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HomeMy WebLinkAbout09.a. Receive 2011 Annual Report of Deferred Compensation Plan Advisory Committee7.Q, Central Contra Costa Sanitary District March 9, 2012 TO: BOARD OF DIRECTORS VIA: JAMES KELLY, GENERAL MANAGER ANN FARRELL, D W GENERAL M AGER/ DIRECTOR OF ENGINEERING RANDALL MUSGRAVES, DIRECTOR OF ADMINISTRATION FROM: DEBBIE RATCLIFF, CONTROLLER SUBJECT: BOARD FIDUCIARY RESPONSIBILITY FOR DEFERRED COMPENSATION PLANS During the review of item 10.a. in the Board packet, "Receive the 2011 Annual Report of the Deferred Compensation Plan Advisory Committee" at agenda review, the question of the Board's role and responsibilities regarding the District's Deferred Compensation Plans (457(b) and 401(a)) was discussed. This question was addressed in November, 1997 by Lee Trucker of Trucker Huss. Mr. Trucker's opinion letter from November 1997 is attached. The letter primarily addresses the Board's responsibility for Plan investments; however, it addresses general fiduciary responsibilities of the Board as well. On page three, the third paragraph describes the method of oversight used at the District. The Board has delegated responsibility to the Controller and Deferred Compensation Plan Advisory Committee to monitor the Plan providers with the Board receiving periodic updates on investment performance and any changes to the contracts. This memo and the attached legal opinion are for educational purposes and do not require any Board action. HABoard Fiduciary Responsibility 2012.doc Lee Trucker TRUCKER + Huss R. Bradford Huss Ina L. Potter A PROFESSIONAL CORPORATION Lisa S. Serebin ATTORNEYS AT LAW Robert S. Unger Benjamin F Spater 456 Montgomery Street, Suite 1100 Nicole A. Diller San Francisco, California 94104 -1244 Of Counsel November 17, 1997 Barbara B. Creed Charles A. Storke Deborah Wiener President Menesini and Members of the Board Central Contra Costa Sanitary District 5019 Imhoff Place Martinez, CA 94553 -4392 Re: Board Responsibility For Plan Investments Dear President Menesini and Members of the Board: Telephone (415) 788 -3111 Facsimile (415) 421 -2017 Internet www.truckerhuss.com You have asked that we comment on the responsibilities of the Board of Directors of the Central Contra Costa Sanitary District ( "District ") with respect to the two employee retirement plans sponsored by the District — the Deferred Compensation Plan, a 457 plan, ( "DC Plan") and the Money Purchase Pension Plan, a 401(a) plan, ( "Pension Plan "). In addition to general fiduciary considerations, you requested that we specifically comment on the obligations of the Board of Directors ( "Board ") with respect to the investments offered under the Hartford and other contracts which provide for Plan investments. Fiduciary obligations for the administration and management of an employee benefit plan are ordinarily determined by the plan documents and related instruments, such as provider contracts. The DC Plan document places initial responsibility for plan administration on the employer. The Pension Plan gives the District the right to appoint and remove the administrator, and it is the District that chooses the entity which provides the investment choices for plan participants. Additionally, the District is named the Trustee of the Pension Plan. There are also contracts for administration and for investments with the International City Management Association (ICMA) and the trust it sponsors, Great Western Life Insurance Company and Hartford Insurance Company. All of these contracts provide for the assumption of certain administrative functions, and offer and provide investment options for participants of the Plans. The contracts do not by their terms shift all responsibility for the Plans from the District to the providers. The resolutions adopting the Plans and appointing the various service and investment providers give certain rights to the Controller and establish a plan advisory committee to consist of certain employees. The resolutions do not delegate or relinquish fiduciary authority for the operation of the Plans. #10195.V2 President Menesini and Members of the Board November 17, 1997 Page 2 In light of the language of the Plan documents, contracts and resolutions we believe the District, and its Board of Directors, have retained the principal fiduciary authority and responsibility for the selection and monitoring of the investment providers