Disclosure Assist User Guide: Creating and delivering your annual fee disclosures

Transcription

1 Disclosure Assist User Guide: Creating and delivering your annual fee disclosures July 2017 Note: TIAA cannot and does not offer legal advice and we recommend that you consult with your own legal advisors for such advice. For institutional investor use only. Not for use with or distribution to the general public.

2 Table of contents Compliance with your annual participant fee disclosures 2 Section One Disclosure Assist Overview 3 Customization features 3 QDIA plan-related notices 4 Your delivery options 4 Your participant delivery file 5 Information for plans with multiple service providers 5 Section Two Instructions for creating your participant disclosure (Plan and Investment Notice) Getting Started: Access Disclosure Assist 6 Option 1: Self-delivery 7 Option 2: Self-delivery + online access 8 Option 3: TIAA delivery assistance + online access 14 Section Three Additional resources for TIAA delivery assistance option Participant delivery file instructions 23 Participant delivery file specifications 24 Participant disclosure delivery schedule 25 Participant edelivery Recommended best practice 25 Frequently asked questions about undeliverable or returned disclosures 26 1 Disclosure Assist User Guide: Annual fee disclosures

3 Compliance with your annual participant fee disclosures The Department of Labor (DOL) established regulation section 404a-5 which requires plan sponsors to send plan- and invested-related information annually to all eligible plan participants, including terminated participants that have account balances. TIAA offers Disclosure Assist, an online tool, to assist in the creation and delivery of your participant Plan and Investment Notice, which includes two sections: Section I: Summary of Plan Services and Costs Section II: Investment Options Comparative Chart The information contained in this guide will help you: Understand how Disclosure Assist can help you meet the annual disclosure requirement Develop a participant delivery file accurately and thoroughly Complete the process of providing plan and investment information successfully Your disclosure deadline is 14 months Annual notices must be sent to participants at least once in any 14-month period, regardless of whether your plan operates on a calendar or fiscal year basis. For example, if you delivered last year s notices on June 1, 2016, you are required to send the 2017 notices by August 1, Familiarize yourself with the participant disclosure deadline. 2 Disclosure Assist User Guide: Annual fee disclosures

4 Section One Disclosure Assist Overview Disclosure Assist is TIAA s online tool that allows you to manage, create and distribute your annual fee disclosure notices and Qualified Default Investment Alternative (QDIA) plan-related notices. By using this tool for your annual fee disclosure notices, you can: Choose the level of service that best meets your needs: Self-delivery or TIAA delivery assistance Access historical disclosure documents and their published dates for all of your plans recordkept by TIAA for the last seven years Customize the plan name displayed on your disclosures, update the cover letter with your own return address, your institution s logo and unique messaging, and add a unique signature and closing Aggregate other service provider information, if applicable, to create consolidated disclosures Review your plan s participant data file, which identifies all the participants TIAA has on record Coordinate the distribution of your disclosures to all eligible participants and beneficiaries and track the delivery status Best in Class Our participant fee disclosures, produced through Disclosure Assist, were named Best in Class in the 2013, 2014 and 2016 PlanSponsor Defined Contribution Surveys.* The step-by-step instructions on the following pages will guide you through the creation, review and delivery of your annual plan- and investment-related information (Plan and Investment Notice) from start to finish. Customization features Disclosure Assist offers features to better connect Plan Sponsors with their participants. You now have the ability to customize your participant notices so the information is coming from you, the employer. You can: Update the way your plan name appears on your Plan and Investment Notice Create a custom cover letter with your own personalized closing, signature, and logo. You can select from the TIAA logo, your institution s logo or no logo at all. A customized return address helps manage any returned mail and helps ensure that your records are up-to-date. * Best in Class recognition is based on results from the 2013, 2014 and 2016 PlanSponsor Defined Contribution Survey, PlanSponsor Magazine, November 2013, 2014 and This annual survey is considered to be one of the retirement industry s leading indicators of institution satisfaction with their service providers and the participant services offered by their providers. 3 Disclosure Assist User Guide: Annual fee disclosures

