To assist recordkeepers in this task, Mid Atlantic has developed the Investment Toolkit. The Toolkit provides the following services:

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1 Overview The new fee disclosure rules have created new responsibilities for plan sponsors and plan service providers. While overall, these new rules should help even the playing field for unbundled or open-architecture recordkeepers, they do create some new and unique challenges for them. These challenges include gathering the required information from their own recordkeeping system, all of the different plan custodians, and detailed investment information. Once gathered, this information must be packaged into compliant summary disclosures for sponsors and participants. To assist recordkeepers in this task, Mid Atlantic has developed the. The Toolkit provides the following services: Investment Data Feed Data for use within your recordkeeping system that includes investment characteristics, performance, benchmarks, investment website, and Mid Atlantic fund rebate levels. This information can be used in your general recordkeeping support of sponsors and participants, including fee disclosures, participant and sponsor web sites, and statements. Investment Fact Sheets Available through a standard web address, for distribution to participants and sponsors. These include a common format for mutual funds, ETF s, and ModelXChange models. Custom fact sheets can also be loaded for other investments for delivery through the Toolkit. Plan Investment Disclosure Report A data reviewed, formatted statement designed to satisfy the investment disclosure requirements under 408(b)2. The report provides summary and investment level breakdowns of fees to the investment issuers, brokers, advisors, the recordkeeper, and the custodian. Plan Investment Option Comparison Report A data reviewed, formatted statement designed to satisfy the participant level fee disclosure requirements under 404(a)5. This report is based on the DOL s model comparative chart and can be private labeled and enhanced with custom content. Plan Investment Glossary A customizable glossary of investment-related terms for disclosures to retirement plan participants that can be used to comply with the DOL regulations. Mid Atlantic will maintain the default glossaries based on the Sample Glossary made available by SPARK/ICI, but you can customize these as needed at a global or plan level. A material amount of the data provided through the is provided by Morningstar. While that data is normalized by Mid Atlantic, it is ultimately proprietary Morningstar data and is subject to Mid Atlantic s agreement with Morningstar. As such, you must sign an addendum to your Mid Atlantic Access Agreement that agrees to the fees for the, royalties to Morningstar, and limitations on how you may redistribute the data or reports accessed through the. Page 1 of 15

2 Investment Data Feed The Investment Data Feed provides a consolidated source of investment data for servicing plan sponsors and participants. Once subscribed to the Toolkit, you have the rights to use the data supplied through the Toolkit to provide most services by third party administrators and recordkeepers, including: fee disclosure documents, participant enrollment kits, participant statements, and participant and sponsor web sites. Mid Atlantic Custody Plans Other Plans Morningstar Data Mid Atlantic Investment Toolkit NSCC Data Fund Rebate Information Mid Atlantic combines our internal data about your plan, data you supply us about plans at other custodians, data provided by the funds through the NSCC, and data provided by Morningstar into a consolidated, normalized data feed. Fund Universe Mutual Funds, Money Market Funds & Exchange Traded Funds The Toolkit includes virtually all of these 40-Act funds through our Morningstar partnership. There is typically no additional information required from you for these investments. Mid Atlantic Collective Funds, Mid Atlantic Unitized Funds, and ModelXChange Funds The Toolkit includes data for all Mid Atlantic sponsored collective funds, as well as any custom funds unitized by Mid Atlantic, and any ModelXChange funds where the model manager has subscribed to our Full-Service solution. Other Investments Mid Atlantic does not actively gather performance and disclosure information for other investments. If you have gathered the information, that information can be maintained within the Toolkit and reported through the Data Feed. Plan Universe Plans in Mid Atlantic Custody For plans in custody or trading through, there is no additional management by you in the Toolkit to maintain the Data Feed. Plans not in Mid Atlantic Custody For plans not in custody at Mid Atlantic, you are required to manage these plans and their lineups through the Toolkit. Page 2 of 15

