Fund Operating Guidelines for the SSGA US Bank-Maintained Commingled Funds 1

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1 March 2017 Fund Operating Guidelines for the SSGA US Bank-Maintained Commingled Funds 1 Defined Contribution Series Fund Edition Table of Contents 02 Overview & Foreword 02 Section 1. Client Trading 05 Section 2. SSGA Commingled Fund Valuation 05 Section 3. Commingled Fund Security Level Holdings & Other Fund Data 06 Section 4. Income Distributions 06 Section 5. Securities Lending Income 06 Section 6. Audited Financial Statements & Internal Controls Examination 06 Section 7. Class Action Filings & Settlements 06 Section 8. Department of Labor Form 5500 Filings 06 Section 9. Fair Value Pricing 06 Section 10. Commingled Fund Expenses 08 Appendix A. Boston Shareholder Services Team 09 Appendix B. SSGA s NSCC Fund/SERV Processing Procedures & Manual Processing Procedures 13 Appendix C. Sample Manual Trade Ticket 1 These operational guidelines pertain only to our Defined Contribution Series Fund SSGA s US bank-maintained Commingled Funds and do not pertain to any other products managed or advised by SSGA or its affiliates, including, but not limited to, our defined benefit commingled funds, common trust funds, Exchange Traded Funds (ETFs), mutual funds, hedge funds, Canadian pooled funds, or other privately offered funds.

2 Overview The purpose of this document is to provide details on specific operational aspects of your, or your retirement plan clients, investments in our Series Funds (as defined below). In the United States, State Street Global Advisors (SSGA) Trust Company ( SSGA ), a wholly-owned subsidiary of State Street Bank and Trust Company ( State Street ), 2 provides investment management services through bank-maintained collective trust funds (each a Commingled Fund and collectively the Commingled Funds ) with different pricing frequencies and conventions. SSGA s Commingled Funds that are available to retirement plans are referred to as Series Funds. 3 This document is supplemental to the relevant Declaration of Trust, Fund Declaration (including class descriptions, as applicable) and Strategy Disclosure Document (together, the Series Fund Governing Documents ), provided that to the extent that the terms of this document conflict with the terms of any of the Series Fund Governing Documents, the terms of the Series Fund Governing Documents shall control and prevail. Upon request and/or in its discretion, SSGA may choose to waive any of the guidelines outlined below when such waiver will not, in the opinion of SSGA, adversely impact the participants of the Series Fund(s). The decision to waive any such guideline shall rest solely with SSGA. References in this document to our Series Fund participants refer to the retirement plan or plan sponsor, not the individual employee/retiree participants of each plan that is invested in the Series Funds. Foreword Business Days & Holidays Unless otherwise noted herein, any notification, settlement or other deadline specified in this document shall be in Business Days (i.e., Trade Date+1 shall mean Trade Date plus one Business Day). A Business Day is one on which the New York Stock Exchange ( NYSE ) is open. Trade Date ( TD ) is the date of record for the contribution or redemption of the Commingled Fund participant s units. The Series Funds are not priced on NYSE holidays. Furthermore, the US Federal Reserve is closed on certain holidays, such as Columbus Day and Veterans Day, on which the NYSE is open. On such holidays, although the Series Funds will be priced and are open for trading, any trades into/ out of the Series Funds that would have settled on any of these days will settle on the following Business Day unless participants are otherwise notified. 4 The US Bank Maintained Commingled Funds 2017 Holiday Trading Schedule is available on the Client Information section of ssga.com. Account Set-up Timeline SSGA s Know Your Customer ( KYC ) standards are designed to ensure State Street meets or exceeds industry best practice and regulatory requirements. To adhere to our KYC requirements, clients should anticipate providing all requisite documentation to SSGA ten Business Days prior to the first desired Trade Date. Similarly, clients should anticipate executing related contractual documentation ten Business Days prior to the first desired Trade Date. Transaction Security Agreement ( TSA ) In order to transact with SSGA, each account must have on file with us a current, executed TSA. The purpose of the TSA is to seek to protect our clients against fraudulent activity within their accounts. The TSA documents information about the participant account, including the names of the individuals authorized to submit trades to SSGA on behalf of the account, the standing wire instructions for redemptions or liquidations, the typical method of trading, and the names of the individuals authorized to make changes to the information contained in the TSA. Annual confirmation of the client-supplied information on the TSA or changes thereto should be directed to the Client Support Team (see Appendix A). Additionally, SSGA performs an annual review of repetitive wire instructions to verify their validity. Section 1. Client Trading SSGA may choose to waive any of the guidelines outlined below with respect to client trading, in its discretion on a case by case basis, when such waiver will not, in the opinion of SSGA, adversely impact the participants of the Series Fund(s). SSGA shall process all transaction requests on the basis of the account and fund codes contained in the transaction request. In the event of a discrepancy between any name indicated on the transaction request and the codes, the account and fund code shall take precedence and govern. 2 Effective April 1, 2017, State Street has appointed State Street Global Advisors Trust Company, a newly-formed limited purpose non-depository trust company and a wholly-owned subsidiary of State Street, successor trustee of the Commingled Funds pursuant to the Declaration of Trust of the applicable Commingled Fund. 3 These operational guidelines apply to all participants in the Series Funds. While these guidelines refer to defined contribution plan participants, to the extent any other types of clients are eligible pursuant to the Series Fund Governing Documents and become participants in the Series Funds, these guidelines apply equally to such clients. 4 NSCC trades placed on Federal Reserve holidays will settle on the next Business Day on which the Federal Reserve Wire Transfer System is open. State Street Global Advisors 2

