Standardized Data Reporting (SDR) Usage Guidelines for Compliance with Rule 22c-2 Reporting. Schwab Retirement Technologies, Inc.

Standardized Data Reporting (SDR) Usage Guidelines for Compliance with Rule 22c-2 Reporting Schwab Retirement Technologies, Inc.

Schwab Retirement Technologies Usage Guidelines for Compliance with Rule 22c-2 Reporting January 3, 2007 Revised June 12, 2007 The material contained herein is proprietary to Schwab and for informational purposes only. The information is not intended to provide tax, legal or investment advice. Schwab does not guarantee the suitability or potential value of any particular information source. Certain information presented herein may be subject to change. The information or material contained in this document may not be copied, assigned, transferred, disclosed or utilized without the express written approval of Schwab. The Charles Schwab Corporation (Charles Schwab) provides services to retirement plans and participants through its subsidiaries, Charles Schwab & Co., Inc. (Member SIPC), The Charles Schwab Trust Company (CSTC), Schwab Retirement Plan Services, Inc. and Schwab Retirement Technologies, Inc. (Schwab RT). Charles Schwab also provides equity compensation plan services and other financial and retirement services to corporations and executives through Charles Schwab & Co., Inc. For further information, contact Schwab Retirement Technologies, Inc. at 13925 Ballantyne Corporate Place, Suite 300, Charlotte, NC 28277, USA, Tel: (800)-628-2416, Web site: schwabrt.com. 2007. Schwab Retirement Technologies, Inc. All rights reserved. (0107-3049) Rule 22c-2 Schwab Retirement Technologies Page 2 of 39

Table of Contents Overview...4 Purpose of Document...4 Schwab RT Standards...5 Request Categories...5 Standard Responses...6 Schwab Trading Platform File Naming Conventions...7 Schwab RT SQL Recordkeeping Highlights...9 System Setup Transaction Mapping...9 Miscellaneous...9 Organizing Files...10 Other System Settings...10 Processing Requests...10 Participant Trading Restrictions...12 Appendix...13 SDR Request (F20) Record 1 of 2...13 SDR Request (F20) Record 2 of 2...17 SDR Header (B/U21) Record 1 of 1...19 SDR (B/U23) Record 1 of 1...24 SDR Detail (B/U24) Record 1 of 2...26 SDR Detail (B/U24) Record 2 of 2...30 SDR Trailer (B/U27) Record 1 of 2...32 SDR Trailer (B/U27) Record 2 of 2...36 SDR Grand Total Trailer (B/F/N/U29) Record 1 of 1...39 Rule 22c-2 Schwab Retirement Technologies Page 3 of 39

Overview SEC Rule 22c-2 (the Rule ) went into effect May 23, 2005 with a compliance date of October 16, 2007. The Rule is intended to ensure that mutual fund companies (the Funds ) follow their published market-timing policies, monitor the frequency of client trading, and determine whether redemption fees are being properly assessed, if applicable. The Rule also requires the Funds to enter into written agreements with the financial intermediaries who submit trades to the Funds on behalf of their own clients ( Clients ) through omnibus accounts held at the Fund ( Financial Intermediaries ). The agreements require Financial Intermediaries to provide the Funds with specific Client-level information with respect to the trades they deliver through the omnibus account(s) held at the Fund, including specific Client Tax Identification Number/Social Security Numbers. The Standardized Data Report (SDR) specifications document developed by the Depository Trust and Clearing Corporation (DTCC) provides the following background: Frequent trading in mutual funds may have harmful effects on the management company, its portfolio and its long-term investors. Frequent trading may dilute the value of the fund shares, disrupt the management of a fund's portfolio, raise fund transaction costs, affect the fund's liquidity, and result in unwanted taxable capital gains for the remaining shareholders. Funds employ various strategies to detect and deter frequent trading including assessing a fee on redemptions made a short time after the purchase of the shares has occurred and surveillance to ensure compliance with funds market timing policies. Mutual fund shares that are purchased by investors through broker-dealers, banks, insurance companies, and retirement plan administrators ("intermediaries") may be combined with other investors' fund shares and registered in the name of the intermediary in a single omnibus account. In order for the funds to monitor the shareholder account for frequent trading, and appropriately evaluate and potentially assess any applicable redemption fees, the funds must be able to identify the investors and their respective trading activity within the omnibus account. DTCC s SDR file specifications can be found on the DTCC website at http://funds.dtcc.com/. Purpose of Document This Usage Guidelines define how Schwab Retirement Technologies (Schwab RT) facilitates Rule 22c-2 reporting by its Schwab RT SQL Recordkeeping clients ( Schwab RT Clients ) to the Funds with respect to retirement plan Client mutual fund trade transactions processed through Schwab RT. These guidelines are based on the SDR requirements and are for use in providing detailed retirement plan participant identification and trade data to the Funds in response to requests received by Schwab RT Clients from both Charles Schwab & Co, Inc. and The Charles Schwab Trust Company (collectively, Schwab ). Schwab RT s reporting solution is available only for fully-migrated plans on the SQL Recordkeeping platform, and we assume that you are familiar with the SDR specifications. Schwab currently supports and will continue to support the delivery of Client s retirement planlevel data directly to the Funds where the data is held on Schwab s systems. If you work with other trading partners, Schwab assumes that the reporting of Client plan-level data to the Funds with respect to accounts held on their trade platforms has been addressed directly with the other trade platform providers. We encourage you to validate these guidelines with your other trading partners. Rule 22c-2 Schwab Retirement Technologies Page 4 of 39

