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all the known facts and circumstances, including, but not limited to:

• The objective analysis (described above)
• Administrative impact on the plan
• Timing
• Employee communication issues
• The availability of other (potential replacement) managers
• Underwriting and plan provider limitations
• Financial considerations (hard and soft dollar fees)
• Professional or client turnover
• A material change in the investment process
• Other relevant factors

Considerable judgment should be exercised in the manager removal decision-making process. A manager should be
removed using one of the following approaches:

• Remove and replace (map assets) with an alternative manager.
• Freeze the assets managed by the removed manager and direct new assets to an alternative manager.
• Phase out the manager over a specific time period.
• Remove the manager and do not provide a replacement manager.

Replacement of a removed manager follows the criteria outlined in Part VI (Selection of Investment Options).

Part IX. PARTICIPANT EDUCATION AND COMMUNICATION
The Plan should communicate to employees that they can direct their own investments and investment changes.
Investment communications materials, educational materials, and enrollment support should be available to help Plan
participants make educated and informed choices, including:

1. Periodic enrollment and investment education, through one or more of the following: on-site meetings, phone
conference, web conference, Internet, phone (voice-response and live representatives), and written
materials;
2. A disclosure that is intended to comply with the concepts of ERISA Section 404(c) as a best practice;
3. Summary plan description made available to all participants;
4. General information regarding investment risk, inflation, potential taxation impact, investment earnings, and asset
classes;
5. Other investment tools (e.g., investment risk profile questionnaire) to assist participants and beneficiaries in
making educated and informed investment decisions; and
6. All additional information required for disclosure by the Internal Revenue Code of 1986, and all other
Federal and state statutes and all regulations promulgated hereunder, and all regulatory guidance
provided thereto.

Notwithstanding the foregoing, all investment education provided by the Plan and/or Committee, and all
communications connected thereto, is not intended, nor shall it be construed, as investment advice to Plan
participants.

Part X. COORDINATION WITH THE PLAN DOCUMENT
Notwithstanding the foregoing, if any term or condition of this Investment Policy Statement conflicts with any section of
the Internal Revenue Code or regulations promulgated hereunder, or any term or condition in the Plan document, the
terms and conditions of the Internal Revenue Code and the Plan document shall control.

Part XI. ERISA 404(c)
The Plan is exempt from ERISA provisions because it operates as a governmental deferred compensation plan.
However, the City and the Committee intend for the Plan to comply with the concepts of ERISA Section 404(c) and the
regulations there under as a best practice. Each participant/beneficiary is provided the opportunity to exercise control
and to give instructions over his/her account with a frequency that is appropriate for each investment option and,
finally, to choose from a broad range of investment options. Plan fiduciaries are thus relieved from liability for investment
performance directly resulting from investment decisions made by Plan participants.

The intention to comply with the concepts of ERISA Section 404(c), and the regulations promulgated hereunder, will be

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