Plan Implementation Guide - Ameriprise

Ameriprise® SIMPLE IRAPlan Implementation Guide

24004 AF (10/20) Page 1 of 40

Ameriprise SIMPLE Plan

Congratulations on your new retirement planYour Ameriprise® SIMPLE IRA plan is a smart choice because it’s designed just for small businesses. This tax-advantaged retirement plan benefits you, your business and your employees in many ways:

Benefitsforyouandyourbusiness.• Attract employees

– You can compete for labor more effectively by offering an attractive retirement program, the cornerstone of many benefit packages

• Reduce taxes

– You can reduce pre-tax profits by making deductible contributions to the plan

• Low administrative costs

– Unlike some other retirement plans, there is no annual IRS Form 5500 reporting required

– There is no requirement to track vesting

• Your employees can contribute to their retirement savings through convenient payroll deductions

Benefitsforyouremployees.

• Salary deferrals

– Employees have a convenient way to save for retirement through salary deferrals

– Employees age 50 and over may make additional “catch-up” salary deferral contributions

• Tax-deferred growth

– Employees can benefit from the advantages of potential earnings on tax-deferred savings while the assets remain in their SIMPLE IRA

• Investment control

– Contributions are made directly to the participant’s SIMPLE IRA, giving your employees control over their own investment

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The Ameriprise Financial advantageFor more than 120 years, Ameriprise Financial has been helping clients just like you reach their long-term financial goals. Count on your Ameriprise financial advisor to provide the high-quality service and support necessary to meet your needs and those of your employees.

• Your financial advisor will help you establish the plan and communicate it to your employees following the steps outlined in this implementation guide

• Your financial advisor can meet with your employees to discuss their financial planning goals and the wide range of investment options available to help them reach their dreams

Thisguidebookcontainseverythingyouneedtosetup,operateandadministeryourSIMPLEIRAplanfromAmeripriseFinancial.

• Checklist of steps for implementing and managing your plan

• IRS-approved plan documents

• Tools for communicating with your employees

• Forms necessary to execute and operate your plan

• Resources for further information

The table on the opposite page provides more information on the use of each required form and document.

You’ll need to use some forms and documents in this guidebook more than once. Therefore, we recommend that you make copies of the enclosed paperwork rather than writing on the originals. Retain this booklet for use with future participants.

Your Ameriprise financial advisor can answer any of your questions about the SIMPLE IRA plan and the procedures for implementing and managing it. We look forward to working with you and your employees!

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Guide to SIMPLE plan forms and documentsForm/Documentletter

Form/Documentname

Reviewdocument

Makecopiesforfutureuse(donotwriteonoriginal)

Keepcompletedformforyourrecords

Givecompletedcopytoyourfinancialadvisor

Makecopiesanddistributetoemployees

Page numbers

A SIMPLE IRA Employer Eligibility Form

Keep original

7

B Basic Plan Document Keep original

9–16

C IRS Department of Treasury Letter

Keep original

17

D.1 Adoption Agreement Instructions

19–20

D Adoption Agreement Keep original

Recommended but not required

21–22

E Employee Participation Notice and Summary Description

Keep original

23–24

F.1 Employee Announcement Letter (Matching Contributions)

Keep original

25

F.2 Employee Announcement Letter (Nonelective Contributions)

Keep original

26

G Employee Salary Reduction Agreement

Keep a copy of

each employee’s completed form

27–28

H Employer Payroll Remittance, Arrangement Setup or Changes Form

Give original to financial advisor

29–31

I Online Payroll ACH Agreement

Give original to financial advisor

33–34

K Employee Frequently Asked Questions

35–36

L Employer Frequently Asked Questions

37–39

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Implementation steps1. Establishyourplan There are three phases to implementing your

SIMPLE IRA plan, and Ameriprise Financial is there to help you every step of the way. First, you need to establish the plan by completing a number of forms, as described below. Then you’re ready to communicate the plan to employees. Lastly, you will set up contribution procedures.

CompletetheSIMPLEIRAplanEmployerEligibilityForm(A)

• Review with your legal counsel and tax advisor

• After all parties approve, complete and sign the form

• Give a copy of the completed form to your Ameriprise financial advisor

• Retain the original in your records

ReviewtheBasicPlanDocument(B)andIRSDepartmentofTreasuryLetter(C)

• The Plan is a legal instrument; have your legal counsel and tax advisor review it before you adopt it

• After all parties approve, retain it in your records

ReviewandcompletetheAdoptionAgreement(D) • Use the AdoptionAgreementInstructions

(D.1) to guide you in completing this form

• The Agreement is a legal instrument; have your legal counsel and tax advisor review it before you complete it

• After all parties approve, complete and sign the Agreement

• It’s recommended that you provide a copy of the completed form to your Ameriprise financial advisor but not required


CompletetheEmployeeParticipationNoticeandSummaryDescription(E)

• Use this notice to select a contribution formula — either Matching Contributions or Nonelective Contributions


• Distribute it to your employees (see Step Two instructions)

2. Employeecommunicationandenrollment Once you have established your plan, you can

communicate it to your employees. Your Ameriprise financial advisor can help you with this process.

CommunicateyournewSIMPLEIRAplantoparticipatingemployees

• Distribute the Employee Participation Notice and Summary Description (E) to participating employees

• This notification must include your plans for Matching or Nonelective Employer Contributions

• You must distribute this notification to all eligible employees before the 60-day election period begins. (Note: The 60-day election period is the period of time wherein eligible employees must be given the opportunity to enter into a salary reduction agreement or to modify a prior agreement. The 60-day period must include the date an employee becomes eligible to participate in the plan or the day before that date.)

• Distribute the Employee Announcement Letter that announces the adoption of the plan and the contribution formula you have elected. Distribute Employee Announcement Letter (F.1) if you have elected Matching Contributions or Employee Announcement Letter (F.2) if you have elected Nonelective Contributions

• Distribute the Employee Frequently Asked Questions (K)

Conductenrollmentmeetingswithyouremployees

• Schedule your Ameriprise financial advisor to speak at enrollment meetings and distribute enrollment kits

• Conduct enrollment meetings where your Ameriprise financial advisor will present the retirement plan and basic investment principles

• Invite employees to discuss their investment options with your Ameriprise financial advisor and to establish their SIMPLE IRA account

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3. Contributetotheplan The final phase in setting up the SIMPLE IRA is to

establish procedures for making plan contributions.

Each participating employee will need to complete an EmployeeSalaryReductionAgreement(G), which authorizes you to withhold an amount from their paycheck. This form should be returned to you.

Establishanongoingremittanceprocedure Ameriprise Financial works with National Benefit

Services (NBS), a third-party administrator (TPA), to provide payroll remittance services.

• Complete the EmployerPayrollRemittance, ArrangementSetuporChangesForm(H) and the OnlinePayrollACHAgreement(I) and give them to your financial advisor

• NBS will send you an e-mail with additional instructions. After you have gone through the setup process for online payroll processing, begin withholding salary deferrals from participants’ paychecks based on their elections made on the EmployeeSalaryReductionAgreement(G)

• Upload your deposit instructions to the secure website and the corresponding payment will be pulled from your bank account

• A Payroll Reduction Detail (PRD) will be available to you on the NBS secure website

ContinuingplanadministrationOngoing administration of your SIMPLE IRA plan involves providing annual notice to employees and enrolling new participants.

Annualnoticetoemployees Each year, an annual notice to employees must

be distributed no later than November 1 (at least 60 days prior to the start of the upcoming plan year). This notice communicates to eligible employees the employer contribution formula you have elected for the upcoming year.

• Each year, complete the EmployeeParticipationNoticeandSummaryDescription(E)

• Update plan information

• Distribute to employees no later than November 1

Enrollnewparticipants As employees become eligible to participate in

the plan, you will need to communicate to them the opportunity to participate.

• Distribute theEmployeeParticipationNoticeandSummaryDescription(E) 60 days prior to the date a new employee becomes eligible to participate in the plan

• If your plan offers immediate eligibility, the notice should be delivered on the first day of employment

• Contact your Ameriprise financial advisor to assist in the enrollment process

• Add the new employee information to payroll processing and begin withholding contributions

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Working toward a confident retirement

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SEP PlanEmployer Eligibility Form

AForm 423pg. 1 of 1

© 2007 Ascensus, Inc., Brainerd, MN

The following questions are designed to help you, the Employer, along with your tax advisor, determine if you are eligible to adopt aSIMPLE IRA plan. Please answer the following questions:

RequirementsYES NO

1. Do you own or control a business for which you provide personal services and receive income?If the answer is NO, STOP. You are not eligible to establish this Plan.

2. Do you have more than 100 employees who received at least $5,000 of compensation from you in the previouscalendar year?If the answer is YES, STOP. You are not eligible to establish this Plan (certain acquisition exception rules apply).

3. Have you maintained any other qualified plan during the current calendar year in which contributions were made or benefits were accrued?If the answer is YES, STOP. You are not eligible to establish this Plan.

NOTE: If your business• is a member of a controlled group of corporations, businesses, or trades, (whether or not incorporated) within the meaning of IRC

Section 414(b) or 414(c);• is a member of an affiliated service group within the meaning of IRC Section 414(m); or• uses the services of leased employees within the meaning of IRC Section 414(n);

You may have to include the leased employees and/or employees of the other business(es) in your Plan. Please consult your tax advisorto determine what additional action, if any, you must take.

SignatureImportant: Please read before signing:

I certify that: 1. I am an authorized representative of the Employer and the Employer is eligible to establish the SIMPLE IRA plan ofthe Prototype Sponsor (Ameriprise Financial).

2. In determining my eligibility to adopt this Plan, I relied solely upon the advice of my own advisors.

3. I agree not to hold the Prototype Sponsor, Ameriprise Financial, responsible for any liabilities I may suffer as a resultof being found ineligible to establish this Plan.

DATE EXECUTED

PRINT NAME OF EMPLOYER

SIGNATURE OF EMPLOYER

24004 R (11/10) ©2007 Ascensus, Inc., Brainerd, MN Page 7 of 44

Form 612pg. 1 of 1

ASIMPLE IRAEmployer Eligibility Form

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SEP PlanBasic Plan Document

BForm 419pg. 1 of 6

DefinitionsAdopting Employer Means any corporation, sole proprietor or other entity named in the Adoption Agreement and any successor who bymerger, consolidation, purchase or otherwise, assumes the obligations of the Plan.

Adoption Agreement Means the document executed by the Employer through which it adopts the Plan and thereby agrees to be bound byall terms and conditions of the Plan.

Basic Plan Document Means this prototype plan document.

Code Means the Internal Revenue Code of 1986 as amended.

Compensation Means with respect to an Employee the sum of the wages, tips, and other compensation from the Employer subject tofederal income tax withholding (as described in Code section 6051(a)(3)) and the Employee’s salary reduction contributions made underthis Plan, and, if applicable, elective deferrals on behalf of the Employee under a Code section 401(k) plan, a SARSEP, a Code section403(b) annuity contract and compensation from the Employer deferred under a Code section 457 plan required to be reported by theEmployer on IRS Form W-2 Wage and Tax Statement (as described under Code section 6051(a)(8)). Compensation does not include anyamounts deferred by the Employee pursuant to a Code section 125 cafeteria plan.

For self-employed individuals, Compensation means the net earnings from self-employment with respect to the Employer determinedunder §1402(a) of the Code, without regard to §1402(c)(6), prior to subtracting any contributions made pursuant to this plan on behalf ofthe individual.

Compensation shall include only the Compensation that is actually paid to the Employee during the Year.