Schwab RT Standards All standards developed by Schwab RT to support delivery of Client data to the Funds are based on the SDR specifications available through DTCC, and Schwab RT assumes that Schwab RT Clients are familiar with the specifications prior to reviewing and implementing the standard defined in these Usage Guidelines. Schwab RT will accommodate Category 1 and Category 2 requests, as defined in the SDR specifications, through an approved SDR file format only. Schwab RT Clients are responsible for downloading request files received from Schwab to their default folder when client participantlevel data is needed ( SDR Request files). Schwab RT Clients are responsible for handling Client plan-level data requests (SDR Summary Responses) as directed by their trading partners other than Schwab. Request Categories DTCC has defined 6 types of requests that may be delivered to intermediaries with respect to specific funds and Clients (only two of which are supported by Schwab RT, as noted in bold): 1. Fund Account Level Schwab RT does not support this request type. For Client plans using Schwab s trading platform, however, Schwab will provide plan-level detailed information in response to Category 1 requests. In some instances, the information provided may also satisfy Fund Account Level requests. Schwab is actively working with the Funds to refine the request down to a Plan level. 2. Plan Level Schwab RT supports this request type with participant-level detailed information. 3. Investor Omnibus Account Level Schwab RT does not support this request type as it applies to brokerage accounts (and not retirement plans). 4. Fund/SERV Control Number Request Schwab RT does not support this request type as the referenced Control Number is not maintained on Schwab systems. 5. Rep Level Schwab RT does not support this request type as this information is not generally available from the recordkeeping system. Rep level requests may apply to those TPAs doing business with Financial Advisors who have access to direct transactions on a participant s behalf. 6. Stop Recurring Schwab RT supports this request type. These requests act as a stop order for previously requested, recurring responses required by a Fund with respect to plans. Rule 22c-2 Schwab Retirement Technologies Page 5 of 39

Standard Responses Schwab RT has programmed standard responses for certain fields on the Request and Response files: Where NAV date is requested, the process date of the transaction will be provided. The National Securities Clearance Corporation (NSCC) defines NAV date as the date of NAV pricing for the transaction. Optional fields will not provided/coded unless a value is stated in the notes. All required fields will be provided/coded unless blank is stated in the notes. A blank required field is either not supported or data is not available. Refer to the file layouts in the appendix for detailed notes on specific fields. Response files generated by the Schwab RT system will not exceed the maximum size of 150 megabytes supported by Schwab through the SI.com web site, as configured on a specific Schwab RT system-level setting. Files exceeding the maximum size limit will be divided into multiple files. Schwab RT Client users are responsible for encrypting or otherwise securing data files. Special Note Schwab RT will be able to provide requested data only for the amount of transaction history converted by the Schwab RT Client to SQL. Rule 22c-2 Schwab Retirement Technologies Page 6 of 39

Schwab Trading Platform File Naming Conventions Schwab has developed the following File Naming Conventions for Request, Response, and Response Files: Requests: Use file name: RMMDDYY #.tpa or RMMDDYY#.sdr where MMDDYY Date the Request file was created # Sequential letter TPA if TPA uses CSTC SDR if TPA uses Schwab Custody or Broker/Dealer Schwab s 3-digit STAR TPA SDR (hardcoded) Responses: Use file name: RMMDDYY### _SDRControlNum.tpa or RMMDDYY###_SDRControlNum.sdr where MMDDYY Date response file created by TPA. ### Sequential number SDRControlNum TPA if TPA uses CSTC SDR if TPA uses Schwab Custody or Broker/Dealer 15-digit SDR Control Number from the originating Request file Schwab s 3-digit STAR TPA SDR (hardcoded) Response s: Use file name: RMMDDYY###_SDRControlNum.tpa or RMMDDYY###_SDRControlNum.sdr where MMDDYY Date request reject file is created ### Sequential.number SDRControlNum TPA if TPA uses CSTC SDR if TPA uses Schwab Custody or Broker/Dealer SDR Control number field from the originating request 3-digit STAR TPA SDR (hardcoded) Rule 22c-2 Schwab Retirement Technologies Page 7 of 39

File Naming Conventions for All Other Trading Platforms The inbound Request file extension can be user defined. However, the total file name (including the date and sequence number) cannot exceed 50 characters (excess characters over the limit are truncated.) The outbound Response and file extension will be coded with the TPA s ID specified in TDI Account Field 2. If this has not been specified, the system will use the TPA number that is used at the trading link. This ID is the Generic Link specified in C282/RK SQL System Maintenance/System Settings under TDI Settings. The 50-character limit also includes the date, SDR control number, and sequence number. We encourage you to contact your other trading partners for their file-naming conventions. Rule 22c-2 Schwab Retirement Technologies Page 8 of 39

