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HomeMy WebLinkAbout07 DEFERRED COMP 10-06-03AGENDA REPORT Agenda Item Reviewed: City Manager Finance Director MEETING DATE: TO: FROM: SUBJECT: OCTOBER 6, 2003 WILLIAM A. HUSTON, CITY MANAGER HUMAN RESOURCES DEPARTMENT AMEND DEFERRED COMPENSATION PLAN DOCUMENTS TO ALLOW LOANS TO PARTICIPANTS AND PERMIT AN ALTERNATE PAYEE PURSUANT TO A DOMESTIC RELATIONS ORDER SUMMARY: This agenda item recommends amending the City's U.S. Conference of Mayors 457(b) Deferred Compensation Plan (administered by Nationwide Retirement Solutions, Inc.), to allow for loans to participants and to permit an alternate payee pursuant to a valid domestic relations order. RECOMMENDATION: Adopt Resolution No. 03-115 amending the U.S. Conference of Mayors (USCM and also known as PEBSCO and/or NRS, Nationwide Retirement Solutions) 457(b) Deferred Compensation Plan to allow for participant loans and to permit an alternate payee pursuant to a valid domestic relations order. FISCAL IMPACT: NONE BACKGROUND AND DISCUSSION: LOANS: The City of Tustin adopted the original USCM deferred compensation plan in November of 1984. Recently the Internal Revenue Code regulations governing 457 (b) plans were amended and eligible public agencies may now allow participants to borrow money from their own vested accounts for general loans, including home loans. Currently our plan only allows for emergency withdrawals, which are limited and only apply in certain cases. Loans that would be made from a 457 plan are still severely restricted by law. In general, any Plan participant may apply for a loan from the Plan. The participant is required to complete and return to the administrator (NRS) a loan application and, before the loan is made, the participant must enter into a legally enforceable loan agreement. The maximum term of a loan is five (5) years or fifteen (15) years if the loan is for the purchase of a participant's principal residence and, a participant may only have one plan loan S:\City Council Agenda Items~2003\LoansDRO03.doc City Council Agenda October 6, 2003 Page 2 outstanding at any given time. The loan is secured by the participant providing a security interest in their vested Plan balance and loans may not exceed the lesser of 50% of the participant's vested account balance or $50,000. COMPLIANCE WITH DOMESTIC RELATIONS ORDERS: Changes to the regulations governing 457 (b) plans now enable eligible public agencies to amend their plans to comply with a valid domestic relations order. Approving a Domestic Relation Amendment to our Plan will provide our employees with a way to separate their vested account balance according to a valid domestic relations order (judgment, decree, order, or approval of marital property settlement) when a divorce occurs. This type of request has been made in the past and we were unable to comply. Adoption of the attached Resolution will amend our current USCM deferred compensation plan documents (utilizing Nationwide Retirement Solutions, Inc. (NRS), as the third party administrator) to enable our employees to take loans from their own vested accounts and, enable those employees who need to separate funds in their account when a divorce occurs to do so. Adoption of the Plan amendments further authorizes the City Manager, or his designee, to take all steps necessary to implement the amendments to the Plan documents. The amendments to the Plan meet all of the various federal regulatory compliance requirements. As a Plan Sponsor offering participant loans, we will be required to communicate the loan program to participants, determine participant eligibility and monitor loan activity/loan repayment. As related to the Domestic Relation Amendment we will be required to determine the validity of a domestic relations order and communicate to the Administrator (NRS) the pertinent information regarding the domestic relations order. As indicated earlier, there is no cost to the City; all costs associated with Plan loans and/or Domestic Relations Orders are paid by the applicant/employee. Arlene Marks, SPHR Director of Human Resources Attachment: Resolution 03-115 Loans to Participants Amendment to Plan Document Participant Loan Administrative Procedures Domestic Relations Amendment to Plan Document Domestic Relations Orders - Required Information S:\City Council Agenda Iterns\2003\LoansDRO03.doc RESOLUTION NO. 03-115 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF TUSTIN, CALIFORNIA, TO APPROVE AMENDMENTS TO THE U.S. CONFERENCE OF MAYORS 457 DEFFERED COMPENSATION PLAN DOCUMENTS WHEREAS, the City's U.S. Conference of