5 Create and deliver your QDIA plan-related participant notices In addition to the annual participant fee disclosure requirement, the Department of Labor also requires ERISA plan sponsors to provide notices about plan-related changes and other important plan information to employees. Plans with TIAA s Qualified Default Investment Alternative (QDIA) Service can now use Disclosure Assist to create and deliver their required QDIA notices to participants who don t have an account with TIAA. For participants that are recordkept by TIAA, we automatically deliver the QDIA notices. The new feature allows sponsors to: View sample QDIA notices such as the Initial QDIA, Ongoing Initial and Annual Select their preferred delivery method: self-delivery or TIAA delivery-assistance Track delivery to participants Access history of completed notices To learn more, refer to the Disclosure Assist User Guide: Creating and delivering participant notices. Your delivery options Through Disclosure Assist, we offer different delivery options from do-it-yourself to full delivery assistance. This flexibility enables you to choose the level of assistance that best meets your plan s needs. The chart below highlights the three available options. Delivery options Option Description Option 1: Self-delivery Refer to page 7 You are responsible for downloading the Plan and Investment Notice prepared by TIAA and delivering it to your participants. Option 2: Self-delivery + online access Refer to page 8 Same as self-delivery with these added features: Ability to aggregate plan and investment information from multiple service providers Ability to post the disclosure online at TIAA.org Option 3: TIAA delivery assistance + online access Refer to page 14 TIAA delivers the Plan and Investment Notice to all of your eligible participants on your behalf. It also offers the following features: Aggregate plan and investment information from multiple service providers Customize your disclosures plan name and cover letter Post the disclosure online at TIAA.org Preparing your file If you plan to use TIAA delivery assistance, additional details and step-by-step instructions for creating your participant delivery file can be found on page 23 of this guide. Best option when: You want to manage the delivery process or are working with another service provider who may be consolidating information from multiple providers. You want to manage the delivery process and also want your participants to have online access to the information. You want the ability to update your Plan and Investment Notice midway through the year and post the most current information on TIAA.org for your participants. You want to update the name that is displayed on your Plan and Investment Notice and customize the cover letter for your participants. You want TIAA to distribute the disclosure for you. Note: TIAA delivery assistance is only available once per year. You are responsible for delivering any additional disclosures, as needed. 4 Disclosure Assist User Guide: Annual fee disclosures

6 Your participant delivery file No matter which delivery option you select, the file should include all employees who are required to receive the notice, including those who are: Actively participating in your plan (lists are available from TIAA and your other service providers, if applicable) Eligible, but not participating in the plan Terminated and still have an account balance in the plan Information for plans with multiple service providers Disclosure Assist enables you to aggregate information from other service providers into one disclosure, allowing your participants to make more meaningful comparisons. If you have multiple providers, you will need the following information: Other service provider information The service provider(s) contact information will be displayed on the Investment Options Comparative Chart and fulfills the obligation to provide participants a source for additional investment-related information. Note: If you plan to use TIAA delivery assistance, download, create/edit and save your participant delivery file when you begin the process. Refer to pages 23 and 24 of this guide for more information on how to create a file with all the information needed to deliver your disclosures. The contact information you provide for your other service provider(s) will complete the following sentence: To request additional plan information from <insert provider name> or a paper copy of information available online, free of charge, contact <insert contact information/address/phone/web>:. In addition you should provide a website address where additional investment-related information (including more current performance) can be found. Ticker and/or CUSIP numbers from other service providers Having the ticker and/or CUSIP numbers will allow for easier entry of your mutual fund information, but you ll need to manually enter this information for the plan s variable annuities and other non-mutual fund investment options. TIAA Plan and Investment Notice This notice includes two sections: Summary of Plan Services and Costs and Investment Options Comparative Chart. You can use our disclosure as a template for consolidating your other provider information. This document is available on the Plan Selection page in Disclosure Assist. 5 Disclosure Assist User Guide: Annual fee disclosures

7 Section Two Instructions for creating your annual participant disclosure (Plan and Investment Notice) The process for creating your participant disclosure depends on which delivery option you choose. Getting Started: Access Disclosure Assist 1. Log on to PlanFocus, the TIAA secure plan sponsor website 2. Go to the Compliance tab 3. Select Disclosure Assist 4. Choose Annual Fee Disclosures 5. Choose the applicable plan This guide provides more detailed step-by-step instructions for each of the three delivery options. Please contact your client services manager or relationship manager if you don t see the Disclosure Assist option. If your plan is serviced by the Administrator Telephone Center, you can speak with one of our experienced consultants at , weekdays, 8 a.m. to 8 p.m. (ET). 6 Disclosure Assist User Guide: Annual fee disclosures

8 Option 1: Self-delivery It s your responsibility to download the Plan and Investment Notice prepared by TIAA and for delivering it to your participants. Step 1 Select which delivery option best meets your needs. If you used Option 1 last year, it will be highlighted in blue. You can select a different option at this time if you like. If you want to change your option, select your preferred delivery option and click Choose to continue. Then, go to the instructions for your new delivery option to continue creating your disclosure. Step 2 View and download the Plan and Investment Notice. Access and download your participant data file, which contains eligible participants (including terminated participants) with an account balance at TIAA. This is the starting point for creating/editing the file that is needed to distribute your annual disclosure. You can download the TIAA sample cover letter and use it to notify participants that the Plan and Investment Notice is available. You are now ready to distribute your Plan and Investment Notice using your participant data file. You can return to the main Disclosure Assist screen (where you can find all of your eligible ERISA plans). Quick tips: As a best practice, you should download, create/edit and save your participant delivery file at the start of the process. Quarter-end performance for variable-return investments is updated on or around the tenth business day after the end of each quarter and is only available with Delivery Options 2 and 3. Please contact your client services manager or the Administrator Telephone Center for more information. You can find historical disclosures and their publish dates under the section titled View/Download Disclosure History. This historical information will be retained for seven years. 7 Disclosure Assist User Guide: Annual fee disclosures