Schwab RT SQL Recordkeeping Highlights System Setup Transaction Mapping DTCC classifies data into 2 categories. Category 1 includes plan participant-directed transactions (i.e., does not include transactions initiated by the plan sponsor), and Category 2 includes all transactions except dividend and interest. Transactions reported for each category are dependent on each Schwab RT Client s tax code mapping. In addition, DTCC requires each transaction to be classified as 01 Buys, 02 Sells, 05 Transfer In and 06 Transfer Out. Schwab RT Clients will be able to select/map the appropriate Schwab RT Tax s to each Category 1 and Category 2 transaction type on the Schwab RT system through and Map Maintenance. Schwab RT users can classify transactions as (i) Participant Directed, and (ii) as a Transfer In or Transfer Out of the plan account. These system-level settings apply across all plans processed on the Schwab RT system for the Schwab RT Client. Selected Tax s must be unique across these four categories: Category 1 Tax Map Category 2 Tax Map Transfers In Tax Map Transfers Out Tax Map Miscellaneous Transactions will be rolled up by transaction date across sources; transactions will not be reported at a source level. Investment Program transactions will not be reported separately; transactions for only the underlying funds will be reported. Contingent Redemption Fees (CRFs) will not be reported separately; they will be reported with the transaction that triggered the CRF in the STR Fee Amount field. The following is a partial list of transaction types for each of the different categories. A complete list can be found on NCSS s Website, http://funds.dtcc.com. Category 1 Buys Exchange In Transfer In Balance Reallocation-Buy Category 2 Buys Employee contribution Employer contribution Additional contribution Loan repayment principal Loan repayment interest Forfeitures reallocated Adjustments Conversion balance transfer Non-discrimination refund Rule 22c-2 Schwab Retirement Technologies Page 9 of 39

Category 1 Sales Exchange out Transfers out Balance Reallocation-Sell Category 2 Sales In-service distribution Installment distribution Termination distribution Hardship withdrawals Lump sum distribution Adjustments Fees Forfeiture Conversion balance transfer Organizing Files Schwab RT users will be able to define default folders to organize incoming Request, Response and files generated through Schwab RT. Other System Settings Schwab RT users will be able to enter your assigned underlying Firm Number in a new enterprise level field (also known as BTRAC ID). Up to four alpha/numeric characters can be entered and will be used in the Response files. Processing Requests Following implementation or upgrade to Schwab RT s Release 2.4.1, Schwab RT users can access three new functional applications to support compliance with the Rule: C604/Participant Trading Restriction Maintenance, C605/Rule 22c-2 Processing, and C606/Rule 22c-2 Inquiry/Reporting. Rule 22c-2 Inquiry/Reporting Module The Rule 22c-2 Inquiry/Reporting module (C606) provides historical information about Request files received and Response files generated. The historical data screens display only identification information for plan participants for which data was requested by the Fund and the specific Response file (and file name) that was created. The screens do not show specific participant-level transaction detail. Schwab RT users can also view the status of Rule 22c-2 Requests through the View Status Detail interface. Rule 22c-2 Processing Module The Rule 22c-2 Processing module (C605) provides options to load Request files, generate Response files and create an Excel version of the following output files: Request Response Request Response Rule 22c-2 Schwab Retirement Technologies Page 10 of 39

Schwab RT users are able to process both one-time requests and recurring requests and to View Request Detail on the incoming file. Request Records The Schwab RT system audits the data associated with each Request Record and SDR Control Number included on the incoming Request file to ensure that the data requested is available, valid and properly formatted. For each of the following data items, Schwab RT determines the noted characteristics: Plan ID (PID) Field is blank or PID is not on system Security Issue ID Asset requested (CUSIP field) exists in the PID request SSN SSN exists in the PID; Note: if blank, Schwab RT reports all participants in the plan From Date Field is blank or not formatted as MMDDYYYY To Date Field is populated and not formatted as MMDDYYYY Threshold Amount Field is not formatted as a whole number (no decimals and no characters are allowed) SDR Request Type Value is NOT 02 or 06 Recurring Indicator Field is NOT populated with 1, 0 or blank SDR Control Number Field is blank Original SDR Control Number Field is populated and the SDR Request Type field is NOT set to 06 Request Records If the validation fails, Schwab RT generates the appropriate Firm and Reason in the Request File. Refer to the Appendix for more information on the SDR s and. Response Files The Response File consists of four sections: Header One record/line for each Response/SDR Control Number. Refer to Record Type #21 in the File Layout document. Detail Two records/lines for each participant rolled up transaction type. Refer to Record Type #24 in the File Layout document. This section will detail the participant transactions. Trailer Two records/lines for each Response/SDR Control Number. Refer to Record Type #27 in the File Layout document. This Rule 22c-2 Schwab Retirement Technologies Page 11 of 39

section provides the total number of lines that have participant transactions (number of #24 Record lines). Grand Total Trailer One record/line for each Response/SDR Control Number. Refer to Record Type #29 in the File Layout document. This section just provides control totals, the total number of lines in the file including headers and trailer (number of #21, #24, #27, #29 lines). The number in Grand Total Trailer line includes the Grand Total line. Response Files Schwab RT does not support the processing of a Response file from a Fund Company. Schwab will notify clients directly if it receives a Response file from a Fund Company. Participant Trading Restrictions Schwab RT also includes a Participant Trading Restriction module (C604) that allows Schwab RT Client users to input a trading restriction for a participant at a fund level to take effect during a specific date range as directed by the Funds. Participants using the realignment and transfer options on Schwab RT Web and Voice (or users using Schwab RT Call Center) will receive a warning that they are blocked due to Rule 22c-2 and the date the block will be removed. Rule 22c-2 Schwab Retirement Technologies Page 12 of 39