and administrators of the Plans. We further believe this responsibility applies even though, technically, the assets of the DC Plan are not held in trust and remain the assets of the employer. Under the California Constitution, a board, committee or other entity charged with the duty of handling the assets of a "retirement system" must do so prudently, for the sole and exclusive benefit of the plan participants. Whether or not the DC Plan and the Pension Plan are part of a "retirement system" as intended by the Constitution, we believe the principles enunciated in the Constitution are applicable to the management of the District's Plans. Furthermore, the District provides an inducement for employees to invest their own compensation in the DC Plan, and it therefore follows that the District has a responsibility to see that the choices offered are appropriate. The law on fiduciary responsibility — specifically in the context of participant investment choices in plans of public employers — has not yet fully evolved. For plans of private employers ERISA, pursuant to Section 404(c) and the regulations thereunder, has specific and elaborate rules and requirements which if fulfilled insulate plan sponsors and their fiduciaries from the consequences of the participants' investment decisions. While the ERISA rules are legally not applicable to public employers we believe the principles, if not the specifics, are relevant. These rules require that the person or entity who is selected to provide the investment choices to participants be chosen in a prudent manner. In this instance this would require that the Board be assured that the vendors were chosen prudently. We believe the prudence requirement reflects the common law rules which determine the responsibility of trustees, even where actions are taken at the direction of a trust beneficiary. See Estate of Talbot, et al. v. Wiltron C. Talbot, 141 Cal. App. 2d 309 (1956). We have been informed that considerable time and effort was spent by the Plan Committee in reviewing proposals for the investment contracts. The Committee analyzed performance information, costs and the alternatives offered under each contract. This would demonstrate that sufficient consideration was given to the vendor selection and that the process was prudent. In these circumstances we believe the Board would not be responsible for the individual selections made by participants from the investment choices offered under the various provider contracts. We further believe that the Board would not be required to review and approve changes in the investment choices which may be made by Hartford or the other providers from time to time during the contract period. Our conclusions are buttressed by the California Probate Code provisions on trustee (fiduciary) responsibility for private trusts. Pursuant to Probate Code Sections 16462, 16463 and 16001, a trustee will not be responsible for the consequences of directions of trust beneficiaries if President Menesini and Members of the Board November 17, 1997 Page 3 those directions are provided for in the trust document and the beneficiaries are aware of their rights. A further responsibility placed on the Board or its delegated agents is to monitor the performance of the investments generally under plan- related contracts. In other words, the duty of prudence does not end with the prudent selection of investment providers. It is certainly the responsibility of the appropriate fiduciaries, be it the Board or its delegates, to continue to monitor the contracts with respect to investment performance and contract compliance, as well as continued suitability. There are different approaches to the fiduciary management of employee plans. One structure is for the Board to retain the complete fiduciary authority to manage the plans and the assets of the plans. In such instance, the Board would choose investments, investment vehicles and/or investment managers and the Board would be solely responsible for the prudence of such selections. Alternatively, the Board may delegate responsibility for the selection of investments or investment managers to others through contract or through a person or committee consisting of employees selected or determined in whatever manner the Board deems appropriate. Under this methodology the Board's responsibility would be limited to the prudent selection of the delegated fiduciaries, and, thereafter, the