Track One: ESOP Administration/Distribution Basics

Transcription

1 Track One: ESOP Administration/Distribution Basics The California/Western States Chapter of The ESOP Association: The 2018 Chapter Conference Thursday, October 4, :15 p.m. 4:15 p.m. Presented by: Debra Stoll Vice President National ESOP Relationship Management Principal Financial Group Wanda Taylor Senior ESOP Analyst

2 Overview Introduction to the Annual ESOP Administration Process Administrative Calendar Sample ESOP Statement of Accounts ESOP Benefit Payments Proactive Measures for Compliance in ESOP Administration 2

3 Introduction to the Annual ESOP Administration Process Importance: Required to Address Mandatory ESOP Disclosure Obligations of the ESOP Plan Administrator Internal Revenue Service ( IRS ) Form 5500 Annual ESOP Statements of Accounts Summary Annual Report Required to Appropriately Calculate Eligible ESOP Benefit Payments 3

4 Introduction to the Annual ESOP Administration Process (Cont.) What ESOP Administration Entails: Trust Accounting ESOP Allocations ESOP Compliance Testing ESOP Plan Audit (as applicable) Participant Statements ESOP Benefit Payments 4

5 Introduction to the Annual ESOP Administration Process (Cont.) Parties Involved in ESOP Administration: Plan Sponsor Responsible for providing the ESOP s Independent Appraiser and Financial Advisor ( ESOP Appraiser ) with the corporate financial statements and financial projections Plan Administrator Frequently but not always the ESOP s plan sponsor Has the direct ESOP disclosure and filing obligations under the Employee Retirement Income Security Act of 1974, as amended ( ERISA ), for ESOP disclosure and filing requirements Responsible for furnishing the ESOP s third party record keeper with payroll and other data 5

6 Introduction to the Annual ESOP Administration Process (Cont.) Parties Involved in ESOP Administration (Cont.): ESOP Trustee and ESOP Custodian Provides ESOP bank and investment account statements Outside or Institutional Trustees often provide separate statements for Trust accounting purposes ESOP Appraiser Issues the annual valuations of Company Stock (if not publicly traded) 6

7 Introduction to the Annual ESOP Administration Process (Cont.) Parties Involved in ESOP Administration (Cont.): Third Party Record Keeper ( TPR ) Conducts the annual accounting for the ESOP ESOP Plan Auditor ( Plan Auditor ) Issuer of Accountant s Opinion for Filing with Schedule H of IRS Form 5500 and auditor of the ESOP s financial statements Please Note: An Accountant s Opinion is not required if the ESOP has 100 or fewer participants, and the ESOP may be exempted from the requirement in the first plan year, provided, however, that the following year s IRS Form 5500 includes an Accountant s Opinion and audited financial statements for the first two plan years. Generally must be a licensed certified public accountant (individual or firm) and must be experienced with conducting ERISA plan audits 7

8 Administrative Calendar Calendar as a useful tool Ideal to agree on service providers internal deadlines either before the beginning of a Plan Year or shortly thereafter Following Sample Calendar for ESOPs with Calendar Year Plan Years Statutory deadlines are absolute Remaining dates are suggested timeframes Actual internal deadlines will depend on the ESOP service providers involved 8

9 Administrative Calendar (Cont.) General Considerations Summary Plan Description ( SPD ) and/or Summary of Material Modifications ( SMM ) Plan Administrators required to furnish SPDs as follows: To the Plan Sponsor s employees within 90 days of an employee s enrollment in the ESOP To Terminated ESOP Participants and Beneficiaries of Deceased ESOP Participants within 90 days of receipt of an ESOP benefit payment To ESOP Participants and Beneficiaries generally once every five (5) years if the ESOP is amended (or once every ten (10) years if the ESOP is not amended during such decade) SMM required within 210 days after the end of the Plan Year for which a material amendment is adopted 9

10 Administrative Calendar January Due Date* Task Responsible Party January 1 st March 1 st (S Corporations) or January 1 st April 1 st (C Corporations) January 31 st If applicable, discuss and make any employer contributions for prior plan year and discuss and close any upcoming ESOP transactions. Prepare and mail IRS Form 1099 R to participants who received a distribution from the ESOP during the prior plan year and IRS Form 945, which reports the tax withheld on distributions made during the prior plan year. Plan Sponsor, ESOP Trustee, and Respective Legal Counsel Plan Administrator or TPR *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 10