Appendix SDR Request (F20) Record 1 of 2 Required Input From Fund to NSCC Output From NSCC to Firm (accepted) and Fund (rejected) Note: SDR Request records do NOT have an application header (Record type 21) or trailer (record type 27) record Field Name Start End Len Type Description Opt/Req SDR Originator Type 1 1 1 A/N F = Fund R 01 Requestor. Record Type 2 3 2 A/N 20 = SDR Request R 02 Sequence Number 4 5 2 A/N 01 R 03 SDR Control Number 6 20 15 A/N ppppyjjjnnnnnnn R 04 Where: pppp = Fund Number y = Last digit of year jjj = Julian Date nnnnnnn = Unique sequential number assigned by fund Firm Number 21 24 4 A/N R 06 Fund Number 25 28 4 A/N R 09 Security Issue ID 29 37 9 A/N R 13 CUSIP or Internal Ticker. Underlying Firm Number 38 41 4 A/N O 07 Rule 22c-2 Schwab Retirement Technologies Page 13 of 39

Field Name Start End Len Type Description Opt/Req SDR Underlying Firm Indicator 42 43 2 A/N Required when Underlying Firm Number is provided. 01 = NSCC Number 02 = OTC Symbol 03 = BTRK Number OC 08 Fund Account Number 44 63 20 A/N Required if Firm Account Number is not provided. Firm Account Number 64 83 20 A/N Required if Fund Account Number is not provided. OC 10 OC 11 Fund/SERV Control Number 84 98 15 A/N Required if SDR Request Type = 04 OC Rule 22c-2 Schwab Retirement Technologies Page 14 of 39

Field Name Start End Len Type Description Opt/Req SDR SDR Request Type 99 100 2 A/N 01 = Fund Account Level 02 = Plan Level 03 = Investor Omnibus Account Level 04 = Fund/SERV Control Number Request 05 = Rep Level 06 = Stop Recurring R 05 Schwab RT supports 02, which is Participant Detail and 06 which is a request to cease producing a recurring request. 01 supported by Schwab only if the Fund Account represents a single plan. 03 not supported as it applies to brokerage accounts. 04 not supported as the Control Number is not available to Schwab systems. 05 not supported as TPAs are not reps for this purpose. From Date 101 108 8 A/N mmddccyy R 12 The process date from which transactions are to be reported. If corresponding To Date is blank, request is for a single date only. SSN/TIN 109 117 9 A/N O 16 If blank, transactions are for all participants in the plan. Filler 118 141 24 A/N Space R Hard coded with blank spaces NSCC Indicator 142 142 1 A/N Input: Space Output: 0 = Accepted by NSCC 1 = ed by NSCC R Hard coded with blank spaces. Rule 22c-2 Schwab Retirement Technologies Page 15 of 39

Field Name Start End Len Type Description Opt/Req SDR NSCC 1 143 144 2 A/N Input: Space R Hard coded with blank spaces Output: code or space NSCC 2 145 146 2 A/N Input: Space Output: code or space NSCC 3 147 148 2 A/N Input: Space Output: code or space NSCC 4 149 150 2 A/N Input: Space Output: code or space R R R Hard coded with blank spaces Hard coded with blank spaces. Hard coded with blank spaces. Rule 22c-2 Schwab Retirement Technologies Page 16 of 39

SDR Request (F20) Record 2 of 2 Optional Input From Fund to NSCC Output From NSCC to Firm (accepted) and Fund (rejected) Field Name Start End Len Type Description Opt/Req SDR Originator Type 1 1 1 A/N F = Fund R 01 Record Type 2 3 2 A/N 20 = SDR Request R 02 Sequence Number 4 5 2 A/N 02 R 03 Plan ID/Investor Omnibus Account Number 6 25 20 A/N O 14 Omnibus Account Indicator 26 26 1 A/N Required if Plan ID/Investor Omnibus Account Number is provided 0 = Plan ID 1 = Investor Omnibus Account OC 15 Recurring Indicator 27 27 1 A/N 0 = No O 17 1 = Yes To Date 28 35 8 A/N mmddccyy O 18 The process date through which transaction are to be reported beginning with the From Date. If not populated, the From Date is the only day reported. Rule 22c-2 Schwab Retirement Technologies Page 17 of 39