For purposes of the two-percent Nonelective Contribution described in Section 4.02(C) of the Plan, the annual Compensation of eachEmployee taken into account under the Plan shall not exceed the compensation limit described in Code section 401(a)(17) as adjustedby the Secretary of the Treasury for increases in the cost-of-living in accordance with Code section 401(a)(17)(B). Such adjustments willbe in multiples of $5,000. (The Compensation limit for 2012 is $200,000.)

Contributing Participant Means an Employee who has met the eligibility requirements and who has enrolled as a Contributing Participantpursuant to Section 3.04(A) of the Plan and on whose behalf the Employer is contributing Elective Deferrals.

Earned Income Means the net earnings from self-employment in the trade or business with respect to which the Plan is established,determined under Code section 1402(a), without regard to Code section 1402(c)(6), prior to subtracting any contributions made pursuantto this Plan on behalf of the Self-Employed individual.

Election Period Means the period during which a Participant may enroll as a Contributing Participant. The Election Period shall be the 60-day period immediately before the beginning of any Year and such other 60-day period or periods as described in Section 3.04(A) of the Plan.

Employee Means a common-law employee of the Employer, and also includes leased employees described in Code section 414(n),unless otherwise elected in the Adoption Agreement, and employees described in Code section 414(o) that are required to be treated as employed by the Employer. The term “Employee” also includes self-employed individuals described in Code section 401(c)(1).

Employer Means the Adopting Employer and any successor who by merger, consolidation, purchase or otherwise assumes the obligationsof the Plan, provided such entity meets the eligibility requirement described in Code section 408(p)(2)(c)(i). A partnership is considered tobe the Employer of each of the partners and a sole proprietorship is considered to be the Employer of the sole proprietor.

If the Adopting Employer is a member of a controlled group of corporations (as defined in Code section 414(b)), a group of trades orbusinesses under common control (as defined in Code section 414(c)), an affiliated service group (as defined in Code section 414(m)) or is required to be aggregated with any other entity as defined in Code section 414(o), then for purposes of the Plan, the term Employershall include the other members of such groups or other entities required to be aggregated with the Adopting Employer.

An Employer meets the eligibility requirement and therefore will be eligible to maintain this Plan with respect to any Year only if theEmployer had no more than 100 Employees who received at least $5,000 of Compensation from the Employer for the preceding Year.

An eligible Employer who establishes and maintains a SIMPLE IRA plan for one or more Years and who fails to be an eligible Employer for any subsequent Year shall be treated as an eligible Employer for the two Years following the last Year the Employer was an eligibleEmployer. If such failure is due to any acquisition, disposition, or similar transaction involving an eligible Employer, the preceding sentenceshall apply only in accordance with rules similar to the rules of Code section 410(b)(6)(C)(i).

Participant Means any Employee who has met the eligibility requirements of Section 3.01 of the Plan and Section 3 of the AdoptionAgreement, may enroll as a Contributing Participant and is or may become eligible to receive an Employer Contribution.


Form 619pg. 1 of 8

B


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SEP Plan (continued)Basic Plan Document

BForm 419 pg. 2 of 6

Plan Means the prototype SIMPLE IRA plan adopted by the Employer that is intended to satisfy the requirements of Code section 408(p). The Plan consists of this Basic Plan Document plus the corresponding Adoption Agreement as completed and signed by the Adopting Employer.

Prior Plan Means a SIMPLE IRA plan which was amended or replaced by adoption of this Plan, as indicated in the Adoption Agreement.

Prototype Sponsor Means the entity specified in the Adoption Agreement that makes this prototype Plan available to employers for adoption.

Regulations Means the Treasury Regulations.

Salary Reduction Agreement Means an agreement, made on a form provided by the Employer, pursuant to which a Participant may electto have his or her Compensation reduced and paid as an Elective Deferral to his or her SIMPLE IRA by the Employer. No Salary ReductionAgreement may apply to Compensation that a Participant received, or had a right to immediately receive, before execution of the SalaryReduction Agreement.

Self-employed Individual Means an individual who has Earned Income for a Year from the trade or business for which the Plan isestablished; also, an individual who would have had Earned Income but for the fact that the trade or business had no net profits for the Year.

SIMPLE IRA Means the individual retirement account or individual retirement annuity, which satisfies the requirements of Code sections408(p) and 408(a) or 408(b), and, with respect to which, the only contributions allowed are contributions under a SIMPLE IRA plan.

Summary Description Means a statement provided by the trustee, custodian or issuer of a SIMPLE IRA to the Adopting Employerpursuant to Section 1.05 of the Plan which contains the following information:

(i) the names and addresses of the Adopting Employer and the trustee, custodian or issuer of the SIMPLE IRA; (ii) the eligibility requirements that must be satisfied to become a Participant in the Plan;(iii) the benefits provided with respect to the Plan;(iv) the timing and method of making elections with respect to the Plan; and(v) the procedures for, and effects of, withdrawals (including rollovers) from the Plan.

Year Means the calendar year.


Form 619pg. 2 of 8

B


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Section 1 Establishment and Purpose of Plan

1.01 PurposeThe purpose of this Plan is to provide, in accordance with its provisions, a SIMPLE IRA plan providing benefits upon retirement for theindividuals who are eligible to participate hereunder.

1.02 Intent to QualifyIt is the intent of the Employer that this Plan shall be for the exclusive benefit of its Employees and shall qualify for approval underCode section 408(p), as amended from time to time (or corresponding provisions of any subsequent federal law at that time in effect)as a SIMPLE IRA plan. This document is intended to conform with the applicable rules and procedures of the Internal Revenue Service(IRS) that apply to prototype SIMPLE IRA plans.

1.03 Exclusive Plan RequirementA. In General

The Employer cannot contribute to this Plan for any Year if the Employer maintains another qualified plan with respect to whichcontributions are made, or benefits are accrued, for any Employee’s service for any plan year beginning or ending in that Year.

For this purpose, a qualified plan is defined in Code section 219(g)(5) as:

a plan described in Code section 401(a) that includes a trust exempt from tax under Code section 501(a); an annuity plandescribed in Code section 403(a); a plan established for its employees by the United States, by a State or political subdivisionthereof, or by an agency or instrumentality of any of the foregoing (but not an eligible deferred compensation plan within themeaning of Code section 457 (b)); a tax-sheltered annuity plan described in Code section 403(b); a simplified employee pension(SEP) plan described in Code section 408(k); and another SIMPLE IRA Plan described in Code section 408(p).

If a failure to meet the exclusive plan requirement is due to an acquisition or similar transaction, the Employer is treated as meetingthe exclusive plan requirement through the end of the following Year (through the end of the following two Years, if permitted byCode section 408(p)). However, the Employer is treated as satisfying the exclusive plan requirement only if, during the perioddescribed above, Employees who would be employed by another employer involved in the transaction had the transaction notoccurred are not eligible to participate in this Plan.

B. Special RuleNotwithstanding Section 1.03(A) of the Plan, the exclusive plan requirement is not violated if the Employer maintains anotherqualified plan that limits participation to Employees covered under a collective bargaining agreement described in Code section410(b)(3)(A) and eligibility to participate in this Plan is limited to other Employees.

1.04 Use with Simple IRA This Plan must be used with an IRS model SIMPLE IRA (Form 5305-S or Form 5305-SA) or any other plan that satisfies Codesection 408(p).

1.05 Summary DescriptionThe Summary Description must be provided each Year by the trustee, custodian or issuer of a SIMPLE IRA to the Adopting Employerwithin a reasonable period of time prior to the Election Period. However, a trustee, custodian or issuer shall be deemed to haveprovided a Summary Description, if it provides, to Participants for whom it maintains SIMPLE IRAs, its name and address and its procedures for taking withdrawals from a SIMPLE IRA. In addition, the trustee, custodian or issuer must obtain reasonableassurance from the Employer that the Employer will provide its name and address, the SIMPLE IRA plan’s eligibility requirements,benefits, required information about SIMPLE IRA plan elections, and the effects of withdrawal pursuant to IRS Notice 98-4, to bedeemed to have provided a Summary Description.

1.06 For More InformationTo obtain more information concerning the rules governing this Plan, contact the Employer listed in Section 6 of the Adoption Agreement.

Section 2 Effective DatesThe Effective Date means the date the Plan (or in the event a Prior Plan is amended, the restatement) becomes effective as indicated in the Adoption Agreement.


Form 619pg. 3 of 8

B


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Section 3 Eligibility and Participation

3.01 Eligibility RequirementsExcept for those Employees described in Section 3.02 of the Plan who are excluded as indicated in the Adoption Agreement, eachEmployee of the Employer who fulfills the eligibility requirements specified in the Adoption Agreement shall become a Participant. EachParticipant must establish a SIMPLE IRA to which Employer Contributions under this Plan will be made.

3.02 Exclusion of Certain EmployeesThe Employer may exclude collective bargaining unit Employees, non-resident aliens and acquired Employees, as defined in paragraphs(A) through (C) below, from participating in the Plan.

A. Collective Bargaining Unit EmployeesA collective bargaining unit Employee is an Employee included in a unit of Employees covered by a collective bargaining agreementbetween the Employer and Employee representatives, if retirement benefits were the subject of good faith bargaining and if twopercent or less of the Employees who are covered pursuant to that agreement are professionals as defined in Regulations section1.410(b)-9. For this purpose, the term “Employee representatives” does not include any organization more than half of whosemembers are Employees who are owners, officers, or executives of the Employer.

B. Non-Resident AliensA non-resident alien is an Employee who is a non-resident alien, within the meaning of Code section 7701(b)(1)(B) and who receivedno earned income (within the meaning of Code section 911(d)(2)) from the Employer which constitutes income from sources withinthe United States (within the meaning of Code section 861(a)(3)).

C. Acquired EmployeesAn acquired Employee is an Employee who would be employed by another employer that has been involved in an acquisition or similar transaction with the Employer, had the transaction not occurred. An acquired Employee will not be eligible to become a Participant in the Plan for the Year of the transaction and the following Year (the following two Years if permitted by Code section 408(p)).

3.03 Admittance as a ParticipantA. Notification of Eligibility

The Employer shall notify each Employee who becomes a Participant of his or her status as a Participant in the Plan and of his or her duty to establish a SIMPLE IRA to which Employer Contributions may be made. Unless the Employer elects to make all Plancontributions to a Designated Financial Institution, the Employer must permit each Participant to select the financial institution thatwill serve as trustee, custodian or issuer of the SIMPLE IRA to which the Employer will make all contributions on behalf of suchParticipant.

B. Establishment of a SIMPLE IRAIf a Participant fails to establish a SIMPLE IRA, the Employer may execute any necessary documents to establish a SIMPLE IRA on behalf of the Participant.

3.04 Contributing ParticipantA. Requirements to Enroll as a Contributing Participant

A Participant for a particular Year must be permitted to enroll as a Contributing Participant or modify an existing Salary ReductionAgreement during the 60-day period immediately preceding the Year, effective as soon as practical after receipt by the Employer (or, if later, the date specified by the Participant in the Salary Reduction Agreement) but not earlier than the first pay periodbeginning during the Year. In the case of a Participant who becomes eligible to participate after the first day of the Year because (1) the Plan does not impose a prior-year Compensation requirement, (2) the Participant satisfied the Plan’s prior-year Compensationrequirement during a prior period of employment with the Employer, or (3) the Plan is first effective after the beginning of a Year, theParticipant must be permitted to enroll as a Contributing Participant or modify an existing Salary Reduction Agreement during the60-day Election Period that begins on the day notice is provided to the Participant and that includes the day the Participant beginsparticipating or the day before. In this case, the Salary Reduction Agreement will become effective as soon as practical after receiptby the Employer (or, if later, the date specified by the Participant in the Salary Reduction Agreement). Notwithstanding the foregoing,any Salary Reduction Agreement completed by the Participant may be modified prospectively at any time during the Election Period.In addition to the Election Periods described above, a Participant may make or modify an existing Salary Reduction Agreement duringany additional Election Periods specified in the Adoption Agreement.