periodic monitoring of the performance of such fiduciaries. The third possibility is for the Board to completely delegate responsibility for the plans to others by establishing under the Plans a structure separate from the Board to manage and determine all matters under the Plans. In such case, the liability for the plans and plan investments should reside solely with the designated fiduciaries. The plan documents, contracts and resolutions indicate the Board presently operates under the second approach — acting as the final decision -maker on vendor selector, and reviewing plan performance as reported by designated District personnel. This approach is used by many public and private plan sponsors and allows for a reasonable balance between Board oversight and efficient plan management. To summarize, we believe that the Board should not be found responsible for the investment performance of each choice given to plan participants where the investment vendor has been selected prudently, where general contract performance is reported to the Board on a periodic basis and where such reports are reviewed and considered by the Board. We understand the Committee provides educational material, presentations on investment options and information on the manner in which investments may be selected. We recommend that a continuous program of information and education continue to be a part of the administration of the Plans and that the program be expanded as and when appropriate. It has been our experience that the world of participant directed investing is most effectively managed President Menesini and Members of the Board November 17, 1997 Page 4 where education is ongoing and participants have access to information which can assist them in making informed investment choices. As always, we thank you for the opportunity to provide assistance in regard to the plans. Please do not hesitate to give me your comments and let me know if you have any further questions. Best regards. Sincerely, OA. ker LAT:bh cc: Kenton L. Alm, Esq. Roger J. Dolan Paul Morsen Deborah Ratcliff Central Contra Costa Sanitary District ' BOARD OF DIRECTORS •a• POSITION PAPER Board Meeting Date: March 15, 2012 Subject: RECEIVE THE 2011 ANNUAL REPORT OF THE DEFERRED COMPENSATION PLAN ADVISORY COMMITTEE Submitted By: Debbie Ratcliff, Controller Initiating Dept. /Div.: Administrative /Finance & Accounting REVIEWED AND RECOMMENDED FOR BOARD ACTION: %A- D. Ratcli / R. Musgraves i7)'�l A. Farrell James M. Kelly, General Manager ISSUE: The Deferred Compensation Plan Advisory Committee (Committee) respectfully submits its 2011 Annual Report. RECOMMENDATION: Receive the Annual Report of the Deferred Compensation Plan Advisory Committee for 2011 and provide any comments to staff. FINANCIAL IMPACTS: None ALTERNATIVES /CONSIDERATIONS: None BACKGROUND: The Board of Directors approved the establishment of the Committee in January 1982. The scope of activities of the Committee includes: • Establishing internal administrative procedures • Educating participants regarding the Plan • Reviewing emergency withdrawal requests • Reviewing investment performance of the Plan • Submission of an annual report to the Board of Directors and Plan participants The Committee is made up of the following Departmental representatives: Debbie Ratcliff, Controller — Chairperson David Rolley, Accounting Technician III — Administrative Michael Penny, Associate Engineer — Engineering Mark Gratis, Maintenance Crew Leader — Collection System Operations Matthew Mahoney, Maintenance Planner — Plant Operations RECOMMENDED BOARD ACTION: Receive the Annual Report of the Deferred Compensation Plan Advisory Committee for 2011 and provide any comments to staff. NAACCOUNTING \GMTEMPI\DEFERRED COMP \Annual.Report.2012.Def.Comp.doc Central Contra Costa Sanitary District DEFERRED COMPENSATION PLAN ADVISORY COMMITTEE ANNUAL REPORT JANUARY 2011 — DECEMBER 2011 The Deferred Compensation Plan Advisory Committee (the Committee) was established by the Board of Directors to facilitate the internal administration of the District's Deferred Compensation Plan. The scope of the Committee's activities encompass the following: • Establish internal District administrative procedures within the provisions of the Deferred Compensation Plan document. • Educate participants regarding the plan provisions by issuing a handbook which summarizes the Deferred Compensation Plan and responding to