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12.10

Requests for new Certificates will undergo the following data checks using a two-

file look back (e.g., for a Certificate requested in July, Retirement Manager will

validate information from both May and June Approved Vendor transmissions):

12.10.1

Retirement Manager will look for Certificates that expired on the last

day of one of the previous two months (e.g., for a Certificate requested

in July, it will check for Certificates with expiration dates of either May

31 or June 30)

12.10.2

If no expired certificates found, Retirement Manager will use loan and

hardship distribution data on file in validation/calculation process.

12.10.3

If one or more expired Certificates is found, Retirement Manager will

verify if a like transaction (e.g., loan Certificate/loan transaction) was

reported for that participant from each Approved Vendor.

12.10.3.1

If Approved Vendor shows transaction, Retirement Manager

will use data on file.

12.10.3.2

If Approved Vendor shows no transaction, Retirement

Manager will use data on file for validation/calculation

process, but print message on Certificate that states:

“Participant has outstanding X transaction with Approved

Vendor A that may have been processed after the last

reporting period.”

12.10.3.3

If multiple Certificates exist and equal number of like

transactions by Approved Vendor exist, Retirement Manager

will use data on file.

12.10.3.4

If multiple transactions exist and some, but not all,

transactions by Approved Vendor exist, Retirement Manager

will use data on file and report all pending and completed

transactions for that Approved Vendor on the Certificate.

12.11

Retirement Manager will always use data on file for plan-level

calculations/validations

.

12.12

Because a Distribution Eligibility Certificate will be based upon information

provided to VRSCO by Employer, one or more providers including Approved

Vendor, and/or a participant, and because an Approved Vendor investment

product may have restrictions in addition to applicable plan restrictions, nothing

in such a Certificate should be interpreted or applied to override more restrictive

provisions in Approved Vendor’s investment product(s) or to authorize or direct

Approved Vendor to disregard relevant information otherwise available to

Approved Vendor that might adversely affect the participant’s eligibility for the

requested distribution or loan.

12.13

Except as otherwise provided in this paragraph, Approved Vendor shall be

responsible for obtaining and maintaining supporting qualification documentation

for a safe harbor hardship distribution, unforeseeable emergency distribution or

loan for a principal residence, including but not limited to invoices, bills or other

documentation for the requested safe harbor hardship or unforeseeable emergency

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