TO: HONORABLE MAYOR AND FROM: Jennifer Schembri
CITY COUNCIL
SUBJECT: 457 DEFERRED COMPENSATION DATE: February 14, 2022
PLAN INVESTMENT FUND
AGREEMENT
Approved Date
2/17/2022
RECOMMENDATION
Adopt a resolution authorizing the City Manager to execute an agreement and any corresponding documents necessary to add the T. Rowe Price Large Cap Growth Trust Class C Fund, a Collective Investment Trust, to the investment options in San Jose’s Voluntary 457 Deferred Compensation Plan (“Plan”).
OUTCOME
Approval of this recommendation will allow the Deferred Compensation Advisory Committee (DCAC) to add the recommended fund to the Plan’s investment line-up, providing a cost savings to plan participants.
BACKGROUND
The Voluntary 457 Deferred Compensation Plan currently contains approximately 8,300 Plan participants, which includes active employees, former employees, and retirees. The total assets in the Plan are approximately $1.3 billion. All expenses related to administering the Plan are paid by Plan participants; there are no expenses paid by the City.
On February 23, 2021,
1 the City Council approved amendments to the Plan which changed the DCAC’s and City Manager's contractual authority relating to the administration of the Plan, which became effective April 9, 2021. Accordingly, contractual authority relating to the administration of the Plan under San José Municipal Code Section 3.48.060 is set forth as follows:
1 February 23, 2021, item 2.14; file 21-315, “Proposed Amendments to the Voluntary Deferred Compensation Plan and PTC Plan” - https://sanjose.legistar.com/LegislationDetail.aspx?ID=4793382&GUID=EA96D3F7- 428A-46B3- A0FF-16A661450915&Options=&Search=
COUNCIL MEETING: 3/1/2022
FILE: 22-214
ITEM: 2.9
HONORABLE MAYOR AND CITY COUNCIL
February 14, 2022
Subject: Deferred Compensation Investment Fund Agreement
C. The City Manager shall have the authority to enter into agreements on behalf of the City for the administration of the Plan, for custodial agreements for funds, and for investments selected by the Advisory Committee under the Plan where the fees under such an agreement are to be paid by the participants of the Plan or where there is no amount to be paid by the City under the agreement.
D. The Advisory Committee shall have the authority to make decisions on behalf of the City as to the investment policy, the choice and nature of investments to be available under the Plan and enter into agreements on behalf of the City for investment advice under the Plan where the fees to be paid under such an agreement are to be paid by participants of the Plan or where there is no amount to be paid by the City under the agreement. The Advisory Committee shall have the authority to review and advise the City Manager on annual budgets and proposed changes to the Plan.
Pursuant to the Municipal Code, the DCAC has the authority to select the investments available under the Plan and the City Manager has the authority to enter into contracts for investments selected by the DCAC, the City Manager is responsible for executing any agreements required for investments selected by the DCAC.
ANALYSIS
The DCAC oversees the investment aspects of the Plan and works with Hyas Group, an independent investment consultant, to review fund performance at each quarterly meeting of the DCAC. The Hyas Group also recommends changes to the investment funds in the Plan for DCAC review and approval.
During the quarterly DCAC meeting on March 15, 2021, Hyas Group introduced Collective Investment Trusts Savings (CITs) as a potential new investment option. It was explained that historically CITs were primarily used in pension plans but are now becoming more popular in governmental 457 plans due to the cost savings and performance compared to mutual funds.
Vanguard and T. Rowe Price CIT products were specifically recommended by Hyas Group.
Since using CIT funds is new to the City’s Plan, the DCAC requested the City Attorney and outside counsel review the agreements and corresponding documents as they related to the potential fund changes. Following their review, no issues with Vanguard’s documents were identified; however, the Participation Agreement for the T. Rowe Price CIT Fund contains a provision that is outside the scope of authority delegated to the DCAC and City Manager under the Plan.
The Participation Agreement in T. Rowe Price’s Onboarding and Next Steps document (which refers back to the Section 8.4 of the Amended and Restated Declaration of Trust) states that “[t
]he Trustee’s compensation shall be paid by the Participating Trust or by the Plan Sponsor, as agreed between the Trustee and the other party...”. The City of San José would be the Plan Sponsor under the Agreement. Under the Plan provisions in the San Jose Municipal Code,
HONORABLE MAYOR AND CITY COUNCIL
February 14, 2022
Subject: Deferred Compensation Investment Fund Agreement
however, the City Manager can only enter into agreements where there is no amount to be paid by the City under the agreements. Thus, the Plan precludes the City Manager from executing the Participation Agreement unless it is modified to provide that the City would not be responsible for any fees, without any conditions or limitations.
While staff and T. Rowe Price tried to address the concerns relating to the Participation Agreement, the parties could not agree on a modification to the Agreement to ensure that the City would not be responsible for any fees. Thus, as it stands, the Participation Agreement allows T. Rowe Price the ability to charge fees to Participants or the City, depending on the investment selected by the DCAC.
The T. Rowe Price Large Cap Growth Trust C (CIT Fund) charges its fees to Plan participants.
The current T. Rowe Price Large Cap Growth I Mutual Fund being offered to Plan participants has a current expense ratio of 0.56% while the T. Rowe Price CIT Fund has a lower expense ratio of 0.45%. Moving to this CIT Fund will reduce the expense ratio for Plan participants by 11 basis points or 0.11%, a savings of approximately $208,000 annually for participants.
As long as the DCAC does not select a T. Rowe Price investment where the fees are to be paid by the Plan Sponsor, the City should not be responsible for any fees. As representatives from T.
Rowe Price explained:
“To the extent the plan is invested in a class of the Trust with a trustee fee (i.e., current Classes A, B, C, D, E, F, G) then the City will not pay any trustee fees; instead, the trustee fees will be deducted from the assets of the participants invested in the Trust and reflected in the NAV
2 per unit for each such class. To the extent the Plan is invested in Class Z of the Trust (which does not have a trustee fee that is reflected in the NAV), then there is a possibility for the City, as sponsor of the Plan, to be responsible for the fees owed to T. Rowe Price Trust Company as such fees are billed outside of the NAV and paid as directed by the sponsor. The decision to invest in Class Z of the trust lies solely with the sponsor and T. Rowe price does not make that determination.”
Staff does not foresee risk to the City for becoming financially responsible for the Plan’s investment fees. City staff along with the DCAC investment consultant will carefully monitor fund changes and not recommend including investment funds, like a Class Z fund, which would require City-paid fees. The DCAC uses the services of an investment consultant to determine what funds to offer pursuant to review and approval by the DCAC. Staff does not believe the investment consultant would recommend a fund change that provides for the City to pay any fees. Furthermore, T. Rowe Price requires an amendment signed by the City in order to invest in a different class.
Ultimately, however, the responsibility to ensure that an investment does not trigger any fees to be paid by the City rests with the DCAC and the DCAC will take steps in conjunction with the investment consultant and Plan recordkeeper to ensure it does not take any action that would
2 NAV – Net Asset Value
HONORABLE MAYOR AND CITY COUNCIL
February 14, 2022
Subject: Deferred Compensation Investment Fund Agreement
result in the City paying fees for investments. This will include an update to the Plan’s Investment Policy to reiterate that the DCAC is not authorized to choose any investments that would result in fees being charged to the City.
In a memorandum to the DCAC dated November 30, 2021, the City Attorney informed the DCAC of the option to seek approval from the City Council for a one-time authorization to expand the City Manager's authority to allow execution of the T. Rowe Price Participation Agreement, if the DCAC wanted to offer the T. Rowe Price CIT Fund. It was confirmed that providing such authorization to the City Manager would not be an issue with respect to Plan compliance.
On December 13, 2021, the DCAC voted, 6 to 1, to have staff seek the City Council’s approval to allow the City Manager to execute the Participation Agreement with T. Rowe Price so it can offer the T. Rowe Price CIT Fund.
CONCLUSION
Approval of the recommendation will allow the City Manager to execute the attached T. Rowe Price Participation Agreement and any corresponding documents, so the Plan can offer the T.
Rowe Price Large Cap Growth Trust Class C Fund to participants.
EVALUATION AND FOLLOW-UP
The City Manager or designee is responsible for administering the Deferred Compensation Plan (Plan), the trust account and for the operation of the Plan in accordance with the terms of the Plan. The City Manager or designee is required to determine all questions arising out of the administration, interpretation and application of the Plan and the Trust, with the exception of evaluating and selecting investment options. The investment consultant, DCAC, City staff, and City Manager all have a fiduciary role in the City’s 457 plans which requires the parties to make decisions that best serve the Plan participants. The DCAC’s recommendation to move to the CIT funds provides cost savings to Plan participants in line with these duties.
CLIMATE SMART SAN JOSE
The recommendation in this memorandum has no effect on Climate Smart San José energy, water, or mobility goals.
HONORABLE MAYOR AND CITY COUNCIL
February 14, 2022
Subject: Deferred Compensation Investment Fund Agreement
PUBLIC OUTREACH
This memorandum will be posted on the City’s Council Agenda website for the March 1, 2022 City Council Meeting.
COORDINATION
This memorandum has been coordinated with the Office of the City Attorney.
COMMISSION RECOMMENDATION/INPUT
No commission recommendation or input is associated with this action.
COST SUMMARY/IMPLICATIONS
All costs associated with the administration of the Plan are paid for by the participants; there is no cost to the City.