9 Option 2: Self-delivery + online access You are responsible for downloading the Plan and Investment Notice prepared by TIAA and for delivering it to your participants. In addition, you can aggregate plan and investment information from multiple service providers and post your disclosure online at TIAA.org. Step 1 Select which delivery option best meets your needs. If you used Option 2 last year, it will be highlighted in blue. You can select a different option at this time if you like. If you want to change your delivery option, select your preferred delivery option and click Choose to continue. Then, go to the instructions for your new delivery option to continue creating your disclosure. Step 2 Scroll down to view and download the Plan and Investment Notice. Access and download your participant delivery file, which contains eligible participants (including terminated participants) with an account balance at TIAA. This is the starting point for creating/editing the file that is needed to distribute your annual disclosure. Scroll up and select Continue to Set Up. Quick tips: As a best practice, you should download, create/edit and save your participant delivery file at the start of the process. You can use our sample letter to notify participants that the Plan and Investment Notice is available. You can find historical disclosures and their publish dates under the section titled View/Download Disclosure History. This historical information will be retained for seven years. You can move between screens using the navigation bar. 8 Disclosure Assist User Guide: Annual fee disclosures

10 Step 3 Answer the question, Does this plan have assets with other retirement service providers? If no, complete Steps 4-6. If yes, complete Steps Step 4 Review and edit TIAA service provider information that can be found in Section II: Investment Options Comparative Chart of the Plan and Investment Notice. Then, click Save & Continue. TIAA contact information is provided to participants by the majority of our clients to allow them to request additional information about the plan s investment options, obtain prospectuses and financial statements or lists of portfolio assets. However, this contact information can be changed if you choose. Step 5 Preview the Plan and Investment Notice and check the Service Agreement box. Then, click Publish Disclosure. Important: Once you publish your disclosure, no changes can be made. Quarter-end performance for variable-return investments is updated on or around the tenth business day after the end of each quarter. For example, first-quarter performance will be available in mid-april and second-quarter performance will be available in mid-july. 9 Disclosure Assist User Guide: Annual fee disclosures

11 Step 6 View your delivery confirmation and instructions that are relevant for your disclosure. Then, print the confirmation page for your records. Since TIAA is your exclusive service provider, this completes the creation process and you are now ready to distribute your Plan and Investment Notice using your participant delivery file. Your disclosure will be available on TIAA.org within three days. You can return to the main Disclosure Assist screen (where you can find all of your eligible ERISA plans) to begin the process for any additional plans. If your employees ask about how they can locate their disclosures, here are the three simple steps: 1. Go to the Research & Performance section at TIAA.org 2. Select Retirement Investment Performance 3. Select the plan name from the drop-down menu and the notice will appear under Helpful Links Reminder: You only need to complete Steps 7-11 if the plan has assets recordkept by other service providers. Step 7 Review and edit TIAA and your other service providers contact information, including their addresses and phone numbers. Then, click Save & Continue. If you used Disclosure Assist last year, the information you provided was saved. Please review this information and update as necessary. The contact information for your plan s other service providers is necessary so participants can request additional information about the plan s investment options. 10 Disclosure Assist User Guide: Annual fee disclosures

12 Step 8 Add plan-related information from all other providers. This information will be included in Section I: Summary of Plan Services and Costs of the Plan and Investment Notice. To add the information, choose the appropriate Heading from the pull-down menu, and then either copy and paste or type the applicable text from each provider s disclosures. Click Save after you have finished entering the information. Then click Save & Continue. Quick tips: If you used Disclosure Assist last year, the information you provided was saved. Please review this information and update as necessary. Keep your other providers disclosures handy to use as a reference when completing this step. The headings in the pull-down menu align with specific DOL content requirements. While your other service providers may use different headings, we suggest aligning the information to the headings in our pull-down menu for consistency and a better participant experience. If you are entering a significant amount of information, you should periodically click SAVE so you don t lose your work if the system times you out. Step 9 Add information for the investment options that have recordkeeping services by other service providers by entering the ticker symbol or CUSIP number for each investment option. Manually enter the information for any investment options that do not have a ticker symbol or CUSIP number. Enter footnotes for all investment options as needed. Once the data is entered, click Save, then Preview Report to view your entire Plan and Investment Notice. After you are done reviewing, close the report, make any necessary changes and click Save & Continue. 11 Disclosure Assist User Guide: Annual fee disclosures