Field Name Start End Len Type Description Opt/Req SDR Includes Category 2 Transactions 36 36 1 A/N 0 = No 1 = Yes O 19 d as 0 for Participant Directed; d as 1 for All, based on transaction mapping. Registered Representative (RR) Number 37 45 9 A/N Required if SDR Request Type is 05 = Rep Level. OC 20 RR Branch 46 54 9 A/N O 21 RR Firm 55 62 8 A/N O 22 Original SDR Control Number 63 77 15 A/N Used to stop a recurring request. O 23 Threshold Amount 78 86 9 N 999,999,999 O 24 Reports rolled up transactions that are equal to or greater than this amount. Transaction Type 87 88 2 A/N 01 = Buy 02 = Sell O 25 Not coded. Buys and Sells are always reported. Space means that the request is for all transactions, which may include transfers. Filler 89 150 62 A/N Space R Rule 22c-2 Schwab Retirement Technologies Page 18 of 39

SDR Header (B/U21) Record 1 of 1 Required Input From Firm to NSCC Output From NSCC to Fund and Firm The SDR Header record is used to introduce SDR Acknowledgment (B/U22), (B/U23), Detail (B/U24) and/or Summary (B/U25) records. Field Name Start End Len Type Description Opt/ Req SDR Originator Type 1 1 1 A/N B = Firm R 01 d as U. U = Underlying Firm Record Type 2 3 2 A/N 21 = SDR Header R 02 Hard coded with 21 Sequence Number 4 5 2 A/N 01 R 03 Hard coded with 01 SDR Control Number 6 20 15 A/N The SDR Control Number submitted by the fund R 04 Pulls from Request File OR The SDR Response Number (see start 101, end 115) for a response provided against a request made outside of NSCC. Firm Number 21 246 4 A/N R 06 Pulls from Request File Fund Number 25 28 4 A/N R 09 Pulls from Request File Security Issue ID 29 37 9 A/N R 13 Pulls from Request File based on CUSIP or Internal Ticker. Rule 22c-2 Schwab Retirement Technologies Page 19 of 39

Field Name Start End Len Type Description Opt/ Req SDR Underlying Firm Number 38 41 4 A/N O 07 Pulls from the Underlying Firm Number (BTRAC ID) field in and Map Maintenance. Underlying Firm Indicator 42 43 2 A/N Required when Underlying Firm Number is provided. 01 = NSCC Number 02 = OTC Symbol 03 = BTRK Number OC 08 Hard coded with 03 Fund Account Number 44 63 20 A/N Required if Firm Account Number is not provided. Firm Account Number 64 83 20 A/N Required if Fund Account Number is not provided. OC 10 Pulls from Request File OC 11 Pulls from Request File Fund/SERV Control Number 84 98 15 A/N O Pulls from Request File Response Type 99 100 2 A/N 01 = Summary Level 02 = Detail Level 03 = Both Summary and Detail 04 = Acknowledgment 05 = Firm R 28 Populated with 02 when responding with detail records and there are no initial errors on the Request File. OR Populated with 05 if Request File contains errors and Recordkeeper is rejecting the Request File. Rule 22c-2 Schwab Retirement Technologies Page 20 of 39

Field Name Start End Len Type Description Opt/ Req SDR SDR Response Number 101 115 15 A/N R 27 Participant Number (pppp) is the first four numbers of the SDR Control Number. y = Last digit of current year jjj = Julian Date (the day of the year. For example, February 2 nd would be 032 (32 nd day of the year) nnnn = TPA followed by a 3 digit TPA sequence number. For Example: SDR Control #: 123456789012345 Today s date: 06/01/2006 (152 nd day of the year) TPA : 0123 Based on the info above the SDR Control Number would be: 123461520123001 Rule 22c-2 Schwab Retirement Technologies Page 21 of 39

Field Name Start End Len Type Description Opt/ Req Partial Response Indicator 116 116 1 A/N 0 = Full/Final Response 1 = Partial Response 2 = Incomplete/Final Response R 29 SDR For One Time Requests: Files that were broken up to stay under the file limit have the Partial Response Indicator set to 1 except for the final file in the group, which is set to 0. Response files that fit into one file have the Partial Response Indicator set to 0. For Recurring Requests: All response files (files that are broken up to stay under the file limit and/or single recurring request files have the Partial Response Indicator set to 1. Correction Indicator 117 117 1 A/N 0 = Regular O 30 Hard coded with 0 1 = Correction Filler 118 141 24 A/N Space R Hard coded with blank spaces NSCC Indicator 142 142 1 A/N Input: Space R Hard coded with blank spaces Output: 0 = Accepted by NSCC 1 = ed by NSCC NSCC 1 143 144 2 A/N Input: Space Output: code or space NSCC 2 145 146 2 A/N Input: Space Output: code or space NSCC 3 147 148 2 A/N Input: Space Output: code or space R R R Hard coded with blank spaces Hard coded with blank spaces Hard coded with blank spaces Rule 22c-2 Schwab Retirement Technologies Page 22 of 39

Field Name Start End Len Type Description Opt/ Req NSCC 4 149 150 2 A/N Input: Space Output: code or space R SDR Hard coded with blank spaces Rule 22c-2 Schwab Retirement Technologies Page 23 of 39