questions from participants. • Review accountability by the Program Administrators, Hartford Life Insurance Company (Hartford), Nationwide Retirement Solutions, and ICMA Retirement Corporation (ICMA -RC) and respond to participants' queries regarding accuracy or propriety of account balances. • Review participants' requests for emergency withdrawal of funds and make recommendations for acceptance or denial to the Board of Directors. • Review investment performance of the Deferred Compensation Plan on an annual basis. During the period of January 2011 through December 2011, the Committee addressed all of the activities included in its scope of responsibilities through the conscientious efforts of all of the Committee members. The performance of Hartford, Nationwide Retirement Solutions, and ICMA -RC in administering the Deferred Compensation Plan during the 2011 report is considered to be satisfactory. The performance results of the Hartford, Nationwide Retirement Solutions, and IMCA -RC stock and bond investments for the calendar year 2011 follow. NAACCOUNTING \GMTEMP1 \DEFERRED COMP\ Annual. Report. 2012. Def. Comp.doc Please note the following when reviewing Plan results: ■ Market index benchmarks have been provided for comparative purposes only. These indexes reflect broad based changes in the market conditions based on average performance. Indices are unmanaged and reflect no fees or expenses and are not available for direct investment. ■ Rate of returns quoted by providers and fund managers include reinvestment of capital appreciation (depreciation), plus realized gain (losses), dividends and interest income. ■ All rate of return performance results are net of annual asset -based fees, which include fund managers fees and expenses, marketing fees and plan administrative fees. ■ In general, plan administrative fees are charged by the carriers and differ between the carriers. The basic plan administrative fees are as follows: Nationwide Retirement Solutions An annual plan administrative fee of .29 percent is deducted from the participants account and is based on the participant's account balance. ICMA There is no plan administrative fee. Hartford The plan administrative fee is .25 percent for all funds with the exception of the General Account. For additional information on fee charges, consult with your plan provider. The above information is general information. Additional fees may be incurred for other items such as transfers and withdrawals. See Attachment 1 to this report. Results shown represent past performance and are not a guarantee of future performance. Ask your Plan Representative for a current prospectus for each fund in which you are interested. The current prospectus presents more complete information about the fund including fund charges and expenses. Read it carefully before investing in that option under the Plan. NAACCOUNTING \GMTEMPI \DEFERRED COMPWnnual . Report. 2012. Def. Comp. doc Helpful Definitions ■ Balanced Fund is a mutual fund that invests in a combination of common stock, preferred stock, bonds and short term bonds, to provide both income and capital appreciation, while managing volatility and avoiding excessive risk. ■ Blue Chip Company is used in the context of general stock market investments. Large and creditworthy company. Company renowed for the quality and wide acceptance of its products or services, and for its ability to make money and pay dividends. ■ Dollar Cost Averaging or Constant Dollar Plan is a method of purchasing securities by investing a fixed amount of money at set intervals. The investor buys more shares when the price is low and fewer shares when the price is high, thus reducing the average cost. ■ Dow Jones Industrial Average or DJIA is the best known U.S. index of stocks. It is comprised of 30 actively traded blue -chip stocks, primarily industrials, including stocks that trade on the New York Stock Exchange. The Dow, as it is called, is an indicator of how the largest U.S. companies are performing. Measuring the Dow Jones Industrial Average is used to gauge the direction of the stock market. ■ Indexing is a passive instrument strategy consisting of the construction of a portfolio of stocks designed to track the total return performance of an index of stocks. * Barclays Capital Aggregate Bond Index is a broad based index, maintained by Barclays Capital and is often used to represent investment grade bonds being traded in