If a Salary Reduction Agreement is made or modified during one of these additional Election Periods, it will become effective assoon as practical after receipt of the Salary Reduction Agreement by the Employer or, if later, the date specified by the Participant inthe Salary Reduction Agreement.


Form 619pg. 4 of 8

B


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The Employer shall notify each Participant immediately before each Election Period of the Participant’s opportunity to complete aSalary Reduction Agreement. The notice shall include, pursuant to rules or procedures promulgated by the IRS, a copy of theSummary Description as described in Code section 408(l)(2)(B) and this Plan. (Code section 6693(c)(1) provides that if theEmployer fails to provide one or more notices, such Employer may be subject to a penalty of $50 per day for each day that thefailure to provide notice occurs.)

A Participant who desires to enroll as a Contributing Participant must complete, sign and deliver to the Employer a Salary ReductionAgreement during the Election Period. In addition, the Employer, in a uniform and nondiscriminatory manner, may provide additionalopportunities for Participants to enroll as Contributing Participants in accordance with procedures established by the Employer.

B. Modification of Elective DeferralsEach Contributing Participant shall be notified by the Employer, immediately before each Election Period, of his or her right toincrease or decrease the amount of Compensation deferred into his or her SIMPLE IRA under the Plan. A Contributing Participantwho desires to make such a modification shall complete, sign and file a new Salary Reduction Agreement with the Employer duringthe Election Period. In addition, if the Employer permits, in a uniform and nondiscriminatory manner, a Contributing Participant maymodify his or her Salary Reduction Agreement more frequently in accordance with procedures established by the Employer.

C. Withdrawal as a Contributing ParticipantA Participant may withdraw as a Contributing Participant at any time during the Year by revoking his or her authorization to theEmployer to make Elective Deferrals on his or her behalf. A Participant who desires to withdraw as a Contributing Participant shallgive written notice of withdrawal to the Employer. The notice of withdrawal must become effective as soon as practical after receiptof the notice by the Employer, or if later, the date specified by the Participant on such notice. A Participant shall cease to be aContributing Participant upon his or her termination of employment, or on account of termination of the Plan.

D. Return as Contributing Participant after WithdrawalA Participant who has withdrawn as a Contributing Participant may not again become a Contributing Participant until the first day of the first Year following the effective date of his or her withdrawal as a Contributing Participant, unless the Employer, in a uniformand nondiscriminatory manner, permits withdrawing Participants to resume their status as Contributing Participants sooner.

3.05 Determinations Under This SectionThe Employer shall determine the eligibility of each Employee to be a Participant. This determination shall be conclusive and bindingupon all persons except as otherwise provided herein or by law.

3.06 Limitation Respecting EmploymentNeither the fact of the establishment of the Plan, nor the fact that an Employee has become a Participant, shall give to that Employeeany right to continued employment; nor shall either fact limit the right of the Employer to discharge or to deal otherwise with anEmployee without regard to the effect such treatment may have upon the Employee’s rights under the Plan.


Form 619pg. 5 of 8

B


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Section 4 Contributions and Allocations

4.01 Elective Deferrals and Catch-Up ContributionsA. Elective Deferrals

Elective Deferrals are contributions made by the Employer to the Plan on behalf of a Contributing Participant under a SalaryReduction Agreement. Elective Deferrals shall include catch-up contributions made to the Plan pursuant to Code section 414(v) andthe applicable Regulations and other guidance of general applicability issued thereunder as described in Section 4.01(B) of thisPlan. Each Participant who has met the eligibility requirements may elect under a Salary Reduction Agreement to have his or herCompensation reduced by a percentage or a fixed dollar amount. The salary reduction election shall be in writing and delivered tothe Employer. The amount of such reduction shall be contributed by the Employer to a SIMPLE IRA on behalf of the ContributingParticipant. For any Year, a Contributing Participant’s Elective Deferrals shall not exceed $7,000 for 2002, $8,000 for 2003, $9,000for 2004, $10,000 for 2005 and later years. After 2005, the maximum amount may be adjusted for cost-of-living increases. Such adjustments will be in multiples of $500. At the election of a Contributing Participant, the Employer shall contribute Elective Deferralsto the SIMPLE IRA of such Contributing Participant. Elective Deferrals for a Contributing Participant must be deposited to the SIMPLE IRAof such Contributing Participant by the Employer as of the earlier of: (1) the first date on which such Elective Deferrals can reasonablybe segregated from the Employer’s general assets or, (2) the close of the 30-day period following the last day of the month in which thecontribution is withheld from the Contributing Participant’s pay.

B. Catch-Up ContributionUnless otherwise specified in Section 4 in the Adoption Agreement, a Contributing Participant who attains age 50 on or before the endof the Year can elect to have his or her Elective Deferrals increased above the amounts specified in Section 4.01(A) of the Plan.The additional amount shall not be greater than $500 for 2002, $1,000 for 2003, $1,500 for 2004, $2,000 for 2005, and $2,500for 2006 and later years. After 2006, the additional amount may be adjusted for cost-of-living increases. Such adjustments will be in multiples of $500.

4.02 Required Employer ContributionsA. Employer Must Make Certain Contributions

An Employer Contribution is the amount contributed by the Employer to this Plan. Each Year, the Employer shall make either theMatching Contribution described in Section 4.02(B) of the Plan or the Nonelective Contribution described in Section 4.02(C) of thePlan to the SIMPLE IRAs of Participants entitled thereto. Such contributions for any Year shall be made not later than the due datefor filing the Employer’s tax return for such Year (including extensions).

B. Matching ContributionA Matching Contribution means an Employer Contribution made pursuant to this Plan on behalf of a Contributing Participant on account of an Elective Deferral, including Catch-up Contributions, made by such Contributing Participant. The Employer may satisfy the requirement set forth in Section 4.02(A) of the Plan by making a Matching Contribution to the SIMPLE IRA of eachContributing Participant for any Year in an amount equal to the amount of the Contributing Participant’s Elective Deferral which does not exceed three percent of the Contributing Participant’s Compensation for the Year (the “Matching Contribution percentage”).Notwithstanding the foregoing, the Employer may elect to apply a lower Matching Contribution percentage (not less than onepercent) for any Year for all Contributing Participants if the Employer notifies Participants of such lower Matching Contributionpercentage within a reasonable period of time before the Election Period for such Year. The Employer may not elect a lower Matching Contribution percentage for any Year if that election would result in the Matching Contribution percentage being lower than three percent in more than two of the Years in the five-Year period ending with such Year. If any Year in the five-Year perioddescribed in the preceding sentence is a Year prior to the first Year for which this SIMPLE IRA plan (or a Prior Plan) is in effect with respect to the Employer (or any predecessor employer), the Employer shall be treated as if the Matching Contributionpercentage was equal to three percent of Compensation for such prior Year.

C. Nonelective ContributionThe Employer may satisfy the requirement set forth in Section 4.02(A) of the Plan by making a Nonelective Contribution of two percent of Compensation to the SIMPLE IRA of each Participant who has at least $5,000 of Compensation (or such lesser amount of Compensation as may be specified in the Adoption Agreement) from the Employer for the Year provided the Employernotifies Participants that the Employer will be making a Nonelective Contribution within a reasonable period of time before theElection Period for such Year.

4.03 No Other ContributionsThe Employer shall make no contributions to the SIMPLE IRAs of Participants other than Elective Deferrals made pursuant to Section 4.01 of the Plan and those contributions required under Section 4.02 of the Plan. Nothing herein shall prevent an Employee from rolling over or transferring funds from another SIMPLE IRA to a SIMPLE IRA maintained under this Plan.


Form 619pg. 6 of 8

B


24004 AF (10/20) Page 15 of 40

4.04 Vesting and Withdrawal RightsAll Employer Contributions made under the Plan on behalf of Employees shall be fully vested and nonforfeitable at all times. EachEmployee shall have an unrestricted right to withdraw at any time all or a portion of the Employer Contributions made on his or herbehalf. However, withdrawals taken are subject to the taxation and penalty provisions of the Code which are applicable to distributionsfrom SIMPLE IRAs.

4.05 Simplified Employer ReportsThe Employer shall furnish reports, relating to account activity under the Plan, in the time and manner and containing the informationprescribed by the Secretary of the Treasury. The Employer shall furnish information to the trustee, custodian or issuer of SIMPLE IRAsof Participants as such trustee, custodian or issuer may reasonably request to enable it to fulfill its reporting and other responsibilitiesin connection with this Plan or the SIMPLE IRAs of Participants.

4.06 Use of Designated Financial InstitutionThis Section shall apply if the Employer has indicated in Section 4 in the Adoption Agreement that the Employer will make all Plancontributions at the Designated Financial Institution specified in the Adoption Agreement provided the financial organization agrees to act as the Designated Financial Institution. A Designated Financial Institution is a financial organization which is the trustee,custodian or issuer of the SIMPLE IRAs to which Plan contributions will be made. Use of a Designated Financial Institution is notrequired under this Plan, unless elected in Section 4 of the Adoption Agreement. If a Designated Financial Institution is named,pursuant to the provisions of Code section 408(p)(7) the Designated Financial Institution will notify Participants in writing (eitherseparately or as part of the notice described in Section 3.04 of the Plan) that their SIMPLE IRA balances may be transferred withoutcost or penalty to another SIMPLE IRA in accordance with the withdrawal and rollover provisions under Code section 408(d)(3).

Section 5 Amendment or Termination of Plan

5.01 Amendment by EmployerThe Employer reserves the right to amend the elections made or not made in the Adoption Agreement by executing a new AdoptionAgreement. The Employer shall neither have the right to amend any nonelective provision of the Adoption Agreement nor the right to amend provisions of this Basic Plan Document. If the Employer adopts an amendment to the Adoption Agreement or Basic PlanDocument in violation of the preceding sentence, the Plan will be deemed to be an individually designed plan and the Employer may no longer participate in this prototype Plan.

5.02 Amendment or Termination of Sponsorship by Prototype SponsorThe Employer, by adopting the Plan, expressly delegates to the Prototype Sponsor the power, but not the duty, to amend the Planwithout any further action or consent of the Employer as the Prototype Sponsor deems either necessary for the purpose of adjustingthe Plan to comply with all laws and applicable Regulations governing SIMPLE IRA plans or desirable to the extent consistent with such laws and applicable Regulations. Specifically, it is understood that the amendments may be made unilaterally by the PrototypeSponsor. However, it shall be understood that the Prototype Sponsor shall be under no obligation to amend the Plan documents andthe Employer expressly waives any rights or claims against the Prototype Sponsor for not exercising this power to amend.

An amendment by the Prototype Sponsor shall be accomplished by giving notice to the Adopting Employer of the amendment to bemade. The notice shall set forth the text of such amendment and the date such amendment is to be effective. Such amendment shalltake effect unless, within the 30-day period after such notice is provided, or within such shorter period as the notice may specify, theAdopting Employer gives the Prototype Sponsor written notice of refusal to consent to the amendment. Such written notice of refusalshall have the effect of withdrawing the Plan as a prototype plan and shall cause the Plan to be considered an individually designedplan. The right of the Prototype Sponsor to cause the Plan to be amended shall terminate should the Plan cease to conform as aprototype plan as provided in this or any other section.

In addition to the amendment rights described above, the Prototype Sponsor shall have the right to terminate its sponsorship of this Plan by providing notice to the Adopting Employer of such termination. Such termination of sponsorship shall have the effect of withdrawing the Plan as a prototype plan and shall cause the Plan to be considered an individually designed plan. The PrototypeSponsor shall have the right to terminate its sponsorship of this Plan regardless of whether the Prototype Sponsor has terminatedsponsorship with respect to other employers adopting its prototype Plan.