Mayors 457 Deferred Compensation Plan permits amendments to the plan documents to include loans to participants and domestic relations orders; and WHEREAS, Nationwide Retirement Solutions Inc. acts as third party administrator of the United States Conference of Mayors Deferred Compensation program and administers the City's Deferred Compensation Plan; and WHEREAS, regulations under Internal Revenue code section 457 provide that eligible governmental 457 (b) plans may permit loans to participants; and WHEREAS, this would allow participant to borrow money from their vested account balance for general loans, including home loans; and WHEREAS, the Domestic Relation Orders amendment will provide for a means of separating the vested account balance according to a valid domestic relations order when divorce occurs; NOW, THEREFORE, The City Council of the City of Tustin, California does hereby resolve as follows: The City Council hereby adopts the amendments to the U.S. Conference of Mayors Deferred Compensation plan document to include loans to participants and domestic relations orders. Nationwide Retirement Solutions, Inc. is authorized to act as the third party administrator for the deferred compensation plan. The City Manager, or his designee, is authorized to act as the "Plan Sponsor" representing the City, and to execute such agreements and contracts as are necessary to implement the amendments to the plan documents. Passed and adopted at a regular meeting of the Tustin City Council held on the 6th day of October 2003. TRACY WILLS WORLEY Mayor PAMELA STOKER City Clerk STATE OF CALIFORNIA ) COUNTY OF ORANGE ) CITY OF TUSTIN ) SS PAMELA STOKER, City Clerk and ex-officio Clerk of the City Council of the City of Tustin, California, does hereby certify that the whole number of the members of the City Council of the City of Tustin is 5; that the above and foregoing Resolution No. 03-115 was duly and regularly introduced, passed, and adopted at a regular meeting of the Tustin City Council, held on the 6th day of October, 2003. COUNCILMEMBER AYES: COUNCILMEMBER NOES: COUNCILMEMBER ABSTAINED: COUNCILMEMBER ABSENT: PAMELA STOKER City Clerk THE UNITED STATES CONFERENCE OF MAYORS DEFERRED COMPENSATION PROGRAM THE DEFERRED COMPENSATION PLAN FOR PUBLIC EMPLOYERS LOANS TO PARTICIPANTS AMENDMENT TO PLAN DOCUMENT WHEREAS, PLAN SPONSOR executed the above referenced Plan Document, as amended: and WHEREAS, effective October 6, 2003, PLAN SPONSOR now desires to further amend the plan document. The following Section 8.06 is hereby added: 8.06 Loans to PARTICIPANTS (a) PLAN SPONSOR has elected make loans available to PARTICIPANTS and has delegated certain administrative duties regarding loans form the PLAN to the A DM IN I STRATOR. (b) Any loan by the PLAN to a PARTICIPANT under this Sections shall be subject to the loan administrative procedures established by the ADMINISTRATOR as well as the following requirements: (i) Loan Eligibility. Any PARTICIPANT may apply for a loan from the PLAN. A PARTICIPANT who has defaulted on a previous loan from the PLAN shall not be eligible for another loan from the PLAN until all defaulted loans are repaid in full, including accrued interest and fees. (ii) Loan Application and Loan Agreement. A PARTICIPANT must complete and return to ADMINISTRATOR a loan application. A non-refundable application fee established by ADMINISTRATOR will be deducted from the PARTICIPANT'S ACCOUNT(s) at the time of loan origination. Before a loan is issued, the PARTICIPANT must enter into a legally enforceable loan agreement as provided for by the ADMINISTRATOR. Loan Repayment. The PARTICIPANT receiving a loan shall be required to furnish to ADMINISTRATOR any information and authorization necessary to effectuate repayment of the loan prior to the commencement of a loan. In the event that a payment cannot be processed because of lack of sufficient funds, the ADMINISTRATOR shall assess an insufficient funds charge which will be deducted from the PARTICIPANT'S ACCOUNT(s). (iv) Loan Term and Interest Rate. The maximum term over which a loan may be repaid is five (5) years (fifteen (15) years if the PLAN SPONSOR permits loans for the purchase of a PARTICIPANT's principal residence). Each loan shall be amortized in substantially equal payments consisting of principal and interest during the term of the loan, except that the amount of the final S:\Policy Guidelines\Loans to Participants,doc (v) (vi) (vii) (viii) (ix) (x) payment may be higher or lower. The ADMINISTRATOR shall establish the interest rate for any loan. Loan Frequency. Each Participant may have only one (1) PLAN loan outstanding at any given time. A PLAN loan which is in default, even if the defaulted loan was treated as a "deemed distribution" under federal regulations, shall be treated as an outstanding loan until such PARTICIPANT'S account balance is offset by the amount of principal and accrued interest under the loan. A PARTICIPANT will be granted a loan no more frequently than two (2) times in any twelve (12) month period. Default. The PARTICIPANT must pay the full amount of each loan payment (principal and interest) on the date that it is due. Failure to make such a payment by the due date, or within any cure period established by the ADMINISTRATOR, shall cause the PARTICIPANT to be in default for the entire amount of the loan, including any accrued interest. A loan will also be in default if the PARTICIPANT either refused to execute, revoke, or rescind any agreement necessary to comply with the provisions of this Section or the loan administrative procedures established by the ADMINISTRATOR, commences or has commenced against PARTICIPANT a bankruptcy case, or upon the death of the PARTICIPANT. Loan Security. By accepting a loan, the PARTICIPANT is giving a security interest in their vested PLAN balance as of the loan process date, together with all additions thereof, to the PLAN that shall at all times be equal to 100% of the unpaid principal balance of the loan together with accrued interest. Loan Amount. The maximum amount of any loan permitted under the PLAN is the lesser of (i) 50% of the participant's VESTED ACCOUNT BALANCE LESS ANY OUTSTANDING LOAN BALANCES UNDER THE plan OR (11) $50,000 LESS THE HIGHEST OUTSTANDING LOAN BALANCE DURING THE PRECEDING ONE-YEAR PERIOD. The ADMINISTRATOR shall establish the minimum loan amount. The PARTICIPANT and not the ADMINISTRATOR shall at all time remain responsible for ensuring that any loan received under the PLAN is in accordance with these limits with regard to any other loans received by the PARTICIPANT under any other plans of the PARTICIPANT's employer. Loan Maintenance Fee. Until a loan is repaid in full, an annual loan maintenance fee established by ADMINISTRATOR will be deducted from the PARTICIPANT'S ACCOUNT(s). Loan Default Fee. At the time when a default occurs, a loan default fee established by ADMINISTRATOR will be deducted from the PARTICIPANT'S ACCOUNT(s). S:\Policy Guidelines\Loans to Participants.doc Page 2 of 3 (c) The ADMINISTRATOR shall fix such other terms and conditions necessary to the administrative maintenance of the provisions of the Section and as necessary to comply with the IRC and regulations there under. IN WITNESS WHEREOF, the undersigned has executed this Amendment this ,2003. day of City of Tustin By: Arlene Marks, Director of Human Resources S:\Policy Guidelines\Loans to PaKicipants.doc Page 3 of 3 THE UNITED STATES CONFERENCE OF MAYORS DEFERRED COMPENSATION PROGRAM PARTICIPANT LOAN ADMINISTRATIVE PROCEDURES Nationwide Retirement Solutions, Inc. ("NRS"), as Third Party Administrator of the United States Conference of Mayors Deferred Compensation Program, administers your Deferred Compensation Plan for Public Employees ("Plan"). Recently issued proposed regulations under Internal Revenue Code Section 457 provide that eligible governmental 457(b) plans may permit loans to Participants. NRS recommends that you, as Plan Sponsor and/or Employer (hereinafter collectively referred to as "Plan Sponsor"), consult with your own legal advisor in determining whether you wish to add this optional feature to your Plan. In the event that you decide to offer loans from your Plan to Participants, you will need to return to NRS at Nationwide Retirement Solutions, PO Box 182797, Columbus, OH 43272-8450 Attn: Loans Administrator a fully executed original of this document and a fully executed original of the enclosed Plan Document Amendment. NRS cannot begin processing Participant loans from your Plan until it receives fully executed originals of both of these documents. NRS may need from time-to-time to make changes to the administrative procedures set forth herein and in the Plan Document Amendment. in such a case, NRS will provide you with timely notice of such changes as they become necessary. The following administrative procedures shall govern the making of loans from your Plan: 1. Loan Administration. Plan Sponsor delegates to NRS certain administrative duties regarding the administration of loans from the Plan, which are set forth herein and which may be modified by NRS upon timely notice to Plan Sponsor. 