. Provide calculated “Maximum Loan Amount Eligible at this Vendor” (“MLAE-Vendor”), subject to all IRS (IRC Section 72(p) and Vendor Product restrictions, if any, without reducing this amount for any outstanding active or defaulted loans. If there have been any outstanding, defaulted or paid off loans during the prior 12 months, then loan data must be reported for all of the loans within the Loan Component data fields, on either a detailed, loan-by-loan basis or as a “SUMMARY” of all loans (Active, Defaulted and/or Paid Off) during the prior 12 months. If there are more than 99 loans to be reported, then provide loan-by-loan detail for the first 98 and one set of SUMMARY data for all of the other loans as the 99th occurrence. The Aggregator (or Employer if self-administering loans) should perform the calculations necessary across all vendors to determine the “Maximum Loan Amount Available-Plan” (“MLAA-Plan”). A vendor’s product restrictions may reduce this amount for accounts at that particular vendor. Please note that the vendor should not over-ride the calculated Maximum Loan Amount EligibleVendor (MLAE-Vendor) amount if there are product rules which would otherwise prohibit a loan (e.g., when the plan rules limit the number of outstanding/defaulted loans and the 47 SHAPING AMERICA’S RETIREMENT

54) participant account has reached the number of loans limit, or if the product restricts taking a new loan within a certain period of time of an earlier outstanding/defaulted loan). In these cases, the calculated Maximum Loan Amount Eligible-Vendor amount should be calculated according to IRS and plan rules and reported without any adjustment. If there have been any outstanding, defaulted or paid loans during the prior 12 months, then loan component data fields must be reported. While the best practice is to report each loan separately, the project team recognized that some vendors may be unable to separately report each outstanding, defaulted, or paid-off loan. In this case, the loan data can be summarized and reported within the first (and only) set of loan component data fields, using default values as follows: • • • • • • • • • Number of Sets of Loan Component Data Reported = 1 Vendor Loan Number = “SUMMARY” (This will inform the Aggregator that the loan component data represents a summary of multiple loans, not just one loan.) Loan Initiation Date = date of the most recently issued loan. Loan Status = If any loan is defaulted, enter “D”, if all loans have been paid off during the prior 12 months, enter “P”, otherwise, enter “A”. Loan Type Indicator = Enter “G” (General) unless it is known that at least one of the loans (Active, Defaulted or Paid Off) is Residential, in which case, enter “R”. Original Loan Amount = total of the original loan amounts for all outstanding and/or defaulted loans. Remaining Loan Balance = total remaining balances of all outstanding and/or defaulted loans. Remaining Balance Date = Cash Value date of the account. Highest Outstanding Balance-12 = Aggregated sum of the highest outstanding loan balances for all outstanding, defaulted and paid off loans during the prior 12 months. Summary of December 5, 2008 Revisions The following changes have been made to the examples that were posted on November 10, 2008: 1) Data element name changes for the following Cash Value fields a. Cash Value 8. Roth Cash Value b. Cash Value 9. 403(b)(7) Employer Cash Value 2) Clarification that the 403(b)(7) Employer Cash Value is always excluded when determining the cash value of the account as the 403(b)(7) Employer Cash Value is a subset of the Employer Cash Value. * * * * * THE EXAMPLES WERE DEVELOPED BY THE SPARK INSTITUTE PROJECT TEAM AND ARE INTENDED SOLELY AS ILLUSTRATIONS OF HOW THE BEST PRACTICES ARE INTENDED TO OPERATE. THE EXAMPLES HAVE NOT BEEN REVIEWED, APPROVED, OR AUTHORIZED BY THE DEPARTMENT OF LABOR, TREASURY DEPARTMENT OR THE INTERNAL REVENUE SERVICE AS MEETING THE REQUIREMENTS OF ANY APPLICABLE RULES OR REGULATIONS. THE SPARK INSTITUTE DOES NOT PROVIDE LEGAL ADVICE. USERS OF THIS MATERIAL SHOULD CONSULT WITH THEIR LEGAL COUNSEL REGARDING THE APPLICABILITY OF THE EXAMPLES TO THEIR PARTICULAR SITUATIONS. Copyright © 2008, The SPARK Institute, Inc. 48 SHAPING AMERICA’S RETIREMENT