13 Quick tips: If you used Disclosure Assist last year, the information you provided was saved. Please review this information and update as necessary. Keep your other providers disclosures handy to use as a reference when completing this step. If you enter any data manually, make sure the performance information is for the same time period as the performance figures automatically provided. Quarter-end performance for variable-return investments is updated on or around the tenth business day after the end of each quarter. For example, first-quarter performance will be available in mid-april and second-quarter performance will be available in mid-july. Ticker and/or CUSIP numbers will allow for easier entry of your mutual fund investment information only. You will need to manually enter the investment information for the plan s variable annuities and other non-mutual fund investment options. If you are entering a significant amount of information, you should periodically click SAVE so you don t lose your work if the system times you out. Step 10 Preview the Plan and Investment Notice and check the Service Agreement box. Then, click Publish Disclosure. Important: Once you publish your disclosure, no changes can be made. If there are investment and/or plan-related changes after your annual disclosure has been sent, you may want to update the disclosure information using Option 2 and then direct your participants to TIAA.org to view current fees, expenses and/or performance information. Additional investment information including expense ratio and other fund-specific fees, such as redemption fees, can be found in the prospectus at TIAA.org/performance. 12 Disclosure Assist User Guide: Annual fee disclosures

14 Step 11 View your delivery confirmation and instructions that are relevant for your disclosure. Then, print the confirmation page for your records. This completes the creation process and you are now ready to distribute your Plan and Investment Notice using your participant delivery file. Your disclosure will be available on TIAA.org within three days. You can return to the main Disclosure Assist screen (where you can find all of your eligible ERISA plans) to begin the process for any additional plans. Your employees can locate their disclosures in three simple steps: 1. Go to the Research & Performance section at TIAA.org 2. Select Retirement Investment Performance 3. Select the plan name from the drop-down menu and the notice will appear under Helpful Links 13 Disclosure Assist User Guide: Annual fee disclosures

15 Option 3: TIAA delivery assistance + online access TIAA will deliver the Plan and Investment Notice to all of your eligible participants on your behalf. In addition, you can aggregate plan and investment information from multiple service providers and post your disclosure online at TIAA.org. Reminder: To help ensure your Plan and Investment Notice is successfully delivered to work addresses, refer to page 25 for more details. With this delivery option, you have the ability to customize the Plan Name that appears on your Plan and Investment Notice, and create a custom cover letter. You can update the content within the body of the letter to include your own messaging, insert a custom signature and closing and add your institution s logo. Step 1 Select which delivery option best meets your needs. If you used Option 3 last year, it will be highlighted in blue for you. If you want to change your option, select your preferred delivery option and click Choose to continue. Then, go to the instructions for your new delivery option to continue creating your disclosures. You can move between screens using the navigation bar. Step 2 Scroll down to view and download the Plan and Investment Notice. Access and download your participant delivery file, which contains eligible participants (including terminated participants) with an account balance at TIAA. This is the starting point for creating/editing the file that is needed to distribute your annual disclosure. Scroll up and select Continue to Set Up. Quick tips: As a best practice, you should download, create/edit and save your participant delivery file at the start of the process. You can use our sample letter to notify participants that the Plan and Investment Notice is available. You can find historical disclosures and their publish dates under the section titled View/Download Disclosure History. This historical information will be retained for seven years. 14 Disclosure Assist User Guide: Annual fee disclosures

16 Step 3 You can update the way your Plan Name is displayed on your Plan and Investment Notice, and create a custom cover letter to accompany your Plan and Investment Notice. You will be able to preview the cover letter before finalizing. Step 3A Review the Plan Name that will appear on your Plan and Investment Notice. Click edit to make any changes. Step 3B Review and edit the following information to create your custom letter. Once finished, click Save, and then review your cover letter by clicking Preview. Once you are satisfied with how your cover letter appears, click Save & Continue. Return Address any returned disclosures will be sent to this address Select one of the available logo options the TIAA logo, your own institution s logo (if currently available) or no logo Edit the standard language that is included on the cover letter Optional signature add your personalized closing and signature. Then select your preferred style Quick tips: The content in Sections A and B have character limitations. You can only display 110 characters per line with a total of 16 lines. If you exceed the limit, your content will be truncated and will not display correctly on your cover letter. Always preview the cover letter for typos and spelling errors. If there isn t an institution s logo on file, a message will be shown notifying plan sponsors that their logo is currently unavailable, and to call their client services manager or the Administrator Telephone Center who will work with them to upload their logo to PlanFocus. Please note that it takes approximately three weeks to load a logo into PlanFocus. Step 4 Answer the question, Does this plan have assets with other retirement service providers? If no, complete Steps 5-8. If yes, complete Steps Disclosure Assist User Guide: Annual fee disclosures