2. Loan Eligibility. Any Participant in the Plan is eligible to receive a loan from the Plan. Each Participant is entitled to one (1) loan at any time. In addition, a Participant who has defaulted on a previous loan shall not be eligible for another loan from the Plan until all defaulted loans are repaid in full, including accrued interest and fees. 3. Loan Application and Loan Agreement. In order to receive a loan from the Plan, an eligible Participant must complete a loan application and return it to NRS. A loan application fee of $50.00* will be deducted from the Participant's account(s). Before a loan is issued, the Participant must enter into a legally enforceable loan agreement as provided by NRS. If the Plan Sponsor permits loans for the purchase of the Participant's principal residence, the Participant will be required to sign a Primary Residence Certificate form and provide NRS with a copy of the contract or other documents relating to the acquisition of the dwelling unit. If the source for a single loan includes both the Participant's Deferred Compensation and Eligible Rollover Accounts, the Participant will be required to complete a loan application and loan agreement for each account which will be treated as separate and distinct for all purposes herein except that they will be considered a single loan for purposes of Sections 2, 6 and 10 herein. *These fees, rates, and minimums are subject to change by NRS upon reasonable notice to Plan Sponsor. Loan fees will appear as administrative charges on Participant Statements. S:\Deferred Comp 457\Tustin Loans-USCM Administrative Procedures ACH 03.doc 4. Loan Repayment/Maximum Loan Term. Repayment of any loan made to a Participant shall be made in a manner and pursuant to the terms set forth in the loan agreement. The Participant receiving a loan shall be required to furnish the information and authorization necessary to effectuate the foregoing payments prior to the commencement of a loan. The maximum term over which a loan may be repaid is five (5) years (fifteen (15) years if the Plan Sponsor permits loans for the pumhase of the Participant's principal residence). In the event that a Participant elects to receive a distribution from the Plan (other than a distribution due to an unforeseeable emergency or other in-service withdrawal) at a time when such person has a Plan loan outstanding, the principal and any accrued interest with respect to such loan shall be taxable. 5. Loan Amortization. Each loan shall be amortized in substantially equal payments consisting of principal and interest during the term of the loan. Payments of principal and interest shall be made in a manner and pursuant to the terms set forth in the loan agreement on a monthly basis in equal amounts, except that the amount of the final payment may be higher or lower. Before the loan is made, the Participant will be notified of the date on which the first payment will be deducted and the dates on which subsequent payments are due. 6. Loan Frequency/Renegotiations. Each Participant may have only one (1) Plan loan outstanding at any given time. A Plan loan which is in default, even if the defaulted loan was treated as a "deemed distribution" under federal regulations, shall be treated as an outstanding loan until such Participant's account balance is offset by the amount of principal and accrued interest under the loan. A Participant will be granted a loan no more frequently than two (2) times in any twelve (12) month period. Under no cimumstances may loan terms be renegotiated. A new loan shall not be granted prior to the repayment of an outstanding loan. 7. Default. The Participant must pay the full amount of each payment (principal and interest) on the date that it is due by having sufficient funds in the account designated for loan payments through the ACH process. If NRS is unable to process a payment on the date due because the Participant fails to have sufficient funds in the account on that date, NRS will assess a fee of $25.00 that will be deducted from Participant account(s) and will send written notification to the Participant. The Participant shall be in default for the entire amount of the loan UNLESS the Participant does each of the following: 1) contacts NRS at the Deferred Compensation Service Center, 2) mutually agrees with NRS on a date, which is within 30 days of the missed payment on which funds sufficient to cover the missed payment will be in the account and; 3) actually pays the missed payments. Failure to make such a payment through mutually agreeable terms shall cause the Participant to be in default for the entire amount of the loan. The loan also shall be defaulted upon