11 Administrative Calendar February Due Date* Task Responsible Party February 1 st If applicable, prepare and mail the necessary paperwork to any eligible participants who must start receiving distributions by March 1st, pursuant to Section 401(a)(14) of the Internal Revenue Code of 1986, as amended (the Code ), in order to process such distributions in a timely manner. Section 401(a)(14) of the Code requires ESOP benefit payments to commence no later than 60 days after the end of a Plan Year in which the latest of the following occurs: (1) A Participant s Normal Retirement Age; (2) A Participant s Termination of Employment with the Plan Sponsor; or (3) The Tenth Anniversary of a Participant s Participation in the ESOP. There is a 30 day minimum notice period for distributions, however, participants and beneficiaries may waive such waiting period upon receiving certain disclosures. Plan Administrator or TPR *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 11

12 Administrative Calendar February (Cont.) Due Date* Task Responsible Party February Prepare and mail IRS Form 1096, which 28 th /29 th summarizes information reported on IRS Forms 1099 R. February 28 th /29 th Provide TPR Engagement Agreement and Preliminary ESOP Administration data request: Payroll data ESOP bank and investment statements Renewal of ERISA Fidelity Bond If the Plan Administrator intends to request an extension of the time to file IRS Form 5500 for the ESOP, this deadline may be extended to March 31 st. Plan Administrator or TPR TPR *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 12

13 Administrative Calendar March Due Date* Task Responsible Party March 1 st Deadline for sending the required minimum distribution ( RMD ) materials to eligible ESOP Participants in order to process such RMDs by April 1 st under Section 401(a)(9) of the Code. There is a 30 day minimum notice period for distributions, however, participants and beneficiaries may waive such waiting period upon receiving certain disclosures. Deadline to process distributions to eligible participants who must start receiving distributions pursuant to Section 401(a)(14) of the Code. See Slide 11. Plan Administrator or TPR *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 13

14 Administrative Calendar March (Cont.) Due Date* Task Responsible Party March 15 th Deadline for S corporations to remit employer contributions to the ESOP for the prior plan year, in order to deduct such contributions for the employer s fiscal year just ended (without extension). Deadline for filing a 6 month extension to file to the corporate tax return for the fiscal year just ended (which by operation of law extends the deadline for making ESOP contributions. See Section 404(a)(6) of the Code. If applicable, deadline for distributions of excess contributions to highly compensated employees (from failure of plans with a 401(k) or (m) feature to pass the ADP/ACP/MUA discrimination tests) without the employer incurring a 10% excise tax. Plan Sponsor *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 14

15 Administrative Calendar March (Cont.) Due Date* Task Responsible Party March 31 st End of the statutory 90 day period for Qualified Participants (as described in Section 401(a)(28) of the Code) to return ESOP diversification elections. Note: This frequently is extended until after the annual ESOP valuation is completed. (See Section 401(a)(35) of the Code for diversification requirements when an ESOP holds publicly traded employer securities.) ESOP Participants *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 15

16 Administrative Calendar March (Cont.) Due Date* Task Responsible Party March 31 st Ideal deadline for Plan Sponsor and Plan Administrator to provide: General employer questions; Any changes to corporate tax status; Information with respect to ESOP transactions in the prior plan year; Employer contributions for the prior plan year; Family members of ESOP Participants for testing under Section 409(p) of the Code; and Census data information. Ideal deadline for ESOP Trustee/Custodian to provide: Trust Statements; and ESOP bank and investment account statements. Plan Sponsor, Plan Administrator, ESOP Trustee, and ESOP Custodian *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 16

17 Administrative Calendar March (Cont.) to April Due Date* Task Responsible Party March 31 st April 1 st April 7 th Provide valuation engagement agreement to ESOP Trustee and valuation data requests to Plan Sponsor for valuation as of prior plan year end. Deadline to process RMDs, pursuant to Section 401(a)(9) of the Code. Provide follow up ESOP administration questions to Plan Administrator. If the Plan Administrator intends to request an extension of the time to file IRS Form 5500 for the ESOP, this deadline may be extended to May 7 th. ESOP Appraiser Plan Administrator or ESOP Trustee TPR *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 17