17 Step 5 Review and edit TIAA Service Provider information that will appear in Section II: Investment Options Comparative Chart of the Plan and Investment Notice. Then, click Save & Continue. TIAA contact information is provided to participants by the majority of our clients to allow them to request additional information about the plan s investment options, obtain prospectuses and financial statements or lists of portfolio assets. However, this contact information can be changed if you choose. Step 6 One of two delivery options is available for your plan: TIAA delivery to all participants TIAA delivery to terminated participants only If you want delivery to all participants, follow Step 6A. If you want to deliver to terminated participants only, follow Step 6B. Step 6A Select TIAA delivery to all participants and upload your participant delivery file. Refer to page 23 for step-by-step instructions to create your delivery file. Then click Save & Continue. You have two options to access your participant delivery file: Click the Download File Template button to create your own participant file using the blank template provided. Click TIAA s participant data file to use a prepopulated file that contains postal addresses for all active participants and terminated participants with a balance that TIAA has on file. We will not deliver disclosures to terminated participants that do not have a balance in their account. Note: Any changes made to your participant delivery file impact only this communication. You are still responsible to notify TIAA of any participant changes (i.e., address, status, etc.). 16 Disclosure Assist User Guide: Annual fee disclosures

18 After you have successfully uploaded your participant delivery file, you can view a date/time stamp by hovering your mouse over the File Uploaded link. This shows the date and time of the last file uploaded into the system and allows you to view the participant data that was uploaded. Quick tips: As a best practice, you should download, create/edit and save your participant delivery file at the start of the process. If there is an error in your participant delivery file, you will receive a message stating the reason and the location of the error that needs to be corrected. The validation error message will be displayed in red at the top of the page. Refer to the participant delivery file specifications on page 24 for additional information. Step 6B Select TIAA delivery to terminated participants only. Then click Save & Continue. If you select this option, TIAA will only deliver the Plan and Investment Notice to the terminated participants that are included in the participant delivery file you uploaded. The Delivery Audit Report will include the delivery status of the disclosures. You are responsible for distributing the information to all other participants and eligible employees. Step 7 Preview the Plan and Investment Notice and check the Service Agreement box. Then, click Publish Disclosure. Important: Once you publish your disclosure, no changes can be made. If there are investment and/or plan-related changes after your annual disclosures have been sent, you may also want to update the disclosure information using Option 2 (see page 8) and then direct your participants to TIAA.org to view current fees, expenses and/or performance information. Additional investment information including expense ratio and other fund-specific fees, such as redemption fees, can be found in the prospectus at TIAA.org/performance. 17 Disclosure Assist User Guide: Annual fee disclosures

19 Step 8 View your delivery confirmation and instructions that are relevant for your disclosure. Then, print the confirmation page for your records. This completes the creation process and your Plan and Investment Notice will be distributed to all required employees within 30 calendar days after you publish it. The disclosure will also be available on TIAA.org within three days. You can return to the main Disclosure Assist screen (where you can find all of your eligible ERISA plans) to begin the process for any additional plans. If your employees ask about how they can locate their disclosures, here are the three simple steps: 1. Go to the Research & Performance section at TIAA.org 2. Select Retirement Investment Performance 3. Select the plan name from the drop-down menu and the notice will appear under Helpful Links Reminder: You only need to complete Steps 9-14 if the plan has assets recordkept by other service providers. Step 9 Review and edit TIAA and your other service providers contact information, including their addresses and phone numbers. Then, click Save & Continue. TIAA contact information is provided to participants by the majority of our clients to allow them to request additional information about the plan s investment options, obtain prospectuses and financial statements or lists of portfolio assets. However, this contact information can be changed if you choose. 18 Disclosure Assist User Guide: Annual fee disclosures

20 Step 10 Add plan-related information from all other providers. This information will be included in Section I: Summary of Plan Services and Costs of the Plan and Investment Notice. To add the information, choose the appropriate Heading from the pull-down menu, and then either copy and paste or type the applicable text from each providers disclosures. Click Save after you have finished entering the information. Then click Save & Continue. Quick tips: If you used Disclosure Assist last year, the information you provided was saved. Please review this information and update as necessary. Keep your other providers disclosures handy to use as a reference when completing this step. The headings in the pull-down menu align with specific DOL content requirements. While your other service providers may use different headings, we suggest aligning the information to the headings in our pull-down menu for consistency and a better participant experience. If you are entering a significant amount of information, you should periodically click SAVE so you don t lose your work if the system times you out. Step 11 Add information for the investment options with recordkeeping services performed by other service providers by entering the ticker symbol or CUSIP number for each investment option. Manually enter the information for any investment options that do not have a ticker symbol or CUSIP number. Enter footnotes for all investment options as needed. Once the data is entered, click Save, then Preview Report to view your entire Plan and Investment Notice. After you are done reviewing, close the report, make any necessary changes and click Save & Continue. 19 Disclosure Assist User Guide: Annual fee disclosures