Form 619pg. 7 of 8

B


24004 AF (10/20) Page 16 of 40

5.03 Limitations on Power to Amend

No amendment by either the Employer or the Prototype Sponsor shall reduce or otherwise adversely affect any Participant’s benefitsacquired prior to such amendment unless it is required to maintain compliance with any law, regulation or administrative rulingpertaining to SIMPLE IRA plans. Any amendment to this SIMPLE IRA Plan can become effective only at the beginning of the Year after which Participants have been properly notified of the amendment or at such other times as permitted or required by the IRS.Participants shall be deemed to be properly notified of an amendment if the notice is provided pursuant to the notice requirementsdescribed in Section 3.04 of the Plan.

5.04 Termination While the Employer expects to continue the Plan indefinitely, the Employer shall not be under any obligation or liability to continuecontributions or to maintain the Plan for any given length of time. The Employer may terminate this Plan at any time by appropriateaction of its managing body.

5.05 Notice of Amendment or Termination Any amendment or termination shall be communicated by the Employer to all appropriate parties as required by law. Amendmentsmade by the Prototype Sponsor shall be furnished to the Employer and communicated by the Employer to all appropriate parties asrequired by law.

5.06 Continuance of Plan by Successor EmployerA successor of the Employer may continue the Plan and be substituted in the place of the present Employer.

5.07 Sending of NoticesTo the extent written instructions or notices are required under this Plan, the Prototype Sponsor or Employer may accept or providesuch information in any other form permitted by the Code or related regulations. Any required notice will be considered effective when it is sent to the intended recipient at the last known address which is on file with the provider of the notice.

5.08 Limitation of LiabilityThe Prototype Sponsor, trustee, custodian or issuer of a SIMPLE IRA shall not be liable for any losses incurred by the SIMPLE IRA by any direction to invest communicated by the Employer, or any Participant or beneficiary. It is specifically understood that thePrototype Sponsor, trustee, custodian or issuer shall have no duty or responsibility with respect to the determination of the adequacy of contributions to the Plan and enforcing the payment of such contributions. In addition, it is specifically understood that the PrototypeSponsor, trustee, custodian or issuer shall have no duty or responsibility with respect to the determination of matters pertaining to theeligibility of any Employee to become a Participant or remain a Participant hereunder; it being understood that all such responsibilitiesunder the Plan are vested in the Employer. Finally, it is specifically understood that the Prototype Sponsor shall have no responsibilityfor SIMPLE IRAs maintained by Participants at SIMPLE IRA trustees, custodians or issuers other than the Prototype Sponsor.

Section 6 Adopting Employer SignatureSection Six of the Adoption Agreement must contain the signature of an authorized representative of the Adopting Employer evidencingthe Employer’s agreement to be bound by the terms of the Basic Plan Document and Adoption Agreement.


Form 619pg. 8 of 8

B


24004 AF (10/20) Page 17 of 4024004 R (11/10) Page 17 of 44

SIMPLE IRAIRS Department of Treasury Letter

C


Ameriprise Financial Services, Inc.70100 Ameriprise Financial CenterMinneapolis, MN 55474

24004 AF (10/20) Page 18 of 40


24004 AF (10/20) Page 19 of 40

600cw (Rev. 10/2017) Page 1 of 2 ©2018 Ascensus, LLC

About The Savings Incentive Match Plan for Employees

WHAT IS SIMPLE IRA PLAN?A savings incentive match plan for employees of small employers individual retirement arrangement (SIMPLE IRA) is a type of retirement plan which allows you, the Employer, to provide an important benefit to the Employees of your business (including yourself if you perform services for the business). An “employer” may be a sole proprietor, partnership, or corporation. Amounts you contribute for your Employees under a SIMPLE IRA plan are deposited into your Employees’ SIMPLE IRAs.

SIMPLE IRA PLAN HIGHLIGHTSTax AdvantagesSIMPLE IRA plan contributions you make to your own SIMPLE IRA and your Employees’ SIMPLE IRAs are tax deductible to you, the Employer. Because SIMPLE IRA plan contributions are made to a SIMPLE IRA, all earnings are tax-deferred, meaning the earnings are not taxed until they are withdrawn from the SIMPLE IRA. In addition, a SIMPLE IRA plan helps you attract and retain quality Employees while you help meet the increasing need for financial security at retirement.

Employer EligibilityTo be eligible to offer a SIMPLE IRA plan, your business must meet two requirements.

1. It must have 100 or fewer employees who received at least $5,000 of compensation from you in the previous calendar year; and

2. It cannot, during the current calendar year, maintain any other qualified retirement plans to which contributions are made or where benefits accrue.

Participant EligibilityNot all Employees have to be covered under a SIMPLE IRA plan. At your option, you can exclude Employees who have not earned at least $5,000 during any two preceding Years and are not expected to earn at least $5,000 during the current Year. In addition, you may exclude Employees who are nonresident aliens, certain union members, and acquired Employees (during a transition period only).

ContributionsEach Employee can specify the percentage of pay he or she wants you to withhold and contribute to the Plan. The maximum amount which Participants may defer each year is limited to $12,500 for 2017 and 2018 (after 2018 this amount is subject to cost-of-living adjustments). Further, Employees who attain age 50 by the end of the Year can contribute an additional amount known as a catch-up contribution.

In addition, you must make either matching contributions, generally equal to the amount of each Participant’s Elective Deferrals up to three percent of his or her Compensation, or nonelective contributions equal to two percent of each Participant’s Compensation. You have until the due date for filing your business’s tax return (plus extensions) to make matching and nonelective contributions under your SIMPLE IRA Plan.

Place of DepositAll contributions made under the Plan must be deposited directly into each eligible Employee’s SIMPLE IRA.

DistributionsOnce SIMPLE IRA plan contributions are made, the normal IRA rules generally apply. For example, all earnings are tax-deferred until they are withdrawn from the SIMPLE IRA and required minimum distributions must begin by April 1 of the year following the year the SIMPLE IRA owner reaches age 70½.

WHAT ABOUT PLAN SET UP?A SIMPLE IRA plan is easy to set up and administer. To establish a SIMPLE IRA plan, you must sign an Adoption Agreement. Once the Plan is set up, all eligible Employees (including yourself) establish SIMPLE IRAs to receive contributions. All eligible Employees must complete and sign a Salary Reduction Agreement to indicate the percentage of pay they wish to contribute to the Plan.

Maintaining a SIMPLE IRA plan is also easy. Unlike other qualified retirement plans, no additional reporting is required. You simply take a deduction on your tax return for the SIMPLE IRA contributions and notify Employees of the contribution and the Plan’s general provisions.

EMPLOYEE COMMUNICATIONSEmployee InformationIf you have Employees, provide each eligible Employee with a Participation Notice & Summary Description.

Establish SIMPLE IRAsEnsure all participating Employees have established SIMPLE IRAs.

Elective Deferral AgreementsHave all eligible Employees complete and sign a Salary Reduction Agreement.

SUMMARYIf you are interested in establishing a SIMPLE IRA plan, consult your tax and legal advisors for guidance in selecting the Plan features which best suit your business’s needs. Once you are ready to adopt a SIMPLE IRA plan, refer to the enclosed instructions for completing the documents and properly establishing your Plan.

SIMPLEIRA Plan

© 2018 Ascensus, LLC

D.1

24004 AF (10/20) Page 20 of 40600cw (Rev. 10/2017) Page 2 of 2 ©2018 Ascensus, LLC

Instructions for Completing Adoption Agreement

These instructions are designed to help you, the Employer, along with your tax or legal advisor, establish your SIMPLE IRA Plan. The instructions are meant to be used only as a general guide and are not intended as a substitute for qualified legal or tax advice.

ADOPTION AGREEMENTIf you wish to have us, the financial organization sponsoring this prototype Plan, help you fill out the Adoption Agreement, we will do so. However, we recommend that you obtain the advice of your legal or tax advisor before you sign the Adoption Agreement.

EMPLOYER INFORMATIONFill in the requested information.

SECTION 1. ESTABLISHMENT AND PURPOSE OF PLANThere are no elections required for Section One. Refer to the Basic Plan Document for information regarding this section.

SECTION 2. EFFECTIVE DATESThis SIMPLE IRA Plan is either a new Plan (an initial adoption) or an amendment and restatement of an existing SIMPLE IRA plan.If this is a new Plan, check Option A and fill in the Effective Date. The Effective Date is usually the first day of the Plan Year in which this Adoption Agreement is signed. For example, if this Adoption Agreement is signed on September 24, 2017, the Effective Date would be January 1, 2017.If the reason you are adopting this Plan is to amend and replace an existing SIMPLE IRA plan, check Option B. The existing plan which will be replaced is called a “Prior Plan.” You will need to know the Effective Date of the Prior Plan. The best way to determine its Effective Date is to refer to the Prior Plan adoption agreement. The Effective Date of this amendment and restatement must be the first day of the Plan Year in which the Adoption Agreement is signed.

SECTION 3. ELIGIBILITY REQUIREMENTSSection Three should be completed even if you do not have Employees.Within limits, you as the Employer can specify the Compensation your Employees must earn from you over a period of years before they are eligible to participate in this Plan. Note that the eligibility requirements which you set up for the Plan also apply to you.Suppose, for example, you establish a service requirement requiring Employees to earn at least $5,000 in compensation from you during any two preceding years and require that Employees be expected to earn at least $5,000 during the current year, only those Employees (includingyourself) would be eligible to participate in this Plan.

Part A. Service RequirementIf you want all Employees to be eligible to participate in the Plan, check Option 1.If you want to limit participation by including a compensation and year(s) requirement, check Option 2. Fill in the amount of annual Compensation required for participation. In addition, provide the number of preceding years Participants are required to satisfy the minimum compensation requirement.

Part B. Exclusion of Certain Classes of EmployeesAll Employees will be eligible to become Participants unless indicated otherwise in the Adoption Agreement. To exclude a particular class of Employee, select the class(es) of Employees you wish to exclude from participating in this Plan. The following describes the Employees which may be excluded.1. Employees covered by the terms of collective bargaining agreement (e.g., a union agreement) where retirement benefits were the subject

of good faith bargaining.2. Employees who are nonresident aliens without any U.S. income.3. New Employees as a result of an acquisition or similar transaction (during a transition period).

SECTION 4. CONTRIBUTIONSPart A. Catch-Up Contributions

If the Plan will allow Participants who attain age 50 by the end of the Year to make an additional Catch-Up Contribution, check Option 1. If not, then check Option 2.

Part B. Employer ContributionsEach Year you must make Matching or Nonelective Contributions to the SIMPLE IRAs of Participants in accordance with the Basic Plan Document. Fill in the amount of annual Compensation required for Participants to be eligible to receive Nonelective Contributions, should they be made.

Part C. Use of Designated Financial InstitutionA Designated Financial Institution may be named for this Plan. If a Designated Financial Institution will be named, select Option 1 and list the name, address, and telephone number of such institution where all SIMPLE IRA Plan contributions will be made.

SECTION 5. AMENDMENT OR TERMINATION OF PLANThere are no elections required for Section Five. Refer to the Basic Plan Document for information regarding this section.

SECTION 6. EMPLOYER SIGNATUREAn authorized representative of the Employer must sign and date the Adoption Agreement. In addition, the Prototype Sponsor must provide its name, address, and telephone number.OTHER ITEMS• Provide a Participation Notice & Summary Description to each Employee eligible to participate in this Plan.• Make sure that all eligible Employees have established SIMPLE IRAs.• Distribute Salary Reduction Agreements to all eligible Employees for completion.