CEQA
Not a Project, File No. PP17-010, City Organizational and Administrative Activities resulting in no changes to the physical environment.
Jennifer Schembri
Director of Employee Relations and
Director of Human Resources
For questions, please contact Emily Hendon, Division Manager, at [email protected]
.
ATTACHMENTS
Participation Agreement
Amended and Restated Declaration of Trust
1 Welcome to
T . Rowe Price
Onboarding and next steps
Not for further distribution.
“If our clients succeed,
our firm will succeed.”
-Thomas Rowe Price, Jr.
For Client use only.
2 T. Rowe Price Trust Company Onboarding
Below you will find links to the governing documents related to investment in the T . Rowe Price Large-Cap Growth Trust.
Amended and Restated Declaration of Trust
Supplemental Declaration of Trust
Offering Circular
408(b)(2) Disclosure
Annual Report
Fact Sheet (Attached)
Should you have any questions regarding the documentation or would like a PDF copy emailed to you, please contact your T . Rowe Price representative.
LARGE-CAP GROWTH TRUST GOVERNING DOCUMENTS
3 T. Rowe Price Trust Company Onboarding
We ask that once you have reviewed all of the documentation, please complete and return the following items to our team:
Investor Information & Participation Agreement
IRS Determination Letter
Should you have any questions or would like to receive a PDF copy, please reach out to your T . Rowe Price representative.
COMMON TRUST FUND ONBOARDING CHECKLIST
Choose One
Choose One
Choose One
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T. Rowe Price Trust Company
CCON0051274
Exhibit A to the Participation Agreement
T. ROWE PRICE TRUST COMPANY
Pursuant to Article 2 of the Agreement and the terms of the Declaration of Trust, the Participating Trust shall make investments into the following Trust and Class
Trust Declaration of Trust Class
Trustee Fee
(Percent of the Class’s
Average Daily Net
Assets)
T. Rowe Price Large-Cap
Growth Trust
DOT: Amended and Restated Declaration
of Trust for the T. Rowe Price Strategic
Common Trust Fund
Supplemental DOT
: Amended and
Restated Supplemental Declaration of
Trust for the T. Rowe Price Large-Cap
Growth Trust
0.4 %
As provided in Section 7.2 of the DOT, each Class shall be charged directly for its respective trustee fees payable to the Trust Company as compensation for its services. The trustee fees for each Class are accrued daily pursuant to the Declaration of Trust and paid monthly. Note: the Named Fiduciary should refer to the Declaration of Trust for complete terms regarding investments in the Trusts, including, but not limited to, Sections 4.1 and 4.2 of the DOT regarding Units (as defined in the DOT) and their valuation, and Section 8.4(c) of the DOT regarding the Trust Company’s right to change its stated compensation for a Class.
CONSOLIDATED DECLARATION OF TRUST
AMENDING AND RESTATING
VANGUARD FIDUCIARY TRUST COMPANY
TARGET RETIREMENT TRUSTS II
Table of Contents
ARTICLE 1. PARTICIPATION ...................................................................................................................................................... 1 ARTICLE 2. TRUSTS ..................................................................................................................................................................... 4 ARTICLE 3. INVESTMENTS AND ADMINISTRATION ............................................................................................................ 5 ARTICLE 4. VALUATION, ACCOUNTING, AND REPORTS .................................................................................................... 8 ARTICLE 5. CONCERNING THE TRUSTEE ............................................................................................................................. 10 ARTICLE 6. GENERAL ................................................................................................................................................................ 11 VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT INCOME AND GROWTH TRUST II ................. 14 VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT 2015 TRUST II..................................................... 18 VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT 2020 TRUST II ..................................................... 20 VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT 2025 TRUST II..................................................... 22 VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT 2030 TRUST II..................................................... 24 VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT 2035 TRUST II..................................................... 26 VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT 2040 TRUST II..................................................... 28 VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT 2045 TRUST II..................................................... 30 VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT 2050 TRUST II..................................................... 32 VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT 2055 TRUST II ..................................................... 34 VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT 2060 TRUST II ..................................................... 36 VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT 2065 TRUST II .................................................. 368
1 CONSOLIDATED DECLARATION OF TRUST
VANGUARD FIDUCIARY TRUST COMPANY
TARGET RETIREMENT TRUSTS II
Vanguard Fiduciary Trust Company (the “Trustee”), a trust company organized under the laws of the Commonwealth of Pennsylvania,
(a) hereby amends and restates, and consolidates, effective as of October 1, 2011, the plans and declarations of trust of the Vanguard Fiduciary Trust Company Target Retirement Trusts II to provide and maintain collective investment trusts for employee benefit plans and other eligible entities, and
(b) hereby declares that it shall continue act as trustee and shall hold and administer, in trust, on the terms and conditions set forth in this Consolidated Declaration of Trust and the Trust Memorandums, all property that may be transferred to or received by it from time to time as a trustee hereunder.
The trusts created and maintained hereunder (each a “Trust”; collectively, the “Trusts”) are intended to qualify as group trusts under Internal Revenue Service Revenue Ruling 81-100, 1981- 1 C.B. 326, as modified by Revenue Rulings 2004-67, 2004-28 I.R.B., and 2011-1, 2011-2 I.R.B., or any successor ruling, regulation, or similar pronouncement, under the Internal Revenue Code of 1986, as amended (the “Code”), and shall be construed, and administered, to give effect to that intention. The Trusts shall also be construed and administered in accordance with the provisions of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and the applicable rules and regulations of the Pennsylvania Department of Banking.
ARTICLE 1. PARTICIPATION
Section 1.01. Eligible Participants. The only participants (“Participating Trusts”) in the Trust shall be any of the following that the Trustee has accepted that is maintained pursuant to a governing instrument that expressly and irrevocably provides that it is impossible for any part of the corpus or income of the Participating Trust to be used for, or diverted to purposes other than for the exclusive benefit of the plan participants and their beneficiaries:
(a) a trust that is
(1) a pension, profit-sharing, or other employee benefit trust exempt from federal income taxation under Section 501(a) of the Code by reason of qualifying under Section 401(a) of the Code and, if such trust covers one or more self -employed individuals within the meaning of Section 401(c)(1) of the Code, which satisfies the applicable requirements of the Securities Act of 1933, as amended from time to time (or Rule 180 of the Securities and Exchange Commission thereunder, or any successor ruling, regulation, or similar pronouncement), regarding participation in a collective investment trust;
(2) maintained pursuant to a plan or trust instrument that authorizes it to participate in the Trust or in any other common, collective, or commingled trust fund and that specifically or in substance and effect adopts this Consolidated Declaration of Trust 2 and applicable Trust Memorandum or the declaration of trust or other governing instrument under which such common, collective, or commingled trust fund is maintained, as a part of the plan of which such trust is a part; and
(3) exempt from federal income taxation under Section 408(e) of the Code with respect to deemed individual retirement accounts described in Section 408(q) of the Code and the regulations thereunder, including for this purpose a custodial account that is treated as a trust under Section 401(f) of the Code; or
(b) any of the following plans that satisfy the applicable requirements of the Securities Act of 1933 and the Investment Company Act of 1940, as each is amended from time to time (or any applicable rules of the Securities and Exchange Commission thereunder), regarding participation in a collective investment fund:
(1) a plan established and maintained for its employees by the U.S. Government, by the government of any State or political subdivision thereof, or by any agency or instrumentality of the foregoing, within the meaning of Section 414(d) of the Code;
(2) an eligible deferred compensation plan within the meaning of Section 457(b) of the Code established and maintained by an eligible governmental employer described in Section 457(e)(1)(A) of the Code, the assets of which are held in a trust described in Section 457(g)(1) of the Code (including for such purpose a custodial account that is treated as a trust under Section 457(g)(3) of the Code); and
(3) any other governmental plan or unit described in Section 818(a)(6) of the Code; or
(c) a separate account maintained in connection with a contract of an insurance company that consists solely of the assets of trusts and plans described in Sections 1.01(a) and (b); or
(d) any common, collective, or commingled trust fund, including, without limitation, any such fund maintained by the Trustee, that
(1) consists solely of the assets of trusts and plans described in Sections 1.01(a), (b), and (c);
(2) is exempt from federal income taxation under Section 501(a) of the Code by reason of qualifying as a “group trust” under Revenue Rulings 81- 100 and 2004- 67; and
(3) is maintained pursuant to an instrument that authorizes it to participate in the Trust or in any other common, collective, or commingled trust fund and that specifically or in substance and effect adopts this Consolidated Declaration of Trust and applicable Trust Memorandum or the declaration of trust or other governing instrument under which such other common, collective, or commingled trust fund is maintained, as a part thereof.
3 To the extent that any qualified plan participates in a Trust, either directly or indirectly through investment in a participating collective investment trust described in (d) above, this Consolidated Declaration of Trust and applicable Trust Memorandum shall constitute an integral part of such plan.
Section 1.02. Participation Procedures/Additions. A trust or other entity described in Section 1.01 may be admitted for participation in a Trust by submitting a written request for participation that is accepted by the Trustee, in the Trustee’s sole discretion; provided however, that the written request requirement may be waived for another collective investment trust maintained by the Trustee. Following acceptance by the Trustee, such Participating Trust may, in accordance with the terms and conditions prescribed by the Trustee, acquire a beneficial interest in a Trust by transferring cash or other property acceptable to the Trustee in exchange for Units (as defined in Section 4.01) in the Trust. All additions to a Trust shall be made as of a Valuation Date (as defined in Section 4.02) and on the basis of the Unit values determined by the Trustee in accordance with Section 4.01.