3 Instructions received by SSGA shall be considered binding unless subsequent cancellation instructions in good order are received and confirmed as canceled by an authorized SSGA employee prior to the applicable Commingled Fund s standard notification deadline. Revisions or cancellations received thereafter will be reviewed by SSGA in its sole discretion on a case-by-case basis. Absent approval by Client Support at SSGA of the requested change or cancellation, the prior instructions will remain in place. Trade Notification Delivery Mechanisms SSGA s preferred method for receiving instructions for contributions and redemptions in the Series Funds is via National Securities Clearing Corporation ( NSCC ), or in limited instances, via a customized automated transmission. SSGA may also receive instructions via 5 or fax (manual trade instruction), if necessary. Automated Trade Instruction NSCC We offer trading via NSCC for our Series Funds, which have trade notification deadlines (described in detail below) that extend past Trade Date. If you are not currently trading via NSCC and would like to learn more, please contact your SSGA Relationship Team. Appendix B (our NSCC Fund/ SERV Processing Procedures and Manual Processing Procedures) contains information that may be useful in understanding the requirements. Proprietary Trading Feeds For designated trading partners, SSGA has established automated trading feeds. Where NSCC is not a viable trading option and trading volume is sufficient, SSGA may consider establishing inter-company, proprietary trading feeds. Manual Trade Instruction Trading partners who are not members of NSCC may or fax trade instructions to SSGA. Please refer to Appendix C for a sample template. Please be aware that in order for an Instruction to be in good order, all required details must be included on the template rather than within the body of an . Standing instructions for cash wires will need to be established in advance. Trade Notification Deadlines Trade Date is the date of record for the purchase or redemption of the Series Fund s units. All deadlines are stated relative to Trade Date ( TD ), e.g., one Business Day following trade date is TD+1. Instructions in good order received by SSGA Shareholder Services prior to the notification deadlines described below will be executed at the net asset value ( NAV ) of each applicable Series Fund, typically determined as of the close of trading on the Trade Date. Automated Trade Instruction NSCC SSGA begins accepting trades at 2:00 p.m. ET on Trade Date. The last NSCC cycle accepted by SSGA is cycle #10 from 7:00 a.m. ET to 7:30 a.m. ET on TD+1. Please refer to Appendix B for more details. Proprietary Trading Feeds All trades must be received by 8:30 a.m. ET on TD+1, or by the deadline established in a mutually agreed upon operating agreement, if applicable. Manual Trade Instruction The trade notification deadline is 8:30 a.m. ET on TD+1. See Appendix B for additional information. Trades of Significant Size In accordance with the relevant Declaration of Trust for the Commingled Funds, SSGA requests ed notice 15 days in advance of Trade Date for all plan-directed contributions or redemptions that are of significant size, as determined by SSGA in its sole discretion. The thresholds that determine whether a trade is large enough to warrant advanced notice vary by Series Fund and are updated periodically and are available upon request. Participants can assess the likelihood that their transaction may exceed our threshold by comparing their Series Fund units value to the total value of the Series Fund, which is shared monthly via reporting on ssga.com. Upon notification of a pending large trade ed to SSGALargeTradeNotification@ssga.com, SSGA will determine the potential impact on the Commingled Fund(s) and coordinate an appropriate implementation strategy that seeks to ensure that other participants in the Commingled Fund(s) are not adversely affected. Our implementation strategy may warrant investing/raising cash prior to TD+1; if so, SSGA will seek written instructions from the plan sponsor to act accordingly. Please note that under the terms of the relevant Declaration of Trust, SSGA as trustee reserves the right to satisfy redemptions in-kind, in a combination of cash and in-kind, solely in cash, may move assets into a segregated account, or delay settlement. Additionally, per the relevant Declaration of Trust, brokerage fees and other expenses incurred in connection with the purchase or sale of securities relating to or arising out of the deposit of assets in a Series Fund or the withdrawal of assets from a Series Fund by a client may, at SSGA s discretion, be charged directly to the client. 5 By use of all forms of electronic transmission of information, including , each Commingled Fund participant accepts the risks associated with such transmissions and authorizes the use of such electronic communications. Each Commingled Fund participant will be responsible for protecting its own systems and interests in relation to electronic communications and neither SSGA nor State Street shall have any liability to such Commingled Fund participant or any other party, whether in contract, tort (including negligence) or otherwise, in respect of any error, damage, loss or omission arising from the interception, corruption, loss, destruction, late or incomplete arrival of information communicated electronically or from information communicated electronically being otherwise adversely affected or unsafe to use. State Street Global Advisors 3