SIMPLEIRA Plan

© 2018 Ascensus, LLC

D.1

24004 AF (10/20) Page 21 of 40

Employer Information

Name of Adopting Employer

Address

City State Zip

Telephone

Adopting Employer’s Federal Tax Identification Number

Section 1

Establishment and Purpose of PlanThere are no elections required for Section One. Refer to the Basic Plan Document for information regarding this section.

Section 2

Effective Dates Check and complete Option A or B.

Option A:This is the initial adoption of a SIMPLE IRA plan by the Employer. The Effective Date of this Plan is _____________.NOTE: The Effective Date may be any date between January 1 and October 1.

Option B:This is an amendment and restatement of an existing SIMPLE IRA plan (a Prior Plan).The Prior Plan was initially effective on _____________.The Effective Date of this amendment and restatement is January 1, _________.

Section 3

Eligibility and Participation Requirements Complete Parts A through C.Part A. Service Requirement

Option 1:Full Eligibility. All Employees are eligible.

Option 2:Limited Eligibility. Eligibility is limited to each Employee who satisfies the requirements in both (a) and (b) below.(a) Prior Year Compensation. An Employee who has received at least $5,000, or ____________, if lesser, in Compensation during

any 2, or __________ (specify 0 or 1), if less, preceding Years (need not be consecutive); and

(b) Current Year Compensation. An Employee who is reasonably expected to receive at least $5,000, or ______________, if lesser, in Compensation during the current Year.

NOTE: If no option is selected, Option 1 shall be deemed to be selected.

Part B. Exclusion of Certain Classes of EmployeesAll Employees will be eligible to become Participants in the Plan except: (Select any that apply)

1. Collective bargaining unit Employees as described in Section 3.02(A) of the Plan. If not selected this box will be deemed to beselected if the exclusive plan requirement as described in Section 1.03 of the Plan applies.

2. Non-resident aliens as described in Section 3.02(B) of the Plan.3. Acquired Employees as described in Section 3.02(C) of the Plan. If not selected, this box will be deemed to be selected if

there is a failure to meet the exclusive plan requirement due to an acquisition or similar transaction as described in Section1.03(A) of the Plan.

Part C. Election Periods (Select one)In addition to the 60-day Election Period described in Section 3.04 of the Plan, a Participant may make or modify a Salary ReductionAgreement during the following Election Periods: _________________________.

(Specify a period or periods (e.g., semi-annually, quarterly, monthly or daily) that will apply uniformly to all Participants.)


Form 618pg. 1 of 2

SIMPLE IRAAdoption Agreement

D


24004 AF (10/20) Page 22 of 40

Section 4

ContributionsPart A. Catch-Up Contributions

Will Catch-Up Contributions, as described in Section 4.01 of the Plan, be permitted under this Plan? (Select one)Option 1: Yes.Option 2: No.

NOTE: If no option is selected, Option 1 will be deemed to be selected.

Part B. Employer ContributionsComplete only if Section 3, Part A, Option 2 is selected.Each Year the Employer shall make either Matching Contributions or Nonelective Contributions to the SIMPLE IRAs of Participants inaccordance with the rules described in Section 4.02 of the Plan. For any Year the Employer makes Nonelective Contributions, suchcontributions will be made on behalf of each Participant who has at least $____________ (enter a dollar amount no less than theamount entered in Section 3, Part A, Option 2 of the Adoption Agreement, if applicable, and no greater than $5,000) of Compensationfor such Year.

Part C. Use of Designated Financial InstitutionWill the Employer make all Plan contributions at a Designated Financial Institution? (See Section 4.06 of the Plan)

Option 1: Yes. Enter the name and address of the Designated Financial Institution below.X Option 2: No.

NOTE: If no option is selected, Option 2 will be deemed to be selected even if the information below is provided.

Name of Designated Financial Institution

Address

City State Zip

Telephone

Signature for Designated Financial Institution

Section 5

Amendment or Termination of PlanThere are no elections required for Section Five. Refer to the Basic Plan Document for information regarding this section.

Section 6

Employer SignatureI acknowledge that I have relied upon my own advisors regarding the completion of this Adoption Agreement and the legal and taximplications of adopting this Plan. I understand that my failure to properly complete this Adoption Agreement may result in

consequences. I have received a copy of this Adoption Agreement and the Basic Plan Document.

Signature of Adopting Employer

Date Signed

(Print Name)

Name of Prototype Sponsor: Ameriprise Financial Services, Inc.10475 Ameriprise Financial CenterMinneapolis, MN 55474Telephone: 612-671-3131

Do not mail thesedocuments to this address


Form 618pg. 2 of 2

D

adverse tax


70100

Page 1 of 224004-5 N (10/20)

24004-5N (10/20)

Page 1 of 2 1

EForm 617

Section A General InformationEmployer InformationName of Employer

Address

City State Zip Telephone

Trustee/Custodian/Issuer Information (for plans electing to use a Designated Financial Institution)Name of Trustee, Custodian, or Issuer

Address

City State Zip Telephone

Section B Eligibility RequirementsOpportunity to ParticipateThis form is intended, in part, to notify you of your right to choose, during the Election Period, to make Elective Deferrals under the savings incentive match plan for employees of small employers (SIMPLE) IRA Plan established by your Employer. The Election Period is generally the 60-day period before the beginning of each Year and the 60-day period before the first day you become eligible to participate. This notice includes a Summary Description of your Employer’s SIMPLE IRA Plan.Eligible Employees You may become eligible to participate in the Plan unless you are:

covered by the terms of collective bargaining agreement where retirement benefits were negotiated a nonresident alien with no United States earned income from your Employer an Employee on account of an acquisition or similar transaction involving your Employer

Compensation and Service To become eligible to participate in the Plan, you must have earned $5,000 during any two preceding years and you must be reasonably expected to earn such amount during the current year, unless otherwise specified below.You are required to earn at least $ (may not exceed $5,000) during any (may not exceed 2) preceding years to be eligible to participate in the Plan. You must also be reasonably expected to earn at least $ (may not exceed $5,000) during the current Year.

Section C Plan ContributionsFinancial Institution Your Employer has has not elected to make all contributions to a Designated Financial Institution.If contributions are not required to be made to a Designated Financial Institution, you must select the financial organization that will serve as trustee, custodian, or issuer of your SIMPLE IRA and notify your Employer by providing a completed Salary Reduction Agreement.If contributions are required to be made to a Designated Financial Institution, you may transfer the balance in your SIMPLE IRA, without cost or penalty, from the Designated Financial Institution to a SIMPLE IRA at the financial organization of your choice. To do so, you must request a transfer during the Election Period or during any other period as allowed by the Designated Financial Institution. Upon request, the Designated Financial Institution will periodically transfer your balance.

Elective DeferralsBy completing a Salary Reduction Agreement, you agree to make Elective Deferrals to this Plan. Your Compensation will be reduced each pay period by an amount equal to the percentage of your Compensation you specify on the Salary Reduction Agreement. Generally, your Elective Deferrals (excluding Catch-Up Contributions) may not exceed $13,500 in 2021 (subject to cost-of-living adjustments for later years).Catch-Up Contributions will will not be permitted under the Plan.If Catch-Up Contributions are available under the Plan and you will attain age 50 on or before the end of the Year, you are eligible to make Catch-Up Contributions. Your Catch-Up Contributions may not exceed $3,000 for 2021 (subject to cost-of-living adjustments for later years).

Ameriprise Financial Services, LLC. 70100 Ameriprise Financial Center Minneapolis, MN 55474

SIMPLE IRA PLANParticipation notice & summary descriptionIMPORTANT: Carefully read and consider the information on both sides of this notice before you decide whether to start, continue, or change your Salary Reduction Agreement.

■

Section 4

ContributionsPart A. Catch-Up Contributions

Will Catch-Up Contributions, as described in Section 4.01 of the Plan, be permitted under this Plan? (Select one)Option 1: Yes.Option 2: No.

NOTE: If no option is selected, Option 1 will be deemed to be selected.

Part B. Employer ContributionsComplete only if Section 3, Part A, Option 2 is selected.Each Year the Employer shall make either Matching Contributions or Nonelective Contributions to the SIMPLE IRAs of Participants inaccordance with the rules described in Section 4.02 of the Plan. For any Year the Employer makes Nonelective Contributions, suchcontributions will be made on behalf of each Participant who has at least $____________ (enter a dollar amount no less than theamount entered in Section 3, Part A, Option 2 of the Adoption Agreement, if applicable, and no greater than $5,000) of Compensationfor such Year.

Part C. Use of Designated Financial InstitutionWill the Employer make all Plan contributions at a Designated Financial Institution? (See Section 4.06 of the Plan)

Option 1: Yes. Enter the name and address of the Designated Financial Institution below.X Option 2: No.

NOTE: If no option is selected, Option 2 will be deemed to be selected even if the information below is provided.

Name of Designated Financial Institution

Address

City State Zip

Telephone

Signature for Designated Financial Institution

Section 5

Amendment or Termination of PlanThere are no elections required for Section Five. Refer to the Basic Plan Document for information regarding this section.

Section 6

Employer SignatureI acknowledge that I have relied upon my own advisors regarding the completion of this Adoption Agreement and the legal and taximplications of adopting this Plan. I understand that my failure to properly complete this Adoption Agreement may result in

consequences. I have received a copy of this Adoption Agreement and the Basic Plan Document.

Signature of Adopting Employer

Date Signed

(Print Name)

Name of Prototype Sponsor: Ameriprise Financial Services, Inc.10475 Ameriprise Financial CenterMinneapolis, MN 55474Telephone: 612-671-3131

Do not mail thesedocuments to this address


Form 618pg. 2 of 2

D

adverse tax

© 2020 Ascensus, Inc.

24004-5 N (10/20) Page 2 of 224004-5N (10/20)

Page 2 of 2 1

EForm 617

SIMPLE IRA PLANParticipation notice & summary description

Section C Plan Contributions continuedElective Deferrals continuedYou may change the amount of your Elective Deferrals by completing and signing a revised Salary Reduction Agreement during the Election Period or any other period specified below.

You may discontinue making Elective Deferrals at any time during the Year by completing and signing a revised Salary Reduction Agreement. You are allowed to commence making Elective Deferrals the first day of the Year following the Year you cease deferring unless specified otherwise below.

Employer ContributionsFor calendar Year , your Employer will make Matching Contributions equal to 100 percent of your Elective Deferrals which do not exceed three percent of your Compensation unless your Employer elects to make either the alternative Matching Contribution or the Nonelective Contribution described in Options 1 and 2 below.

Option 1: Matching Contributions in an amount equal to your Elective Deferrals which do not exceed % (must not be less than 1%).Option 2: Nonelective Contributions equal to two percent of Compensation on behalf of each Participant who earns at least $5,000

during the year unless a different dollar amount is specified below. (may not exceed $5,000) during the year to be eligible to receive Nonelective You are required to earn at least $

Contributions.

Section D DistributionsThe following is a summary of the rules applicable to distributions from SIMPLE IRAs. You are advised to refer to your SIMPLE IRA documents and/or seek the assistance of a qualified tax advisor if you have additional questions.ProceduresSIMPLE IRA assets are fully vested and may be withdrawn at any time subject to taxes and penalties as explained below. The trustee, custodian, or issuer of your SIMPLE IRA, and not your Employer, is responsible for making distributions to you upon your request.Federal Income TaxDistributions from SIMPLE IRAs are taxed as ordinary income in the year in which you receive them. In addition, federal income tax withholding will be applied to your distribution at a rate of 10 percent unless you specify a higher rate or waive your right to withholding.PenaltiesA 25 percent early distribution penalty tax applies to SIMPLE IRA distributions taken within two years of your initial participation in the Plan, unless you are age 59½ or older or can claim an exemption from the early distribution penalty described in Internal Revenue Code (IRC) Sec. 72(t)(6). If you are under age 59½, have satisfied the two-year requirement and receive a distribution, you will be subject to a 10 percent early distribution penalty tax.RolloversSIMPLE IRA distributions may be rolled over to other SIMPLE IRAs. If a SIMPLE IRA distribution is properly rolled over, your rollover amount will be excluded when determining the amount of your federal income tax or early distribution penalty tax. You may roll over SIMPLE IRA distributions to Traditional IRAs, qualified retirement plans, tax-sheltered annuities, and governmental 457(b) deferred compensation plans. However, you must wait two years from the date you become a participant before doing so.Required Minimum DistributionsYou are required to begin taking minimum distributions from your SIMPLE IRA upon attainment of age 72 in accordance with IRS regulations.Procedures for WithdrawalsIf you wish to take a distribution from your SIMPLE IRA, you must complete a withdrawal authorization provided by the trustee, custodian, or issuer of your SIMPLE IRA. In addition, the following procedures apply to you upon requesting a distribution.