21 Quick tips: If you used Disclosure Assist last year, the information you provided was saved. Please review this information and update as necessary. Keep your other providers disclosures handy to use as a reference when completing this step. If you enter any data manually, make sure the performance information is for the same time period as the performance figures automatically provided. Quarter-end performance for variable-return investments is updated on or around the tenth business day after the end of each quarter. For example, first-quarter performance will be available in mid-april and second-quarter performance will be available in mid-july. Ticker and/or CUSIP numbers will allow for easier entry of your mutual fund investment information only. You will need to manually enter the investment information for the plan s variable annuities and other non-mutual fund investment options. If you are entering a significant amount of information, you should periodically click SAVE so you don t lose your work if the system times you out. Step 12 One of two delivery options is available for your plan: TIAA delivery to all participants TIAA delivery to terminated participants only If you want delivery to all participants, follow Step 12A. If you want to deliver to terminated participants only, follow Step 12B. Step 12A Select TIAA delivery to all participants and upload your participant delivery file. Refer to page 23 for step-by-step instructions to create your delivery file. Then click Save & Continue. You have two options to access your participant delivery file: Click the Download File Template button to create your own participant file using the blank template provided. Click TIAA s participant data file to use a prepopulated file that contains postal addresses for all active participants and terminated participants with a balance that TIAA has on file. We will not deliver disclosures to terminated participants that do not have a balance in their account. 20 Disclosure Assist User Guide: Annual fee disclosures

22 Note: Any changes made to your participant delivery file impact only this communication. You are still responsible to notify TIAA of any participant changes (i.e., address, status, etc.). After you have successfully uploaded your participant delivery file, you can view a date/time stamp by hovering your mouse over the File Uploaded link. This latest enhancement shows the date and time of the last file uploaded into the system and allows you to view the participant data that was uploaded. As a best practice, you should download, create/edit and save your participant delivery file at the start of the process. If there is an error in your participant delivery file, you will receive a message stating the reason and the location of the error that needs to be corrected. The validation error message will be displayed in red at the top of the page. Refer to the participant delivery file specifications on page 24 for additional information. Step 12B Select TIAA delivery to terminated participants only. Then click Save & Continue. If you select this option, TIAA will deliver the Plan and Investment Notice only to the terminated participants that are included in the participant delivery file you uploaded. The Delivery Audit Report will include the delivery status of the disclosures. You are responsible for distributing the information to all other participants and eligible employees. 21 Disclosure Assist User Guide: Annual fee disclosures

23 Step 13 Preview the Plan and Investment Notice and check the Service Agreement box. Then, click Publish Disclosure. Important: Once you publish your disclosure, no changes can be made. If there are investment and/or plan-related changes after your annual disclosure has been sent, you may also want to update the disclosure information using Option 2 (see page 8) and then direct your participants to TIAA.org to view current fees, expenses and/or performance information. Additional investment information including expense ratio and other fund-specific fees, such as redemption fees, can be found in the prospectus at TIAA.org/performance. Step 14 View your delivery confirmation and instructions that are relevant for your disclosure. Then, print the confirmation page for your records. This completes the creation process and your Plan and Investment Notice will be distributed to all required employees within 30 calendar days after you publish it. The disclosure will also be available on TIAA.org within three days. You can return to main Disclosure Assist screen (where you can find all of your eligible ERISA plans) to begin the process for any additional plans. If your employees ask about how they can locate their disclosures, here are the three simple steps: 1. Go to the Research & Performance section at TIAA.org 2. Select Retirement Investment Performance 3. Select the plan name from the drop-down menu and the notice will appear under Helpful Links 22 Disclosure Assist User Guide: Annual fee disclosures