4 The charge may be applied either by a corresponding unit adjustment or by a direct invoice. In cases where a retirement plan is structured to include a predetermined rebalance trading schedule (e.g. monthly, quarterly, annually) SSGA will work with a combination of the client, recordkeeper, TPA, custodian, and/or external advisor to review and approve a standing procedure that addresses notification, trade submission, and trade settlement. Confirmation of Trades/Activity Reporting Automated Trade Confirmation NSCC Confirmation SSGA promptly confirms trades via NSCC provided that our nightly pricing cycle has been completed. For example, if pricing is completed at 6:30 p.m. ET, confirmations for trades received prior to 6:30 p.m. will be withheld until that time. Confirmations for trades received after the time that pricing has been completed will normally be sent immediately. Amendments to trades by SSGA, for any reason, after NSCC confirmation statements have been processed for the applicable time period will normally be released to the client or their designated trade confirmation contact via fax or . Proprietary Trading Feeds Confirmation Upon receipt of the trading data feed, SSGA promptly sends an automated response confirming receipt and processing of trades. Manual Trade Confirmation Letters of Direction ( LODs ) transmitted via will receive an auto-reply message confirming receipt of the . Please note that this auto-reply does not constitute the trade confirmation, only that the trade instruction has been received. If an receipt is not received within 10 minutes, please contact SSGA Shareholder Services for more details (see Appendix A for contact information). Regardless of the LOD transmission method, a trade confirmation is sent to the address(es) that SSGA has on file once the instruction has been audited by the SSGA Shareholder Services Team and has been entered into SSGA s point of entry trade system. This is the trade confirmation and will include trade details as specified in the LOD. Recipients of this should review this message to ensure we have captured the trade(s) per your intent. If you do not receive a trade confirmation by Noon ET on TD+1, contact the respective Client Support Team (see Appendix A for contact information). In the absence of a response to our confirmation, the trades contained in the confirmation will be considered final and conclusive. Furthermore, if you have elected not to receive trade confirmation s, you will still receive a post-execution trade activity report as described below. Opting not to receive confirmation s may mean that you may not be able to identify any issues with your intended trade(s) prior to execution, and therefore the trades as processed will be considered final and conclusive. Post-execution, a trade activity report is provided via fax or on TD+1 and is available on the Client Information section of ssga.com (hereafter ssga.com). Confirmation of execution of instructions shall be provided within 24 hours of execution or pricing, whichever is later. SSGA trade confirmations shall be deemed accurate unless written notification is provided to SSGA within three (3) business days of receipt of the trade activity report. Report recipients are designated at the time the account is established by the client or a retirement plan s external service provider. The client or plan s external service provider may request updates to the distribution list at any time by contacting the SSGA Client Support Team (see Appendix A). Please note that these faxed or ed trade confirmations are the only available format if an SSGA account has been revised more than 24 hours past Trade Date. Revised account data will not be reported through NSCC or via proprietary feeds. If you do not receive a trade confirmation or cannot access ssga.com, contact the SSGA Client Support Team (see Appendix A). Trade Settlement Wire instructions for our Series Funds are available by contacting the Client Support Team. Please be advised that any wire instructions you receive from SSGA will be to State Street Bank and Trust Company with an ABA number of Settlement of cash related to buys into Series Funds is due on TD+1 prior to the daily close of the FedWire Funds Service. Redemptions and liquidations from our Series Funds normally will settle on TD+1 in order to facilitate smooth transitions for the defined contribution plan sponsor and the plan s employee/retiree participants. Please note that although the circumstances that may delay settlement beyond TD+1 are rare, our Series Fund Governing Documents do allow for delayed settlement. Wires for redemptions will be sent by 6:00 p.m. ET on settlement date. We may be able to send wires earlier in the day on a best-efforts basis upon request. Please contact the SSGA Client Support Team if you have further questions. Automated Trade Settlement NSCC Settlement will be facilitated by NSCC, via their net settlement process. State Street Global Advisors 4

5 Proprietary Trading Feeds Settlement Proceeds from redemptions and liquidations will be sent in accordance with the standing wire instructions on file per the TSA. Manual Trade Settlement In the event that a manual trade becomes necessary (NSSC trade failure or technology failure of some nature) proceeds from redemptions and liquidations will be sent to the standing wire instructions on file per the TSA. Trades for accounts with no standing wire instructions must include wire instructions on any request for a redemption or liquidation. In-Kind Contributions & Redemptions Clients contemplating in-kind transactions should contact the Client Support Team (see Appendix A for contact information) in advance to discuss the parameters (i.e., date, amount, fund, direction). SSGA, in its sole discretion, also reserves the right to approve or reject client requests for in-kind contributions and redemptions from the Series Funds. Please be advised that SSGA will require execution of a Non-Disclosure Agreement before sharing a buy-list or carve-out of securities held within the Commingled Funds. Pursuant to the relevant Declaration of Trust, SSGA may require securities to be delivered in-kind in response to a contribution or redemption request that is of significant size relative to the Series Fund(s). Please note, for in-kind contributions and redemptions, participants will receive a transaction value using the closing market value on TD of the in-kind securities, as determined by SSGA using its standard pricing sources, as described in the valuation