If you wish to take a distribution from your SIMPLE IRA, you may contact your financial advisor, the Ameriprise home office at 800-862-7919, or complete a withdrawal authorization provided by the trustee, custodian or issuer of your SIMPLE IRA.

72

Page 25 of 40248585 D (12/15)

SAMPLE

Employer Instructions — personalize [where indicated] and distribute employee announcement letter (F.1) to eligibleemployees if you have elected to make Matching Contributions.

[Date]

To: All employees

I am happy to announce that effective [date], [name of company] has implemented a new retirement savings plan. Our newplan, called a “Savings Incentive Match Plan for Employees” or SIMPLE IRA Plan, gives eligible employees the opportunity tosave for retirement in a tax-favored manner.

ContributionsIn a SIMPLE IRA Plan, both the company, and you individually, can make contributions to your retirement account. You can contribute a portion of your compensation to the plan through elective deferrals. Here’s how you benefit fromelective deferrals. You designate a portion of your pre-tax compensation (up to the annual limit outlined in the SummaryDescription) to be withdrawn from your paycheck and contributed to your SIMPLE IRA. This reduces your current income,which in turn reduces the taxes you pay today and defers the tax until you withdraw the money, usually in retirement when you may be in a lower tax bracket. All money contributed to the plan, either by the company or by you, belongs to you even after you leave employment.

The company will also make contributions on your behalf according to a formula and eligibility criteria that will becommunicated to you at the beginning of each year as part of the Summary Description (this will be distributed to youshortly). This year, if you are eligible to participate, the company will make a matching contribution of the amount you deferinto the plan, up to 3% of your compensation.

Tax-deferred growthOne of the most important benefits of your SIMPLE IRA is that the contributions in your account, along with any earnings, growtax-deferred until withdrawn. Over time, money that’s kept tax-deferred may grow faster than an equivalent taxable investment.

DistributionsYou may take distribution of the assets at any time, however, these assets are intended for your retirement and penalties mayapply for distributions taken before age 591⁄2. You must begin taking distributions the year after the year you turn age 701⁄2.

EnrollmentAn Ameriprise financial advisor will be available to assist you in opening a SIMPLE IRA and can answer questions you mayhave about the plan and the investment options available to help you meet your retirement goals.

I am pleased to offer this valuable employee benefit to you. I encourage you to take advantage of this opportunity to savefor your future financial security.

Sincerely,

[Employer’s Signature]

24004 R (11/10) Page 27 of 44

SIMPLE IRAEmployee Announcement Letter (MatchingContributions)

F.1

(withdrawals)

72.

Page 26 of 40

[Date]

To: All employees

I am happy to announce that effective [date], [name of company] has implemented a new retirement savings plan. Our new plan, called a “Savings Incentive Match Plan for Employees” or SIMPLE IRA Plan, gives eligible employees the opportunity to save for retirement in a tax-favored manner.

ContributionsIn a SIMPLE IRA Plan, both the company, and you individually, can make contributions to your retirement account. The company will make contributions on your behalf according to a formula and eligibility criteria that will be communicated to you before the beginning of each year as part of the Summary Description (this will be distributed to you shortly). This year, if you are eligible to participate, the company will contribute an amount equal to 2% of your compensation*.

You can also contribute a portion of your compensation to the plan through elective deferrals. Here’s how you benefit from elective deferrals. You designate a portion of your pre-tax compensation (up to the annual limit outlined in the Summary Description) to be withdrawn from your paycheck and contributed to your SIMPLE IRA. This reduces your current income, which in turn reduces the taxes you pay today and defers the tax until you withdraw the money, usually in retirement when you may be in a lower tax bracket. All money contributed to the plan, either by the company or by you, belongs to you even after you leave employment.

Tax-deferred growthOne of the most important benefits of your SIMPLE IRA is that the contributions in your account, along with any earnings, grow tax-deferred until withdrawn. Over time, money that’s kept tax-deferred may grow faster than an equivalent taxable investment.

Distributions (withdrawals)You may take distribution of the assets at any time; however, these assets are intended for your retirement. Distributions are taxable, and penalties may apply for distributions taken before age 591⁄2. You must begin taking distributions by April 1st of the year after the year you turn age 701⁄2.

EnrollmentAn Ameriprise financial advisor will be available to assist you in opening a SIMPLE IRA and can answer questions you may have about the plan and the investment options available to help you meet your retirement goals.

I am pleased to offer this valuable employee benefit to you. I encourage you to take advantage of this opportunity to save for your future financial security.

Sincerely,


*Subject to annual compensation limits

248586 G (2/19)

SAMPLE

Employer Instructions — personalize [where indicated] and distribute employee announcement letter (F.2) to eligibleemployees if you have elected to make Nonelective Contributions.

[Date]

To: All employees


ContributionsIn a SIMPLE IRA Plan, both the company, and you individually, can make contributions to your retirement account. Thecompany will make contributions on your behalf according to a formula and eligibility criteria that will be communicated toyou at the beginning of each year as part of the Summary Description (this will be distributed to you shortly). This year, ifyou are eligible to participate, the company will contribute an amount equal to 2% of your compensation.*

You can also contribute a portion of your compensation to the plan through elective deferrals. Here’s how you benefit fromelective deferrals. You designate a portion of your pre-tax compensation (up to the annual limit outlined in the SummaryDescription) to be withdrawn from your paycheck and contributed to your SIMPLE IRA. This reduces your current income,which in turn reduces the taxes you pay today and defers the tax until you withdraw the money, usually in retirement whenyou may be in a lower tax bracket. All money contributed to the plan, either by the company or by you, belongs to you evenafter you leave employment.





Sincerely,


*subject to annual compensation limits

24004 R (11/10) Page 28 of 44

SIMPLE IRAEmployee Announcement Letter (NonelectiveContributions)

F.2

(withdrawals)

SAMPLE72.

SAMPLE

Employer Instructions — personalize [where indicated] and distribute employee announcement letter (F.2) to eligibleemployees if you have elected to make Nonelective Contributions.

[Date]

To: All employees


ContributionsIn a SIMPLE IRA Plan, both the company, and you individually, can make contributions to your retirement account. Thecompany will make contributions on your behalf according to a formula and eligibility criteria that will be communicated toyou at the beginning of each year as part of the Summary Description (this will be distributed to you shortly). This year, ifyou are eligible to participate, the company will contribute an amount equal to 2% of your compensation.*

You can also contribute a portion of your compensation to the plan through elective deferrals. Here’s how you benefit fromelective deferrals. You designate a portion of your pre-tax compensation (up to the annual limit outlined in the SummaryDescription) to be withdrawn from your paycheck and contributed to your SIMPLE IRA. This reduces your current income,which in turn reduces the taxes you pay today and defers the tax until you withdraw the money, usually in retirement whenyou may be in a lower tax bracket. All money contributed to the plan, either by the company or by you, belongs to you evenafter you leave employment.





Sincerely,


*subject to annual compensation limits

24004 R (11/10) Page 28 of 44

SIMPLE IRAEmployee Announcement Letter (NonelectiveContributions)

F.2

(withdrawals)

24004-2 X (10/20) 1


Employer and Plan Information

Name of Employer

Address

City ZIP code

Employee Information

Employee Number Social Security Number

Form 616 G

State

Effective DateThis Salary Reduction Agreement will be effective for the pay period which begins .

Limits On Elective Deferrals Subject to the requirements of the Employer's SIMPLE IRA Plan, each Employee who is eligible to enroll as a Contributing Participant may set aside a percentage of his or her pay into the Plan (Elective Deferrals) by signing this Salary Reduction Agreement. This Salary Reduction Agreement replaces any earlier Salary Reduction Agreement and will remain in effect as long as the Employee remains an eligible Employee, or until he or she provides the Employer with a new Salary Reduction Agreement as permitted by the Plan. A Participant who is age 50 or older by the end of the year may be allowed to make Catch-Up Contributions. An employee may defer up to $13,500 in 2021 (subject to cost-of-living adjustments for later years).

Changing This AgreementAn Employee may change the percentage of pay he or she is setting aside into the Plan. Any employee who wishes to make such a change must complete and sign a new Salary Reduction Agreement, and give it to the employer during the Election Period or any other period the Employer specifies on the Participation Notice and Summary Description.

Terminating This AgreementAn Employee may terminate this Salary Reduction Agreement. After terminating this Salary Reduction Agreement, an employee cannot again enroll as a Contributing Participant until the first day of the year following the year of termination or any other date the Employer specifies on the Participation Notice and Summary Description.

Name

Home Address

City ZIP code State

Part 1 General Information

Ameriprise Financial Services, LLC. 70100 Ameriprise Financial Center Minneapolis, MN 55474

SIMPLE IRAEmployee salary reduction agreement Important: Carefully read all sections of this agreement before signing it.

Part 2 Terms of Agreement (To Be Completed By the Employer)

Text

Sign on page 2

Page 1 of 2

SAMPLE

24004-2 X (10/20) 1

% of my current rate of pay) into my Employer's SIMPLE IRA Plan by way of payroll deduction.

Note: If you are eligible to defer and you attain age 50 before the close of the Plan Year, you may be able to make Catch-Up Contributions under the SIMPLE IRA plan. Certain limits, as required by law, must be met prior to being eligible to make Catch-Up Contributions. Your election above will pertain to Elective Deferrals which may include Catch-Up Contributions. See your Employer for additional information, including the Catch-Up Contribution limit for the Year.

I agree that my pay will be reduced in the manner I have indicated above, and I affirmatively elect to have this amount contributed to the investments listed below. This Salary Reduction Agreement will continue to be effective while I am employed, unless I change or terminate it as explained in Part 2. I acknowledge that I have read this entire Salary Reduction Agreement, I understand it and I agree to its terms. Furthermore, I acknowledge that I have received a copy of the Participation Notice and Summary Description.

I have elected to invest my contributions with the financial institution listed below (Select one):

Signatures

Signature of Employee Date (MMDDYYYY)

Title

Salary Reduction Agreement

SIMPLE IRAEmployee Salary Reduction Agreement (continued)

Form 616 G

I, the undersigned employee, wish to set aside, as Elective Deferrals, % or $ (which

equals

Ameriprise Financial Services, Inc.70100 Ameriprise Financial Center Minneapolis, MN 55474

Other (list name and address below)

Name

Address

City State ZIP code

Authorized Signature for Employer Date (MMDDYYYY)

Financial Institution

Part 3 Authorization (To Be Completed By the Employee)

X

X

Page 2 of 2

24004 AF (10/20) Page 29 of 40402450 K (11/15) 1

1

2

3

Complete Employer Information below: (Introductory information will be mailed to the address provided)Employer Name

Employer Contacts

Employer Identification Number

Part 1

Address

Add / Chg/ Delete Name Phone Fax EmailPrimary(Select One)

City State ZIP code

Select one: New group Changes to existing group # Delete the whole group #

If existing employer, complete sections 1, 2 and 7 only, unless making changes.