the United States. ■ MSCI Europe, Australia/Asia, and far East. or EAFE index is the European, Australian, and Far East stock index, computed by Morgan Stanley Capital International. This index is used to measure the general performance of the international market. ■ Model Portfolio fund is a fund that consists of a combination of stocks, bonds and cash equivalents in a preset or predetermined ratio based on market risk tolerance. Model Portfolios are rebalanced, typically every quarter, to maintain adherence to the preset ratio. ■ Mutual Funds are pools of money that are managed by an investment company and regulated by the Investment Company Act of 1940. The investment company purchases securities which become jointly owned by its shareholders. The fund's portfolio is managed by a professional money manager. They offer investors a variety of goals depending on the fund and can invest in equity, debt, cash, real estate, options and futures. ■ NASDAQ (once an acronym for National Association of Securities Dealers Automated Quotation System) is a computerized system that provides price quotations to market participants about the more actively traded common stock issues in the over the counter market. This market is comprised of securities not listed on a stock or bond exchange. Large technology stocks have a major effect on this index value. The NASDAQ stock market is comprised of two separate markets, namely the NASDAQ National Market, which trades large, active securities and the NASDAQ Smallcap Market that trades emerging growth companies. The NASDAQ market includes approximately 5,000 common stocks in the system. ■ Standard & Poor's 500 or S &P 500 is an index of blue chip stocks, which measures changes in stock market conditions based on the average performance of 500 widely held common stocks. The S &P 500 is one of the most widely used benchmarks of U.S. equity performance. This index tracks industrial, transportation, financial and utility stocks with heavy emphasis on industrial companies. ■ Treasury Bill or T Bill is a discounted government security that matures in one year or less. It is a negotiable debt obligation issued by the U.S. government. CCCSD Deferred Comp Distribution BY ADMINISTRATOR AND INVESTMENT TYPE CCCSD Deferred Comp Distribution BY ADMINISTRATOR December 31, 2011 HARTFORD $5,208,659 NATIONWIDE 06.98% $6,689,020.05 8.96% ICMA 401(a) �r $23,024,583 30.84% ICMA 457 $39,733,229 53.22% ❑ NATIONWIDE ® ICMA 457 ❑ ICMA 401(a) ❑ HARTFORD CCCSD Deferred Comp Distribution BY INVESTMENT TYPE December 31, 2011 SAVINGS $30,259,042 0 STOCK $28,801,070 38.58% 40.53 /o i BALANCED FUNDS BONDS $12,991,984 $2,603,395 17.40% 3.49% ❑ STOCK ■ BONDS ❑ BALANCED FUNDS ❑ SAVINGS CALENDAR YEAR ENDED DECEMBER 31, 2011 NATIONWIDE INVESTMENT TYPE % RETIREMENT ICMA 457 ICMA 401(a) HARTFORD TOTAL 38.6% 3.5% 17.4% 40.5% $2,610,203 474,235 1,121,014 2,483,567 $15,581,757 1,141,750 6,346,283 16,663,439 $8,842,647 758,204 5,474,473 7,949,258 $1,766,462 229,206 50,215 3,162,777 $28,801,070 2,603,395 12,991,984 30,259,042 STOCK BONDS BALANCED FUNDS SAVINGS TOTAL INVESTMENTS 100.0% $6,689,020 $39,733,229 $23,024,583 $5,208,659 $74,6551491 CCCSD Deferred Comp Distribution BY ADMINISTRATOR December 31, 2011 HARTFORD $5,208,659 NATIONWIDE 06.98% $6,689,020.05 8.96% ICMA 401(a) �r $23,024,583 30.84% ICMA 457 $39,733,229 53.22% ❑ NATIONWIDE ® ICMA 457 ❑ ICMA 401(a) ❑ HARTFORD CCCSD Deferred Comp Distribution BY INVESTMENT TYPE December 31, 2011 SAVINGS $30,259,042 0 STOCK $28,801,070 38.58% 40.53 /o i BALANCED FUNDS BONDS $12,991,984 $2,603,395 17.40% 3.49% ❑ STOCK ■ BONDS ❑ BALANCED FUNDS ❑ SAVINGS CCCSD Deferred Comp Saving Performance Calendar Year Ended December 31, 2011 Rate of Return ( %) Market Index Benchmark 90 Day T -Bill 0.10% Nationwide - Average annual yield rate. Stable Value Fund 1.95% 5 YR CDs 2.09% 3 YR CDs 1.36% 1 YR CDs 0.89% Liquid Savings 0.77% ICMA - Source: ICMA Retirement Corporation Fund Performance Report as of 12/31/2011. Vantagepoint Funds VP Money Market 0.00% Plus Funds Plus Fund (401a) 2.93% Plus Fund (457) 2.93% Vantagepoint Funds (VP) are certain funds available through ICMA. These funds are sponsored by the ICMA Retirement Corporation and registered with the U.S. Securities and Exchange Commission. Hartford - Source: Investment Choices Performance Plan Summary Statement as of 12/31/2011. Money Market 0.25% General Account 4.00% CENTRAL CONTRA COSTA SANI DIST 