section in the relevant Declaration of Trust. SSGA requires receipt of a certified asset list, via soft copy in Excel and signed or fax, by 3:00 p.m. ET on TD-1 from the transition manager, custodian or any other authorized party indicated in the LOD for in-kind contributions. Notification regarding either the estimated size of any cash component of the in-kind trade, or its final value if known, is due one day earlier (TD-2), also via soft copy and signed or fax. Please note that tendered certified asset lists and cash amounts shall be considered binding. Operational Contacts Client Trading Inquiries The communication of client trading (redemption/ purchase activity) is managed by SSGA s Client Trading Team (see Appendix A). General Operational Inquiries Other questions of an operational nature can be addressed to SSGA s Client Advocacy Team within North America Investment Operations at ssga-gioclientadvocacy@ssga.com. Section 2. SSGA Commingled Fund Valuation SSGA employs best efforts to communicate Commingled Fund unit prices or NAVs each Business Day by 6:30 p.m. ET. NAVs are communicated via . NAVs are also available via NSCC (provided that your organization trades with SSGA via NSCC) and on ssga.com. Valuation Errors If SSGA determines that a NAV previously reported was materially incorrect, we will communicate a revised NAV. On these occasions, all transaction activity within the Commingled Funds is automatically reprocessed by SSGA at the revised NAV. SSGA recognizes the inconvenience and trade reprocessing requirements that may arise as a result of a revised NAV. SSGA will review client claims and claims made on their behalf relating to trade reprocessing that is a direct result of a revised NAV, provided that all such requests are communicated to SSGA in writing within 60 days of notification of the NAV error. Your SSGA Client Service Manager can assist you by providing a list of necessary information for claim submission and in submitting any such claim. Section 3. Commingled Fund Security Level Holdings A list of the holdings of a Commingled Fund, including the number of participants in such Commingled Fund, is posted on a monthly basis on ssga.com. The files are available by the 5th Business Day post month-end. SSGA maintains a Portfolio Holdings Policy designed to provide reasonable assurance that only appropriate disclosure of non-public information related to the securities holdings of SSGA-managed portfolios occurs. In conjunction with this Policy, SSGA requires non-disclosure agreements to be in place with transition managers or other managers (i.e. other management firms who will receive SSGA-managed portfolio asset lists) prior to providing security lists for the Commingled Funds. This Policy is intended to ensure that all asset owner and vendor information is only disseminated to the appropriate parties and that SSGA maintains control over sensitive data. As a reminder, participants of the Series Funds own an undivided proportionate beneficial interest in all of the assets and liabilities of the Series Fund. This proportionate interest is represented by units. State Street Global Advisors 5

6 Section 4. Income Distributions Except for our Cash Series Funds, income is not distributed to participants and accumulates in the Series Fund, contributing to the Series Fund s NAV and unit price. A limited number of Series Funds, however, operate with a daily income accrual or interest rate factor, and in these cases income is generally credited to participant accounts monthly, on the last Business Day of each month. Section 5. Securities Lending Income For those clients participating in Series Funds that engage in securities lending, the lending income earned by the Series Fund is shared with the participants as outlined in the relevant Fund Declaration. For our Series Funds, securities lending income is not distributed to participants, but is regularly reinvested into the Series Fund, contributing to the Series Fund s NAV and unit price. Section 6. Audited Financial Statements & Internal Controls Examination The Series Funds are audited annually by an independent external auditor and operate on a December 31 fiscal yearend schedule. The audited financial statements are typically available during mid-april of the following year and posted on ssga.com soon thereafter. SSGA s internal controls are audited annually by an independent external auditor for the 12-month period ended June 30. Our Service Organization Controls 1 (SOC 1, formerly a SAS-70 Type II or SSAE 16) report is typically available in late August of the same calendar year. Copies may be obtained by contacting your SSGA Client Service Manager. Section 7. Class Action Filings & Settlements For information on class action filings and settlements please refer to the US Essential SSGA brochure. Section 8. Department of Labor Form 5500 Filings Plan sponsors who file an information return ( Form 5500 ) for an employee benefit plan covered, or electing coverage, by the Employment Retirement Income Security Act of 1974 ( ERISA ) may need to report additional information to the Department of Labor ( DOL ) regarding plan investments in Commingled Funds known as Direct Filing Entities ( DFEs ). State Street will file on behalf of our DFEs with the DOL each applicable calendar year in accordance with the Form 5500 instructions. Please note that the DOL s instructions for Form 5500 indicate that certain interest-bearing investments, such as SSGA s short-term investment fund strategies and Cash Series Funds are to be reported as Interest Bearing Cash Accounts on Schedule H of Form 5500 rather than as an interest in a collective trust fund. As a result, certain short-term cash Series Funds have been categorized as Interest Bearing Cash Accounts and do not make a direct filing with the DOL. Section 9. Fair Value Pricing In order to ensure equitable treatment for participants in the Series Funds and in accordance with SSGA s fair value procedures, SSGA may adjust security valuations to estimate a security s fair value if market quotations are not readily available for a security or if subsequent events suggest that a market quotation is not reliable. The effect of fair value pricing is that securities