55) EXAMPLE 1. DESCRIPTION - VENDOR A No loans have ever been taken for this account, there are no additional Plan, Product, or Fund loan restrictions. In order for the Aggregator to determine the “Maximum Loan Amount Available – Plan”, Vendors must report Cash Values, Maximum Loan Amount Eligible-Vendor (MLAE) and other loan data as applicable. The MLAE is calculated by the Vendor applying all IRC (72(p) and Vendor Product restrictions only; the MLAE amount is NOT reduced by any outstanding active or defaulted loan balances. PART II-Section A: Account Data Cash Value Data Elements 1. Cash Value Type 2. Employer Cash Value 3. EE Deferral Cash Value 4. Rollover EE Pre-Tax Cash Value 5. Rollover EE Post-Tax Cash Value 6. Rollover Roth Cash Value 7. EE Post-Tax Cash Value 8. Roth Cash Value (acct type 008) 9. 403(b)(7) Employer Cash Value* Vendor Calculation of MLAE-Vendor G $40,000 $30,000 50% of total CV always excluded Total Account Cash Value = $70,000 PART II-Section G: Loan Data Data required for all accounts 1. Method of Reporting Loan Data M 2. Maximum Loan Amount Eligible-Vendor $35,000 3. Filler 1 – no longer used NULL 4. Number of Loans Outstanding 0 5. Filler 2 – no longer used NULL 6. Loan Default Indicator N 7. Number of sets of Loan Component Data 0 Loan Component Data fields when the account has had any loan (Active, Defaulted or Paid Off) during the prior 12 months C-1. Vendor loan number C-2. Loan Initiation Date C-3. Loan Status no Loan C-4. Loan Type Indicator Component Data C-5. Original Loan Amount is reported when C-6. Remaining Loan Balance Method of C-7. Remaining Balance Date reporting is “M” C-8. Highest Outstanding Loan Balance-12 months Total Remaining Balances = $0 Total Highest Outstanding Loan Balance-12 months = $0 MLAE-Vendor $35,000 Impact on Aggregator’s Calculation of MLAA-Plan 49 SHAPING AMERICA’S RETIREMENT

56) EXAMPLE 2. DESCRIPTION - VENDOR B The participant’s account at Vendor B has had one loan, originally issued on mm/dd/yyy (Year 1) in the amount of $10,000. This loan was paid off during Year 3 and had $3,000 as its highest outstanding loan balance during the last 12 months. In order for the Aggregator to determine the “Maximum Loan Amount Available – Plan”, Vendors must report Cash Values, Maximum Loan Amount Eligible-Vendor (MLAE) and other loan data as applicable. The MLAE is calculated by the Vendor applying all IRC (72(p) and Vendor Product restrictions only; the MLAE amount is NOT reduced by any outstanding active or defaulted loan balances. PART II-Section A: Account Data Cash Value Data Elements 1. Cash Value Type 2. Employer Cash Value 3. EE Deferral Cash Value 4. Rollover EE Pre-Tax Cash Value 5. Rollover EE Post-Tax Cash Value 6. Rollover Roth Cash Value 7. EE Post-Tax Cash Value 8. Roth Cash Value (acct type 008) 9. 403(b)(7) Employer Cash Value* Vendor Calculation of MLAE-Vendor G $20,000 $20,000 50% of total CV No reduction in MLAE-Vendor is made due to a loan during the last 12 months. always excluded Total Account Cash Value = $40,000 PART II-Section G: Loan Data Data required for all accounts 1. Method of Reporting Loan Data C 2. Maximum Loan Amount Eligible-Vendor $20,000 3. Filler 1 – no longer used NULL 4. Number of Loans Outstanding 0 5. Filler 2 – no longer used NULL 6. Loan Default Indicator N 7. Number of sets of Loan Component Data 1 Loan Component Data fields when the account has had any loan (Active, Defaulted or Paid Off) during the prior 12 months C-1. Vendor loan number Loan B-1 C-2. Loan Initiation Date mm/dd/yyyy (Year 1) C-3. Loan Status P C-4. Loan Type Indicator G C-5. Original Loan Amount $10,000 C-6. Remaining Loan Balance $0.00 C-7. Remaining Balance Date mm/dd/yyyy (Year 3) C-8. Highest Outstanding Loan Balance-12 months $3,000 Total Remaining Balances = $0 Total Highest Outstanding Loan Balance-12 months = $3,000 MLAE-Vendor $20,000 Impact on Aggregator’s Calculation of MLAA-Plan Despite the fact that there are no outstanding/defaulted loans on the date the data is being reported, there has been an outstanding loan during the last 12 months. This would impact the Aggregator’s calculation on MLAAPlan and must be reported. 50 SHAPING AMERICA’S RETIREMENT