SDR (B/U23) Record 1 of 1 Required Input From Firm to NSCC Output From NSCC to Fund (accepted) and Firm (rejected) Note: This record will be submitted within the Header (B/U21) and Trailer (B/U27). Field Name Start End Len Type Description Opt/ Req SDR Originator Type 1 1 1 A/N B = Firm R 01 d as U. U = Underlying Firm Record Type 2 3 2 A/N 23 = SDR R 02 Hard coded with 23 Sequence Number 4 5 2 A/N 01 R 03 Hard coded with 01 Firm 1 6 7 2 A/N R 66 Audit checks determine s. Firm 2 8 9 2 A/N O 66 Audit checks determine s. Firm 3 10 11 2 A/N O 66 Audit checks determine s. Firm 4 12 13 2 A/N O 66 Audit checks determine s. Filler 14 141 128 A/N Space R Hard coded with blank spaces NSCC Indicator 142 142 1 A/N Input: Space R Hard coded with blank spaces Output: 0 = Accepted by NSCC 1 = ed by NSCC NSCC 1 143 144 2 A/N Input: Space Output: code or space R Hard coded with blank spaces Rule 22c-2 Schwab Retirement Technologies Page 24 of 39

Field Name Start End Len Type Description Opt/ Req NSCC 2 145 146 2 A/N Input: Space R SDR Hard coded with blank spaces Output: code or space NSCC 3 147 148 2 A/N Input: Space Output: code or space NSCC 4 149 150 2 A/N Input: Space Output: code or space R R Hard coded with blank spaces Hard coded with blank spaces Rule 22c-2 Schwab Retirement Technologies Page 25 of 39

SDR Detail (B/U24) Record 1 of 2 Required Input From Firm to NSCC Output From NSCC to Fund (accepted) and Firm (rejected) The Detail records represent the Shareholder SSN/TIN within a particular Plan ID or Investor Omnibus Account. The Detail may be repeated within the Header (B/U21) and Trailer (B/U27) records. Field Name Start End Len Type Description Opt/Req SDR Originator Type 1 1 1 A/N B = Firm R 01 d as U. U = Underlying Firm Record Type 2 3 2 A/N 24 = SDR Detail R 02 Hard coded with 24 Sequence Number 4 5 2 A/N 01 R 03 Hard coded with 01 for Record #1. Plan ID/Investor Omnibus Account Number 6 25 20 A/N O 14 Pulls Plan ID from Request File Omnibus Account Indicator 26 26 1 A/N 0 = Plan ID 1 = Investor Omnibus Account O 15 Hard coded as 0. SSN/TIN 27 35 9 A/N R 16 Participant s Social Security Number. Rule 22c-2 Schwab Retirement Technologies Page 26 of 39

Field Name Start End Len Type Description Opt/Req SDR SSN/TIN Indicator 36 36 1 A/N 0 = Tax ID number R 32 Hard coded as 1. 1 = Social security number 2 = Investor TIN/EIN NAV Date 37 44 8 A/N mmddccyy R 33 Transaction Process Date. Transaction Type 45 46 2 A/N 01 = Buy 02 = Sell 03 = Exchange (Intra-Fund Buy Side) 04 = Exchange (Intra-Fund Sell Side) 05 = Transfer In(such as ACATS, Networking B52, and transfers in kind) R 25 Transfers represent transfers in and out of the plan (conversion, mergers, rollovers in, rollovers out). User maps tax codes to these categories. All other transactions would be coded as 01 = Buy or 02 = Sell. 06 = Transfer Out (such as ACATS, Networking B52, and transfers in kind) Rule 22c-2 Schwab Retirement Technologies Page 27 of 39

Field Name Start End Len Type Description Opt/Req SDR Transaction (Used to indicate detailed/specific transaction codes that fall under the respective Transaction Types) 47 48 2 A/N 01 = Employee Contribution 02 = Employer Contribution 03 = Additional Contribution 04 = Loan repayment-principal 05 = Loan repayment-interest 06 = Forfeiture 07 = Adjustments 08 = Fund Transfer 09 = Exchange 10 = Conversion Balance Transfer 11 = Non-discrimination refund 12 = Loan Distribution 13 = In-service distribution 14 = Installment Distribution 15 = Termination Distribution 16 = Hardship Distribution 17 = Lump Sum Distribution 18 = QDRO Distributions 19 = Required Minimum Distribution 20 = STR Fee 21 = CDSC Fee 22 = Other Fees 23 = Rebalance 24 = Return of Excess Distribution 25 = Rollover 50 = Initial/Subsequent Purchase 51 = Sell/Redemption 52 = Physical Transfer of Shares 53 = Automated Investment Transaction O 34 Hard coded blank spaces Transaction Category 49 49 1 A/N 1 = Category 1 2 = Category 2 Dollar Amount 50 65 16 N 99,999,999,999,999.99 Optional if Transaction Type = 05, or if Transaction = 7 or 52. R 35 RC 36 Category 1 are participant directed trades; Category 2 are All transactions as mapped by the user. Dollar Amount of transaction Rule 22c-2 Schwab Retirement Technologies Page 28 of 39