may not be priced on the basis of quotations from the primary market in which they are traded or on recent or closing market prices, but rather may be priced by another method that SSGA believes reflects fair value. SSGA may use a number of factors to calculate the fair value of a security or may employ a third-party service to estimate fair value adjustments to the local closing prices. By its nature, a fair value price is a good faith estimate of the valuation in a current sale and may differ from the market price realized in an actual sale. To the extent applicable, SSGA s decision to fair value may cause unanticipated tracking error as a Series Fund s performance benchmark index may not reflect the same fair value determinations. For more information about SSGA s fair value pricing, please contact your SSGA Relationship Team. Section 10. Commingled Fund Fees & Expenses There are a variety of direct and indirect fees and expenses that may be incurred related to operating SSGA Series Funds. A brief summary of certain of these expenses is provided below. More information about the composition of a Series Fund s fees and expenses is available in the Series Fund s class description, Fund Declaration, most recent audited financial statement and in SSGA s reports provided in accordance with ERISA Section 404(a). Total Annual Operating Expense Ratio Effective January 1, 2016, each Series Fund (excluding our Cash Series Funds) operates with a fixed, not variable, total annual operating expense ratio which is stated for each Series Fund in its respective class description. The expense ratio is comprised of direct and, if applicable, indirect expenses. Direct fees and expenses ( Direct Expenses ) may State Street Global Advisors 6

7 include, among others, audit, custody, service, administration, and legal fees. The investment management fee, if assessed outside the Series Fund, is not included as part of the Direct Expenses and a portion (which may vary) may be paid to third-parties or intermediaries. In addition, Series Funds, if applicable, indirectly bear a proportional share of the fees and expenses of other SSGA funds in which the Series Fund invests ( Indirect Expenses ). Audit Fee A fee is accrued daily to cover the cost of each Series Fund s annual audit. The Series Fund s annual audited financial statement indicates the actual amount charged to the Series Fund. Custody (Transaction) Fees Each time a security is bought or sold within a Series Fund or received in or delivered out in-kind, the Series Fund s custodian receives a fee to record and settle each trade. The cost per security transaction largely depends on whether the securities traded are US securities, non-us securities or emerging market securities. Each Series Fund s applicable Fund Declaration includes a schedule that states the particular rate that is charged to the Series Fund to cover these costs. These charges are a component of the Total Annual Operating Expense Ratio discussed above. Other transaction costs (including, for example, brokerage costs and taxes, if any) are not reflected in either the Net or Gross Total Annual Operating Expense Ratio but are reflected in the performance returns of the Series Funds. Third-party Service Fees Our Series Funds may pay compensation to third parties or intermediaries for services that include, but are not limited to, record keeping, asset servicing, sub-accounting and communication services to plans invested in the Series Funds. Such fees, if any, are typically accrued daily as a fund expense and disclosed in the Series Fund s Fund Declaration and class description. Administration Fee The administration fee includes fees and expenses paid by the Series Funds to the Trustee or its affiliates relating to the provision of custody, bookkeeping and accounting services, shareholder servicing, transfer agency and other services that the Trustee may from time to time consider necessary or appropriate. The fee is either a set basis point rate or, if the majority of the Series Fund s assets are invested in other Commingled Funds or in derivatives, the fee is a set dollar amount. Each Series Fund s applicable Fund Declaration and Class Description set forth the administration fee charged to each class of such Series Fund and the Series Fund s annual audited financial statement indicates the actual amount charged to each class of the Series Fund. Investment Management Fees Investment management fees may either be paid outside of a Series Fund or may accrue and be paid directly from such Series Fund (each such Series Fund, a Net of Fee Fund ). For all Net of Fee Funds, the investment management fee is captured in the Total Annual Operating Expense Ratio. Other Fees & Expenses The Series Funds may also accrue and/or incur other fees or expense in addition to those noted above. Examples of such other charges include, without limitation, index fees and the anti-dilution levy we call market effect that applies to certain contributions or withdrawals from our Commingled Funds. Please refer to the Series Fund Governing Documents and the Series Fund s most recent annual audited financial statement for additional information. State Street Global Advisors 7

8 Appendix A. Boston Shareholder Services Team Contact Details Client Support Team Hours of Operation 8:00 am 7:30 pm ET Telephone LODS (5637) Fax for Inquiries Defined Contribution Trading & Pricing Fax for Inquiries for Trade Communication Name Telephone Hours (ET) Anthony Marchesiani (Team Leader) :00 am 3:30 pm Daniel Connors :30 am 5:00 pm Ken Li :00 am 3:30 pm Amy Liang :00 am 3:30 pm Jean-Claude Mulemba :00 am 5:30 pm Alexia Saengsavang :00 am 3:30 pm For all pricing and trading related inquiries after 3:00 pm (ET), please contact the Client Support Team. State Street Global Advisors 8

