HomeMy WebLinkAboutCAG2019-397 - Original - ICMA Retirement Corporation - Deferred Compensation Third Party Administrator Services - 05/23/2019 REQUEST FOR MAYOR'S SIGNATURE
KENT Print on Cherry-Colored Paper
Routing Information:
(ALL REQUESTS MUST FIRST BE ROUTED THROUGH THE LAW DEPARTMENT)
Approved by Director
Originator: Laura Horea Phone (Originator): 253,856.5290
Date Sent: 8/22/19 Date Required: 8/27/19
Return Signed Document to: Laura Horea Contract TS Y 0LCt te:jj�afters
VENDOR NAME: Date Finance No lfied:
ICMA-RC (Only required on contracts May 2019
20 000 and over or on any Grant
DATE OF COUNCIL APPROVAL: 6/18/19 Date Risk Manager Notified:May 2019
(Required on Non-City Standard Contracts/Agreements
Has this Document been Specificall Account Number: 130800 (?)
Authorized in the Budget? • YES NO
Brief Explanation of Document:
Deferred Compensation Third Party Administrator Services
aol9- 3ci-7
All Contracts Must Be Routed Through The Law Department
(Thi ea to comple ed y the Law Department)
Received:
Approval of Law Dept.:
Law Dept. Comments:
Date Forwarded to mayor:
Shaded Areas To Be Completed By Administration Staff
Received: AUG 2 7 2019
City of Kent
Recommendations and Comments: VE71)�
Office of the Mayor
Disposition: AUK 26 2019
k�AlDate Returned: ! VV
\ rvil\orrns\ ocument rocessing\Request for Mayor's Signature docx V(/
1
ADMINISTRATIVE SERVICES AGREEMENT
Between
IC\TA Retirement Corporation
and
City of Kent
Plan niunber 301655
ADMINISTRATIVE SERVICES AGREEMENT Oh
This Administrative Services Agreement("Agreement"),made as of the2-5 day
of Mood' . 201�(herein referred to as the"Inception Date"),between the International
City Management Association Retirement Corporation("ICMA-RC"), a nonprofit
corporation organized and existing under the laws of the State of Delaware, and the City
of Kent("Employer"), an entity organized and existing tinder the laws of the State of
Washington with an office at 220 4t'Avenue South Kent Washington,98032.
RECITALS
Employer acts as public plan sponsor of a retirement plan("Plan"), and in that
capacity, has responsibility to obtain administrative services and investment alternatives
for the Plan;
VantageTrust is a group trust established and maintained in accordance with New
Hampshire Revised Statutes Annotated section 391:1 and Internal Revenue Service
Revenue Ruling 81-100, 1981-1 C.B. 326,which provides for the commingled
investment of retirement fiends;
ICMA-RC acts as investment adviser to VantageTrust Company,LLC, the
Trustee of VantageTrust;
ICMA-RC has designed, and VantageTrust offers, a series of separate fiords (the
"Fronds")for the investment of plan assets as referenced in VantageTrust's principal
disclosure documents, the VantageTrust Disclosure Memorandum and the Funds' Fact
Sheets(together,"VT Disclosures"); and
In addition to serving as investment adviser to VantageTrust Company LLC,
ICMA-RC provides a range of services to public employers for the operation of
employee retirement plans including,but not limited to, conummications concerning
investment alternatives, accouunt maintenance, account recordkeeping, investment and tax
reporting,transaction processing, and benefit disbursement.
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Plan munber 301655
AGREEMENTS
1. Appointment of ICMA-RC
Employer hereby appoints ICMA-RC as Administrator of the Plan to perform all
nondiscretionary finnctions necessary for the administration of the Plan. The fimctions to
be performed by ICMA-RC shall be those set forth in Exhibit A to this Agreement.
2. Adoption of Trust
Employer has adopted the Declaration of Trust of VantageTrust Company and agrees to
the commingled investment of assets of the Plan within VantageTrust. Employer agrees
that the investment, management, and distribution of amounts deposited in VantageTrust
shall be subject to the Declaration of Trust, as it may be amended from time to time and
shall also be subject to terms and conditions set forth in disclosure documents(such as
the VT Disclosures or Employer Bulletins) as those terms and conditions may be adjusted
from time to time.