3 Data Universe The data fields included through the feed include: Data Field General Data Security Ticker Description Family Family Web Site Family Phone Number Mid Atlantic Fact Sheet URL Portfolio Data Asset Type Style/Category Risk Level Objective Strategy Principal Risks Expense Data Total Annual Operating Expenses (% of Assets) Total Annual Operating Expenses per $1,000 Expense / Trading Restriction Disclosure Performance Data Performance Date Performance Source Year to Date Return 1 Year Return 3 Year Return 5 Year Return 10 Year Return Inception to Date Return Description The CUSIP if available, otherwise a unique identifier for the investment. The NASDAQ or NYSE exchange symbol for the investment, if available. The description used by Mid Atlantic for reporting on the investment. For publicly available funds this is typically the name of the fund family. For collective funds, this is the sponsoring trust company. For unitized and ModelXChange funds, this is typically the investment/model manager. A URL which can be used by participants and sponsors for more information about the investment from the fund provider. A telephone number which can be used by participants and sponsors for more information about the investment from the fund provider. A URL which can be used to retrieve the Mid Atlantic Investment Fact Sheet. A general asset type used for classification (Equity Fund, Balanced Fund, Fixed Return Fund, etc.). The investment style/category assigned to the fund (Small-Cap Value, International Fixed Income, etc.). Our universe of categories is the Morningstar category list. A relative ranking of risk from 1 to 5 relating to: Capital Preservation, Income, Balanced, Growth, and Aggressive. A paragraph provided by the issuer (either directly or through prospectus) describing the objective of the fund to investors. A paragraph or two provided by the issuer (either directly or through prospectus) describing the strategy the fund will employ to achieve the objective. A description of the principal risks the investor should consider before investing in this option. The total annual operating expenses of the investment expressed as a percentage of assets (current expense ratio). The total annual operating expenses of the investment expressed as dollars per one thousand dollars invested. A paragraph describing any additional expense disclosures or trading restrictions (redemption fees, round-trip rules, etc.). You may override Mid Atlantic s disclosure with your own disclosure, and your override can be done globally, or for a specific plan. The date for which performance is being provided. The source of the supplied performance data (i.e., Morningstar, Mid Atlantic, Other) Rate of return reported since the beginning of the year. Rate of return reported for the last 12 months. Annualized rate of return reported over the last 3 years. Annualized rate of return reported over the last 5 years. Annualized rate of return reported over the last 10 years. Annualized (if fund is over one year old) rate of return reported since inception of the investment. Page 3 of 15

4 Data Field Inception Date Return Disclosure Description Inception date of the investment. A paragraph describing any additional disclosures about the return calculations or other return considerations. This is typically only used for Fixed Return investments, and other non-40 Act funds. You may override Mid Atlantic s disclosure with your own disclosure, and your override can be done globally, or for a specific plan. Benchmark Data Benchmark Name The name of the benchmark (index). Morningstar publishes a list of primary benchmarks for each of the Morningstar categories. For all investments, we use the Morningstar primary benchmark assigned to the Category assigned to the investment. Year to Date Return Rate of return reported since the beginning of the year. 1 Year Return Rate of return reported for the last 12 months. 3 Year Return Annualized rate of return reported over the last 3 years. 5 Year Return Annualized rate of return reported over the last 5 years. 10 Year Return Annualized rate of return reported over the last 10 years. Fund Rebates / Revenue Sharing 12b-1 Fees The actual amount of 12b-1 (distribution) fees paid by the fund, as reported in the last prospectus (expressed as an annual percentage of assets). Min Asset Based Sub-TA The minimum amount of sub transfer agent and/or shareholder servicing fees paid by the and SSF investment that are based on assets (expressed as an annual percentage of assets). Max Asset Based Sub-TA The maximum amount of sub transfer agent and/or shareholder servicing fees paid by and SSF the investment that are based on assets (expressed as an annual percentage of assets). Min Participant Based Sub- The minimum amount of sub transfer agent and/or shareholder servicing fees paid by the TA and SSF investment that are based on the number of participants invested in the fund (expressed as an annual dollar amount per participant). Max Participant Based Sub- The maximum amount of sub transfer agent and/or shareholder servicing fees paid by TA and SSF the investment that are based on the number of participants invested in the fund (expressed as an annual dollar amount per participant). Note: All Sub-TA and SSF fields will contain the rebates available through the Mid Atlantic platform and will only be provided for plans in custody at Mid Atlantic. If you collect these fees under your own agreement with the provider, you can override this information globally. Delivery The Data Feed is available in an XML format as well as a tab delimited text format. The data feed can be accessed via a web service, available via FTP, or scheduled through Mid Atlantic s Communication Server application. Details on the formats and communications can be found in the Mid Atlantic Data Feed Guide. Page 4 of 15

