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11.

Loan and Hardship Withdrawal Compliance

11.1

Compliance Reports

. All reports in Retirement Manager are available for

download in Excel spreadsheet format for further data manipulation and, where

applicable, to allow for date range search.

11.1.1

Hardship Withdrawal Report – Employees who have taken a Hardship

Withdrawal from an Approved Vendor. The Hardship Withdrawal data is

provided by each Approved Vendor on a periodic frequency and the data

is available at the plan level across all Approved Vendors.

11.1.2

Loan Report – Employees who have taken a Loan from an Approved

Vendor. The Loan data is provided by each Approved Vendor on a

periodic frequency and the data is available at the plan level across all

Approved Vendors.

11.2

Loan and Distribution Data

11.2.1

Employee Hardship Withdrawal data is provided by each Approved

Vendor that administers plan distributions. VRSCO will refresh and

update the data reflected in the Hardship Withdrawal compliance report

upon receipt of the refresh files on a frequency as determined by the

Employer and VRSCO. This Employee data is aggregated across

Approved Vendors and reported at the plan and Employee levels.

11.2.2

Employee Loan data is provided by each Approved Vendor that

administers plan loans. VRSCO will refresh and update the data reflected

in the Loan compliance report upon receipt of the refresh files on a

frequency as determined by the Employer and VRSCO. This Employee

data is aggregated across Approved Vendors and reported at the plan and

Employee levels.

11.2.3

The Vendor distribution file must be delivered to VRSCO by each

Approved Vendor via secure FTP file transfer. Each Approved Vendor

providing loans and hardship withdrawals under the plan shall send a

distribution file electronically and in a file format agreed upon by the

Employer and VRSCO. If the data is not received in this approved file

format, the Approved Vendor will not be included in Loan and Hardship

Withdrawal Retirement Manager compliance monitoring.

11.3

Vendor Access and Communication

11.3.1

Approved Vendors are offered access to the Retirement Manager web site

as described in this section.

11.3.2

As negotiated between the Employer and Approved Vendor, account

balance update file submissions may be required of the Approved Vendor

on a periodic basis (as determined by Employer). As part of the upload

process, Retirement Manager will perform online edits to ensure the file is

in the proper format. To complete the submission of the file, the

Approved Vendor must validate the record total and the sum of YTD

contributions and account balances. Account balances are displayed as

provided.

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