Group Type: (Check one)

Billing SelectionsPart 2

Simple 403b - With employer contribution SEP

401(a) IRA Loan Repayment Non-Qualified

403b - Without employer contribution

Billing Selections continued on next page...

Page 1 of 5

DOC0105402450

© 2012 - 2015 Ameriprise Financial, Inc. All rights reserved.

Employer Payroll Remittance, Arrangement Setup or Changes Form

If setting up a new payroll remittance arrangement, review the "Terms and Conditions" in Part 4with the employer/plan sponsor.Mailing Instructions

When remitting contributions, mail check and payment detail to the following address: Ameriprise Financial Services, Inc. 70213 Ameriprise Financial Center Minneapolis, MN 55474

When establishing a new or changing an existing payroll remittance mail to thefollowing address:

Ameriprise Financial Services Inc. 70100 Ameriprise Financial Center Minneapolis, MN 55474

Ameriprise Financial Services, Inc., 70100 Ameriprise Financial Center, Minneapolis, MN 55474

i H

402450 K (11/15) 1

TPA Contacts

Add / Chg/ Delete Name Phone Fax EmailPrimary(Select One)

1

2

3

Third Party Administrator (TPA) Information (if applicable)TPA Name

Part 3

Mailing Address

City State ZIP code

Terms and ConditionsPart 4

It is the responsibility of the employer to provide Ameriprise Financial Services, Inc. ("AFSI") with clear and complete contribution information on this form. Upon verifying that there are no discrepancies between the total contribution amount and the total of each employee's contribution amount, AFSI shall forward to Ameriprise Trust Company ("Custodian"), or RiverSource Life Insurance Company ("Issuer") the contributions for deposit into each participant's account.

In the event of incomplete or unclear contribution information, or if a discrepancy in the contribution amount cannot be resolved to the satisfaction of Ameriprise Financial Services, Inc., the contribution check will be returned to the employer on the fourth business day. If an amount is contributed on behalf of an employee for whom an account has not been established, Ameriprise Financial Services, Inc. will return the employer the contribution amount for that employee.

Page 2 of 5

DOC0205402450

Billing Selections continued

Weekly (52/yr) Bi-weekly (26/yr) Monthly (12/yr) Semi-monthly (24/yr)

Quarterly (4/yr) Annually (1/yr)Semi-annually (2/yr) Bi-fortnightly (13/yr)

Other

Frequency: (Check One)

List any months to exclude

Date of first reminder (MMDDYYYY)

H

24004 AF (10/20) Page 31 of 40402450 K (11/15) 1

Employee RosterPart 5If an employee has more than one account, use more than one line. *Each employee added must have an existing Ameriprise accountNote: Annuity contracts with an APB Rider - Payroll Remittance is not an option.

Add,Modify or Delete

Employee Name Employee TIN Account Number Allocation Amount persubmitted bill ($ or %)

DOC0305402450

Page 3 of 5

H

This page intentionally left blank

24004 AF (10/20) Page 33 of 40402450 K (11/15) 1

Email Address:

Main contact Person (Will be issued login credentials):

Page 4 of 5

DOC0405402450

Employer Contact Information

Section 2 Bank Information

Section 1Payroll Remittance (Group Bill) ID #:

Account #:Bank Routing # (9 digits):

Employer Name:

Email Address: Telephone:

Address:

Date:

Bank Name:

Account Owner:

Bank Address:

ZIP code StateCity

Secondary contact person (if needed):

Payroll schedule: This schedule may or may not coincide with the payroll frequency for your company. Please indicate the schedule you will follow formaking online submissions. Example: If your payroll frequency is weekly, but you submit contributions monthly, then select the monthly option below.If semi-monthly please give specific dates (For example: 1st & 15th).

Monthly Bi-Weekly Quarterly Other (specify)

Next Payroll end date to show online:

Telephone:

Online Payroll ACH Agreement

This agreement must be completed in order to obtain access to the Online Payroll Remittance payment functionality (employer online payroll tools) of the National Benefit Services, LLC web site. An email address is required to gain access.

Corporate Account Personal Account

SavingsChecking or

or

List the largest anticipated transaction amount. If you submit a contribution remittance request through the NBS website that exceeds this amount by more than 25%, NBS will not process it without receiving your written approval to make an exception. This exception process will delay the processing of the online transaction.

Largest anticipated transaction amount:

(required)

(required)

Weekly Semi-monthly

(required)

Should the secondary contact receive a separate login to the website? Yes No (required)

I

24004 AF (10/20) Page 34 of 40402450 K (11/15) 1

Authorized Person (please print full name)

Title Date:

Section 4 Agreement

Bank Fraud Filter InformationSection 3

I understand that this Agreement will remain in effect until I provide written notice of cancellation to Ameriprise Financial Services, Inc. and NBS. I further agree to promptly notify NBS in writing of any changes to the account information contained herein.If the ACH debit request is scheduled to occur on a weekend or holiday, I understand that the payments may be executed on the next business day.I authorize Ameriprise/NBS to debit my account in the amount of $0.01 as a test transaction necessary to verify that the information I have provided on this form is correct. After account validation has been successfully completed, this amount will be refunded.I authorize NBS to make charges (debit entries) to the bank account identified on this form to correct any deposits (credit entries) made in error by NBS or the processing bank.I acknowledge that I am responsible for the security of the log-in credentials to the web site that NBS will provide to me. I understand that I should notify NBS if my log-in credentials should be terminated or revoked for any reason. I certify that I am an authorized person to agree to the terms inthis authorization form and to sign for this bank account and, provided the transactions correspond to the terms indicated in this authorization form, I will not dispute the requested transactions.I certify that the information provided on this form is true to the best of my knowledge and that I am authorized to agree to these terms.

By signing this agreement, you authorize Ameriprise Financial Services, Inc. (AFSI) and its affiliates to act upon instructions from you to debit or creditthe account held at the financial institution named in this Agreement. You agree that this arrangement will remain in effect until you notify NBS, acting as agent, in writing to cancel it; allowing reasonable time to act upon your cancelation. AFSI reserves the right to terminate this arrangement at any time in its sole discretion.

Please check with your bank regarding any ACH fraud filters you may have on your account. In order for the transaction to be successful, you may need to identify Ameriprise Financial and NBS as trusted partners. The company name and company ID which will appear in ACH transactions are AMERIPRISE/NBS and D411667086 respectively.

DOC0505402450

Page 5 of 5

Signature

X

I

What is a SIMPLE IRA (Savings Incentive Match Planfor Employees) plan?

A SIMPLE IRA plan is a type of retirement plan that allows both you and your employer to makecontributions to a SIMPLE Individual RetirementAccount (IRA) that is established for you when youenroll in the plan.

A SIMPLE IRA plan offers two very important advantages: • Your contributions to the plan are made with

pre-tax dollars, so 100% of your money goes to work for you immediately

• Your investment earnings grow tax-deferred until they are withdrawn, allowing your savings tocompound faster than an account that is taxed every year

What are other benefits of a SIMPLE IRA at Ameriprise Financial?

Because your SIMPLE IRA is offered through Ameriprise Financial, you have a broad range ofinvestment choices. A professional financial advisorfrom Ameriprise Financial can consult with you to helpyou determine your investment strategy. You can alsochoose to meet with this advisor at regular intervals todiscuss your progress toward all your financial goals.

How much can I contribute each year?You may elect to have a percentage of yourcompensation contributed to your SIMPLE IRA, upto the maximum allowed which is $13,000 for 2019.Plan participants who are age 50 and older can, if allowed under the plan document, make catch-upcontributions of up to $3,000 over the maximumelective contribution, for a total contribution maximumof $16,000 for 2019. These limits may be increasedto reflect a cost-of-living adjustment, if any.

How much will my employer contribute?Your employer can contribute dollar-for-dollar, from 1% to 3% of your compensation, up to the maximumelective contribution amount. Your employer can alsochoose to contribute 2% for all eligible employees.Employers must give notice of their exact contributionintentions in advance of the calendar year.

How will I keep track of my SIMPLE IRA assets?You will receive quarterly statements showingcontributions, earnings and the most recent balance.You will also receive confirmation statements for eachcash investment purchase.

How often can I make investment changes?You can make unlimited transfers, subject only to thelimitations of the particular investments you purchase.

How often can I change the amount I contribute to mySIMPLE IRA?

You can change your contribution at any time, as longas you give the minimum amount of notice required byyour employer.

Can I stop making contributions to my SIMPLE IRA?You may stop making elective deferrals at any time.However, to begin making deferrals again, you will needto wait until the first day of the year following the yearthat you stopped your deferrals, unless your employerhas specified otherwise.

Are the contributions tax-deductible?Employee elective deferrals are exempt from federaltaxes and, in most cases, state taxes.* You do not pay taxes on the contributions or any earnings until the money is withdrawn, typically in retirement. However,the elective deferrals are subject to all normalemployment taxes. The company contributions are exempt from federal, state and employment taxes.

Are there any other tax benefits for employees?A non-refundable credit is available for eligibleemployees meeting certain AGI (Adjusted GrossIncome) limits. The maximum credit is 50% of electivedeferral retirement contributions up to $2,000.

2019 AGI limits for Retirement Savings Tax Credit

pg. 1 of 2

SIMPLE IRAEmployee Frequently Asked Questions

K

24004 R (11/10) Page 39 of 44

Joint Return

Head of Household

All Other Cases

ApplicablePercentage

$0 – $38,500 $0 – $28,875 $0 – $19,250 50

$38,501 – $41,500 $28,876 – $31,125 $19,251 – $20,750 20

$41,501 – $64,000 $31,126 – $48,000 $20,751 – $32,000 10

$64,000+ $48,000+ $32,000+ 0

*These rules vary by state. Consult your business tax advisor or payroll service for information about your state’s regulations.

24004 AF (10/20) Page 35 of 40

What is a SIMPLE IRA (Savings Incentive Match Planfor Employees) plan?

A SIMPLE IRA plan is a type of retirement plan that allows both you and your employer to makecontributions to a SIMPLE Individual RetirementAccount (IRA) that is established for you when youenroll in the plan.

A SIMPLE IRA plan offers two very important advantages: • Your contributions to the plan are made with

pre-tax dollars, so 100% of your money goes to work for you immediately

• Your investment earnings grow tax-deferred until they are withdrawn, allowing your savings tocompound faster than an account that is taxed every year

What are other benefits of a SIMPLE IRA at Ameriprise Financial?

Because your SIMPLE IRA is offered through Ameriprise Financial, you have a broad range ofinvestment choices. A professional financial advisorfrom Ameriprise Financial can consult with you to helpyou determine your investment strategy. You can alsochoose to meet with this advisor at regular intervals todiscuss your progress toward all your financial goals.

How much can I contribute each year?You may elect to have a percentage of yourcompensation contributed to your SIMPLE IRA, upto the maximum allowed which is $13,000 for 2019.Plan participants who are age 50 and older can, if allowed under the plan document, make catch-upcontributions of up to $3,000 over the maximumelective contribution, for a total contribution maximumof $16,000 for 2019. These limits may be increasedto reflect a cost-of-living adjustment, if any.

How much will my employer contribute?Your employer can contribute dollar-for-dollar, from 1% to 3% of your compensation, up to the maximumelective contribution amount. Your employer can alsochoose to contribute 2% for all eligible employees.Employers must give notice of their exact contributionintentions in advance of the calendar year.

How will I keep track of my SIMPLE IRA assets?You will receive quarterly statements showingcontributions, earnings and the most recent balance.You will also receive confirmation statements for eachcash investment purchase.

How often can I make investment changes?You can make unlimited transfers, subject only to thelimitations of the particular investments you purchase.