9 Appendix B. SSGA s NSCC Fund/SERV Processing Procedures & Manual Processing Procedures General Information The purchase, redemption and settlement of units of Series Funds will normally follow the Fund/SERV Processing Procedures set forth below, and the rules and procedures of the NSCC shall govern the purchase, redemption and settlement of units through NSCC by the retirement plan s Trading Agent (as defined in the TSA), typically the plan s recordkeeper or third party administrator. In the event of equipment failure or technical malfunctions or the parties inability to otherwise perform transactions pursuant to the FUND/SERV Processing Procedures, or the parties mutual consent to use manual processing, the Manual Processing Procedures below will apply. Receipt by the Trading Agent or recordkeeper of any instructions from the retirement plan s employee/retiree participants prior to the close of trading on any Business Day shall be deemed to be receipt by SSGA of such instructions solely for pricing purposes and shall cause purchases and sales to be deemed to occur at the unit price for such Business Day, except as provided in 3(c) of the Manual Processing Procedures. Each instruction shall be deemed to be accompanied by a representation by the Trading Agent that it has received proper authorization from each plan participant whose purchase or redemption transaction is effected as a result of such instruction. If the employee/retiree participant, Trading Agent or any person or entity with investment authority on behalf of such participant is, or may be, following a market-timing strategy or is, or may be, otherwise engaged in excessive trading or illegal activities as determined in the sole discretion of SSGA, SSGA may cause or require such participant or any person or entity with investment authority on behalf of such participant to (i) suspend purchases and/or withdrawal of units on a temporary basis, (ii) cease any additional purchases of units of a Series Fund for a specified period of time or on a permanent basis, (iii) withdraw some or all of its units from a Series Fund, and/or (iv) liquidate sufficient units of any such participant (including those attributable to any person or entity that directed or engaged in the conduct described above) and apply all or part of the net proceeds realized upon such liquidation to satisfy and/ or reimburse the Series Fund for any losses or damages suffered by the Series Fund. Information Required for Establishing Trading via NSCC 1. SSGA supports DTCC s Fund/ SERV transaction processing, Mutual Fund Profile (MFP) Daily Price and Rate file, Networking Position and Activity files and Defined Contribution Clearance & Settlement (DCC&S) service level SSGA s Firm Number is SSGA will require the Trading Agent s NSCC Firm Code so that we may link the client s account(s) within our internal record keeping system to receive and confirm trades back to the Trading Agent. 4. In advance of the on-boarding of the client s assets, a Client Implementation Officer will be assigned to the event to operationally assist the Trading Agent, including an initial test trade. 5. In advance of the first Trade Date, SSGA and the Trading Agent will directly coordinate agreement on which day will be the first Trade Date and Settlement Date. When Trading with State Street Global Advisors, the Following Rules Apply: 1. The Trading Agent may send daily trades via NSCC as early as 2:00 p.m. ET on TD but not later than 7:30 a.m. ET (typically Cycle #10) on TD+1 for value as of Trade Date. 2. The Trading Agent shall not cancel trades after 7 a.m. ET on T All account and fund codes must be sent in Upper Case Letters. 4. The sender needs to use Code 0 in the Book/Physical Share Indicator Field in order for the trades to settle. A settlement override can also be used to settle the trades. 5. We can accept Record Types of 001 or 004. a. If trades are sent between 2:00 p.m. ET and 7:30 p.m. ET on TD they must be sent as 001 and the AutoRoute file ID is a. If trades are sent between 7:30 p.m. ET and 8:00 p.m. ET on TD they must be sent as 001 and the AutoRoute file ID is b. If trades are sent between 8:00 p.m. ET and Midnight ET on TD they must be sent as 001 and the AutoRoute file ID is c. If trades are sent between 2:00 a.m. ET and 7:30 a.m. ET on TD+1 they must be sent as 004 and the AutoRoute file ID is If the Trading Agent is unable to trade with us before 7:00 a.m. ET on TD+1 via NSCC, there is an 8:30 a.m. ET on TD+1 deadline for manual processing. The trade ticket needs to include: TD, SSGA fund code, SSGA account code, dollar amount and transaction type. The trade ticket should also be signed by an authorized signer per the TSA. Wire Instructions should be included if the transaction type is a sell, unit sell or liquidation. Trades can be ed to SSGATradeInstruct@ssga.com or faxed to the Shareholder Services Team at ed instructions must include a signed LOD as an attachment. State Street Global Advisors 9

10 7. In the event of a discrepancy between any account or fund name indicated on the transaction request and the account and fund codes, the account and fund codes shall take precedence and govern. 8. SSGA cannot accept on-line registrations using B50 records because a physical contract between the client and SSGA must first be in place. 9. Please note that selling down positions to zero dollars may cause a rejection due to rounding differences SSGA reserves the right, in its sole discretion, to decline to process or delay the processing of an instruction which, if a transaction request, (a) is in excess of the actual balance in the Account (defined as a particular group of assets identified by a single account number) to be charged at the time SSGA is in receipt of such transaction request, or (b) if initiating such transaction request would cause SSGA, in SSGA s sole judgment, to exceed any wire transfer limits which are applicable to SSGA. Furthermore, SSGA reserves the right to decline to process or delay the processing of an instruction if SSGA, in good faith, is unable to satisfy itself that the instruction has been properly authorized. 11. SSGA shall use reasonable efforts to act on authorized requests to cancel or amend Instructions received in compliance with the Security Procedure (as defined in the TSA) that has been elected on the client s TSA, provided that such requests are received in a timely manner. However, SSGA assumes no liability if the request for amendment or cancellation cannot be satisfied. 