3. Exclusivity Agreement
Employer agrees that for the initial or succeeding term of this Agreement specified in
Section 11, so long as ICMA-RC continues to perform in all material respects the
services to be performed by it under this Agreement, Employer shall not obtain plan
administration from anyone other than ICMA-RC. Employer acknowledges that ICMA-
RC has agreed to the compensation to be paid to ICMA-RC under this Agreement in the
expectation that ICMA-RC will be able to offset costs allocable to performing this
Agreement with revenues arising from Employer's exclusive use of ICMA-RC at the
rates provided herein throughout the initial or succeeding term.
4. Employer Duty to Fu1711'sh Information
Employer agrees to fiunish to ICMA-RC on a timely basis such information as is
necessary for ICMA-RC to carry out its responsibilities as Administrator of the Plan,
including information needed to allocate individual participant accotunts to Fluids in
VantageTrust, and information as to the employment status of participants, and
participant ages, addresses, and other identifying information(including tax identification
numbers). Employer also agrees that it will notify ICMA-RC in a timely mamier
regarding changes in staff as it relates to various roles. Such notification is to be
completed through the online EZLink employer contact options. ICMA-RC shall be
entitled to rely upon the accuracy of any information that is furnished to it by a
responsible official of the Employer or any information relating to an individual
participant or beneficiary that is furnished by such participant or beneficiary, and IC1ti1A-
RC shall not be responsible for any error arising from its reliance on such information.
ICMA-RC will provide reports, statements and account information to the Employer
through EZLink, the online plan administrative tool.
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Plan number 30165.5
Employer is required to send in contribution information through EZLink, the online plan
administration tool provided by ICMA-RC. Alternative electronic methods may be
allowed,but must be approved by ICMA-RC for use. Contributions may not be sent
through paper submittal documents.
To the extent Employer selects third-party fiends that do not have fiend profile
information provided to ICMA-RC through our electronic data feeds from external
sources(such as Morningstar)or third party fund providers, the Employer is responsible
for providing to ICMA-RC timely fiord investment updates for disclosure to Plan
participants. Such updates may be provided to ICMA-RC through the Employer's
Investment consultant or other designated representative.
5. ICMA-RC Representations and Warranties
ICMA-RC represents and warrants to Employer that:
(a) ICMA-RC is a non-profit corporation with full power and authority to
enter into this Agreement and to perform its obligations under this
Agreement. The ability of ICMA-RC,or its wholly owned subsidiary,to
serve as investment adviser to VantageTnust Company is dependent upon
the continued willingness of VantageTnust Company for ICMA-RC, or its
wholly owned subsidiary,to serve in that capacity.
(b) ICMA-RC is an investment adviser registered as such with the U.S.
Securities and Exchange Commission under the Investment Advisers Act
of 1940,as amended.
(c)(i) ICMA-RC shall maintain and administer the 457(b)Plan in accordance
with the requirements for eligible deferred compensation plans under
Section 457 of the Internal Revenue Code and other applicable federal
law, provided,however, that ICMA-RC shall not be responsible for the
eligible status of the 457(b) Plan in the event that the Employer directs
ICMA-RC to administer the 457(b)Plan or disburse assets in a manner
inconsistent with the requirements of Section 457 or otherwise causes the
457(b)Plan not to be carried out in accordance with its terms. Further, in
the event that the Employer uses its own customized plan document,
ICMA-RC shall not be responsible for the eligible status of the 457(b)
Plan to the extent affected by terms in the Employer's plan document that
differ from those in ICMA-RC's model plan document. ICMA-RC shall
not be responsible for monitoring state or local law applicable to
retirement plans or for administering the 457(b)Plan in compliance with
local or state requirements regarding plan administration unless Employer
notifies ICMA-RC of any such local or state requirements.
6. Employerpresentations and Warranties
Employer represents and warrants to ICMA-RC that:
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Plan number 301655
(a) Employer is organized in the form and manner recited in the opening
paragraph of this Agreement with fiill power and authority to enter into
and perform its obligations under this Agreement and to act for the Plan
and participants in the manner contemplated in this Agreement. Execution,
delivery, and performance of this Agreement will not conflict with any
law,rule,regulation or contract by which the Employer is bound or to
which it is a party.
