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EMPOWER <br /> PET!REM ENT <br /> Procedures for Complying with Fund Company <br /> Market Timing and Excessive Trading <br /> The prospectuses, policies and/or procedures of certain fund companies require retirement plan providers <br /> offering their fund(s)to agree to restrict market timing and/or excessive trading ("prohibited trading") in <br /> their funds. The following procedures describe how we, as your recordkeeper,will comply with fund <br /> company instructions designed to prevent or minimize prohibited trading. <br /> Various fund companies instruct intermediaries to perform standardized trade monitoring while others <br /> perform their own periodic monitoring and request trading reports when they suspect that an individual is <br /> engaging in prohibited trading. If an individual's trading activity is determined to constitute prohibited <br /> trading, as defined by the applicable fund company,the individual will be notified that a trading restriction <br /> will be implemented if prohibited trading does not cease. (Some funds may require that trading <br /> restrictions be implemented immediately without warning, in which case notice of the restriction will be <br /> provided to the individual and plan, if applicable). If the individual continues to engage in prohibited <br /> trading, the individual will be restricted from making transfers into the identified fund(s)for a specified time <br /> period, as determined by the applicable fund company. Individuals are always permitted to make <br /> transfers out of the identified fund(s)to other available investment options. When the fund company's <br /> restriction period has been met,the individual will automatically be allowed to resume transfers into the <br /> identified fund(s). <br /> Additionally, if prohibited trading persists, the fund company may reject all trades initiated by the plan, <br /> including trades of individuals who have not engaged in prohibited trading. <br /> Note: certain plan sponsors have or may elect to implement plan level restrictions to prevent or minimize <br /> individual prohibited trading. To the extent that such procedures are effective,we may not receive <br /> requests for information from the fund companies or requests to implement the restrictions described <br /> above. <br /> 10/16/07 <br /> SAGWTPACOGOV0521 <br /> 17 <br />