57) EXAMPLE 3. DESCRIPTION - VENDOR C The participant’s account at Vendor C has two outstanding loans which have a total outstanding balance of $6,000; the vendor is unable to provide loan detail for each loan but knows that the most recently issued loan was issued on mm/dd/yyyy (Year 1) in the amount of $8,000 and the earlier loan was originally issued for $10,000. Neither loan was residential. The Highest Outstanding Loan Balance during the last 12 months for both loans was $12,000. In order for the Aggregator to determine the “Maximum Loan Amount Available – Plan”, Vendors must report Cash Values, Maximum Loan Amount Eligible-Vendor (MLAE) and other loan data as applicable. The MLAE is calculated by the Vendor applying all IRC (72(p) and Vendor Product restrictions only; the MLAE amount is NOT reduced by any outstanding active or defaulted loan balances. PART II-Section A: Account Data Cash Value Data Elements 1. Cash Value Type 2. Employer Cash Value 3. EE Deferral Cash Value 4. Rollover EE Pre-Tax Cash Value 5. Rollover EE Post-Tax Cash Value 6. Rollover Roth Cash Value 7. EE Post-Tax Cash Value 8. Roth Cash Value (acct type 008) 9. 403(b)(7) Employer Cash Value* Vendor Calculation of MLAE-Vendor N $24,000 $24,000 always excluded Total Account Cash Value (NET) = $48,000 Total Account Cash Value (GROSS) = $54,000 PART II-Section G: Loan Data Data required for all accounts 1. Method of Reporting Loan Data C 2. Maximum Loan Amount Eligible-Vendor $27,000 3. Filler 1 – no longer used NULL 4. Number of Loans Outstanding 2 5. Filler 2 – no longer used NULL 6. Loan Default Indicator N 7. Number of sets of Loan Component Data 1 Loan Component Data fields when the account has had any loan (Active, Defaulted or Paid Off) during the prior 12 months C-1. Vendor loan number SUMMARY C-2. Loan Initiation Date mm/dd/yyyy (Year 1) C-3. Loan Status A C-4. Loan Type Indicator G C-5. Original Loan Amount $18,000 C-6. Remaining Loan Balance $6,000 C-7. Remaining Balance Date mm/dd/yyyy (Year 2) C-8. Highest Outstanding Loan Balance-12 months $12,000 Total Remaining Balances = $6,000 Total Highest Outstanding Loan Balance-12 months = $12,000 50% of total CV Because the CV is NET, the Vendor must add outstanding and/or defaulted loan balances before performing the 50% CV calculation. 50% (48,000+6,000)=$27,000 MLAE-Vendor $27,000 Impact on Aggregator’s Calculation of MLAA-Plan Although SUMMARY loan data has been provided, all relevant Information is available for the Aggregator to calculate the MLAA-Plan. 51 SHAPING AMERICA’S RETIREMENT

58) EXAMPLE 4. DESCRIPTION - VENDOR D The fund used by this participant restricts loans to 45% of the total cash value. One loan has been taken for this account; the original amount taken was $15,000 when issued on mm/dd/yyyy (Year 1) and there is $10,000 remaining on the loan. In order for the Aggregator to determine the “Maximum Loan Amount Available – Plan”, Vendors must report Cash Values, Maximum Loan Amount Eligible-Vendor (MLAE) and other loan data as applicable. The MLAE is calculated by the Vendor applying all IRC (72(p)) and Vendor Product restrictions only; the MLAE amount is NOT reduced by any outstanding active or defaulted loan balances. PART II-Section A: Account Data Cash Value Data Elements 1. Cash Value Type 2. Employer Cash Value 3. EE Deferral Cash Value 4. Rollover EE Pre-Tax Cash Value 5. Rollover EE Post-Tax Cash Value 6. Rollover Roth Cash Value 7. EE Post-Tax Cash Value 8. Roth Cash Value (acct type 008) 9. 403(b)(7) Employer Cash Value* Vendor Calculation of MLAE-Vendor N $12,000 $24,000 always excluded Total Account Cash Value (NET) = $36,000 Total Account Cash Value (GROSS) = $46,000 PART II-Section G: Loan Data Data required for all accounts 1. Method of Reporting Loan Data C 2. Maximum Loan Amount Eligible-Vendor $20,700 3. Filler 1 – no longer used NULL 4. Number of Loans Outstanding 1 5. Filler 2 – no longer used NULL 6. Loan Default Indicator N 7. Number of sets of Loan Component Data Loan Component Data fields when the account has had any loan (Active, Defaulted or Paid Off) during the prior 12 months C-1. Vendor loan number 0001 C-2. Loan Initiation Date mm/dd/yyyy (Year 1) C-3. Loan Status A C-4. Loan Type Indicator G C-5. Original Loan Amount $15,000 C-6. Remaining Loan Balance $10,000 C-7. Remaining Balance Date mm/dd/yyyy (Year 1) C-8. Highest Outstanding Loan Balance-12 months $15,000 Total Remaining Balances = $10,000 Total Highest Outstanding Loan Balance-12 months = $15,000 50% of total CV Because the CV is NET, the Vendor must add outstanding and/or defaulted loan balances before performing the CV calculation. Fund restricts loan to 45% CV 45% (36,000+10,000)=$20,700 MLAE-Vendor $20,700 Impact on Aggregator’s Calculation of MLAA-Plan 52 SHAPING AMERICA’S RETIREMENT