(b) Employer understands and agrees that ICMA-RC's sole finction under
this Agreement is to act as recordkeeper and to provide administrative,
investment or other services at the direction of Plan participants, the
Employer, its agents or designees in accordance with the terms of this
Agreement. Under the terms of this Agreement,ICMA-RC does not
render investment advice, is neither the "Plan Administrator"nor"Plan
Sponsor"as those terms are defined under applicable federal, state, or
local law, and does not provide legal, tax or accounting advice with
respect to the creation, adoption or operation of the Plan and its related
bust. ICMA-RC does not perform any service under this Agreement that
aught cauuse ICMA-RC to be treated as a "fiduciary"of the Plan under
applicable law, except, and only, to the extent that ICMA-RC provides
investment advisory services to individual participants enrolled in Guided
Pathways Advisory Services.
(c) Employer acknowledges and agrees that ICMA-RC does not assume any
responsibility with respect to the selection or retention of the Plan's
investment options. Employer shall have exclusive responsibility for the
Plan's investment options, including the selection of the applicable mutual
find share class. Where applicable, Employer understands that the VT
Retirement IncomeAdvantage Fund is an investment option for the Plan
and that the find invests in a separate account available through a group
variable annuity contract. By entering into this Agreement, Employer
acknowledges that it has received the Important Considerations document
and the VT Disclosures and that it has read the information therein
concerning the VT Retirement IncomeAdvantage Fund.
(d) Employer acknowledges that certain such services to be performed by
ICMA-RC under this Agreement may be performed by an affiliate or
agent of ICMA-RC pursuant to one or more other contractual
arrangements or relationships,and that ICMA-RC reserves the right to
change vendors with which it has contracted to provide services in
connection with this Agreement without prior notice to Employer.
(e) Employer acknowledges that it has received ICMA-RC's Fee Disclosure
Statement,prepared in substantial conformance with ERISA regulations
regarding the disclosure of fees to plan sponsors.
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Plan ntunber 301655
(f) Employer approves the use of its Plan in ICMA-RC external media,
publications and materials. Examples include press releases
announcements and inclusion of the general plan information in request
for proposal responses.
7. Participation in Certain Proceedings
The Employer hereby authorizes ICMA-RC to act as agent,to appear on its behalf, and to
join the Employer as a necessary party in all legal proceedings involving the garnishment
of benefits or the transfer of benefits pursuant to the divorce or separation of participants
in the Plan. Unless Employer notifies ICMA-RC otherwise,Employer consents to the
disbursement by ICMA-RC of benefits that have been garnished or transferred to a
former spouse, cturent spouse, or child pursuant to a domestic relations order or child
support order.
8. Compensation and Payment
(a) Participant Fees.Plan participant accounts shall be assessed an asset-based
fee to cover the costs of record-keeping and other services provided by
ICMA-RC, and other costs associated with the Plans as directed by the
Employer.The Employer shall work with ICMA-RC to determine the
appropriate amount of the gross asset-based fee to be charged to participant
accounts,which may be increased or decreased fiom time to time at the
direction of the Employer. At the inception of this contract the participant fee
shall be 0.105%.
(b) Revenue Requirement.ICMA-RC shall receive total annual aggregate
revenue of 0.0350,0 of Plan assets under ICMA-RC's administration for
providing recordkeeping and other services to the Plans. Such revenue shall
be deducted by ICMA-RC from amounts collected through the application of
the asset-based fee described in section 8(a)prior to allocation of any
participant level asset-based fees to the Administrative Allowance Account
described is section 8(c)below.
(c) Administrative Allowance Account.Amounts collected through the
application of the asset-based fee described in section 8(a) above in excess of
the Revenue Requirement specified in subsection 8(b)above, if any, shall be
held in an Administrative Allowance Account(that is maintained as a Plan
asset by ICMA-RC). Employer understands that the Plan administrative
allowance is to be used only to pay for reasonable plan administrative
expenses of the Plan or allocated to Plan participants at the instruction of the
Employer.
(d) Revenue Received From Investment Options.Neither ICMA-RC nor the
Employer shall receive recordkeeping revenue directly from investment
options made available under the Plan. ICMA-RC shall be compensated from
fees collected from participant accounts through the application of the asset-
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• Plan nuruber 301655
based fee described in section 8(a)above.In the event that any Plan
investment options do generate revenue from plan investments,ICMA-RC
shall,as directed by the Employer, credit any and all revenue back to those
participant accounts invested in the option in question.