Field Name Start End Len Type Description Opt/Req SDR Share Amount 66 79 14 N 9,999,999,999.9999 R 37 Unit precision is 4 decimals. Price 80 91 12 N 999,999.999999 RC 38 Unit precision is 6 decimals. Optional if Transaction Type = 05, or if Transaction = 7 or 52. Transaction ID 92 111 20 A/N O 39 Hard coded with spaces Contra Security Issue ID 112 120 9 A/N O 40 Hard coded with spaces Social 121 122 2 A/N Space R Hard coded with spaces Filler 123 141 19 A/N Space R Hard coded with spaces NSCC Indicator 142 142 1 A/N Input: Space R Hard coded with spaces Output: 0 = Accepted by NSCC 1 = ed by NSCC NSCC 1 143 144 2 A/N Input: Space R Hard coded with spaces Output: code or space NSCC 2 145 146 2 A/N Input: Space R Hard coded with spaces Output: code or space NSCC 3 147 148 2 A/N Input: Space R Hard coded with spaces Output: code or space NSCC 4 149 150 2 A/N Input: Space Output: code or space R File terminated with standard CR/LF. Rule 22c-2 Schwab Retirement Technologies Page 29 of 39

SDR Detail (B/U24) Record 2 of 2 Optional Input From Firm to NSCC Output From NSCC to Fund (accepted) and Firm (rejected) Field Name Start End Len Type Description Opt/ Req SDR Originator Type 1 1 1 A/N B = Firm R 01 Hard coded as U. U = Underlying Firm Record Type 2 3 2 A/N 24 = SDR Detail R 02 Hard coded with 24 Sequence Number 4 5 2 A/N 02 R 03 Hard coded with 02 STR Fee Amount 6 12 7 N 99,999.99 O CDSC Amount 13 19 7 N 99,999.99 O 41 42 Short term redemption fee associated with a transaction. Hard coded with spaces Transaction Source 20 20 1 A/N 0 = Participant/Shareholder O 43 Hard coded as 3. 1 = Plan/Administrator 2 = Rep 3 = Firm Cannot Differentiate Registered Representative (RR) Number 21 29 9 A/N O Hard coded with spaces RR Branch 30 38 9 A/N O Hard coded with spaces Rule 22c-2 Schwab Retirement Technologies Page 30 of 39

Field Name Start End Len Type Description Opt/ Req SDR RR Firm 39 46 8 A/N O Hard coded with spaces Agent For Firm 47 50 4 A/N O Plan Name 51 85 35 A/N O Customer Name 86 120 35 A/N O Hard coded with spaces Hard coded with spaces Hard coded with spaces Filler 121 150 30 A/N Space R Hard coded with spaces Rule 22c-2 Schwab Retirement Technologies Page 31 of 39

SDR Trailer (B/U27) Record 1 of 2 Required Input From Firm to NSCC Output From NSCC to Fund and Firm The SDR Trailer record Sequence #1 is used to recap the SDR Acknowledgment (B/U22), (B/U23), Detail (B/U24) and/or Summary (B/U25) records. Field Name Start End Len Type Description Opt/ Req SDR Originator Type 1 1 1 A/N B = Firm R 01 d as U. U = Underlying Firm Record Type 2 3 2 A/N 27 = SDR Trailer R 02 d as 27 Sequence Number 4 5 2 A/N 01 R 03 d as 01 SDR Control Number 6 20 15 A/N Same as in the Header (B/U21) R 04 Pulls from Request File Firm Number 21 24 4 A/N Same as in the Header (B/U21) R 06 Pulls from Request File Fund Number 25 28 4 A/N Same as in the Header (B/U21) R 09 Pulls from Request File Security Issue ID 29 37 9 A/N Same as in the Header (B/U21) R 13 Pulls from Request File Underlying Firm Number 38 41 4 A/N Same as in the Header (B/U21) O 07 Pulls from the Underlying Firm Number (BTRAC ID) field in & Map Maintenance. Rule 22c-2 Schwab Retirement Technologies Page 32 of 39

Field Name Start End Len Type Description Opt/ Req SDR SDR Response Number 42 56 15 A/N Same as in the Header (B/U21) R 27 Participant Number (pppp) is the first four numbers of the SDR Control Number. Y=Last digit of current year jjj = Julian Date (the day of the year. For example, February 2nd would be 032 (32nd day of the year). The Julian date is based on the calendar date and NOT the System Process Date. nnnn = TPA followed by a 3 digit TPA sequence number. For Example: SDR Control #: 123456789012345 Today s date: 06/01/2006 (152nd day of the year) TPA : 0NNN Based on the info above the SDR Control Number would be: 123461520NNN001 Total Acknowledgment Items 57 65 9 N 999,999,999 Number of record type 22 with sequence 01 within this group (Zero Allowed) R d as 0. Rule 22c-2 Schwab Retirement Technologies Page 33 of 39