18 Administrative Calendar April (Cont.) Due Date* Task Responsible Party April 15 th Deadline for C corporations to remit employer contributions to the ESOP for the prior plan year, in order to deduct such contributions for the employer s fiscal year just ended (without extension). Deadline for filing a 6 month extension to file to the corporate tax return for the fiscal year just ended (which by operation of law extends the deadline for making ESOP contributions. See Section 404(a)(6) of the Code. Plan Sponsor *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 18

19 Administrative Calendar April (Cont.) Due Date* Task Responsible Party April 15 th Provide response to TPR supplemental data questions. If the Plan Administrator intends to request an extension of the time to file IRS Form 5500 for the ESOP, this deadline may be extended to May 15 th. Provide completed internal corporate financial statements as of the end of the prior plan year to the ESOP Appraiser. If the Plan Administrator intends to request an extension of the time to file IRS Form 5500 for the ESOP, this deadline may be extended to May 15 th. Plan Sponsor or Plan Administrator *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 19

20 Administrative Calendar April (Cont.) Due Date* Task Responsible Party April 21st April 28 th Provide preliminary employee status report ( ESR ) to Plan Administrator for review. If the Plan Administrator intends to request an extension of the time to file IRS Form 5500 for the ESOP, this deadline may be extended to May 21 st. Approve preliminary ESR. If the Plan Administrator intends to request an extension of the time to file IRS Form 5500 for the ESOP, this deadline may be extended to May 31 st. Things to review: Dates of Birth, Dates of Hire, Dates of Termination; Compensation Details; 401(k) Elective Deferrals and Matching Contributions. TPR Plan Administrator *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 20

21 Administrative Calendar April (Cont.) Due Date* Task Responsible Party April 28 th April 30 th Provide preliminary trust accounting to the Plan Administrator (and Plan Auditor as applicable). If the Plan Administrator intends to request an extension of the time to file IRS Form 5500 for the ESOP, this deadline may be extended to May 31 st. Complete preliminary fair market value analysis as of the end of the prior plan year and circulate report to ESOP Trustee. If the Client intends to request an extension of the time to file IRS Form 5500 for the ESOP, this deadline may be extended to May 31 st. TPR ESOP Appraiser *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 21

22 Administrative Calendar May Due Date* Task Responsible Party May 5 th Approve preliminary trust accounting. If the Plan Administrator intends to request an extension of the time to file IRS Form 5500 for the ESOP, this deadline may be extended to June 5 th. May 15 th Review and discuss preliminary fair market value analysis as of the end of the prior plan year. If the Client intends to request an extension of the time to file IRS Form 5500 for the ESOP, this deadline may be extended to June 15 th. Plan Administrator (and Plan Auditor, as applicable) ESOP Appraiser, ESOP Trustee, and Plan Administrator (solely with respect to the description of the Company and accuracy of corporate financial information) *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 22

23 Administrative Calendar May (Cont.) to June Due Date* Task Responsible Party May 31 st June 9 th Provide final fair market value report as of the end of the prior plan year to ESOP Trustee. If the Plan Administrator intends to request an extension of the time to file IRS Form 5500 for the ESOP, this deadline may be extended to June 30 th. Complete and provide preliminary allocation report. If the Plan Administrator intends to request an extension of the time to file IRS Form 5500 for the ESOP, this deadline may be extended to July 9 th. ESOP Appraiser (ESOP Trustee to inform Plan Administrator and TPR of final per share price) TPR *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 23

24 Administrative Calendar June (Cont.) Due Date* Task Responsible Party June 16 th June 23 rd Approve preliminary allocation report. If the Plan Administrator intends to request an extension of the time to file IRS Form 5500 for the ESOP, this deadline may be extended to August 1 st. Provide final record keeping reports, Summary Annual Report and Participant Statements for prior plan year (if no audit is required). If the Plan Administrator intends to request an extension of the time to file IRS Form 5500 for the ESOP, this deadline may be extended to September 15 th. If audit required, provide ESR, allocation report, and trust accounting to Plan Auditor. Plan Administrator TPR *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 24