24 Section Three Additional resources for TIAA delivery assistance option Participant delivery file instructions If you are using TIAA delivery assistance, we will need current contact information for all employees required to receive the Plan and Investment Notice to help ensure successful delivery. Below are the step-by-step instructions for creating the participant delivery file that you will need to upload into Disclosure Assist. The file specifications are on the following page. Steps to build the delivery file Step Action Quick tip Access and download the TIAA participant delivery data file from Disclosure Assist. Save the file to your computer. Add work addresses for all employees for whom a computer is used as an integral part of their job duties and have the ability to effectively access documents furnished in electronic form at any location where the participant is reasonably expected to perform his or her duties as an employee. Remove participants who do not have access to a computer as part of their job. Add employees who are eligible but not currently participating. If you have other service providers, add employees who do not have accounts with TIAA, but have accounts with these other providers. Save your participant delivery file to your computer. Once your participant file is completed, upload it into Disclosure Assist. Access this file from the bottom of the Delivery Option Selection page in Disclosure Assist. As a best practice, you should download, create/edit and save your participant delivery file at the start of the process. Use this suggested file format: Plan#_PlanYearEnd_FD_Participant_Delivery_File.xls Requirements for using work addresses are outlined in the DOL safe harbor guidelines. We will automatically mail paper disclosures to the addresses on file for these employees unless we have received their approval to receive electronic documents via an alternate address. If an employee meets the DOL safe harbor guidelines for electronic delivery, provide their address. Otherwise, provide their home address. If an employee meets the DOL safe harbor guidelines for electronic delivery, provide their address. Otherwise, provide their home address. Make sure your file: Is saved as an.xls file; other file extensions are not compatible Meets the required file specifications on page 24 of this guide Has the correct 9-digit SSN format under Column C * Does not contain number signs, hyphens, symbols, periods, etc. in any alphanumeric data fields. (See page 24) Does not contain any duplicate records Contains only one worksheet Refer to Step 6A or Step 14A for Delivery Option 3 for more details. * To format the SSN column, use the Excel format cells feature. Select Column C, press Ctrl+1 and go to the Number tab in the dialog box. Select the custom category and enter the format as Click OK to set the format. 23 Disclosure Assist User Guide: Annual fee disclosures

25 Participant delivery file specifications Column Column Name Max Length Data Type Example Required/ Optional Comments A Employer Name 64 Alphanumeric ABC Nonprofit Required The name of the employer B C D E F Employer Plan ID 6 Alphanumeric Required The Employer Plan ID uniquely identifies the Plan on TIAA recordkeeping system. Employee SSN * 9 Numeric Required The participant s SSN will be used to identify the participant. * See page 23 for details. Employee First Name Employee Middle Name Employee Last Name 35 Text John Required Employee first name to be used for fee disclosure, or other purposes as agreed by TIAA and employer. 35 Text B Optional Employee middle name to be used for fee disclosure, or other purposes as agreed by TIAA and employer. 35 Text Sample Required Employee last name to be used for fee disclosure, or other purposes as agreed by TIAA and employer. G Address 1 50 Alphanumeric 123 Central St Required Employee home address H Address 2 50 Alphanumeric Apartment 34 Optional Second address line if needed for employee home address. I Address 3 50 Alphanumeric Optional Third address line if needed for employee home address. City 32 Alphanumeric Somewhere Conditional, Employee city. For foreign addresses, no city is required. J required for employees in U.S. K L M N State 2 Alphanumeric AZ Conditional, required for employees in U.S. Zip 9 Numeric Conditional, or required for employees in U.S. Work Address Employee Plan Status 255 Alphanumeric Jsample@ABS. edu 1 Text E, P, X, N, D, A, T, R Conditional/ Required Optional Employee state. For foreign addresses, enter FN for the state. For APO addresses, enter NA for the state. Employee zip. For foreign addresses, no zip is required. Employee s work address if the employee has access to a computer and a work address as part of their integral job duties (refer to safe harbor details). E = Eligible, not participating P = Eligible and participating (self-elected) X = Excluded class N = Not eligible D = Default enrolled A = Auto enrolled T = Terminated R = Retired Any updates to the Employee Plan Status Code will not change a participant s status in our records. 24 Disclosure Assist User Guide: Annual fee disclosures

26 Participant disclosure delivery schedule Your Plan and Investment Notice will be delivered to your participants within 30 calendar days after you publish it. If you select delivery assistance, we will deliver your required disclosures as follows: Group 1 Group 2 Group 3 All employees with work s listed in the participant delivery file. Employees with a TIAA account and no work . We will deliver the information electronically if we have received affirmative consent from the employee as outlined by the DOL. Otherwise, a paper copy will be sent regular mail to the address on file. Employees with a non-tiaa account and no work . We will send a paper copy regular mail to the address you provided in your participant delivery file. Participant edelivery Recommended best practice Edelivery is the preferred delivery option as it is the fastest and most cost-effective way to distribute the disclosures to your participants. As a reminder, the DOL safe harbor regulations allow you to add work addresses for employees for whom a computer is used as an integral part of their job duties and have the ability to effectively access documents furnished in electronic form at any location where the participant is reasonably expected to perform his or her duties as an employee. In addition, the safe harbor also applies to other participants (e.g., retirees, former employees and active employees who do not use a computer as an integral part of their duties), beneficiaries and other persons entitled to disclosures under Title I of ERISA who affirmatively consent to receiving disclosures through electronic media in the manner prescribed by the regulation. TIAA encourages sending notices to your participants electronically. Not only will this save your organization money, but you won t have the hassle of returned mail. And, there are many benefits for participants such as: Participants receive their notice faster They receive notifications when their notice is available Reduction in paper clutter in participants home and office Participants can change their delivery preference at any time Important notes: Edelivery is the preferred delivery option as it is the fastest and most cost-effective way to distribute the disclosures. If you want to provide your participants with updated disclosures each quarter, you will need to use Option 2: Self-delivery + online access within Disclosure Assist to republish your disclosures to the TIAA website. We will only deliver disclosures to your participants once per year. 25 Disclosure Assist User Guide: Annual fee disclosures