1CMA Building Retirement Security The performance data quoted represents past performonce, is no guarantee of future results, and is annualized for periods greater than one year. Investment returns and principal value will fluctuate, so that an investor's shares, when redeemed, may be worth more or less than their original cost. Curront performance may be lower or higher than the perfonnanco shown. For current performance, contad ICMA -RC by «filling 800.669 -7400 or by visiting www,icniar(.org. Stable Value/Cash Management Per ormance or perio ended December 31, 2011 tGross tNet Fund Since Inception Expense Expense Investment Code Month Your to Date Quarter 1 Year 3 Year 5 Year 10 Your Inception Date Ratio Ratio VantageTrust PLUS Fund (Annualized) i, ii 71 2.65% 2.93% 2.74% 2.93% 3.27% 3.84% 4.11% 5.33% Jan 1991 0.56% 0.56% VantageTrust Cash Management Fund " iii, i" MW 0.00% 0.00% 0.00% 0.00% 0.05% 1.45% 1.71% - Mar 1999 0.61% 0.61% The 7 -Day Yields below are a better reflection of the earnings of the VantageTrust Cash Management Fund than the quotation of total return in the row above. VantageTrust Cash Management Fund for the period ended December 31, 2011 7 -Day Annualized Current Yield: 0.00% 7 -Day Annualized Effective Yield: N/A „ Bond Performance for period ended December 31, 2011 tGross tNet Fund Since Inception Expense Expense Investment Code Month Year to Date Quarter 1 Year 3 Year 5 Year 10 Year Inception Date Ratio Ratio VT Vantagepoint Core Bond Index Fund i, viii, o WN 1.09% 7.57% 1.10% 7.57% 6.57% 6.25% 5.53% - Apr 1999 0.22% 0.22% VTPIMCO Total Return FundOx, viii, a 18 1.71% 3.91% 2.16% 3.91% 8.60% 7.82% 6.53% 7.31% Sep 1994 #0.71% 0.71% VT Vantagepoint Inflation Protected Securities Fund i, viii, o MT 0.23% 11.53% 2.38% 11.53% 9.05% 7.21% 5.23% - Jul 1992 0.65% 0.65% VT PIMCO High Yield Fund i, ix, viii, o L2 2.55% 3.74% 6.25% 3.74% 19.32% 6.00% 7.35%1 7.59%1 Jan 1995 1 #0.80% 1 0.80% Returns for periods greater than one year are annualized. Page 1 of 6 303896 tGross Not Fund Since Inception Expense Expense Investment Code Month Year to Date Quarter 1 Year 3 Year 5 Year 10 Year Inception Date Ratio Ratio VT Retirement IncomeAdvantage Fund' " 91 0.13%1 .0.35%1 6.21%1 -0.35%1 - I - I - I 7.52% Aug 2010 1.59% 1.59% Investment VT Vantagepoint Equity Income Fund VT Eaton Vance Large -Cap Value Fund i, ix, viii Returns for periods greater than one year are annualized. Performance for period ended December 31, 2011 Fund Since Code Month Year to Date Quarter 1 Year 3 Year 5 Year 10 Year Inception MM 1.09% 0.04% 11.67% 0.04% 15.31% -0.66% 4.67% - 2H 1.62% 4.48% 11.26% 4.48% 7.15% -2.38% 3.50% 8.98% Page 2 of 6 tGross Net Performance for period ended December 31, 2011 Expense Expense Date Ratio Ratio Apr 1994 0.85% 0.85% Sep 1931 #0.98% 0.98% tGross Net Fund Since Inception Expense Expense Investment Code Month Year to Date Quarter 1 Year 3 Year 5 Year 10 Year Inception Date Ratio Ratio VT Vantagepoint Milestone Retirement Income Fund i, viii- xi, xii 4E 0.33% 2.37% 3.48% 2.37% 8.45% 3.13% - 3.78% Jan 2005 0.92% 0.92% VT Vontagepoint Milestone 2010 Fund i, Iiii, Xi, xii CA 0.04% 1.41% 5.21% 1.41% 9.01% 2.65% - 3.81% Jan 2005 0.96% 0.96% VT Vantagepoint Milestone 2015 Fund i, viii, xi, xii (H 0.12% 0.70% 6.03% 0.70% 10.58% 2.01% - 3.79% Jan 2005 0.91% 0.91% VT Vantagepoint Milestone 2020 Fund i, viii, Xi, zii U 0.03% -0.26% 6.65% -0.26% 11.06% 1.43% - 3.58% Jan 2005 0.89% 0.89% VT Vantagepoint Milestone 2025 Fund i, viii, xi, xii CN 0.02% -0.85% 7.52% -0.85% 11.75% 0.95% - 3.43% Jan 2005 0.93% 0.93% VT Vantagepoint Milestone 2030 Fund i, viii, xi, xii CR -0.01% -1.46% 8.27% -1.46% 12.38% 0.50% - 3.28% Jan 2005 0.94% 0.94% VT Vantagepoint Milestone 2035 Fund i, viii, xi, xii CU -0.10% -2.24% 9.12% -2.24% 13.04% 0.16% - 3.15% Jan 2005 0.95% 0.95% VT Vantagepoint Milestone 2040 Fund i, viii, Xi, zii CX -0.09% -2.61% 9.63% -2.61% 13.51% 0.03% - 3.08% Jan 2005 0.94% 0.94% VT Vantagepoint Milestone 2045 Fund i, viii, xi, zii DB -0.16% -2.81% 9.68% -2.81% - - - 5.55% Jan 2010 01.63% 1.10% VT Vantagepoint Model Portfolio Savings Oriented Fund', viii, ,ii SF 0.28% 2.38% 3.49% 2.38% 7.98% 3.38% 4.08% - Feb 1995 0.88% 0.88% VT Vantagepoint Model Portfolio Conservative Growth Fund i, viii, xii SG 0.13% 1.15% 4.74% 1.15% 9.18% 2.72% 3.97% - Apr 1996 0.89% 0.89% VT Vantagepoint Model Portfolio Traditional Growth Fund i, viii, xii SL -0.02% -0.56% 6.56% -0.56% 10.93% 1.74% 3.77% - Apr 