(a) On or before the Valuation Date as of which an addition is to be made, the Trustee shall enter in the Trustee’s fiduciary records a written request for or notice of intention of taking such action. No such request or notice may be cancelled or countermanded after the Valuation Date as of which such addition is made.
(b) The Trustee, in its discretion, may establish minimum or maximum dollar amounts for initial or subsequent additions to a Trust.
(c) The Trustee, in its discretion, may require that the request or notice referred to in Section 1.02(a) be received by the Trustee up to 15 days before the Valuation Date as of which such addition is to be made.
Section 1.03. Conditions of Participation. A trust or other entity described in Section
1.01 shall become a Participating Trust upon its acceptance by the Trustee. Any such trust or entity shall establish to the Trustee’s satisfaction that it meets the requirements of that Section and shall provide, at the request of the Trustee, written representations (including, without limitation, representations to the effect that its tax -exempt status will not be jeopardized as a result of participation in the Trust) and other information (including, wi thout limitation, a written opinion of counsel regarding its status or a copy of a determination letter from the Internal Revenue Service) or other assurances that the Trustee may deem necessary or advisable. A trust or other entity that has been accepted as a Participating Trust of a Trust shall continue to be eligible to participate in that Trust, subject to the following conditions:
(a) During such time as any assets of a Participating Trust are held in the Trust, (i) this Consolidated Declaration of Trust and applicable Trust Memorandum shall govern the administration of such assets, and (ii) any inconsistency between the governing instrument of the Participating Trust and either this Consolidated Declaration of Trust or such Trust’s Trust Memorandum relating to the management or administration of the Participating Trust’s assets held hereunder or to the rights, powers, responsibilities or liabilities of the Trustee with respect thereto shall be resolved in favor of this Consolidated Declaration of Trust and such Trust Memorandum.
4 (b) If the Trustee receives actual notice that a Participating Trust no longer satisfies the conditions of Section 1.01, or if the Trustee determines in its sole discretion that a Participating Trust should withdraw for any reason, the Trustee shall take all steps necessary to distribute to such Participating Trust its entire interest in the Trusts, other than any interest the Participating Trust may have in a Liquidating Account, as soon as practicable after the Trustee receives such notice or makes such determination; provided however, that, in the Trustee’s sole discretion, if the Participating Trust is a common, collective or commingled trust, only the assets of the Participating Trust representing assets of participating plan(s) in such Participating Trust that do not meet the requirements for eligibility set forth in Article 1.01 must be so withdrawn.
Section 1.04. Redemption of Units. Upon request provided in a manner acceptable to the Trustee, a Participating Trust may redeem one or more Units at the Unit price, calculated in accordance with Article 4, next determined after receipt of the redemption request. The Trustee, in its sole discretion, but upon consultation with the Participating Trust, shall decide whether to honor a redemption request in cash, in kind, or a combination of both. The Trustee will use its best efforts to distribute proceeds to the redeeming Participating Trust as soon as practicable; provided however, that (i) cash proceeds from the sale of securities liquidated to fund a withdrawal need not be paid until after the actual settlement date or dates of the sale of such securities; and (ii) the Trustee may suspend redemptions and/or postpone the payment of redemption proceeds at times when the New York Stock Exchange is closed or during other emergency circumstances.
Section 1.05. Frequent Trading. Each Trust is intended for long-term investors and will generally reject short-term investments. Notwithstanding any other provision of this Consolidated Declaration of Trust or any Trust Memorandum, the Trustee in its sole discretion may reject any purchase, redemption, or other transaction that it deems to constitute abusive trading in a Trust. With respect to any Participating Trust that is an individual account plan that permits participants and beneficiaries to direct the investment of their accounts, the Trustee may further require, as a condition of initial or continued participation in a Trust, that such Participating Trust adopt policies limiting the frequency with which participants and beneficiaries may give investment instructions with respect to Trust interests allocated to their individual accounts.
ARTICLE 2. TRUSTS
Section 2.01 Trusts. The Trustee may create, maintain, and administer hereunder one or more Trusts, as the Trustee in its sole discretion deems necessary or desirable from time to time.
Each Trust created or maintained hereunder shall constitute a separate trust, and will be separately held, managed, administered, valued, invested, reinvested, distributed, accounted for, and otherwise dealt with hereunder and no Trust will be answerable for any obligation or liability of any other Trust. Any person having any claim of any type against any Trust (including, but not limited to, contract, tort and statutory claims) may look only to the assets of such Trust for payment of such claim. No Participating Trust, nor any participant, beneficiary, trustee, employee or agent thereof, nor the Trustee, nor any of its officers, directors, shareholders, partners, employees or agents will be personally liable for any obligation of any Trust.
Section 2.02 Trust Memorandum.
5 (a) The terms of each Trust created and maintained hereunder will consist of this Consolidated Declaration of Trust and its Trust Memorandum. The Trustee may create a Trust at any time by approval of a new Trust Memorandum, which may include such investment guidelines and other provisions as may be necessary, desirable, or convenient for the creation, administration, and investment of such Trust.
(b) Each Trust Memorandum creating a new Trust shall not be considered an amendment to the Consolidated Declaration of Trust but shall ins tead constitute a supplement to it and will form a part hereof. The Trustee shall have each Trust Memorandum approved by its Board of Directors (or, if permitted by applicable law, a committee appointed by its Board of Directors) and shall file each such memorandum with such regulatory agencies and bodies as may be required under applicable law.
Section 2.03 Deposits Into the Respective Trusts. Money received from a Participating Trust may be deposited in one or more of the Trusts in such proportions as shall be directed by a person who controls the investments of such Participating Trust.
ARTICLE 3. INVESTMENTS AND ADMINISTRATION
Section 3.01. Investment Objective of Trust . Each Trust will be invested, directly or indirectly, primarily in shares of regulated open -end investment companies registered under the Investment Company Act of 1940, as amended, including any share class of such an investment company that is available to the Trust, in such proportions as the Trustee deems advisable, w ith the principal investment objective of providing a diversified portfolio of equity and fixed-income securities that will gradually become more conservative over time in accordance with its Trust Memorandum.
Section 3.02. Authorized Investments. In furtherance of its investment objective, a Trust will generally invest its assets in one or more collective investment trusts that are invested in shares of registered open- end investment companies as further described in its Trust Memorandum. A Trust may also invest in open-end investment companies, single-stock futures, stock index futures, convertible securities, swap agreements, shares of exchange -traded funds, bond futures, and common stocks whose characteristics are consistent with the investment objective. The Trustee has claimed an exclusion from the definition of “commodity pool operator” under the Commodity Exchange Act, and therefore is not subject to registration or regulation as a pool operator under such Act. The Trustee may amend a Trust Memorandum at any time to change the targeted asset allocations of the Trust or to add or remove investment companies from the target allocations of the Trust following notice to Participating Trusts. Notice will be provided least 30 days in advance of such addition, and any Participating Trust objecting to such addition will be permitted to withdraw its assets from the Trust without penalty prior to such addition and within such reasonable time as is necessary to effect the withdrawal in an orderly manner. Nothing in this Section 3.02 may be construed as limiting the strategies, techniques, and investments in which a Trust may engage pursuant to Section 3.03, 3.04, and 3.05.
Section 3.03. Trust Management. The Trustee’s determination whether any investment, investment technique, or strategy is within the class or classes of investments in which a Trust may invest, and whether any particular investment technique or strategy is consistent with the guidelines, policies, and objectives of the Trust, shall be conclusive. 6 Section 3.04. Short-Term Investments: Except where specifically prohibited or restricted by this Consolidated Declaration of Trust or applicable Trust Memorandum, the Trustee, in its discretion, may temporarily invest a Trust in short -term money market instruments or vehicles, including, without limitation, U.S. Government obligations, bankers’ acceptances, commercial paper, certificates of deposit and other deposit accounts insured by the Federal Deposit Insurance Corporation, repurchase agreements, money market mutual funds (including, without limitation, but subject to applicable law, those sponsored or advised by the Trustee or any of its affiliates), and any short-term investment fund (including, without limitation, but subject to applicable law, any such fund maintained by the Trustee or any of its affiliates pursuant to this Consolidated Declaration of Trust or otherwise) for which such Trust is an eligible participant. The governing instrument, as amended from time to time, of any such fund that is intended to qualify as a group trust under Revenue Rulings 81- 100, 2004- 67, and 2011- 1 shall, to the extent of the Trust’s participation therein, be incorporated herein and made a part of this Consolidated Declaration of Trust and applicable Trust Memorandums, and the combining of the assets of the Trust with the assets of other participants in such fund, to be held and administered in accordance with the fund’s governing instrument is hereby specifically authorized.
Section 3.05. Cash Balances and Deposits. The Trustee is authorized to hold temporarily such part of a Trust uninvested as the Trustee may deem reasonably necessary for the orderly administration of such Trust, and to deposit cash awaiting investment or distribution in interest- bearing accounts maintained in the commercial or savings department of any bank or savings association, the deposits of which are insured by the Federal Deposit Insurance Corporation.