27 Frequently asked questions about undeliverable or returned disclosures As the plan sponsor, you are responsible for making a good faith effort to locate any eligible, participating or terminated employees who have not received the participant disclosure as a result of undeliverable U.S. mail. There are several reasons why the disclosure may be returned as undeliverable, including: The employee has recently moved. The forwarding address has expired. The address on file is not correct. Below are some frequently asked questions to help you understand how the returned to sender mail process works and resources to help you locate a missing participant or beneficiary. 1. Is there a report that shows the delivery method and whether delivery was successful? Yes, you will receive a Delivery Report that includes: A summary of the success rate for each delivery method, including edelivery and hard copy Participant details by delivery method, sorted by delivery status (successful/unsuccessful) and then last name (You can access your Delivery Report online via Disclosure Assist in both pdf and csv (EXCEL) formats and it will be available for seven years>) Participants with an Undeliverable/Bad Address: A disclosure was not mailed as the address on file is invalid; mail was previously returned from that address and TIAA has not received an updated address from the employee or the U.S.P.S. Participants with an Undeliverable/No Address: A disclosure was not mailed as TIAA does not have an address on file 2. What happens to the participant disclosures that are returned as undeliverable? If TIAA has received other mail/communications back from an employee and it has been determined that the address on file is invalid, we will not mail the disclosure. The employee will be listed on the Delivery Report as Undeliverable/Bad Address. It is then your responsibility to deliver the disclosure to the employee. If an employee s address has recently changed, you may receive the returned mail back via the U.S.P.S. and you should follow the instructions mentioned to make sure a good faith effort is followed to notify the employee. Returned mail will be sent back to you via U.S.P.S. to the address you provided when you submitted your request. The Plan Administrator is the default contact. 26 Disclosure Assist User Guide: Annual fee disclosures

28 3. What do I need to do after receiving the returned mail? The DOL does not provide any specific guidance on this issue. It only states that a good faith effort must be made to deliver the disclosures. There are no penalties imposed for undelivered mail, but as a part of your fiduciary process, you should document your efforts to redeliver the disclosures. To help manage your returned mail, consider providing TIAA with work addresses for employees for whom a computer is used as an integral part of their job duties, and who have the ability to effectively access documents furnished in electronic form at any location where the participant is reasonably expected to perform his or her duties as an employee. 4. How can I locate individuals who have mail returned? The DOL suggests a number of options in the Field Assistance Bulletin for locating missing participants and beneficiaries. You can also try: Sending disclosures via certified mail Checking the records of related plans to the extent not precluded by privacy requirements Checking with the designated plan beneficiary Using free electronic search tools 5. How do I make sure that disclosures sent electronically via work s get past my organization s internal firewall? To successfully deliver your notice to work addresses, your system must recognize the From and IP addresses that TIAA uses when delivering the notices. Make sure your IT department has the current information to ensure s are not blocked from TIAA. Refer to the TIAA Delivery Alert for more information. 27 Disclosure Assist User Guide: Annual fee disclosures

29 TIAA is here to help you Disclosure Assist was developed to help make compliance with the fee disclosure regulation as simple as possible for you. If you have any questions about Disclosure Assist, please contact your client services manager or relationship manager. If your plan is serviced by the Administrator Telephone Center, you can speak with one of our experienced consultants at , weekdays, 8 a.m. to 8 p.m. (ET). This material is for informational or educational purposes only and does not constitute a recommendation or investment advice in connection with a distribution, transfer or rollover, a purchase or sale of securities or other investment property, or the management of securities or other investments, including the development of an investment strategy or retention of an investment manager or advisor. This material does not take into account any specific objectives or circumstances of any particular investor, or suggest any specific course of action. Investment decisions should be made in consultation with an investor s personal advisor based on the investor s own objectives and circumstances. TIAA-CREF Individual & Institutional Services, LLC, Teachers Personal Investors Services, Inc., and Nuveen Securities, LLC, Members FINRA and SIPC, distribute securities products Teachers Insurance and Annuity Association of America-College Retirement Equities Fund, 730 Third Avenue, New York, NY For institutional investor use only. Not for use with or distribution to the general public _ (11/17)