the death of the Participant or if the Participant commences or has commenced against Participant a bankruptcy case. No additional loans shall be made to a Participant who has defaulted on a Plan loan and who has not repaid all defaulted loans in full, including accrued interest and fees. 8. Loan Prepayment. The entire amount of a loan, including outstanding principal and any accrued interest, may be paid without penalty prior to the end of the term of the loan in the manner prescribed by NRS. However, payments made that are less than the remaining principal amount of the loan and any accrued interest with respect to the loan, or which are not paid in the form prescribed by NRS, are not permitted. *These fees, rates, and minimums are subject to change by NRS upon reasonable notice to Plan Sponsor. Loan fees will appear as administrative charges on Participant Statements. S:\Deferred Comp 457\Tustin Loans-USCM Administrative Procedures ACH 03.doc 9. Loan Security. By accepting a loan, the Participant is giving a security interest in his or her vested Plan balance as of the date of the Loan Process Date, together with all additions thereof, to the Plan that shall at all times be equal to 100% of the unpaid principal balance of the loan together with accrued interest. 10. Maximum/Minimum Loan Amount. The maximum amount of any loan permitted under the Plan is the lesser of (i) 50% of the Participant's vested account balance (not including any value attributable to applicable life insurance or deemed IRA account) less any outstanding loan balances under the Plan or (ii) $50,000 less the highest outstanding loan balance during the preceding one-year period. The minimum loan amount permitted is $1,000.00'. Loans shall be made in accordance with these limits and those limits imposed under federal regulations without regard to any other loans received by the Participant from any other investment provider under the Plan or any other plans of the employer. The Participant and not NRS shall remain at all times responsible for ensuring that any loan received under the Plan is in accordance with these limits with regard to any other loans received by the Participant under any other plans of the Participant's employer. Any tax reporting required as a result of the receipt by a Participant of a loan that exceeds the limits imposed by federal regulations shall not be the responsibility of NRS, unless it is determined that such limits were exceeded solely as a result of a loan made through NRS as service provider. Consequently, NRS shall not be required to account for loans made pursuant to a plan other than this Plan or loans made under this Plan that are made by an investment provider other than Nationwide Life Insurance Company. 11. Suspension of Loan Payments. NRS may suspend a Participant's obligation to repay any loan under the Plan during the period in which the Participant is performing service in the uniformed services as may be required by law. At the expiration of any suspension of loan payments period, the outstanding loan balance, including any accrued interest and fees, will be re-amortized and the Participant will be required to execute an amended Loan Agreement. 12. Loan Interest Rate. The interest rate for any loan shall be established by NRS. These interest rates shall commensurate with interest rates being charged by entities in the business of lending money under similar circumstances. Generally, the rate assumed will be Prime Rate + 1.00%*. The Prime Rate shall be the prime rate published by the Wall Street Journal two weeks prior to the end of the most recent calendar-year quarter. NRS may adjust the loan interest rate for loans to Participants entering active duty in the military services as may be required by law. 13. Annual Loan Maintenance and Asset Fees. An annual loan maintenance fee of $50.00* will also be deducted from the Participant's account until the loan is repaid in full. The amount of the outstanding loan balance will be subject to the maximum Variable Account Annual Expense Fee applicable under the Plan at the time the loan is issued. 14. Loan Default Fee. At the time when a default occurs, a $50.00' loan default fee will be deducted from the Participant's account. This charge will only affect Participants who fail to make a required loan payment. 