Section 3.06. Management Responsibility. The Trustee has exclusive management and investment authority with respect to each Trust, except as a prudent person might delegate responsibilities to others. Subject to the foregoing, the Trustee may retain and consult with such investment advisers or other consultants, including, without limitation, any affiliate of the Trustee, as the Trustee in its discretion may deem advisable to assist it in carrying out its responsibilities under this Consolidated Declaration of Trust and any Trust Memorandum. The Trustee may appoint the manager or sponsor of any trust or fund (other than a registered investment company) in which the assets of a Trust may be invested pursuant to Section 3.04 or 3.08(a) as trustee or investment manager for the Participating Trusts with authority to manage and control such assets in accordance with such fund’s governing instrument. For this purpose, the Trustee shall be deemed a “named fiduciary,” as defined by Section 402(a)(1) of ERISA, of each Participating Trust with respect to the assets of such Participating Trust invested in a Trust, with responsibilities limited to managing and controlling such assets in accordance with this Consolidated Declaration of Trust and the Trust Memorandum of such Trust.
Section 3.07. Transaction Fees. The Trustee reserves the right to charge a transaction fee on cash purchases to, or redemptions from, a Trust that the Trustee, in its sole discretion, deems to be disruptive of efficient portfolio management or determines will impose inordinately high costs on other Participating Trusts. Unlike a sales charge or load paid to a broker or management company, any transaction fee shall be paid directly to such Trust to offset the cost of buying and selling securities. Transaction fees will not be assessed in conjunction with (a) in- kind purchases or redemptions or (b) any transactions when a Trust is funded by a single Participating Trust. 7 Section 3.08. Management Powers. In administering a Trust, the Trustee shall have full authority and sole discretion (exercisable without approval of any court, Participating Trust, or any other person) to do all of the following:
(a) To invest in and to retain all kinds of property, whether or not productive of income, not prohibited by law and without restriction to investments authorized by state law for fiduciaries, in accordance with the Trust’s investment objective as stated in this Article III and in its Trust Memorandum, including without limitation on the amount that may be invested therein, any registered investment companies and collective investment trusts sponsored, maintained, or managed by the Trustee or any of its affiliates.
(b) To hold property in bearer form or to register or cause to be registered such property in the name of a nominee of the Trustee or any custodian appointed by the Trustee; provided that, the records of the Trustee and any such custodian shall show that such property belongs to the Trust.
(c) To dispose of all or any part of the investments, securities, or other property that may from time to time or at any time constitute the Trust, and to exercise all voting rights arising from Trust property.
(d) To give proxies, both ministerial and discretionary.
(e) To compromise, arbitrate, or otherwise adjust claims in favor of or against the Trust, including but not limited to claims for taxes.
(f) To join in any merger, reorganization, voting trust plan, or other concerted action of security holders, and to delegate discretionary duties with respect thereto.
(g) To write and sell call options under which the holder of the option has the right to purchase shares of stock held by the Trustee as a part of the assets of the Trust , if such options are traded on and sold through a national securities exchange and so long as the Trustee at all times up to and including the time of exercise or expiration of any such option holds sufficient stock in the assets of the Trust to meet the obligations under such option if exercised. In addition, the Trustee is expressly authorized to purchase and acquire call options for the purchase of shares of stock covered by such options if the options are traded on and purchased through a national securities exchange and so long as any such option is purchased through a national securities exchange and so long as any such option is purchased solely in a closing purchase transaction. A closing purchase transaction is a purchase of an exchange traded call option the effect of which is to reduce or eliminate the obligations of the Trustee with respect to a stock option contract which it has previously written and sold in a transaction authorized under this Section 3.08(g).
(h) To purchase and acquire put options under which the Trustee, as the holder of the option, has the right to sell shares of stock held in the Trust to the grantor of the option, if such options are traded on, and sold through, a national securities exchange, and so long as the Trustee, at all times up to and including the time of its exercise of any such option, holds sufficient stock in the assets of the Trust to meet its obligations to the grantor of the option, if exercised by the Trustee; and to write and sell put options for sale to the Trustee 8 of shares of stock covered by such options, if the options are traded on, and purchased through, a national securities exchange.
(i) To enter into stock-index and bond futures contracts as a hedge against the Trust’s cash flows and as a means of minimizing the Trust’s trading costs if such futures contracts are traded on, and sold through, a national futures exchange.
(j) To allocate any property received or charge incurred to capital or income, or partly to each, as the Trustee may determine to be proper.
(k) To borrow and to pledge assets of the Trust as security for repayment.
(l) To loan securities held by the Trust, and to secure the same in any manner, to the extent permitted by ERISA.
(m) To make division or distribution in cash or in other property or undivided interests therein, or partly in cash and partly in other property or undivided interests therein.
(n) To employ, at the expense of the Trust, agents, experts, certified public accountants, auditors, and legal counsel, and to delegate discretionary powers to, and rely upon information and advice furnished by, such agents, experts, and counsel.
(o) To do all such acts, take all such proceedings, and exercise all such rights and privileges in the proper discharge of its trust hereunder, whether hereinbefore specially referred to or not, with relation to any property, as could be done, taken, or exercised by the absolute owner thereof.
Section 3.09. Reinvestment of Income and Capital Gains. Unless provided otherwise by this Consolidated Declaration of Trust or applicable Trust Memorandum, all net income and realized capital gains of a Trust shall be accumulated and added to the principal of such Trust, and invested and reinvested as a part thereof.
ARTICLE 4. VALUATION, ACCOUNTING, AND REPORTS
Section 4.01. Units in the Trust. The beneficial ownership of a Trust shall be divided into units (“Units”), each of which shall represent a proportionate undivided interest in the Trust as a whole. The Trustee shall have legal title to the assets of a Trust and no Participating Trust shall be deemed to have individual ownership of any asset. All Units shall be of equal value and none shall have any priority or preference over any other. In any distribution of income or capital all Units shall be treated alike. Fractional Units may also be issued in the Trustee’s discretion. The Trustee may from time to time divide or combine the Units of a Trust into a greater or lesser number, provided that the proportionate interest of each Participating Trust in such Trust may not thereby be changed.
Section 4.02. Valuation of the Units . The initial value of each Unit of a Trust created hereunder shall be $30.00, or such other value as is specified in its Trust Memorandum. Thereafter, the Trustee shall determine the value of each Unit on each day the New York Stock Exchange is open for trading (each such day hereinafter called the “Valuation Date”). A Trust’s Unit price is calculated by dividing the total assets of the Trust (determined in accordance with Section 4.03 9 hereof and excluding any liquidating or reserve accounts), less all liabilities (as determined by the Trustee in good faith in accordance with procedures consistently followed and uniformly applied), by the total number of Units of the Trust outstanding on the Valuation Date. The Unit price will be determined as of the close of the New York Stock Exchange (generally 4:00 p.m. Eastern Time) on each day that the Exchange is open for trading.
Section 4.03. Valuation of Assets . The value of the assets of a Trust on any Valuation Date shall be established as follows:
(a) Portfolio securities for which market quotations are readily available (including those securities listed on national securities exchanges) are valued at the last quoted sales price at or before the time when assets are valued on the Valuation Date. Shares of an open-end investment company, other than exchange -traded shares, are valued at such investment company’s closing net asset value (NAV) on the Valuation Date. Portfolio securities that are not traded on the Valuation Date are valued at the mean of the bid and ask prices. Price information on exchange-listed securities is taken from the exchange where the security is primarily traded.
(b) Other assets and securities for which no quotations are readily available or which are restricted as to sale (or resale) are valued at fair value as determined by the Trustee in good faith in accordance with procedures consistently followed and uniformly applied.
(c) If, because of unusual circumstances, the Trustee finds that the methods set forth above are not properly suited to establishing the value of a particular asset or type of assets, then the executive officers of the Trustee may establish the value of such asset or assets by a procedure consistently followed and uniformly applied, notwithstanding any other provision of this Section 4.03.
Section 4.04. Separate Accounts . The Trustee will evidence the ownership of the Units of a Trust by designating clearly upon its records the name of each Participating Trust in such Trust and the number of Units owned by the Participating Trust, and such record shall be sufficient evidence for all purposes of the ownership thereof. A separate account will be maintained for each Participating Trust to reflect its Units in a Trust, and the account will reflect all contributions, distributions, and the investment experience of the Participating Trust.
Section 4.05. Fiscal Year. The Trustee shall establish the fiscal year of a Trust from time to time, which initially shall be the twelve-month period ending March 31, unless a different period is specified in the Trust Memorandum of such Trust.
Section 4.06. Audits and Reports . At least once every twelve months, a Trust shall be audited by auditors responsible only to the Board of Directors of the Trustee, and the Trustee shall prepare a financial report of such Trust.
(a) The Trustee shall file a copy of such financial report with applicable regulatory agencies as may be required by law. In addition, the Trustee shall furnish the person designated by each Participating Trust with a copy of such financial report and, upon request, a copy of the audited financial statements of the Trust. The Participating Trust shall provide such documents and other information necessary for the Trustee to satisfy any government filings required by law.
10 (b) If no written objec tions to specific items in the financial report are filed with the Trustee within 120 days after the report is sent by the Trustee, the report shall be deemed to have been approved with the same effect as though judicially approved by a court of competent jurisdiction in a proceeding in which all persons interested were made parties and were properly represented before such court, and, to the fullest extent permitted by applicable law, the Trustee shall be released and discharged from liability and accountability with respect to the propriety of its acts and transactions disclosed in the report. Any such written objection shall apply only to the proportionate share of the Participating Trust on whose behalf the objection is filed and shall not affect the proportionate share of any other Participating Trust. The Trustee shall, in any event, have the right to a settlement of its accounts in a judicial proceeding if it so elects.
