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10.

Retirement Manager Limits Enforcement

10.1

Proactive Enforcement.

Proactive Enforcement is designed to prevent a

Participating Employee’s contributions in excess of the available monitored IRC

Contribution Limits each Participating Employee is eligible for, from being

deposited in the Participating Employee’s account in the Retirement Plan.

10.1.1

Retirement Manager will use available data to identify the payroll cycle in

which, based upon the data provided by the Employer, an excess is

projected to occur. The Employer will be notified of a projected excess

through the payroll feedback file to the Employer. The Employer directs

VRSCO to reduce and, as needed, stop contributions.

10.1.2

Retirement Manager will inform Participating Employees that RMLM will

calculate IRC Contribution Limits and reduce or stop contributions at the

direction of the Employer (on the Employee Enrollment/Contribution

Change Page). For employees who enroll or make contribution changes

online, an appropriate disclaimer will be included on the on-line page. It

is the Employer’s responsibility to inform Eligible Employees who submit

paper salary reduction agreements to the Employer to enter into

Retirement Manager of RMLM.

10.1.3

The Participating Employee will be notified via email of a contribution

reduction or stoppage. Participating Employee email notification is

dependent on the Employer’s providing a current, valid email address for

the Participating Employee.

10.1.4

Retirement Manager will generate a reduce- or stop-contribution change

prior to the cut-off date of the first payroll an excess over a monitored IRC

Contribution Limit is projected to occur.

10.1.5 If payroll dates have been entered in Retirement Manager by the Employer

for the subsequent calendar year, Retirement Manager will generate a start

contribution change for all Participating Employees who had their

contributions stopped in the prior year. Start changes will not generate for

unpopulated payroll dates or if the auto restart function is not selected by

the Employer.

10.1.6

Participating Employees may not override a stop or reduce change in their

contributions, but may override an automatic start change. The Employer

can override all contribution changes. Thus, the Employer can elect to

disregard a stop or reduce change, such as in a situation where the

Employer obtains new information supporting the contribution amount.

10.1.7 Participating Employee-generated contribution changes will supersede

automatic start contribution changes.

10.2

Reactive Enforcement.

Reactive Enforcement is designed to address

contributions that exceed applicable limits due to remittance of an excess

contribution by Employer.

10.2.1

Once the Employer determines that excess contributions were remitted to

Retirement Manager, all Employer corrective activity for contributions not

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