15. Loans for the Purchase of a Principal Residence. All loans issued by the Plan will be general loans to be repaid in five (5) years unless the Plan Sponsor affirmatively elects to offer loans for the purchase of the Participant's principal residence, which may be repaid in fifteen (15) years. *These fees, rates, and minimums are subject to change by NRS upon reasonable notice to Plan Sponsor. Loan fees will appear as administrative charges on Participant Statements. S:~Deferred Comp 457\Tustin Loans-USCM Administrative Procedures ACH 03.doc Such loans shall be solely secured by the Participant's vested account balance. All administrative procedures set forth herein shall apply to such loans. If the Plan Sponsor elects to permit loans for the purchase of the Participant's principal residence, please check this box. r~ The undersigned Plan Sponsor hereby adopts these Participant Loan Administrative Procedures, effective for loans issued on or after the effective date set forth in the Loans to Participants Amendment to Plan Document, and instructs NRS to administer loans made to Plan Participants in accordance with these terms. The Plan Sponsor acknowledges the following: (i) that the Plan Sponsor has decided to offer loans under the Plan and is instructing NRS to administers loans under the Plan; (ii) that it understands that, as a result of offering loans under the Plan, the Plan Sponsor, its Participants, and/or the Plan could be subject to adverse tax consequences; (iii) that the Plan Sponsor has independently weighed this risk and has determined that offering loans under the Plan is in the best interest of the Plan Sponsor, its Participants, and the Plan; and (iv) NRS shall not be liable for any adverse tax consequences described in (ii), except as specifically stated under paragraph 10 herein, resulting from the Plan Sponsor's decision to offer loans under the Plan. *These fees, rates, and minimums are subject to change by NRS upon reasonable notice to Plan Sponsor. Loan fees will appear as administrative charges on Participant Statements. S:\Deferred Comp 457\Tustin Loans-USCM Administrative Procedures ACH 03.doc Plan Sponsor or Employer: City of Tustin Street Address: 300 Centennial Way City, State, Zip Code: Tustin, CA 92780 Plan Name: City of Tustin - Deferred Compensation Plan Entity No.: 0506 By: Its: Director of Human Resources E-mail Address: amarks@tustinca.orq Date: *These fees, rates, and minimums are subject to change by NRS upon reasonable notice to Plan Sponsor. Loan fees will appear as administrative charges on Participant Statements. S:\Deferred Comp 457\Tustin Loans-USCM Administrative Procedures ACH 03.doc THE UNITED STATES CONFERENCE OF MAYORS DEFERRED COMPENSATION PROGRAM THE DEFERRED COMPENSATION PLAN FOR PUBLIC EMPLOYERS DOMESTIC RELATIONS AMENDMENT TO PLAN DOCUMENT WHEREAS, EMPLOYER executed the above referenced Plan Document, as amended: and WHEREAS, effective October 6, 2003, EMPLOYER now desires to further amend the plan document. 1. The following Article Xlll is hereby added: ARTICLE Xlll 1301 When the PLAN received a judgment, decree or order entered or enforceable pursuant to local domestic relations marital property law ("domestic relations order"), and relating to the property rights of a PARTICIPANT's present or former spouse, child or other dependent ("ALTERNATE PAYEE"), then: (a) The ADMINISTRATOR shall promptly notify the PARTICIPANT and ALTERNATE PAYEE of the receipt of such order, and (b) The EMPLOYER, within a reasonable time, shall determine the validity of the domestic relations order as set forth in the Article. Once a determination as to the validity of the domestic relation order is made, the ADMINISTRATOR shall notify the PARTICIPANT and ALTERNATE PAYEE of such determination. 13.02 A valid domestic relations order must be a judgment, decree, order, or approval of marital property settlement relating to: (1) the property rights of the ALTERNATE PAYEE; and (2) is an order made pursuant to state domestic relations law (including community property law), which relates to the property rights of the ALTERNATE PAYEE. In addition, the domestic relations order must: (a) Create or recognize the existence of, or assign to an ALTERNATE PAYEE a claim for a portion of any benefits that actually become payable to a PARTICIPANT under the PLAN. (b) Clearly specify the following information: (i) The name, social security number, and last known mailing address of the PARTICIPANT and ALTERNATE PAYEE covered by the domestic relations order; (ii) The amount or percentage, or the manner to be used in determining the amount or percentage, of the PARTICIPANT's benefit to be paid by the PLAN to the ALTERNATE PAYEE; (111) The number of payments or period to which the order applies; and (iv) The applicability of the order to the PLAN. S:\Policy Guidelines\Domestic Relations Amend.doc 13.03 When the EMPLOYER has