Section 4.07. Expenses and Taxes. The Trustee may charge to a Trust any expense, claim, or charge properly payable from such Trust under this Consolidated Declaration of Trust, its Trust Memorandum, or applicable law, including, but not limited to, (i) costs, commissions, brokerage fees, income taxes, withholding taxes, transfer and other taxes, and any other expenses associated with, or resulting from, the holding, purchase and/or sale, and receipt of income from, investments by the Trust, (ii) the reasonable expenses of an audit of the Trust by independent public accountants, and (iii) reasonable attorneys’ fees and litigation expenses, including any advance necessary to defend the Trustee regarding any allegation of fiduciary breach in connection with the Trust, provided that if a court finds in a final decision that the Trustee engaged in such a breach, such expenses shall be reimbursed to the Trust. In addition, the Trustee is entitled to reimbursement for any of the foregoing that it has incurred in managing or administering a Trust, or that it has paid on behalf of a Trust.
ARTICLE 5. CONCERNING THE TRUSTEE
Section 5.01. Trustee Compensation . The Trustee is entitled to receive reasonable compensation for its services in managing and administering a Trust. Such compensation will be based on the value of such Trust’s assets, determined in accordance with this Consolidated Declaration of Trust and its Trust Memorandum, and disclosed in the participation agreement executed by the Participating Trusts. To the extent that a Trust invests in another common, collective or commingled investment trust maintained by the Trustee or its affiliate, no investment management or advisory fees will be payable to the Trustee by the Trust with respect to any such investment. To the extent that a Trust invests in open- end investment companies managed by the Trustee or its affiliate, including indirect investments through another common, collective, or commingled investment trust maintained by the Trustee, no investment management or advisory fees will be payable to the Trustee by the Trust with respect to any such investment. These conditions shall not preclude the payment of investment management or advisory fees to an affiliate of the Trustee by such an open-end investment company under the terms of its investment management or advisory agreement adopted in accordance with section 15 of the Investment Company Act of 1940. These conditions also shall not preclude the payment of any investment management or advisory fee to the Trustee by a Trust based on total plan assets invested in the Trust from which a credit has been subtracted representing the Trust’s pro rata share of investment management or advisory fees paid to the Trustee or its affiliate by the open- end investment company or common, collective, or commingled investment trust. 11 Section 5.02. Trustee’s Authority. No person dealing with the Trustee shall be under any obligation to inquire regarding the authority of the Trustee, the validity or propriety of any transaction, or the application of any payment made to the Trustee.
Section 5.03. Advice of Counsel . The Trustee may consult with legal counsel of its choosing with respect to the interpretation of the Consolidated Declaration of Trust and any Trust Memorandum, the Trustee’s rights or responsibilities hereunder, any legal proceeding or question of law, or any act the Trustee proposes to take or omit, and may pay such counsel reasonable compensation from the Trust. The Trustee shall not be liable for any action taken or omitted in good faith pursuant to the advice of such counsel.
Section 5.04. Reliance on Communications. The Trustee shall be fully protected in acting upon any instrument, certificate, or document believed by it to be genuine and to be signed or presented by the proper person or persons. The Trustee shall have no duty to make an investigation or inquiry of any statement contained in any such writing, but may accept the same as conclusive evidence of the truth and accuracy of the statements therein contained.
Section 5.05. Accountings and Necessary Parties. Except as otherwise required by this Consolidated Declaration of Trust or applicable law, the Trustee has no obligation to render an accounting to any Participating Trust or be neficiary thereof. If at any time the Trustee or any Participating Trust applies to a court of competent jurisdiction for a judicial settlement of the Trustee’s accounts, it shall be necessary to join as parties in any such proceeding only the Trustee and each person to whom a regular periodic accounting would ordinarily be rendered with respect to each Participating Trust.
Section 5.06. Limitation on Liability. Except as otherwise provided by applicable law, (i) the Trustee shall not be liable by reason of the purchase, retention, sale, or exchange of any investment, or for any loss in connection therewith, except to the extent such loss has been caused by its own negligence, willful misconduct, or lack of good faith, and (ii) the Trustee shall not be liable for any mistake made in good faith in the administration of the Trust if, promptly after discovering the mistake, the Trustee takes whatever action the Trustee, in its discretion, may deem to be practicable under the circumstances.
ARTICLE 6. GENERAL
Section 6.01. Diversion, Assignment Prohibited. The following provisions shall apply, notwithstanding any provision of this Consolidated Declaration of Trust, any Trust Memorandum, or any amendment to either to the contrary.
(a) No part of the corpus or income of a Trust that equitably belongs to a Participating Trust, other than that portion required for taxes (if any), reasonable expenses incurred in the administration of the Trust, and Trustee Compensation as permitted by this Consolidated Declaration of Trust and applicable law, shall be used or diverted to any purposes other than for the exclusive benefit of the participants or their beneficiaries entitled to benefits under such Participating Trust.
(b) No Participating Trust may assign all or any portion of its equity or interest in a Trust. 12 (c) No part of a Trust that equitably belongs to a Participating Trust shall be subject to any legal process, levy of execution, or attachment or garnishment proceedings for payment of any claim against any such Participating Trust or any employee or beneficiary thereof.
Section 6.02. Successor Trustee. Any company that may hereafter succeed to the Trustee’s trust business, including the Trusts, will automatically become successor trustee of the Trusts, without the necessity of executing any instrument or performing any further act.
Section 6.03. Termination. The Trustee may terminate a Trust as of any Valuation Date by resolution of its Board of Directors. Notice of termination shall be sent at least thirty (30) days before termination to each person entitled to an audit report under Section 4.06(a). On termination, the principal of such Trust, together with all accrued income, shall be distributed to all Participating Trusts pro rata according to the number of Units held by each. The time and manner of making such final distribution shall be determined by the Trustee.
Section 6.04. Choice of Law. All questions arising under this Consolidated Declaration of Trust and any Trust Memorandum shall be governed by Pennsylvania law without regard to its provisions concerning conflicts of law, except to the extent that Pennsylvania law has been superseded by ERISA.
Section 6.05. Amendments. The Trustee may amend this Consolidated Declaration of Trust and any Trust Memorandum hereto at any time in its sole discretion, except as limited by Section 6.01 above and applicable law. Any such amendment shall be effective no earlier than fifteen (15) days following the date tha t written notice of the amendment is furnished to each Participating Trust, unless an earlier effective date (including a retroactive effective date) is otherwise required by law, including any amendment necessary or desirable to maintain any Trust’s qualification under Section 401(a) of the Code or its tax-exempt status under Section 501(a) of the Code. Such amendment will be binding on all persons with respect to each Participating Trust and will be automatically incorporated by reference into each Participating Trust and associated plans.
Section 6.06. Merger.
(a) The Trustee may cause any Trust to be merged with or into any other Trust or with any other collective investment trust maintained by the Trustee as of any Valuation Date; in addition, every Trust created hereunder, other than the Vanguard Fiduciary Trust Company Target Retirement Income Trust II (“Income Trust”), is expected to be merged into the Income Trust when its investment allocations become comparable to the Income Trust’s investment allocations.
(b) If a Trust does not survive the merger, the Participating Trusts invested in that Trust must receive beneficial interests in the surviving collective investment trust equal in value to the value of its interest in the Trust, with both values determined as of the date of trust merger. In the case of a Trust’s merger with the Income Trust, the Income Trust shall be the surviving Trust.
(c) The Trustee may effect a trust merger by any means permitted by law, including by having a Trust invest all of its assets in the surviving trust in exchange for interests in the 13 surviving trust, which the Trust will distribute to its Participating Trusts in proportion to their interests in the Trust.
(d) The Trustee will provide written notice to all Participating Trusts invested in a merging Trust at least 30 days before the date of merger, but the Trustee need not obtain advance consent from any Participating Trust in connection with any Trust merger. Any Participating Trust that does not consent to the merger may withdraw from such Trust without penalty provided that an authorized fiduciary requests the withdrawal in writing at least five (5) business days before the date of merger.
Section 6.07. Domestic Trust. Every Trust created hereunder shall at all times be maintained as a domestic trust in the United States.
Section 6.08. Integral Part of Participating Trusts. This Consolidated Declaration of Trust and the Trust Memorandum of a Trust shall be an integral part of each pension or profit- sharing trust that is a Participating Trust in such Trust, and of the plan of the employer establishing such Participating Trust; likewise, this Consolidated Declaration of Trust and the Trust Memorandum of a Trust shall be an integral part of each governmental plan that is a Participating Trust in such Trust.
Section 6.09. Titles. The titles and headings in this Consolidated Declaration of Trust and any Trust Memorandum are for convenience and reference only, and shall not limit or affect in any manner any provision herein.
Section 6.10. Invalid Provisions. If any paragraph, section, sentence, clause, or phrase contained in this Consolidated Declaration of Trust or any Trust Memorandum is illegal, null, or void, or against public policy, the remaining provisions thereof shall not be affected.
IN WITNESS WHEREOF, Vanguard Fiduciary Trust Company has caused this Consolidated Declaration of Trust to be executed by its duly authorized officers this 21st day of September, 2011.