1996 0.92% 0.92% VT Vantagepoint Model Portfolio Long -Term Growth Fund i, viii, xii SM -0.16% -1.98% 7.85% -1.98% 12.09% 0.93% 3.71% - Apr 1996 0.96% 0.96% VT Vantagepoint Model Portfolio All -Equity Growth Fund', viii, xii SP -0.36% -4.23% 10.17% -4.23% 14.13% -0.74% 2.94% - Oct 2000 1.03% 1.03% VT Fidelity Puritan® Fund i, viii 24 0.64% 0.67% 6.25% 0.67% 13.30% 1.81% 4.92% 10.96% Apr 1947 0.60% 0.60% Investment VT Vantagepoint Equity Income Fund VT Eaton Vance Large -Cap Value Fund i, ix, viii Returns for periods greater than one year are annualized. Performance for period ended December 31, 2011 Fund Since Code Month Year to Date Quarter 1 Year 3 Year 5 Year 10 Year Inception MM 1.09% 0.04% 11.67% 0.04% 15.31% -0.66% 4.67% - 2H 1.62% 4.48% 11.26% 4.48% 7.15% -2.38% 3.50% 8.98% Page 2 of 6 303896 tGross Net Inception Expense Expense Date Ratio Ratio Apr 1994 0.85% 0.85% Sep 1931 #0.98% 0.98% 303896 Performance for period ended December 31, 2011 tGross Net Fund Since Inception Expense Expense Investment (ode Month Year to Date Quarter 1 Your 3 Year 5 Year 10 Year Inception Date Ratio Ratio VT Allianz NFJ Dividend Value Fund i, ix, viii GZ 2.11% 3.24% 12.74% 3.24% 9.74% -2.52% 5.21% 6.52% May 2000 0.96% 0.96% VT Vantagepoint 500 Stock Index Fund i, Iiii WL 1.00% 1.97% 11.73% 1.97% 13.93% -0.44% 2.70% - Apr 1999 0.23% 0.23% VT Vantagepoint Broad Market Index Fund i, viii WH 0.87% 1.07% 12.09% 1.07% 14.87% 0.13% 3.65% - Apr 1999 0.22% 0.22% VT Vantagepoint Growth & Income Fund i, viii MJ 0.56% -0.69% 11.93% -0.69% 15.06% -0.03% 2.76% - Oct 1998 0.79% 0.79% VT Oppenheimer Main Street Fund, Class Y i, viii U9 1.76% 0.19% 11.43% 0.19% 14.69% -0.57% 2.98% 5.22% Nov 1996 #0.57% 0.57% VT Vantagepoint Growth Fund i, viii MG -0.76% -4.27% 9.30% -4.27% 12.91% -2.03% 0.49% - Apr 1983 0.83% 0.83% VT Fidelity Contrafund(0) i, viii 33 -1.06% -0.12% 8.29% -0.12% 14.70% 2.58% 6.96% 12.07% May 1961 #0.92% 0.92% VT Calvert Equity Portfolio i, ix, xiii, viii L9 -1.63% -2.23% 6.32% -2.23% 15.21% 1.62% 3.28% 7.04% Aug 1987 t1.23% 1.23% VT T Rowe Price® Growth Stock Fund i, viii, xiv 511.1 -0.97% -1.22% 9.91% -1.22% 18.12% 0.90% 3.43% 3.43% 00 001 t0.93% 0.93% VT Vantagepoint Select Value Fund', viii, b M2 0.14% -0.16% 13.44% -0.16% 18.07% - - 0.55% Oct 2001 1.00% 1.00% VT Goldman Sachs Mid Cap Value Fund i, viii, b 5X -0.75% -6.61% 10.72% -6.61% 15.51% 0.07% 7.06% 7.43% Aug 1997 11.16% 1.16% VT Columbia Mid Cap Value Fund i, ix, viii, b 9D 0.68% -4.03% 13.38% -4.03% 16.16% -0.31% 6.69% 7.24% Nov 2001 t0.90% 0.90% VT Vontagepoint Mid /Small Company Index Fund i, viii, b WE 0.07% -3.70% 12.84% -3.70% 18.97% 1.75% 6.61% - Apr 1999 0.25% 0.25% VT Vantagepoint Aggressive Opportunities Fund', viii, b MA -1.08% - 10.42% 10.06% - 10.42% 17.22% -0.04% 2.83% - 00 1994 0.93% 0.93% VT Harbor Mid Cap Growth Fund i, ix, viii, b WQ -4.22% -9.18% 4.18% -9.18% 13.29% 0.42% - 8.68% Nov 2002 11.12% 1.12% VT Royce Premier Fund i, ix, viii, b YN -1.99% -1.07% 12.05% -1.07% 18.36% 5.97% - 12.32% Sep 1002 11.39% 1.39% VT Rainier Small /Mid Cap Equity Portfolio i, ix, viii, b U -1.82% -2.51% 15.53% -2.51% 16.47% -0.35% 6.16% 10.41% May 1994 11.24% 1.24% VT Vantagepoint Discovery Fund i, v"'- b M3 0.92% -6.15% 14.81% -6.15% 18.13% - - -1.27% Oct 2007 0.98% 0.98% VT T Rowe Price® Small Cap Value Fund i, ix, viii, xiv, b K3 0.33% - 0.87% 16.13% -0.87% 16.19% 2.19% 8.92% 10.74% Mar 2000 t1.21% 1.21% VT Royce Value Plus Fund, Class Service i, viii, b 2( -1.86% -9.98% 11.44% -9.98% 15.07% -1.51% 9.43% 10.95% Jun 2001 11.44% 1.44% VT Nuveen Real Estate Securities Fund', viii, c International/Globol PA 4.46% 1.96% 14.83% 1 7.96% 22.54% 0.35% 12.34% 12.06% Jun 1995 . 11.04% 1.04% Performance Yor period ended December 31, 2011 tGross Not Investment Fund Since Inception Expense Expense (ode Month Year to Date Quarter 1 Year 3 Year 5 Year 10 Year Inception Date Ratio Ratio VT Vantagepoint International Fund i, viii, d MD -2.63%1 -8.57%1 4.65%1 -8.57%1 8.54%1 -3.57%1 4.13%1 - Oct 1994 0.98% 0.98% Returns for periods greater than one year are annualized. Page 3 of 6 303896 International/Global Stock Performance for period ended December 31, 2011 tGross tNet Fund Since Inception Expense Expense Investment Code Month Year to Date Quarter 1 Year 3 Your 5 Year 10 Year Inception Date Ratio Ratio VT Vantagepoint Overseas Equity Index Fund', "' -d WC -2.39% - 12.28% 3.99% - 12.28% 6.74% -4.86% 4.33% -- Apr 1999 0.36% 0.36% VT Fidelity Diversified