How often can I change the amount I contribute to mySIMPLE IRA?

You can change your contribution at any time, as longas you give the minimum amount of notice required byyour employer.

Can I stop making contributions to my SIMPLE IRA?You may stop making elective deferrals at any time.However, to begin making deferrals again, you will needto wait until the first day of the year following the yearthat you stopped your deferrals, unless your employerhas specified otherwise.

Are the contributions tax-deductible?Employee elective deferrals are exempt from federaltaxes and, in most cases, state taxes.* You do not pay taxes on the contributions or any earnings until the money is withdrawn, typically in retirement. However,the elective deferrals are subject to all normalemployment taxes. The company contributions are exempt from federal, state and employment taxes.

Are there any other tax benefits for employees?A non-refundable credit is available for eligibleemployees meeting certain AGI (Adjusted GrossIncome) limits. The maximum credit is 50% of electivedeferral retirement contributions up to $2,000.


pg. 1 of 2

SIMPLE IRAEmployee Frequently Asked Questions

K

24004 R (11/10) Page 39 of 44

Joint Return

Head of Household

All Other Cases


$0 – $38,500 $0 – $28,875 $0 – $19,250 50

$38,501 – $41,500 $28,876 – $31,125 $19,251 – $20,750 20

$41,501 – $64,000 $31,126 – $48,000 $20,751 – $32,000 10

$64,000+ $48,000+ $32,000+ 0

*These rules vary by state. Consult your business tax advisor or payroll service for information about your state’s regulations.

2021.13,500

2021.16,500

2021

$0 - $39,500

$39,501 - $43,000

$43,001 - $66,000

$66,001 +

$0 - $29,625

$29,626 - $32,250

$32,251 - $49,500

$49,501 +

$0 - $19,750

$19,751 - $21,500

$21,501 - $33,000

$33,001 +

24004 AF (10/20) Page 36 of 40

What happens if I leave my current employer?All amounts contributed to your SIMPLE IRA belong to you, even after you discontinue employment with that employer.

Are there early withdrawal penalties attached to mySIMPLE IRA?

If you take a distribution within two years of beginningyour SIMPLE IRA and you are under age 591⁄2, you willhave to pay the IRS a 25% early withdrawal penalty, inaddition to ordinary income taxes. After the two yearsare up, your SIMPLE IRA is subject to the samedistribution rules as a traditional IRA, i.e., a 10% earlywithdrawal penalty before age 59 1⁄2, plus ordinaryincome taxes. Refer to the Ameriprise Financial “YourGuide to SIMPLE IRAs” for additional tax informationrelating to your SIMPLE IRA.

How do I enroll?Your employer will provide you with a copy of theEmployee Participation Notice and SummaryDescription containing eligibility requirements and other information about your SIMPLE IRA. You will also need to complete a Salary Reduction Agreementand an IRA Investment Application.

pg. 2 of 2

K

24004 R (11/10) Page 40 of 44

24004 AF (10/20) Page 37 of 40

Plan Description:Savings Incentive Match Plan for Employees IRA (SIMPLE IRA) plan is a tax-deferred plan for self-employed individuals and small business owners(with 100 or fewer employees) who want workers toshare in saving for retirement. Plan sponsor s mustcontribute annually to a SIMPLE IRA. A typical plansponsor has fewer than 50 employees and seeks aneasy-to-administer plan that features contributions from both the plan sponsor (employer) and planparticipants (employees).

Questions about the plan:

When can I establish a SIMPLE IRA plan?A SIMPLE IRA plan may be established for a particularcalendar year on any date between January 1 andOctober 1 of that year. The October 1 deadline doesnot, however, apply to new businesses established afterOctober 1 of a given year. For a business establishedafter October 1, a SIMPLE IRA may be set up if done so as soon as administratively feasible.

Must I set up my SIMPLE IRA plan on a calendar-year basis?

Yes. All SIMPLE IRA plans must run on a calendar-yearbasis, even if your business’s fiscal year does not.

What happens if my company grows to more than 100 employees?

According to IRS regulations, an employer thatpreviously maintained a SIMPLE IRA plan is treated as satisfying the 100-employee limitation for the twocalendar years immediately following the calendar yearfor which it last satisfied the 100-employee limitation.In other words, the government gives you approximatelytwo years to switch over to another plan after yourbusiness has more than 100 employees.

How much can an employee defer into a SIMPLE IRAeach year?

Using a Salary Reduction Agreement, eligibleemployees may elect to have a percentage of theircompensation contributed to their SIMPLE IRAs, ratherthan receive it in cash. The maximum electivecontribution limit is $13,000 for 2019. Additionally,unless you selected Option 2 in Section 4, Part A of theAdoption Agreement, plan participants who are age 50and older can make catch-up contributions of up to$3,000 for a total contribution maximum of $16,000for 2019. These limits may be increased to reflect acost-of-living adjustment, if any.

Are there any tax benefits for employees?A non-refundable credit is available for eligibleemployees meeting certain AGI (Adjusted GrossIncome) limits. The maximum credit is 50% of electivedeferral retirement contributions up to $2,000.


Are there any additional incentives for business owners?Yes, a tax credit is available for small businesses thatpay expenses for retirement plans. Small businessesmay claim a credit for 50% of the first $1,000 ofadministrative and retirement education expensesconnected with star ting and maintaining a new SIMPLEIRA plan during each of the first three plan years. Asmall business is defined as one with no more than100 employees having compensation in excess of$5,000 in the preceding year and with at least onenon-highly compensated employee.

24004 R (11/10) Page 41 of 44

pg. 1 of 3

SIMPLE IRAEmployer Frequently Asked Questions

L

Joint Return

Head of Household

All Other Cases


$0 – $38,500 $0 – $28,875 $0 – $19,250 50

$38,501 – $41,500 $28,876 – $31,125 $19,251 – $20,750 20

$41,501 – $64,000 $31,126 – $48,000 $20,751 – $32,000 10

$64,000+ $48,000+ $32,000+ 0

13,500 2021.

2021.16,500

2021

$0 - $39,500

$39,501 - $43,000

$43,001 - $66,000

$66,001 +

$0 - $29,625

$29,626 - $32,250

$32,251 - $49,500

$49,501 +

$0 - $19,750

$19,751 - $21,500

$21,501 - $33,000

$33,001 +

Yes, a tax credit is available for small businesses that pay start up expenses for retirement plans. Small businesses may claim a credit for the greater of (1) $500, or (2) the lesser of: (a) $250 multiplied by the number of non-highly compensated employees of the eligible employer who are eligible to participate in the plan, or (b) $5,000.

The credit helps make it more affordable for small businesses to set up retirement plans and applies for up to three years. A small business is defined as one with no more than 100 employees having compensation in excess of $5,000 in the preceding year and with at least one non-highly compensated employee.

24004 AF (10/20) Page 38 of 40

What amount must I (the employer/plan sponsor)contribute to a SIMPLE IRA?

As the employer/plan sponsor, you must make either:• A dollar-for-dollar matching contribution that cannot

exceed 3% of the employee’s compensation, or• A 2% non-elective contribution to all

eligible participants

The 3% matching contribution may be reduced to as low as 1% in two out of any five years, provided that either the 3% matching contribution or the 2% non-elective contribution was made in the other three years. The 3% match is the greatest amount you, the employer/plan sponsor, can contribute.

As the employer/plan sponsor, you are required todisclose what your contribution will be for the comingyear to your employees/plan participants at least 60days prior to the start of the upcoming year.

Can I implement a vesting schedule for my contributions?No. All contributions to a SIMPLE IRA plan must be fullyvested at all times.

Are plan contributions subject to employment taxes?Employee elective deferrals are exempt from federaltaxes and, in most cases, state taxes. (These rulesvary by state. Consult your business tax advisor orpayroll service for information about your state’sregulations.) However, the elective deferrals are subject to all normal employment taxes. The companycontributions are exempt from federal, state andemployment taxes.

When must contributions be made to a SIMPLE IRA?Matching and non-elective contributions must be madeto the employee’s SIMPLE IRA by the employer’s taxfiling deadline (including extensions) for that year.Elective deferrals must be made to the SIMPLE IRA as of the earliest date on which the contribution can bereasonably separated from the employer’s generalassets, but in no event later than the close of the 30-day period following the last day of the month inwhich such amounts would otherwise have been paidto the employee.

Who is eligible to participate in a SIMPLE IRA?Any employee who has received at least $5,000 incompensation during any two preceding years, and is reasonably expected to receive at least $5,000 incompensation during the current year, must be allowedto participate in a SIMPLE IRA. You may exclude non-resident aliens and employees covered bycollective bargaining agreements. While you may setless restrictive requirements, you may not set morerestrictive ones.

May an employee participate in a SIMPLE IRA if he orshe participates in a plan offered by a different employer?

Yes, an individual may participate in multiple plans.However, the individual’s total salary reductioncontributions for all plans must not exceed themaximum salary reduction contribution limit set forqualified plans.

Where can employees invest their SIMPLE IRA contributions?

Employees’ plan contributions are placed into theirindividual SIMPLE IRAs, which they can set up throughAmeriprise Financial.

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What are the tax consequences when amounts aredistributed from a SIMPLE IRA?

Generally, the same tax rules apply to distributionsfrom SIMPLE and other IRAs. However, a specialpenalty tax rule applies to distributions from SIMPLEIRAs during the first two years of plan participation. If a distribution is received within this two-year period,the premature distribution penalty tax increases from10% to 25%. The two-year rule and increased penaltyare not applied in cases that meet specificrequirements for exceptions to the prematuredistributions rule. The Ameriprise Financial “Your Guideto SIMPLE IRAs” explains the tax treatment in more detail.

Can amounts in a SIMPLE IRA be rolled over?Tax-free rollovers and custodian-to-custodian transfersare allowed at any time from one SIMPLE IRA toanother SIMPLE IRA. However, a distribution from aSIMPLE IRA may only be rolled over to another type of IRA or qualified retirement plan if it has been morethan two years since the date the employee firstparticipated in any SIMPLE plan maintained by theemployer. Only taxable amounts can be rolled from an IRA into a non-IRA plan.

Can the owner of a business pay his/her spouse a wagefor performing services for the business and allowhim/her to contribute to a SIMPLE IRA?

Yes.

Can an employee take a loan from his/her SIMPLE IRA?Loans are not permitted.

Is payroll remittance available for a SIMPLE IRA Plan?Yes. Payroll remittance is available for Ameriprise Brokerageor Managed Accounts, Columbia Threadneedlefunds held on the broker/dealer platform, AmeripriseCertificates, annuities issued by RiverSource LifeInsurance Company or, in New York issued byRiverSource Life Insurance Co. of New York, Albany, NY.

Complete and submit the Employer Payroll Remittance,

Ameriprise works with National Benefit Services (NBS),a third-party administrator (TPA), to provide these services.

Arrangement Setup or Changes Form 402450(or 402451 in New York) to establish the arrangement.

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Yes. Payroll remittance is available for Ameriprise Brokerage or Managed Accounts, Ameriprise Certificates, annuities issued by RiverSource Life Insurance Company or, in New York issued by RiverSource Life Insurance Co. of New York, Albany, NY. Ameriprise works with National Benefit Services (NBS), a third-party administrator (TPA), to provide these services. Complete and submit the Employer Payroll Remittance, Arrangement Setup or Changes Form 402450 (or 402451 in New York) to establish the arrangement.

Tax-free rollovers and custodian-to-custodian transfers are allowed at any time from one SIMPLE IRA to another SIMPLE IRA. However, a distribution from a SIMPLE IRA may only be rolled over to another type of IRA or qualified retirement plan if it has been more than two years since the date the employee first participated in any SIMPLE plan maintained by the employer

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Documents

Plan Implementation Guide - Ameriprise