determined that a valid domestic relations order applies to a PARTICIPANT's account, the EMPLOYER shall notify the ADMINISTRATOR and provide the ADMINISTRATOR with all pertinent information regarding the domestic relations order, including the information set forth in Section 13.02. The EMPLOYER shall direct the ADMINISTRATOR to comply with the domestic relations order and specify the value or benefit of the PARTICIPANT's account to which the ALTERNATE PAYEE is entitled. Once the ADMINISTRATOR has received from the EMPLOYER the required information and direction, the ADMINISTRATOR shall establish a separate account for the ALTERNATE PAYEE and place the value or benefit of the PARTICIPANT's account in the ALTERNATE PAYEE's account as requested by the EMPLOYER. 3.04 The ALTERNATE PAYEE is entitled to receive distributions immediately upon the establishment of his or her account under Section 13.03, and commencement of distributions must begin no later that April 1 following the year in which the ALTERNATE PAYEE attains age 70 ~, in accordance with the terms of Section 8.02. Distributions made to an ALTERNATE PAYEE are reported as taxable income to the ALTERNATE PAYEE. State taxes, if applicable, and Federal taxes will be withheld from any distribution on the ALTERNATE PAYEE's account based upon the tax withholding elections of the ALTERNATE PAYEE. The ALTERNATE PAYEE may not make any contributions to an account established under Section 13.03. The ALTERNATE PAYEE is permitted to name beneficiaries to his or her account and exercise exchanges among the funding options as permitted by the PLAN and the investment providers under the PLAN. IN WITNESS WHEREOF, the undersigned has executed this Amendment this ,2003. __day of City of Tustin By: Arlene Marks, Director of Human Resources S:\Policy Guidelines\Domestic Relations Amend.doc Page 2 of 2 DOMESTIC RELATIONS ORDERS REQUIRED INFORMATION This is not intended to be legal or tax advice, and should not be relied upon as such. Instead, this is in response to your request for information regarding domestic relations orders. The Internal Revenue Code does not require eligible deferred compensation plans established pursuant to Code Section 457 to accommodate domestic relations orders. However, some plans accommodate such orders. Whether a particular plan accommodates such orders is determined by the plan document. A domestic relations order is a judgment, decree, or order made pursuant to state domestic relations law (including community property law), relating to the property dghts of the Alternate Payee. A certified copy of such a judgment, decree, or order is required. In addition, the domestic relations order should: · Be directed to the deferred compensation plan and not directed to the administrator of the plan; · Create or recognize the existence of the right of an Alternate Payee to all or a portion of the benefits payable with respect to a Participant under the Plan; · Clearly specify the names, last known addresses, and social security numbers of the Participant and Alternate Payee; · Clearly specify the amount or percentage of the Participant's benefits which are to be segregated for the Altemate Payee with a specific "as of" date for the segregation; · If applicable, clearly specify the rate of accrual of interest or earnings on the Alternate Payee's benefits from the "as of" date to the actual date of segregation. (The administrator will not perform hypothetical calculations to adjust for market fluctuations); · Not provide for any actions to be taken by the Plan which are inconsistent with the Plan document; · Not provide for any form of payment to the Alternate Payee that is not permitted by the Plan; and · Not require the payment of benefits to an Alternate Payee, which is required by a prior domestic relations order to be paid to another Alternate Payee. The following items also should be considered: · Distributions made to an Alternate Payee are reported as taxable income to the Alternate Payee. Taxes will be withheld from any distributions to the Alternate Payee's account based upon the tax withholding elections of the Alternate Payee. · The Alternate Payee may not make any contributions to the separate account. · The Altemate Payee is permitted to designate beneficiaries for his or her account and to exercise exchanges among the funding options as permitted by the Plan and the investment providers under the plan. The Alternate Payee will receive quarterly statements on his or her account which will be sent to their address. S:\Deferred Comp 457\DRO Requirements Memo - EGTRRA Compliance.doc