(e) Compensation for Management Services to VantageTrust,
Compensation for Advisory and other Services to the VT III
Vantagepoint Funds and Payments from Third-Party Mutual Funds.
Employer acknowledges that, in addition to amounts payable under this
Agreement, ICMA-RC receives fees from VantageTnist for investment
advisory services and plan and participant services furnished to
VantageTrust. Employer fiu-ther acknowledges that ICMA-RC, including
certain of its wholly owned subsidiaries, receives compensation for
advisory and other services ftimished to the VT III Vantagepoint Funds,
which serve as the underlying portfolios of a number of Funds offered
through VantageTrust. For a VantageTrust Fund that invests substantially
all of its assets in a third-party mutual find not affiliated with ICMA-RC,
ICMA-RC or its wholly owned subsidiary receives payments from the
third-party mutual fimd families or their service providers in the form of
12b-1 fees, service fees, compensation for sub-accounting and other
services provided based on assets in the underlying third-party mutual
fimd. These fees are described in the VT Disclosures and ICMA-RC's fee
disclosure statement. In addition, to the extent that third party mutual
finds are included in the investment line-up for the Plan,ICMA-RC
receives administrative fees from its third party mutual fund settlement
and clearing agent for providing administrative and other services based
on assets invested in third party mutual finds; such administrative fees
come from payments made by third party mutual finds to the settlement
and clearing agent.
(f) Redemption Fees. Redemption fees imposed by outside mutual finds in
which Plan assets are invested are collected and paid to the mutual fimd by
ICMA-RC. ICMA-RC remits 100010 of redemption fees back to the
specific mutual fund to which redemption fees apply. These redemption
fees and the individual mutual fimd's policy with respect to redemption
fees are specified in the prospectus for the individual mutual find and
referenced in the VT Disclosures.
(g) Phis Fund Share Class. ICMA-RC shall provide the R-12 share class
version of the Plus Fiuud as the stable value investment option in the City
of Kent 457 Plan.
(h) Fees for Investment Advice. ICMA-RC shall waive the standard fee of$20
for participant utilization of the on-line investment advice tool.
(i) Financial Planning Break-Points. The amount of participant assets required
for a participant to receive a written financial plan once annually from ICMA-
RC at no cost shall be as follows:
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Plan number 301655
a. For a fitll financial plan: $100,000 in combined ICMA-RC assets,to
include Plan assets,IRAs and spousal assets held with ICMA-RC.
b. For a goal-speck financial plan: $50,000 in combined ICMA-RC
assets, to include Plan assets, IRAs and spousal assets held with
ICMA-RC
(j} Payment Procedures. All payments to ICMA-RC pursuant to this Section
8 shall be made from Plan assets held by VantageTrust or received from
third-party mutual fimds or their service providers in connection with Plan
assets invested in such third-party mutual fiords, to the extent not paid by
the Employer. The amount of Plan assets administered by ICMA-RC shall
be adjusted as required to reflect any such payments as are made from the
Plan. In the event that the Employer agrees to pay amounts owed pursuant
to this Section 8 directly, any amounts unpaid and outstanding after 30
days of invoice to the Employer shall be withdrawn from Plan assets.
The compensation and payment set forth in this Section 8 are contingent upon the
Employer's use of ICMA-RC's EZLink system for contribution processing and
submitting contribution fiords by ACH or wire transfer on a consistent basis over the
term of this Agreement. The compensation and payment set forth in this Section 8 is
also contingent upon the Vantagepoint PLUS Fund as the sole stable value fund.
The compensation and payment in this Section 8 will take effect July 1, 2019 or the
month following receipt at a Delivery Address (defined below the signature line)if
receipt is after July 1, 2019, of one fiilly executed copy of this Administrative
Services Agreement.
Employer fin-ther acknowledges and agrees that compensation and payment under this
Agreement shall be subject to re-negotiation in the event that the Employer(a)
chooses to implement additional mutual fiends that neither(i)trade via NSCC nor(ii)
meet ICMA-RC's daily trading operational guidelines or(b)chooses to implement
investment options that are not mutual fiends.
8. Contribution Remittance
Employer understands that amounts invested through VantageTrust are to be remitted
directly to VantageTrust in accordance with instructions provided to Employer by ICMA-
RC and are not to be remitted to ICMA-RC. In the event that any check or wire transfer is
incorrectly labeled or transferred to ICMA-RC, ICMA-RC may return it to Employer
with proper instructions.