25 Administrative Calendar June (Cont.) Due Date* Task Responsible Party June 29 th End of 90 day statutory deadline for processing ESOP diversification elections under Section 401(a)(28) of the Code. Note: This frequently is extended until after the annual ESOP valuation is completed. (See Section 401(a)(35) of the Code for diversification requirements when an ESOP holds publicly traded employer securities.) Plan Administrator and ESOP Trustee *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 25

26 Administrative Calendar June (Cont.) to July Due Date* Task Responsible Party June 30 th July 15 th Provide draft IRS Form 5500 for the ESOP for the prior plan year (with all schedules) to the Plan Administrator (and the Plan Auditor, as applicable) for review. Provide Accountant s Opinion and audited ESOP financial statements for filing with the IRS Form 5500 (if applicable). If the Plan Administrator intends to request an extension of time to file IRS Form 5500 for the ESOP, this deadline may be extended to September 30 th. TPR Plan Auditor *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 26

27 Administrative Calendar July (Cont.) Due Date* Task Responsible Party July 31 st Deadline for filing the ESOP s annual return/report for the prior plan year (final IRS Form 5500 with related schedules), and for furnishing Participant Statements and Summary Annual Reports to ESOP Participants, without extension. Note: ESOPs that permit participant directed investments (other than statutory diversifications) must provide Participant Statements within 45 days following the end of each calendar quarter. Alternatively, deadline for preparing and filing IRS Form 5558, which requests an automatic 2½ month extension of the deadline to file the IRS Form 5500 (with all schedules) for the ESOP for the prior plan year to October 15 th. Plan Administrator *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 27

28 Administrative Calendar August to September Due Date* Task Responsible Party August September 15 th September 30 th No significant deadlines Deadline for filing S corporation s tax returns for the prior fiscal year (and for S corporations to remit employer contributions to the ESOP) on extension. Discuss projected ESOP benefit payments Review and revise the ESOP Distribution Policy, as appropriate Plan Sponsor Plan Administrator, ESOP Trustee, TPR *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 28

29 Administrative Calendar October Due Date* Task Responsible Party October 15 th October 15 th Deadline for filing C corporation s tax returns for the prior fiscal year (and for C corporations to remit employer contributions to the ESOP) on extension. Deadline for filing the ESOP s annual return/report for the prior plan year (final IRS Form 5500 with related schedules), and for furnishing Participant Statements and Summary Annual Reports to ESOP Participants, on extension. Note: ESOPs that permit participant directed investments (other than statutory diversifications) must provide Participant Statements within 45 days following the end of each calendar quarter. Plan Sponsor Plan Administrator *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 29

30 Administrative Calendar October (Cont.) to December Due Date* Task Responsible Party October 1 st December 1 st Provide ESOP benefit payment packages to eligible ESOP participants to process ESOP benefit payments in compliance with Section 409(o) of the Code. There is a 30 day minimum notice period for distributions, however, participants and beneficiaries may waive such waiting period upon receiving certain disclosures. Plan Administrator and ESOP Trustee *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 30

31 Administrative Calendar October (Cont.) to December Due Date* Task Responsible Party October 1 st December 31 st Discuss and close any ESOP stock acquisition transactions for the current plan year. Discuss and declare any C corporation dividends (under Section 404(k) of the Code) or S corporation distributions (under Section 1368 of the Code) on ESOP owned shares of the common stock of the Plan Sponsor ( Company Stock ). Plan Sponsor, ESOP Trustee, ESOP Appraiser, and Legal Counsel *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 31

32 Administrative Calendar December (Cont.) Due Date* Task Responsible Party December 1 st December 31 st Annual Corporate Governance Meetings: ESOP Trustee to vote the ESOP s shares of Company Stock to elect the Plan Sponsor s Directors; and The Board of Directors of the Plan Sponsor to Appoint Officers and Successor ESOP Trustee (of applicable) Finish processing all ESOP benefit payments for the current plan year. Provide preliminary ESOP diversification notices and election forms to Qualified Participants (to ensure compliance with the statutory 90 day period for such elections). Plan Sponsor and ESOP Trustee Plan Administrator, ESOP Trustee, and TPR *Filing deadlines on a weekend or government holiday are automatically extended to the next business day. 32