5 Investment Fact Sheets Mid Atlantic has designed Investment Fact Sheets geared towards participants. These fact sheets are designed to give a common look and feel across different investment types: mutual funds, money market funds, exchange traded funds, collective funds and custom ModelXChange funds. As an example: Page 5 of 15

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7 Investment Fact Sheet Elements Investment Objective / investment Strategy / Principal Risk These required elements provide an overview of the investment, as given by the issuer of the investment. Participants can use this to gain a general understanding of the goals and risks of the fund. Morningstar Category / Benchmark / Risk Level These elements provide information on how this investment would typically be classified and compared against other investments. Participants can use this to gain a general understanding of how to compare this investment to other options and what other investments would be in its peer group. Fund Overview This element provides general information about the investment. Participants can use this to see general characteristics of the investment as well as use the ticker symbol and website to get more information about the investment. Fees & Expenses This element provides information about the fees and expenses of the fund. Participants can use this to understand how expenses may affect their returns and what other fees may apply to them when choosing this investment. Performance Overview Page 7 of 15

8 This element provides historical performance for the fund and its benchmark. Participants can use this to see how the fund has performed historically against its benchmark, and also compare this to performance of other investment options. Hypothetical Growth of $10,000 Initial Investment This element shows a graph of the hypothetical growth of a $10,000 initial investment over the last 10 years. Participants can use this to visually see how the fund has performed over the last 10 years, and also gain a perspective on the volatility of the investment. Risk Analysis This element shows the 3-year Alpha, Beta, R-Squared and Standard Deviation for the investment. Participants can use this to analyze this risk and volatility associated with the investment. Asset Allocation This element shows the allocation of the underlying holdings of the investment option graphed across broad asset classes. Participants can use this to understand how the investment has allocated its underlying holdings. Page 8 of 15

9 Top Holdings / Holdings For 40 Act funds and collective funds (when available), this element will show the top 10 holdings of the fund. For custom funds, this will show all holdings of the fund. Participants can use this to get a better understanding of the types of securities the investment option is using to achieve its objective. Investment Fact Sheet Access These fact sheets can be accessed via TNS, but are also available through a URL that is supplied to you so participants and sponsors access to these fact sheets directly from your website. The URL is static so you can embed it once and any calls to it will provide sponsors or participants with real time versions of the fact sheet. PDF versions are also available from the site and can be run on demand. Page 9 of 15

10 Plan Investment Comparison Report The Plan Investment Comparison Report is designed to assist the plan in fulfilling its responsibilities under the ERISA 404(a) regulations issued by the Department of Labor ( DOL ). More specifically, it is designed to help fulfill the requirement that each employee or beneficiary eligible for the plan must be provided with comprehensive data about each of the plan s investment options. This data requirement includes historical performance, comparable benchmark performance, expense charges and investment restrictions all in a way that allows participants to make meaningful comparisons, in the form of a comparative chart, of their investment alternatives. Report Sections The report contains the following sections: Overview The overview gives the date of the report and contact information for the Recordkeeper / TPA. You can upload your logo, and specify the company name, phone number and web site to be used. Variable Return Investments The first section of the report contains information about variable return investments. The language used in the header comes directly from the DOL s model comparative chart. Variable Return Investments Performance Information This section contains the information for the participant to make a meaningful comparison of the available variable return investment options between each other investments and their associated benchmarks. It also includes the web site the participant can access to get additional information about the fund. Page 10 of 15

11 Variable Return Investments Fee and Expense Information The Variable Return Investments Fee and Expense information shows the annual operating expenses as a percentage of assets, and per $1,000 invested. It also contains a paragraph per investment showing any additional shareholder fees and/or trading restrictions. This disclosure can be overridden globally or at the plan level (i.e., This investment option is no longer open to plan participants for additional contributions. ). The section ends with the DOL s example language about the effect of fees and a link to their publication. Fixed Return Investments The Fixed Return Investments section is available for those options that have a fixed or stated rate of return. Each investment option shows a Return Information disclosure and a Fees and Restrictions disclosure. These disclosures can be overridden globally or at the plan level. Other Investments After the Fixed Return Investments section you have the ability to insert any other investment options that are available to the participant. This may include annuities, brokerage windows, company stock, etc. To do this, you simply create a Word document (.docx), and upload the file to the Toolkit. The upload is done at a global level. Then you attach the document to each plan for which that option is available. Page 11 of 15