VANGUARD FIDUCIARY TRUST COMPANY
By: /s/ Heidi Stam
Senior Vice President & General Counsel
Attest: /s/ Michael Kimmel
Secretary
14 TRUST MEMORANDUM:
VANGUARD FIDUCIARY TRUST COMPANY
TARGET RETIREMENT INCOME AND GROWTH TRUST II
Vanguard Fiduciary Trust Company (the “Trustee”) hereby establishes, effective as of June 1, 2021, the Vanguard Fiduciary Trust Company Target Retirement Income and Growth Trust II (the “Trust”). The terms of the Trust shall consist of this Trust Memorandu m and the Consolidated Declaration of Trust for the Vanguard Fiduciary Trust Company Target Retirement Trusts II (“Consolidated Declaration”), which is incorporated herein by reference.
In furtherance of its investment objective as described in Article II I of the Consolidated Declaration, the Trust shall be invested primarily in units of the Vanguard Fiduciary Trust Company Target Retirement Income and Growth Master Trust with the objective of creating a diversified portfolio of open- end investment companies and collective investment trusts, as further described in Appendix A hereto.
IN WITNESS WHEREOF, Vanguard Fiduciary Trust Company has caused this Trust Memorandum to be executed by its duly authorized officers this 14
th day of May, 2021.
VANGUARD FIDUCIARY TRUST COMPANY
By: /s/ Caroline Cosby
Vice President & General Counsel
Attest: /s/ Beth Morales Singh
Secretary
(CORPORATE SEAL)
15 Appendix A
VFTC Target Retirement Income and Growth Trusts
Target Allocation Ranges*
Effective September 1, 2021
2021+
Vanguard Total Stock Market Index Fund 30%
Vanguard Total International Stock Market
Index Trust II
20%
Vanguard Total Bond Market II Index Fund 30.5%
Vanguard Total International Bond Market
Index II Fund
13%
Vanguard Short-Term Inflation-Protected
Securities Index Fund
6.5%
Generally, 40% of total equity exposure will be dedicated to international equity and 30% of total fixed income exposure will be dedicated to international fixed income. TIPS are capped at 30% of U.S. fixed income exposure.
* These represent target allocations. Actual asset allocations generally may vary +/- five (5) percentage points from these targets.
16 TRUST MEMORANDUM:
VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT INCOME TRUST II
Vanguard Fiduciary Trust Company (the “Trustee”) hereby amends and restates, effective as of October 1, 2011, the Vanguard Fiduciary Trust Company Target Retirement Income Trust II (the “Trust”). The terms of the Trust shall consist of this Trust Memorandum and the Consolidated Declaration of Trust for the Vanguard Fiduciary Trust Company Target Retirement Trusts II (“Consolidated Declaration”), which is incorporated herein by reference.
In furtherance of its investment objective as described in Article III of the Consolidated Declaration, the Trust shall be invested primarily in the Vanguard Fiduciary Trust Company Target Retirement Income Master Trust with the objective of creating a diversified portfolio of open-end investment companies, as further described in Appendix A hereto.
IN WITNESS WHEREOF, Vanguard Fiduciary Trust Company has caused this Trust Memorandum to be executed by its duly authorized officers this 21st day of September, 2011.
VANGUARD FIDUCIARY TRUST COMPANY
By: /s/ Heidi Stam
Senior Vice President & General Counsel
Attest: /s/ Michael Kimmel
Secretary
17 Appendix A
VFTC Target Retirement Income Trusts (Master, I, II, III, Plus, Select) Target Allocations*
Effective September 1, 2021
2015 &
After
Vanguard Total Stock Market Index Fund 18%
Vanguard Total International Stock Market Index
Trust II
12%
Vanguard Total Bond Market II Index Fund 37%
Vanguard Total International Bond Market Index
II Fund
16%
Vanguard Short-Term Inflation-Protected
Securities Index Fund
17%
Generally 40% of total equity exposure will be dedicated to international equity and 30% of total fixed income exposure will be dedicated to international fixed income. TIPS are capped at 30% of U.S. fixed income exposure.
* These represent target allocations. Actual asset allocations generally may vary +/- five (5) percentage points from these targets.
18 TRUST MEMORANDUM:
VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT 2015 TRUST II
Vanguard Fiduciary Trust Company (the “Trustee”) hereby amends and restates, effective as of October 1, 2011, the Vanguard Fiduciary Trust Company Target Retirement 2015 Trust II (the “Trust”). The terms of the Trust shall consist of this Trust Memorandum and the Consolidated Declaration of Trust for the Vanguard Fiduciary Trust Company Target Retirement Trusts II (“Consolidated Declaration”), which is incorporated herein by reference.
In furtherance of its investment objective as described in Article III of the Consolidated Declaration, the Trust shall be invested primarily in the Vanguard Fiduciary Trust Company Target Retirement 2015 Master Trust with the objective of creating a diversified portfolio of open -end investment companies, as further described in Appendix A hereto.
IN WITNESS WHEREOF, Vanguard Fiduciary Trust Company has caused this Trust Memorandum to be executed by its duly authorized officers this 21st day of September, 2011.
VANGUARD FIDUCIARY TRUST COMPANY
By: /s/ Heidi Stam
Senior Vice President & General Counsel
Attest: /s/ Michael Kimmel
Secretary
19 Appendix A
VFTC Target Retirement 2015 Trusts (Master, I, II, III, Plus, Select) Target Allocation Ranges*
Effective September 1, 2021
2015 2020 2025
&
After
Vanguard Total Stock Market Index Fund 31% 22% 18%
Vanguard Total International Stock Market Index Trust II 20% 15% 12% Vanguard Total Bond Market II Index Fund 29% 34% 37%
Vanguard Total International Bond Market Index II Fund 13% 15% 16% Vanguard Short-Term Inflation Protected Securities Index Fund 7% 14% 17%
Generally 40% of total equity exposure will be dedicated to international equity and 30% of total fixed income exposure will be dedicated to international fixed income. TIPS are capped at 30% of U.S. fixed income exposure.
* These represent target allocations. Actual asset allocations generally may vary +/- five (5) percentage points from these targets.
20 TRUST MEMORANDUM:
VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT 2020 TRUST II
Vanguard Fiduciary Trust Company (the “Trustee”) hereby amends and restates, effective as of October 1, 2011, the Vanguard Fiduciary Trust Company Target Retirement 2020 Trust II (the “Trust”). The terms of the Trust shall consist of this Trust Memorandum and the Consolidated Declaration of Trust for the Vanguard Fiduciary Trust Company Target Retirement Trusts II (“Consolidated Declaration”), which is incorporated herein by reference.
In furtherance of its investment objective as described in Article III of the Consolidated Declaration, the Trust shall be invested primarily in the Vanguard Fiduciary Trust Company Target Retirement 2020 Master Trust with the objective of creating a diversified portfolio of open -end investment companies, as further described in Appendix A hereto.
IN WITNESS WHEREOF, Vanguard Fiduciary Trust Company has caused this Trust Memorandum to be executed by its duly authorized officers this 21st day of September, 2011.
VANGUARD FIDUCIARY TRUST COMPANY
By: /s/ Heidi Stam
Senior Vice President & General Counsel
Attest: /s/ Michael Kimmel
Secretary
21 Appendix A
VFTC Target Retirement 2020 Trusts (Master, I, II, III, Plus, Select) Target Allocation Ranges*
Effective September 1, 2021
2015 2020 2025 2030 &
After
Vanguard Total Stock Market Index Fund 36% 31% 22% 18%
Vanguard Total International Stock Market Index Trust II 24% 20% 15% 12% Vanguard Total Bond II Market Index Fund 27% 29% 34% 37% Vanguard Total International Bond Market Index II Fund 12% 13% 15% 16% Vanguard Short-Term Inflation Protected Securities
Index Fund
0% 7% 14% 17%
Generally 40% of total equity exposure will be dedicated to international equity and 30% of total fixed income exposure will be dedicated to international fixed income. TIPS are capped at 30% of U.S. fixed income exposure.
* These represent target allocations. Actual asset allocations generally may vary +/- five (5) percentage points from these targets.
22 TRUST MEMORANDUM:
VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT 2025 TRUST II
Vanguard Fiduciary Trust Company (the “Trustee”) hereby amends and restates, effective as of October 1, 2011, the Vanguard Fiduciary Trust Company Target Retirement 2025 Trust II (the “Trust”). The terms of the Trust shall consist of this Trust Memorandum and the Consolidated Declaration of Trust for the Vanguard Fiduciary Trust Company Target Retirement Trusts II (“Consolidated Declaration”), which is incorporated herein by reference.
In furtherance of its investment objective as described in Article III of the Consolidated Declaration, the Trust shall be invested primarily in the Vanguard Fiduciary Trust Company Target Retirement 2025 Master Trust with the objective of creating a diversified portfolio of open -end investment companies, as further described in Appendix A hereto.
IN WITNESS WHEREOF, Vanguard Fiduciary Trust Company has caused this Trust Memorandum to be executed by its duly authorized officers this 21st day of September, 2011.