33 Sample ESOP Statement of Accounts ABC ESOP Company Employee Stock Ownership Plan Participant Statement Jane Doe December 31, 2017 Date of Participation: 01/01/2001 Participant Status: Active Years of Service: 6 % Vested (nonforfeitable) Number of Common Shares Value of Common Shares Other Investments Total Balance at Beginning of Plan Year $10, $3, $13, Distributions Reallocation Distribution Share Purchase Reallocations of Forfeited Shares Dividend & Interest Income & Expense Employer Contributions , , Increase (or Decrease) in Value of Accounts Balance at the End of Plan Year 100% $12, $3, $15, Total Amount Vested (Capital Accumulation) $15, Fair Market Value Per Share $

34 ESOP Benefit Payments ESOP Distributions to Former Employees or Beneficiaries of Deceased Participants Statutory and Enhanced ESOP Diversifications In Service Distributions (rare) Loans (rare) 34

35 Distributions Timing, Method, Form Typically defined in the plan document or a separate Distribution Policy Timing When the distribution will begin Method The manner in which the distribution will be paid (Lump sum or Installments) Form Cash, stock or a combination of both 35

36 Distributions Timing Internal Revenue Code (IRC) Section 401(a)(14) Distribution must commence no later than the 60th day after the end of the plan year in which the latest of the following occurs: Earlier of age 65 or age based on the plan s normal retirement age The 10 th anniversary of the date on which the participant began participating in the plan Termination of the participant s service 36

37 Distributions Timing IRC Section 401(a)(14) Rules governing early retirement benefits IRC Section 401(a)(9) Required minimum distributions Age 70 ½ * Death * Required each year beginning the later of reaching age 70 ½, or terminate employment. If still employed and more than a 5% owner of company sponsoring, owner required to receive distribution at age 70 ½. 37

38 Distributions Timing Accelerated ESOP Distribution Rules IRC Section 409(o) Apply to stock acquired by an ESOP after 1986 Retirement, death or disability End of the plan year following the plan year in which the event occurs Other termination End of the sixth plan year following the plan year in which employment terminates (unless reemployed) 38

39 Distributions Timing Accelerated ESOP Distribution Rules Exception for leveraged ESOPs Distributions attributable to leveraged shares may be delayed until the plan year following the plan year in which the loan is repaid Applies only to C corporations? General ERISA Requirements may require an earlier payment 39

40 Distributions Timing Notice and Consent Notice Requirements Notice provided between 30 and 180 days before the date of distribution 30 day waiting period can be waived Consent required For any distribution before the later of age 62 or the plan s normal retirement age, if vested balance exceeds $5,000 If vested balance exceeds $1,000 automatic rollover rules apply (unless plan limits cash out amount to $1,000) 40

41 Distributions Method Lump Sum distributions may be made in a single lump sum Installments Must occur in a substantially equal series of installments (not less frequently than annually) Over no more than 5 years (can be as many as 6 installments) Extension for large balances One additional year (but not more than 5 additional years) for each $1,105,000 and $220,000 or fraction thereof by which the participant s balance exceeds $1,105,000 (2018 indexed)* * As indexed by the IRS for calendar year

42 Distributions Form Cash Stock a participant has a right to demand stock Exceptions Charter or bylaw provision that restricts substantially all stock ownership to the ESOP or current employees S corporation May still distribute employer securities subject to the requirement that the shares be immediately resold to the employer or ESOP Put Option Participants should consider the differences in investment options and risks, fees and expenses, tax implications, services and penaltyfree withdrawals for various options. There may be other factors to consider due to your specific needs and the situation. You may wish to consult your tax advisor or legal counsel. 42

43 Diversification Diversification defined Traditional diversification rights (IRC 401(a)(28)(B)) Age 55 Ten years of participation Applies to employer stock acquired after 1986 Pension Protection Act of 2006 (PPA) Defined contribution plans holding publicly traded securities Ability to direct the investment of their account on at least a quarterly basis among three other diversified investment choices Participant contributions are subject to participant direction immediately Employer contributions are subject to participant direction after the participant has attained three years of vesting service 43