9. Indemnification
ICMA-RC shall not be responsible for any acts or omissions of any person with respect
to the Plan or its related Lust, other than ICMA-RC in connection with the administration
or operation of the Plan. To the extent allowed by law,Employer shall indemnify ICMA-
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Plan munber 301655
RC against, and hold ICMA-RC harmless from, any and all loss, damage,penalty,
liability, cost, and expense, including without limitation,reasonable attorney's fees, that
may be incurred by, imposed upon,or asserted against ICMA-RC by reason of any claim,
regulatory proceeding, or litigation arising from any act done or omitted to be done by
any individual or person with respect to the Plan or its related trust, excepting only any
and all loss, damage,penalty, liability, cost or expense resulting from ICMA-RC's
negligence, bad faith, or willful misconduct.
10. Tenn
This Agreement shall be in effect and continence on the date all parties have signed and
executed this Agreement ("Inception Date"). The term of this Agreement will continence
on the Inception Date and extend five(5)years from that date. The Employer understands
and agrees that, in the event the Employer terminates this Agreement (or replaces the
Vantagepoint PLUS Fund of VantageTrust as an investment option in its investment line-
up), ICMA-RC retains full discretion to release Plan assets invested in the Vantagepoint
PLUS Fund in an orderly manner over a period of up to 12 months fi-om the date ICMA-
RC receives written notification from the Employer that it is initiating withdrawal of all
or part of the Plans' assets from the VT Vantagepoint PLUS Find.
11. Amendments and Adjustments
(a) This Agreement may be amended by written instrument signed by the parties.
(b)ICMA-RC may modify this agreement by providing 60 days' advance written
notice to the Employer prior to the effective date of such proposed modification.
Such modification shall become effective unless, within the 60-day notice period,
the Employer notifies ICMA-RC in writing that it objects to such modification.
(c) The parties agree that enhancements may be made to administrative services
under this Agreement. The Employer will be notified of enhancements through
the Employer Bulletin, quarterly statements, electronic messages or special
mailings. Likewise, if there are any reductions in fees,these will be announced
through the Employer Bulletin,quarterly statement,electronic messages or
special mailing.
12. Notices
All notices required to be delivered sunder this Agreement shall be in writing and shall be
delivered, mailed, e-mailed or faxed to the location of the relevant party set forth below
or to such other address or to the attention of such other persons as such party may
hereafter specify by notice to the other party.
ICMA-RC: Legal Department, ICMA Retirement Corporation, 777
North Capitol Street,N.E., Saute 600, Washington, D.C._, 20002-4240
Facsimile; (202)962-4601
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Plan number 301655
Employer: at the office set forth it the first paragraph hereof, or to any
other address, facsimile number or e-mail address designated by the
Employer to receive the same by written notice sinularly given.
Each such notice, request or other communication shall be effective: (i) if given by
facsimile, when transmitted to the applicable facsimile number and there is appropriate
confirmation of receipt; (ii) if given by mail or e-mail, upon transmission to the
designated address with no indication that such address is invalid or incorrect; or (iii) if
given by any other means,when actually delivered at the aforesaid address.
13. Complete Agreement
This Agreement shall constitute the complete and full understanding and sole agreement
between ICMA-RC and Employer relating to the object of this Agreement and correctly
sets forth the complete rights,duties and obligations of each party to the other as of its
date. This Agreement supersedes all written and oral agreements,communications or
negotiations among the parties. Any prior agreements,promises, negotiations or
representations,verbal or otherwise,not expressly set forth in this Agreement are of no
force and effect.
14. Titles
The headings of Sections of this Agreement and the headings for each of the attached
schedules are for convenience only and do not define or limit the contents thereof.
15. Incorporation of Exhibits
All Exhibits (and any subsequent amendments thereto), attached hereto,and referenced
herein, are hereby incorporated within this Agreement as if set forth fully herein.
16. Governuig Law
This Agreement shall be governed by and constnied in accordance with the laws of the
State of Washington,applicable to contracts made in that jurisdiction without reference to
its conflicts of laws provisions.
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Plan munber 301655
In Witness Whereof, the parties hereto certify that they have read and understand this
Agreement and all Schedules attached hereto and have caused this Agreement to be
executed by their duly authorized officers as of the Inception Date first above written.