VANGUARD FIDUCIARY TRUST COMPANY
By: /s/ Heidi Stam
Senior Vice President & General Counsel
Attest: /s/ Michael Kimmel
Secretary
23 Appendix A
VFTC Target Retirement 2025 Trusts (Master, I, II, III, Plus, Select) Target Allocation Ranges*
Effective September 1, 2021
2015 2020 2025 2030 2035 &
After
Vanguard Total Stock Market Index Fund 41% 36% 31% 22% 18% Vanguard Total International Stock Market Index Trust II 27% 24% 20% 15% 12% Vanguard Total Bond Market II Index Fund 22% 27% 29% 34% 37% Vanguard Total International Bond Market Index II Fund 10% 12% 13% 15% 16% Vanguard Short-Term Inflation Protected Securities
Index Fund
0% 0% 7% 14% 17%
Generally 40% of total equity exposure will be dedicated to international equity and 30% of total fixed income exposure will be dedicated to international fixed income. TIPS are capped at 30% of U.S. fixed income exposure.
* These represent target allocations. Actual asset allocations generally may vary +/- five (5) percentage points from these targets.
24 TRUST MEMORANDUM:
VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT 2030 TRUST II
Vanguard Fiduciary Trust Company (the “Trustee”) hereby amends and restates, effective as of October 1, 2011, the Vanguard Fiduciary Trust Company Target Retirement 2030 Trust II (the “Trust”). The terms of the Trust shall consist of this Trust Memorandum and the Consolidated Declaration of Trust for the Vanguard Fiduciary Trust Company Target Retirement Trusts II (“Consolidated Declaration”), which is incorporated herein by reference.
In furtherance of its investment objective as described in Article III of the Consolidated Declaration, the Trust shall be invested primarily in the Vanguard Fiduciary Trust Company Target Retirement 2030 Master Trust with the objective of creating a diversified portfolio of open -end investment companies, as further described in Appendix A hereto.
IN WITNESS WHEREOF, Vanguard Fiduciary Trust Company has caused this Trust Memorandum to be executed by its duly authorized officers this 21st day of September, 2011.
VANGUARD FIDUCIARY TRUST COMPANY
By: /s/ Heidi Stam
Senior Vice President & General Counsel
Attest: /s/ Michael Kimmel
Secretary
25 Appendix A
VFTC Target Retirement 2030 Trusts (Master, I, II, III, Plus, Select) Target Allocation Ranges*
Effective September 1, 2021
2015 2020 2025 2030 2035 2040 &
After
Vanguard Total Stock Market Index Fund 46% 41% 37% 31% 22% 18% Vanguard Total International Stock Market Index
Trust II
30% 27% 24% 20% 15% 12%
Vanguard Total Bond Market II Index Fund 17% 22% 27% 29% 34% 37% Vanguard Total International Bond Market Index
II Fund
7% 10% 12% 13% 15% 16%
Vanguard Short-Term Inflation Protected
Securities Index Fund
0% 0% 0% 7% 14% 17%
Generally 40% of total equity exposure will be dedicated to international equity and 30% of total fixed income exposure will be dedicated to international fixed income. TIPS are capped at 30% of U.S. fixed income exposure.
* These represent target allocations. Actual asset allocations generally may vary +/- five (5) percentage points from these targets.
26 TRUST MEMORANDUM:
VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT 2035 TRUST II
Vanguard Fiduciary Trust Company (the “Trustee”) hereby amends and restates, effective as of October 1, 2011, the Vanguard Fiduciary Trust Company Target Retirement 2035 Trust II (the “Trust”). The terms of the Trust shall consist of this Trust Memorandum and the Consolidated Declaration of Trust for the Vanguard Fiduciary Trust Company Target Retirement Trusts II (“Consolidated Declaration”), which is incorporated herein by reference.
In furtherance of its investment objective as described in Article III of the Consolidated Declaration, the Trust shall be invested primarily in the Vanguard Fiduciary Trust Company Target Retirement 2035 Master Trust with the objective of creating a diversified portfolio of open -end investment companies, as further described in Appendix A hereto.
IN WITNESS WHEREOF, Vanguard Fiduciary Trust Company has caused this Trust Memorandum to be executed by its duly authorized officers this 21st day of September, 2011.
VANGUARD FIDUCIARY TRUST COMPANY
By: /s/ Heidi Stam
Senior Vice President & General Counsel
Attest: /s/ Michael Kimmel
Secretary
27 Appendix A
VFTC Target Retirement 2035 Trusts (Master, I, II, III, Plus, Select) Target Allocation Ranges*
Effective September 1, 2021
2015 2020 2025 2030 2035 2040 2045 &
After
Vanguard Total Stock Market Index Fund 50% 46% 41% 37% 31% 22% 18% Vanguard Total International Stock Market
Index Trust II
33% 30% 27% 24% 20% 15% 12%
Vanguard Total Bond Market II Index
Fund
12% 17% 22% 27% 29% 34% 37%
Vanguard Total International Bond Market
Index II Fund
5% 7% 10% 12% 13% 15% 16%
Vanguard Short-Term Inflation-Protected
Securities Index Fund
0% 0% 0% 0% 7% 14% 17%
Generally 40% of total equity exposure will be dedicated to international equity and 30% of total fixed income exposure will be dedicated to international fixed income. TIPS are capped at 30% of U.S. fixed income exposure.
* These represent target allocations. Actual asset allocations generally may vary +/- five (5) percentage points from these targets.
28 TRUST MEMORANDUM:
VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT 2040 TRUST II
Vanguard Fiduciary Trust Company (the “Trustee”) hereby amends and restates, effective as of October 1, 2011, the Vanguard Fiduciary Trust Company Target Retirement 2040 Trust II (the “Trust”). The terms of the Trust shall consist of this Trust Memorandum and the Consolidated Declaration of Trust for the Vanguard Fiduciary Trust Company Target Retirement Trusts II (“Consolidated Declaration”), which is incorporated herein by reference.
In furtherance of its investment objective as described in Article III of the Consolidated Declaration, the Trust shall be invested primarily in the Vanguard Fiduciary Trust Company Target Retirement 2040 Master Trust with the objective of creating a diversified portfolio of open -end investment companies, as further described in Appendix A hereto.
IN WITNESS WHEREOF, Vanguard Fiduciary Trust Company has caused this Trust Memorandum to be executed by its duly authorized officers this 21st day of September, 2011.
VANGUARD FIDUCIARY TRUST COMPANY
By: /s/ Heidi Stam
Senior Vice President & General Counsel
Attest: /s/ Michael Kimmel
Secretary
29 Appendix A
VFTC Target Retirement 2040 Trusts (Master, I, II, III, Plus, Select) Target Allocation Ranges*
Effective September 1, 2021
2015 2020 2025 2030 2035 2040 2045 2050 &
After
Vanguard Total Stock Market Index
Fund
54% 50% 46% 41% 37% 31% 22% 18%
Vanguard Total International Stock
Market Index Trust II
36% 33% 30% 27% 24% 20% 15% 12%
Vanguard Total Bond Market II
Index Fund
7% 12% 17% 22% 27% 29% 34% 37%
Vanguard Total International Bond
Market Index II Fund
3% 5% 7% 10% 12% 13% 15% 16%
Vanguard Short-Term Inflation
Protected Securities Index Fund
0% 0% 0% 0% 0% 7% 14% 17%
Generally 40% of total equity exposure will be dedicated to international equity and 30% of total fixed income exposure will be dedicated to international fixed income. TIPS are capped at 30% of U.S. fixed income exposure.
* These represent target allocations. Actual asset allocations generally may vary +/- five (5) percentage points from these targets.
30 TRUST MEMORANDUM:
VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT 2045 TRUST II
Vanguard Fiduciary Trust Company (the “Trustee”) hereby amends and restates, effective as of October 1, 2011, the Vanguard Fiduciary Trust Company Target Retirement 2045 Trust II (the “Trust”). The terms of the Trust shall consist of this Trust Memorandum and the Consolidated Declaration of Trust for the Vanguard Fiduciary Trust Company Target Retirement Trusts II (“Consolidated Declaration”), which is incorporated herein by reference.
In furtherance of its investment objective as described in Article III of the Consolidated Declaration, the Trust shall be invested primarily in the Vanguard Fiduciary Trust Company Target Retirement 2045 Master Trust with the objective of creating a diversified portfolio of open -end investment companies, as further described in Appendix A hereto.
IN WITNESS WHEREOF, Vanguard Fiduciary Trust Company has caused this Trust Memorandum to be executed by its duly authorized officers this 21st day of September, 2011.
VANGUARD FIDUCIARY TRUST COMPANY
By: /s/ Heidi Stam
Senior Vice President & General Counsel
Attest: /s/ Michael Kimmel
Secretary
31 Appendix A
VFTC Target Retirement 2045 Trusts (Master, I, II, III, Plus, Select) Target Allocation Ranges*
Effective September 1, 2021
2015 2020 2025 2030 2035 2040 2045 2050 2055 &
after
Vanguard Total Stock
Market Index Fund
54% 54% 50% 46% 41% 37% 31% 22% 18%
Vanguard Total International
Stock Market Index Trust II
36% 36% 33% 30% 27% 24% 20% 15% 12%
Vanguard Total Bond Market
II Index Fund
7% 7% 12% 17% 22% 27% 29% 34% 37%
Vanguard Total International
Bond Market Index II Fund
3% 3% 5% 7% 10% 12% 13% 15% 16%
Vanguard Short-Term
Inflation Protected Securities
Index Fund
0% 0% 0% 0% 0% 0% 7% 14% 17%
Generally 40% of total equity exposure will be dedicated to international equity and 30% of total fixed income exposure will be dedicated to international fixed income. TIPS are capped at 30% of U.S. fixed income exposure.
* These represent target allocations. Actual asset allocations generally may vary +/- five (5) percentage points from these targets.