44 Diversification Traditional Diversification Participation Credit Ten years of participation All plan years in which a participant has an account balance Only plan years in which a participant is eligible for contributions and forfeitures Be specific in plan document 44

45 Diversification Timing of Election Participant election period ESOP trustee has 90 days after the election period to satisfy the diversification election Annual elections for six consecutive years Can diversify up to 25% of shares ever allocated to the account (cumulative) over the first five years Can diversify an additional 25% of shares ever allocated to the account (cumulative) in the sixth election year 45

46 Diversification Satisfying the Election Offer three or more alternative investment options from various asset classes within the ESOP Offer a transfer to a sister qualified plan that offers three or more alternative investment options from various asset classes Distribute cash equal to stock value Distribute stock (subject to the put option in a closely held company) 46

47 Diversification Example Susan attains age 55 during the 2014 plan year Her tenth year of participation is met in the 2016 plan year First election period begins January 1,

48 Diversification Example Year 1 Year 2 Year 3 Year 4 Year 5 Year 6 Beginning shares 1, New shares allocated Plus shares previously diversified Subtotal 1, , , , , ,200.0 x25% (years 1 5) (50% year 6) Less shares previously diversified Shares eligible for diversification Shares diversified Balance after diversification For Illustrative purposes only. 48

49 Proactive Measures for Plan Compliance in ESOP Administration Read and understand the ESOP plan documents; Retain ESOP service providers (legal, accounting, plan auditor, etc.), as needed; Docket the key deadlines for ESOP administration; Provide the ESOP service providers with all requested information well in advance of deadlines; and Coordinate with ESOP service providers to ensure all applicable deadlines are satisfied. 49

50 Questions? Thank you Contact Information: Debra Stoll Vice President, National ESOP Relationship Management Principal Financial Group T: (916) E mail: stoll.debra@principal.com Wanda M. Taylor Senior ESOP Analyst Hawkins Parnell Thackston & Young LLP 1776 Second Street Napa, CA T: (510) E mail: wtaylor@hptylaw.com 50

51 Brief Bio: Debra Stoll Debra has been with Principal for 5 years. She has over 16 years of employee benefits experience, including consulting with employers on all aspects of qualified retirement plans with an emphasis on ESOPs and ESOP transactions. She is a member of the State Bar of California, American Society of Pension Professionals & Actuaries, the National Center for Employee Ownership and ESOP Association. She is a frequent speaker at local, regional and national conferences and events. Debra leads Principal s national team of ESOP relationship managers and the ESOP operations teams, including financial analysis, communication, consulting and support. Her focus is on operations and strategic planning for existing ESOP clients. She is responsible for all aspects of ESOP EdgeSM, a Principal online ESOP newsletter. 51

52 Brief Bio: Wanda M. Taylor Wanda M. Taylor is a Senior ESOP Analyst in the Napa office of Hawkins Parnell Thackston & Young LLP. Ms. Taylor has over 27 years of service in the ESOP industry, starting as the Chief Financial Officer for an ESOP owned company in Ms. Taylor conducts the annual ESOP record keeping reports for a broad array of clients. Ms. Taylor also provides analytical support to the Firm with respect to ESOP feasibility studies, informal ESOP repurchase obligation projections, and ESOP benefit payments. Ms. Taylor has served on the Steering Committee of the California/Western States Chapter of The ESOP Association for 20 years and frequently lectures on ESOP Administration topics. 52

53 The Presenters gather their data from sources they consider reliable; however, they do not guarantee the accuracy or completeness of the information provided within this presentation. The material presented reflects information known to the Presenters at the time this presentation was written, and this information is subject to change. The Presenters make no representations or warranties, expressed or implied, regarding the accuracy of this material. The views expressed in this material accurately reflect the personal views of the authors and do not necessarily coincide with those of their employers. The Presenters do not provide accounting, tax or legal advice. The information and material presented herein is provided for educational and informational purposes only and is not intended to constitute accounting, tax or legal advice or to substitute for obtaining accounting, tax or legal advice from an attorney or licensed CPA. Wanda Taylor or Hawkins Parnell Thackson & Young is not affiliated with any company of the Principal Financial Group