CITY OF KENT
By �.
Signature/Date
By XS
Name and Title (Please Pant)
INTERNATIONAL CITY MANAGEhIENT
ASSOCIATION RETIREMENT CORPORATION
,7
By
Erica Mcfarquhaf
Assistant Secretary
Please return an executed copy of the Agreement to a Delivery Address,either:
(a)Electronically to PlanAdoptionServices aOicmarc_org,or
(b)In paper farm to ICMA-RC
ATTN:PLAN ADOPTION SERVICES
777 North Capitol Street NE
Suite 600
Washington DC 20002-4240
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Plan number 301655
Exhibit A
Administrative Services
The administrative services to be performed by ICMA-RC under this Agreement shall be
as follows:
(a) Participant enrollment services, including providing a welcome package and
enrollment kit containing instnictions and notices necessary to implement the
Plan's administration. Employees will enroll online or through a paper
form. Employer can also enroll employees through EZLink.
(b) Establishment of participant accounts for each employee participating in the Plan for
whom ICMA-RC receives appropriate enrollment instnictions. ICMA-RC is not
responsible for determining if such Plan participants are eligible under the terms of
the Plan.
(c) Allocation in accordance with participant directions received in good order of
individual participant accounts to investment fiuids offered under the Plan.
(d) Maintenance of individual accounts for participants reflecting amounts deferred,
income, gain or loss credited, and amounts distributed as benefits.
(e) Maintenance of records for all participants for whom participant accounts have been
established. These files shall include enrollment instructions(provided to ICMA-
RC through Account Access or EZLunk),beneficiary designation instnictions and all
other documents concerning each participant's account.
(t) Provision of periodic reports to the Employer through EZLink. Participants will
have access to account information through Investor Services,Voice Response
System, Account Access, TextAccess and through quarterly statements that can
be delivered electronically through Account Access or by postal service.
(g) Communication to participants of information regarding their rights and elections
under the Plan.
(h) Making available Investor Services Representatives through a toll-fiee telephone
number from 8:30 a.m. to 9:00 p.m. Eastern Time,Monday through Friday
(excluding holidays and days on which the securities markets or ICMA-RC are
closed for business (including emergency closings)),to assist participants.
(i) Making available access to ICMA-RC's web site, to allow participants to access
certain account information and initiate certain plan transactions at any time.
Account access is normally available 24 hours a day, seven days a week except
during scheduled maintenance periods designed to ensure high-
quality performance. The scheduled maintenance window is outlined
at hgps://haiDerI.icmarc.or /logiu jsy
(j) Maintaining the security and confidentiality of client information through a
system of controls including but not limited to, as appropriate: restricting plan and
participant information only to those who need it to provide services, software
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Plan munber 301655
and hardware security, access controls, data back-up and storage procedures,non-
disclosure agreements, sectnity incident response procedures, and audit reviews.
(k) Making available access to ICMA-RC's plan sponsor EZLink web site to allow
plan sponsors to access certain plan information and initiate plan transactions
such as enrolluig participants and managing contributions at any time. EZLiuk is
normally available 24 hours a day, seven days a week except dining scheduled
maintenance periods designed to ensure high-quality performance. The scheduled
maintenance window is outlined at https://harperl.icmarc orgAogin isp.
(1) Distribution of benefits as agent for the Employer in accordance with terns of the
Plan. Participants who have separated fiom service can request distributions
through Account Access or via form.
(m)Upon approval by the Employer that a domestic relations order is an acceptable
qualified domestic relations order under the terns of the Plan,ICMA-RC will
establish a separate account record for the alternate payee and provide for the
investment and distribution of assets held thereunder.
(n) Loans may be made available on the terms specified in the Loan Guidelines,if loans
are adopted by the Employer. Participants can request loans through Account
Access. If allowed by the City,loans will be available to both active and separated
participants.
(o) Guided Pathways Advisory Services—ICMA-RC's participant advice service,
"Fund Advice", and asset allocation service, "Asset Class Guidance"may be
made available through a third party vendor on the terns specified on ICMA-
RC's website. If allowed by the City, the Guided Pathway Managed Account
Service may be made available to separated/retired employees only. {
(p) ICMA-RC will determine appropriate delivery method(electronic and/or print)
)
for plan sponsor/participant communications and education based on a number of
factors (audience, effectiveness, etc.).
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