12. SSGA shall assume no responsibility for failure to detect any erroneous instruction provided that SSGA complies with the Instruction (as defined in the TSA) as received and SSGA complies with the Security Procedure. The Security Procedure is established for the purpose of authenticating instructions only and not the detection of errors in instructions. 13. The Trading Agent or its designees shall maintain records sufficient to identify the date and time of receipt of all employee/retiree participant or plandirected transactions involving the Series Funds and shall make or cause such records to be made available upon reasonable request for examination by the Series Funds or its designated representative or, by appropriate governmental authorities. Unless it is required to restrict or prohibit an employee/retiree participant from purchasing or exchanging units of a Series Fund pursuant to applicable law or other legal agreement, Trading Agent shall not change, alter or modify any Instructions received by it in good order. Should your NSCC Trade be Rejected, Please Know the Following: 1. The Trading Agent should not resubmit the trade via NSCC, particularly if Cycle 10 has past. Resubmitting the trade will very likely generate another rejection. Instead, the Trading Agent should revert to a manual process and submit the trade to us via fax or . See #6 above. 2. As a courtesy, SSGA will contact the Trading Agent on a best efforts basis to encourage the sender to submit a new trade to SSGA via fax. Refer to the instructions above in #6. The Trading Agent is strongly encouraged to call one of the SSGA contacts listed in Appendix A once an NSCC rejection has been detected. 3. SSGA does not offer price protection. All trades must be received in good order by 8:30 a.m. ET on TD+1. Fund/SERV Processing Procedures 1. On each Business Day, SSGA shall accept, and effect changes in its records upon receipt of purchase and redemption instructions from the Trading Agent electronically through Fund/SERV ( Instructions ) without supporting documentation from the participant. On each Business Day, SSGA shall accept for processing any Instructions from the Trading Agent and shall process such Instructions in a timely manner. 2. SSGA shall perform any and all duties, functions, procedures and responsibilities established by the NSCC. SSGA shall conduct each of the foregoing activities in a competent manner and in compliance with (a) all applicable laws, rules and regulations, including NSCC Fund/SERV rules and procedures relating to Fund/ SERV; (b) the then-current relevant Fund Declaration and class description relating to the applicable Series Fund; and (c) any provision relating to Fund/SERV in any other agreement of SSGA that would affect its duties and obligations. 3. Confirmed trades and any other information provided by SSGA to the Trading Agent through Fund/SERV shall be accurate, complete and in the format prescribed by the NSCC. 4. Trade information provided by the Trading Agent to SSGA through Fund/SERV shall be accurate, complete and in the format prescribed by the NSCC. All Instructions by the Trading Agent regarding each Fund/ SERV Account shall be true and correct and will have been duly authorized by the registered holder. 5. For each Fund/SERV transaction, the Trading Agent shall provide SSGA with all information necessary or appropriate to establish and maintain each Fund/ SERV transaction (and any subsequent changes to such State Street Global Advisors 10

11 information), which the Trading Agent hereby certifies is and shall remain true and correct. The Trading Agent shall maintain documents required by the Series Funds to effect Fund/ SERV transactions. The Trading Agent certifies that all Instructions delivered to SSGA on any Business Day shall have been received by Trading Agent or recordkeeper from the retirement plan s employee/ retiree participants or from the retirement plan by the close of trading (generally 4:00 p.m. ET) on the NYSE (the Close of Trading ) on such Business Day and that any Instructions received by it after the Close of Trading on any given Business Day will be transmitted to SSGA on the next Business Day. Manual Processing Procedures 1. On each Business Day, the Trading Agent or recordkeeper may receive Instructions from the retirement plan s employee/retiree participants for the purchase or redemption of units of the Series Funds based solely upon receipt of such Instructions prior to the Close of Trading on that Business Day. Instructions in good order received by the Trading Agent or recordkeeper prior to the Close of Trading on any given Business Day (generally, 4:00 p.m. ET) and transmitted to SSGA by no later than 8:30 a.m. ET the Business Day following the Trade Date ( Trade Date plus One or TD+1 ), will be executed at the NAV ( Unit Price ) of each applicable Series Fund, determined as of the Close of Trading on the Trade Date. 2. By 6:30 p.m. ET on each Trade Date ( Price Communication Time ), SSGA will use its best efforts to communicate to the Trading Agent and/or recordkeeper via electronic transmission acceptable to all parties, the Unit Price of each applicable Series Fund, as well as dividend and capital gain information and, in the case of Series Funds that credit a daily dividend, the daily accrual or interest rate factor, determined at the Close of Trading on that Trade Date. 3. As noted in Paragraph 1 above, by 8:30 a.m. ET on TD+1 ( Instruction Cutoff Time ) and after the Trading Agent has processed all approved transactions, the Trading Agent will transmit to SSGA, via electronic transmission acceptable to all parties, a report (the Instruction Report ) detailing the Instructions that were received by Trading Agent or recordkeeper prior to the Series Funds daily determination of Unit Price for each Series Fund (i.e., the Close of Trading) on Trade Date. a. It is understood by the parties that all Instructions from the plan s employee/retiree participants shall be received and processed by the Trading Agent in accordance with its standard transaction processing procedures. b. Following the completion of the transmission of any Instructions by the Trading Agent to SSGA by the Instruction Cutoff Time, the Trading Agent will verify that the Instruction was received by SSGA. c. In the event that an Instruction transmitted by the Trading Agent on any Business