Field Name Start End Len Type Description Opt/ Req SDR Total Items 66 74 9 N 999,999,999 Number of record type 23 with sequence 01 within this group (Zero Allowed). Total Detail Items 75 83 9 N 999,999,999 Number of record type 24 with sequence 01 within this group (Zeroes Allowed). Total Summary Items 84 92 9 N 999,999,999 R Sum of the number of lines that have a Record Type = 23 and Sequence = 01. R Sum of the number of lines that have a Record Type = 24 and Sequence = 01. R d as 0. Number of record type 25 with sequence 01 within this group (Zeroes Allowed). Total Records 93 101 9 N 999,999,999 Total number of PHYSICAL records (including SDR headers and trailers) within this group. R Sum of the total of all lines including headers and trailers. Filler 102 141 40 A/N Space R Hard coded with spaces. NSCC Indicator 142 142 1 A/N Input: Space R Hard coded with spaces. Output: 0 = Accepted by NSCC 1 = ed by NSCC NSCC 1 143 144 2 A/N Input: Space Output: code or space NSCC 2 145 146 2 A/N Input: Space Output: code or space R R Hard coded with spaces. Hard coded with spaces. Rule 22c-2 Schwab Retirement Technologies Page 34 of 39

Field Name Start End Len Type Description Opt/ Req NSCC 3 147 148 2 A/N Input: Space R SDR Hard coded with spaces. NSCC 4 149 150 2 A/N Input: Space Output: code or space Output: code or space R Hard coded with spaces. Rule 22c-2 Schwab Retirement Technologies Page 35 of 39

SDR Trailer (B/U27) Record 2 of 2 Output From NSCC to Fund and firm The SDR Trailer record Sequence #2 is used by NSCC to inform Firms and Funds of the number of items that have been accepted or rejected by NSCC on input. Note: The Trailer Record #2 of 2 is not generated by the Recordkeeping system. This record is added later by the Charles Schwab Trust Company and/or NSCC. Field Name Start End Len Type Description Opt/ Req SDR Originator Type 1 1 1 A/N B = Firm R 01 d as U. U = Underlying Firm Record Type 2 3 2 A/N 27 = SDR Trailer R 02 Hard coded 27 Sequence Number 4 5 2 A/N 02 R 03 Hard coded 02 Total Input Acknowledgment Items accepted Total Input Items Accepted 6 14 9 N 999,999,999 Number of record type 22 with sequence 01 accepted by NSCC on input. 15 23 9 N 999,999,999 Input: Space Output: Number of record type 23 with sequence 01 accepted by NSCC on input. R Hard coded with spaces. Acknowledgment is not supported. R Hard coded with spaces. Rule 22c-2 Schwab Retirement Technologies Page 36 of 39

Field Name Start End Len Type Description Opt/ Req SDR Total Input Detail Items Accepted Total Input Summary Items Accepted Total Input Acknowledgment Items ed Total Input Items ed 24 32 9 N 999,999,999 Input: Space Output: Number record type 24 with sequence 01 accepted by NSCC on input. 33 41 9 N 999,999,999 Input: Space Output: Number of record type 25 with sequence 01 accepted by NSCC on input. 42 50 9 N 999,999,999 Input: Space Output: Number of record type 22 with sequence 01 rejected by NSCC on input. 51 59 9 N 999,999,999 Input: Space Output: Number of record type 23 with sequence 01 rejected by NSCC on input. R Hard coded with spaces. R Hard coded with spaces. R Hard coded with spaces. R Hard coded with spaces. Rule 22c-2 Schwab Retirement Technologies Page 37 of 39

Field Name Start End Len Type Description Opt/ Req SDR Total Input Detail Items ed Total Input Summary Items ed 60 68 9 N 999,999,999 Input: Space Output: Number of record type 24 with sequence 01 rejected by NSCC on input. 69 77 9 N 999,999,999 Input: Space Output: Number of record type 25 with sequence 01 rejected by NSCC on input R Hard coded with spaces. R Hard coded with spaces. Filler 78 150 73 A/N Space R Hard coded with spaces. Rule 22c-2 Schwab Retirement Technologies Page 38 of 39

SDR Grand Total Trailer (B/F/N/U29) Record 1 of 1 Required Input/Output The SDR grand total trailer record is used to recap all records for a submitting participant (on input to NSCC) or receiving participant (on output from NSCC). Note: The Trailer Record #2 of 2 is not generated by the Recordkeeping system. This record is added later by the Charles Schwab Trust Company and/or NSCC. Field Name Start End Len Type Description Opt/ Req Originator Type 1 1 1 A/N Input: B = Firm F = Fund U = Underlying Firm Output: N = NSCC R Hard coded as U Record Type 2 3 2 A/N 29 = SDR Grand Total Trailer R Hard coded 29 Sequence Number 4 5 2 A/N 01 R Hard coded 01 Participant Number 6 9 4 A/N Input: Submitter (Originator) R Uses the first four numbers of the SDR Control Number from the Request File Output: Recipient Total records 10 18 9 N 999,999,999 R Sum of all lines, including headers and trailers. Total number of PHYSICAL records per submitter (input to NSCC) or recipient (output from NSCC) Filler 19 150 132 A/N Space R Hard coded as spaces Page 39 of 39