12 Investment Fact Sheets The end of the report will contain an Investment Fact Sheet for each investment option in the plan, in the same order they are listed in the earlier sections. You also have the ability to upload a PDF file to be used as a fact sheet for any investment. This is especially useful for the Fixed Return investments. Report Publishing Due to the scrutiny that will be placed on these disclosures, the Plan Investment Comparison Report features automated data scrubbing, audit trails, and monthly history available through the Toolkit. Reports are produced monthly, and will not publish until: - - Recordkeeper s phone and website are entered Performance data for all investment options is current Each investment option has an asset type assigned Each variable return investment has o An investment category defined o Current performance data o A benchmark assigned with current data loaded o A website defined for participants to access additional information Each fixed return investment has o A provided performance disclosure at either the Mid Atlantic, recordkeeper, or plan level o A provided fee and restriction disclosure at either the Mid Atlantic, recordkeeper, or plan level o A website defined for participants to access additional information Additionally, warnings are generated if: - - Each variable return investment does not have o An Objective, Strategy or Principal Risks defined o Turnover data Each fixed return investment does not have: o A loaded custom Investment Fact Sheet You may manually force a report to publish, even with the above conditions, but an audit will be made and all error and warning messages will be saved with the report. This history can be accessed in TNS: Page 12 of 15

13 Report Access These Plan Investment Comparison Reports can be accessed via TNS, but are also available through a URL that is supplied to you so you can provide participants and sponsors access to the most recently published version of the report directly from your website. Page 13 of 15

14 Plan Investment Glossary The Plan Investment Glossary is designed to assist the plan in fulfilling its responsibilities under the ERISA 404(a) regulations issued by the Department of Labor ( DOL ). More specifically, it is designed to help fulfill the requirement that participant-directed retirement plans provide participants access to a glossary of investment-related terms. In response, the non-profit industry organizations, The SPARK Institute ( SPARK ) and the Investment Company Institute ( ICI ), have created a Sample Glossary of Investment-Related Terms for Disclosures to Retirement Plan Participants ( Sample Glossary ). This Sample Glossary has been endorsed by many other non-profit industry organizations. The Sample Glossary serves as a solid base to create a deliverable glossary. However, the Sample Glossary itself must be reformatted for delivery. And as the Sample Glossary is updated, it needs to be maintained. Furthermore, customizations may be required at a plan level. SPARK/ICI made the following note about the Sample Glossary: Certain terms that a particular plan sponsor may want to include in its glossary because of specific plan investment options and other circumstances may not appear. Moreover, none of the definitions represents the only way to define a particular term. Plans using the Glossary may want to customize or modify the language as they deem appropriate. With these challenges, it is easy to see how what most view as relatively mundane requirement that can be solved by providing a link to the Sample Glossary PDF file could easily become a maintenance problem of manually managing a list of custom PDF files. The Toolkit automates this potential burden, allowing you to easily maintain current individual glossaries. Glossary Sections Report Heading The heading displays the plan name, and the logo and contact information for the Recordkeeper / TPA. This is designed to have the same look and feel as the Plan Investment Option Comparison Report. Overview A general overview about the glossary and its suitable use. Defined Terms All of the defined terms for the glossary in alphabetical order, using a three column layout. Disclosures General disclosure information for the protection of your firm and Mid Page 14 of 15

15 Atlantic. Mid Atlantic Maintained Glossaries Mid Atlantic will maintain two publicly available glossaries. The first public glossary will satisfy the needs of most plans, and will contain the all of the defined terms from the Sample Glossary included in Part 1. Part 1 covers a broad group of general investment-related terms. The Toolkit will use this glossary for any plan where another glossary is not explicitly defined. The second public glossary will contain the all of the defined terms from the Sample Glossary included in Part 1 and Part 2. Part 2 covers terms that are specific to insurance products. Custom Glossaries Custom glossaries are easily created by exporting one of the existing glossaries to a spreadsheet, making any additions, deletions, or changes and uploading the spreadsheet back into the Toolkit. Glossary Access These Plan Investment Glossaries are delivered as PDF files and can be accessed via TNS, but are also available through a URL that is supplied to you so you can provide participants and sponsors access to the most recently published version of the report directly from your website. Page 15 of 15