Day is not received by SSGA by the Instruction Cutoff Time, due to mechanical difficulties or for any other reason beyond the Trading Agent s reasonable control, such Instruction may nonetheless be treated by SSGA, in its discretion, as if it had been received by the Instruction Cutoff Time, provided that the Trading Agent retransmits such Instruction and telephones SSGA s Shareholder Services Team prior to 8:30 a.m. ET on TD+1 that an electronic transmission concerning the Instruction will be sent and such Instruction is received by Shareholder Services no later than 9:00 a.m. ET on TD+1. d. With respect to all Instructions, SSGA s Shareholder Services will manually adjust a Series Fund s records for the Trade Date to reflect any Instructions sent by the Trading Agent. e. By no later than 4:00 p.m. on TD+1, and based on the information transmitted to SSGA pursuant to Paragraph 3(c) above, the Trading Agent will use its best efforts to verify that all Instructions provided to SSGA on TD+1 were accurately received and that the trades for each account were accurately completed and the Trading Agent will use its best efforts to notify SSGA of any discrepancies. 4. As set forth below, upon the timely receipt from the Trading Agent of the Instructions, the Series Fund will execute the purchase or redemption transactions (as the case may be) at the Unit Price for each Series Fund computed as of the Close of Trading on the Trade Date. a. Except as otherwise provided herein, all purchase and redemption transactions will settle on TD+1. Settlements will be made through net Federal Wire transfers to an omnibus settlement account if for a trade that typically would have been sent via NSCC, or to an account for the designated Series Fund or customized strategies that require detailed allocations of assets if for a trade that is routinely processed via fax or . In the case of Instructions which constitute a net purchase order, settlement shall occur by the Trading Agent or its designee initiating a wire transfer by 1:00 p.m. ET on TD+1 to the custodian for the Series Fund for receipt by the Series Funds custodian by no later than the Close of Business at the New York Federal Reserve Bank on TD+1, using its reasonable best efforts to cause the remittance of the requisite funds to SSGA to cover such net purchase order. In the case of Instructions which constitute a net redemption order, settlement shall occur by SSGA State Street Global Advisors 11

12 using its reasonable best efforts to cause the remittance of the requisite funds to cover such net redemption order by Federal Funds Wire on TD+1, provided that the Series Fund reserves the right to (i) delay settlement of redemptions for up to seven (7) Business Days after receiving a net redemption order, or (ii) suspend redemptions as required by law or otherwise defined under the terms of the Series Funds relevant Declaration of Trust or other Series Fund Governing Documents. Settlements shall be in US dollars. b. SSGA will provide the Trading Agent with all written confirmations required under federal and state securities laws. c. On any Business Day when the Federal Reserve Wire Transfer System is closed, all communication and processing rules will be suspended for the settlement of Instructions. Instructions will be settled on the next Business Day on which the Federal Reserve Wire Transfer System is open. The original TD+1 Settlement Date will not apply. Rather, for purposes of this Paragraph 4(c) only, the Settlement Date will be the date on which the Instruction settles. d. The Trading Agent shall, upon receipt of any confirmation or statement concerning the accounts by such method acceptable to SSGA and the Trading Agent, verify the accuracy of the information contained therein against the information contained in the Trading Agent s internal record-keeping system and shall promptly advise SSGA in writing of any discrepancies between such information. SSGA and the Trading Agent shall cooperate to resolve any such discrepancies as soon as reasonably practicable. State Street Global Advisors 12

13 Appendix C. Sample Manual Trade Ticket For Series Funds Only State Street Global Advisors State Street Financial Center One Lincoln Street Boston, MA Attention: SSGA Boston Shareholder Services Revision Dear State Street Global Advisors: Requests the below transaction: Trade Date Transaction Cash Contribution/Cash Withdrawal/Unit Buy/Unit Sell/Full Liquidation (select one) SSGA Fund Name SSGA Fund Code SSGA Account Code Amount Standing instructions already on file will be followed in all cases except for NSCC correcting trades or full account liquidations. Instructions For Corrections or Full Liquidations Only Receiving Custodian/Bank Name (including location) Receiving Custodian/Bank ABA # Beneficiary Account Name Beneficiary Account Number (DDA) Beneficiary Location Further Credit Beneficiary Further Credit Account Number Reference Information: Special Instructions: We understand that this letter should be signed and either faxed to the SSGA Shareholder Services Team at the fax number listed below or scanned and ed to the address below by the deadlines outlined in the Fund Operating Guidelines. SSGAtradeinstruct@ssga.com Fax: Payment for contributions is due to SSGA on trade date + one business day. Should there be any impact because of the delay in the receipt of payment, SSGA will seek funding for the impact and will not be responsible for any market impact that results from a delay in payment. We understand that SSGA is providing this template in order to ensure that all required information is included in the trade request. Before signing and returning the letter, we have reviewed it for accuracy and completeness and ensured that all instructions, as they appear, match our intent. We understand that SSGA will not be responsible for any inaccurate or incomplete information. Unless otherwise requested in the Special Instructions field, we understand and agree that to the extent this Transaction is a Redemption of all of our interests in the SSGA Fund (i.e., a full liquidation), our SSGA Account will be closed. Sincerely yours, Authorized Signature (per Transaction Security Agreement) Date State Street Global Advisors 13