32 TRUST MEMORANDUM:
VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT 2050 TRUST II
Vanguard Fiduciary Trust Company (the “Trustee”) hereby amends and restates, effective as of October 1, 2011, the Vanguard Fiduciary Trust Company Target Retirement 2050 Trust II (the “Trust”). The terms of the Trust shall consist of this Trust Memorandum and the Consolidated Declaration of Trust for the Vanguard Fiduciary Trust Company Target Retirement Trusts II (“Consolidated Declaration”), which is incorporated herein by reference.
In furtherance of its investment objective as described in Article III of the Consolidated Declaration, the Trust shall be invested primarily in the Vanguard Fiduciary Trust Company Target Retirement 2050 Master Trust with the objective of creating a diversified portfolio of open -end investment companies, as further described in Appendix A hereto.
IN WITNESS WHEREOF, Vanguard Fiduciary Trust Company has caused this Trust Memorandum to be executed by its duly authorized officers this 21st day of September, 2011.
VANGUARD FIDUCIARY TRUST COMPANY
By: /s/ Heidi Stam
Senior Vice President & General Counsel
Attest: /s/ Michael Kimmel
Secretary
33 Appendix A
VFTC Target Retirement 2050 Trusts (Master, I, II, III, Plus, Select) Target Allocation Ranges*
Effective September 1, 2021
2015 2020 2025 2030 2035 2040 2045 2050 2055 2060 &
after
Vanguard Total Stock
Market Index Fund
54% 54% 54% 50% 46% 41% 37% 31% 22% 18%
Vanguard Total International
Stock Market Index Trust II
36% 36% 36% 33% 30% 27% 24% 20% 15% 12%
Vanguard Total Bond Market
II Index Fund
7% 7% 7% 12% 17% 22% 27% 29% 34% 37%
Vanguard Total International
Bond Market Index II Fund
3% 3% 3% 5% 7% 10% 12% 13% 15% 16%
Vanguard Short-Term
Inflation Protected Securities
Index Fund
0% 0% 0% 0% 0% 0% 0% 7% 14% 17%
Generally 40% of total equity exposure will be dedicated to international equity and 30% of total fixed income exposure will be dedicated to international fixed income. TIPS are capped at 30% of U.S. fixed income exposure.
* These represent target allocations. Actual asset allocations generally may vary +/- five (5) percentage points from these targets.
34 TRUST MEMORANDUM:
VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT 2055 TRUST II
Vanguard Fiduciary Trust Company (the “Trustee”) hereby amends and restates, effective as of October 1, 2011, the Vanguard Fiduciary Trust Company Target Retirement 2055 Trust II (the “Trust”). The terms of the Trust shall consist of this Trust Memorandum and the Consolidated Declaration of Trust for the Vanguard Fiduciary Trust Company Target Retirement Trusts II (“Consolidated Declaration”), which is incorporated herein by reference.
In furtherance of its investment objective as described in Article III of the Consolidated Declaration, the Trust shall be invested primarily in the Vanguard Fiduciary Trust Company Target Retirement 2055 Master Trust with the objective of creating a diversified portfolio of open -end investment companies, as further described in Appendix A hereto.
IN WITNESS WHEREOF, Vanguard Fiduciary Trust Company has caused this Trust Memorandum to be executed by its duly authorized officers this 21st day of September, 2011.
VANGUARD FIDUCIARY TRUST COMPANY
By: /s/ Heidi Stam
Senior Vice President & General Counsel
Attest: /s/ Michael Kimmel
Secretary
35 Appendix A
VFTC Target Retirement 2055 Trusts (Master, I, II, III, Plus, Select) Target Allocation Ranges*
Effective September 1, 2021
2015 2020 2025 2030 2035 2040 2045 2050 2055 2060 &
after
Vanguard Total Stock
Market Index Fund
54% 54% 54% 50% 46% 41% 37% 31% 22% 18%
Vanguard Total International
Stock Market Index Trust II
36% 36% 36% 33% 30% 27% 24% 20% 15% 12%
Vanguard Total Bond Market
II Index Fund
7% 7% 7% 12% 17% 22% 27% 29% 34% 37%
Vanguard Total International
Bond Market Index II Fund
3% 3% 3% 5% 7% 10% 12% 13% 15% 16%
Vanguard Short-Term
Inflation Protected Securities
Index Fund
0% 0% 0% 0% 0% 0% 0% 7% 14% 17%
Generally 40% of total equity exposure will be dedicated to international equity and 30% of total fixed income exposure will be dedicated to international fixed income. TIPS are capped at 30% of U.S. fixed income exposure.
* These represent target allocations. Actual asset allocations generally may vary +/- five (5) percentage points from these targets.
36 TRUST MEMORANDUM:
VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT 2060 TRUST II
Vanguard Fiduciary Trust Company (the “Trustee”) hereby establishes, effective as of October 1, 2011, the Vanguard Fiduciary Trust Company Target Retirement 2060 Trust II (the “Trust”). The terms of the Trust shall consist of this Trust Memorandum and the Consolidated Declaration of Trust for the Vanguard Fiduciary Trust Company Target Retirement Trusts II (“Consolidated Declaration”), which is incorporated herein by reference.
In furtherance of its investment objective as described in Article III of the Consolidated Declaration, the Trust shall be invested primarily in the Vanguard Fiduciary Trust Company Target Retirement 2060 Master Trust with the objective of creating a diversified portfolio of open -end investment companies, as further described in Appendix A hereto.
IN WITNESS WHEREOF, Vanguard Fiduciary Trust Company has caused this Trust Memorandum to be executed by its duly authorized officers this 21st day of September, 2011.
VANGUARD FIDUCIARY TRUST COMPANY
By: /s/ Heidi Stam
Senior Vice President & General Counsel
Attest: /s/ Michael Kimmel
Secretary
37 Appendix A
VFTC Target Retirement 2060 Trusts (Master, I, II, III, Plus, Select) Target Allocation Ranges*
Effective September 1, 2021
2015 2020 2025 2030 2035 2040 2045 2050 2055 2060 &
after
Vanguard Total Stock
Market Index Fund
54% 54% 54% 50% 46% 41% 37% 31% 22% 18%
Vanguard Total International
Stock Market Index Trust II
36% 36% 36% 33% 30% 27% 24% 20% 15% 12%
Vanguard Total Bond Market
II Index Fund
7% 7% 7% 12% 17% 22% 27% 29% 34% 37%
Vanguard Total International
Bond Market Index II Fund
3% 3% 3% 5% 7% 10% 12% 13% 15% 16%
Vanguard Short-Term
Inflation Protected Securities
Index Fund
0% 0% 0% 0% 0% 0% 0% 7% 14% 17%
Generally 40% of total equity exposure will be dedicated to international equity and 30% of total fixed income exposure will be dedicated to international fixed income. TIPS are capped at 30% of U.S. fixed income exposure.
* These represent target allocations. Actual asset allocations generally may vary +/- five (5) percentage points from these targets.
38 TRUST MEMORANDUM:
VANGUARD FIDUCIARY TRUST COMPANY TARGET RETIREMENT 2065 TRUST II
Vanguard Fiduciary Trust Company (the “Trustee”) hereby establishes, effective as of July 1, 2017, the Vanguard Fiduciary Trust Company Target Retirement 2065 Trust II (the “Trust”). The terms of the Trust shall consist of this Trust Memorandum and the Consolidated Declaration of Trust for the Vanguard Fiduciary Trust Company Target Retirement Trusts II (“Consolidated Declaration”), which is incorporated herein by reference.
In furtherance of its investment objective as described in Article III of the Consolidated Declaration, the Trust shall be invested primarily in units of the Vanguard Fiduciary Trust Company Target Retirement 2055 Master Trust with the objective of creating a diversified portfolio of open-end investment companies, as further described in Appendix A hereto.
IN WITNESS WHEREOF, Vanguard Fiduciary Trust Company has caused this Trust Memorandum to be executed by its duly authorized officers this 14 th day of November, 2016.
VANGUARD FIDUCIARY TRUST COMPANY
By: /s/ Anne Robinson
Senior Vice President & General Counsel
Attest: /s/ Marc Lindsay
Secretary
(CORPORATE SEAL)
39 Appendix A
VFTC Target Retirement 2065 Trusts
Target Allocation Ranges*
Effective September 1, 2021
2015 2020 2025 2030 2035 2040 2045 2050 2055 2060 2065 2070 & after
Vanguard Total
Stock Market Index
54% 54% 54% 54% 54% 54% 46% 41% 37% 31% 22% 18%
Vanguard Total
International Stock
Market Index Trust II
36% 36% 36% 36% 36% 36% 30% 27% 24% 20% 15% 12%
Vanguard Total
Bond Market II
Index Fund
7% 7% 7% 7% 7% 7% 17% 22% 27% 29% 34% 37%
Vanguard Total
International Bond
Market Index II
Fund
3% 3% 3% 3% 3% 3% 7% 10% 12% 13% 15% 16%
Vanguard Short-
Term Inflation
Protected Securities
Index Fund
0% 0% 0% 0% 0% 0% 0% 0% 0% 7% 14% 17%
Generally 40% of total equity exposure will be dedicated to international equity and 30% of total fixed income exposure will be dedicated to international fixed income. TIPS are capped at 30% of U.S. fixed income exposure.
* These represent target allocations. Actual asset allocations generally may vary +/- five (5) percentage points from these targets.
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