59) EXAMPLE 5. DESCRIPTION - VENDOR E The product used by this participant restricts loans to two, however this is NOT a factor when reporting MLAE-Vendor even though there are already two outstanding loans on this account, as follows: 1) an existing loan taken on mm/dd/yyyy (Year 1) for $15,000 with an outstanding balance of $10,000 (highest outstanding loan balance during prior 12 months = $12,000, and 2) a defaulted loan taken on mm/dd/yyyy (Year 1) in the amount of $5,000; the defaulted amount is $4,500. In order for the Aggregator to determine the “Maximum Loan Amount Available – Plan”, Vendors must report Cash Values, Maximum Loan Amount Eligible-Vendor (MLAE) and other loan data as applicable. The MLAE is calculated by the Vendor applying all IRC (72(p) and Vendor Product restrictions only; the MLAE amount is NOT reduced by any outstanding active or defaulted loan balances. PART II-Section A: Account Data Cash Value Data Elements 1. Cash Value Type 2. Employer Cash Value 3. EE Deferral Cash Value 4. Rollover EE Pre-Tax Cash Value 5. Rollover EE Post-Tax Cash Value 6. Rollover Roth Cash Value 7. EE Post-Tax Cash Value 8. Roth Cash Value (acct type 008) 9. 403(b)(7) Employer Cash Value* Vendor Calculation of MLAE-Vendor N $30,000 $15,000 50% CV Must add loan balance back in to arrive at GROSS CV to determine MLAE-Vendor. 50% (45,000+14,500)=$29,750 always excluded Total Account Cash Value (NET) = $45,000 Total Account Cash Value (GROSS) = $59,500 PART II-Section G: Loan Data Data required for all accounts 1. Method of Reporting Loan Data C 2. Maximum Loan Amount Eligible-Vendor $29,750 3. Filler 1 – no longer used NULL 4. Number of Loans Outstanding 2 5. Filler 2 – no longer used NULL 6. Loan Default Indicator Y 7. Number of sets of Loan Component Data 02 Loan Component Data fields when the account has had any loan (Active, Defaulted or Paid Off) during the prior 12 months C-1. Vendor loan number Loan 001 C-2. Loan Initiation Date mm/dd/yyyy (Year 1) C-3. Loan Status A C-4. Loan Type Indicator G C-5. Original Loan Amount $15,000 C-6. Remaining Loan Balance $10,000 C-7. Remaining Balance Date mm/dd/yyyy (Year 3) C-8. Highest Outstanding Loan Balance-12 months $12,000 MLAE-Vendor $29,750 Impact on Aggregator’s Calculation of MLAA-Plan Component data for two loans has been reported. 53 SHAPING AMERICA’S RETIREMENT

60) C-1. Vendor loan number Loan 002 C-2. Loan Initiation Date mm/dd/yyyy (Year 1) C-3. Loan Status D C-4. Loan Type Indicator G C-5. Original Loan Amount $5,000 C-6. Remaining Loan Balance $4,500 C-7. Remaining Balance Date mm/dd/yyyy (Year 1) C-8. Highest Outstanding Loan Balance-12 months $5,000 Total Remaining Balances = $14,500 Total Highest Outstanding Loan Balance-12 months = $17,000 The $50,000 maximum loan rule under IRC Section 72(p) should be considered when reporting the Maximum Loan Amount Eligible-Vendor field. The comments for Maximum Loan Amount Eligible-Vendor field states that the "Maximum Loan Amount Eligible should not exceed the IRS Maximum limit of $50,000. If it does, report the value as $50,000." In regards to the exception to the 50% limit, if the reporting party will issue a loan of $10,000 or less without regard to the 50% rule then it should report the maximum amount available based on the method it follows for determining the amount. For example, assuming the account balance at issue is $16,000. If the reporting party will issue a loan for $10,000 because it will issue loans for under $10,000 without regard to the 50% rule then it should report the MLAE as $10,000. However, if the reporting party will apply the 50% rule in this situation then it should report the MLAE as $8,000 or 50% of the account balance. 54 SHAPING AMERICA’S RETIREMENT