International Fund', ix, viii, d 5G -2.67% - 13.78% 4.86% - 13.78% 7.60% -4.55% 5.79% 7.95% Dec 1991 #0.90% 0.90% VT Harbor International Fund i, ix, viii, d P9 -1.96% - 11.35% 7.27% - 11.35% 11.03% -0.99% - 11.02% Nov 2002 1$1.05% Certifi(ates of Deposit Window Period: 11/30/2011 to 12/29/2011 Window Period: 10/31/2011 toll /29/2011 Fund Investment Code Annual % Rate Annual % Yield Annual % Rate Annual % Yield VnntageTrust Three Year Certificate of Deposit Account i, v, vi, vii 1.3 0.26% 0.26% 0.23% 0.23% VnntageTrust Five Year Certificate of Deposit Account i, v, vi, vii 1.5 0.42% 0.42% 0.46% 0.46% Disclosures Investments listed were available at the time this report was created. Since investment options can change over time, the investments listed may be different from the investment options that were available on December 31, 2011. Fund performance is available the 5th business day after month end. Creating this report prior to that time period may result in incomplete information. Additional Information on Fund Expenses and Waivers of Expenses $ Information on the underlying Fund expense ratio is provided by Morningstar, Inc.® All rights reserved. The information contained herein; (1) is proprietary to Morningstar and /or its affiliates; (2) is not warranted to be accurate, complete or timely. Please consult the current fund prospectus or other appropriate document for additional information. tDefinitions of Expense Ratio Terms Gross Expense Ratio- The annualized amount, expressed as a percentage of your total investment, that you will pay annually for the mutual fund's operating expenses and management fees before any waivers. Net Expense Ratio -The amount shown in the gross expense ratio less any expense waivers. The daily portion of this expense is deducted from the fund prior to the fund company's calculation of the daily price reported to the public. Expense Waiver Amount -The amount a mutual fund has agreed to waive in order to reduce or limit operating expenses for the fund. Fee waivers may not be available to fund shareholders in the future. A. An expense waiver or discount of -% exists for this fund. Please read the prospectus carefully for all information on the fees and expenses for this fund. B. An expense waiver or discount of -% exists for this fund. Please read the prospectus carefully for all information on the fees and expenses for this fund. C. An expense waiver or discount of 0.53% exists for this fund. This reduction is contractual and will expire on April 30, 2012. Some waivers may be renewed or extended. D. An expense waiver or discount of 0.01% exists for this fund. This reduction is contractual and will expire on February 29, 2012. Some waivers may be renewed or extended. Returns for periods greater than one year are annualized. Page 4 of 6 303896 Risks Associated with Asset Classes a. A rise /fall in the interest rates can have a significant impact on bond prices and the NAV (net asset value) of the fund. Funds that invest in bonds can lose their value as interest rates rise and an investor can lose principal. b. Funds that invest in small and /or mid -sized company stocks typically involve greater risks, particularly in the short-term, than those investing in large, more established companies. C. Funds that concentrate investments in one industry may involve greater risks than more diversified funds, including greater potential for volatility. d. Foreign investments are subject to more risks not associated with domestic investments (i.e. currency, economy and political risks). Investment Specific Footnotes i. Please read Making Sound Investment Decisions: A Retirement Investment Guide ( "Guide") carefully for a complete summary of all fees, expenses, investment objectives and strategies, and risks. Investment returns and principal value will fluctuate, so that an investor's shares, when redeemed, may be worth more or less than their original cost. Current performance may be lower or higher than the performance shown. For current performance, contact ICMA -RC by calling 800 -669 -7400 or by visiting www.icmarc.org. ii. PLUS Fund return is annualized for all periods. iii. The VantageTrust Cash Management Fund is invested in a single registered mutual fund, the Dreyfus Cash Management money market fund (Participant Shares). Investments in the VantageTrust Cash Management Fund are not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. iv. Certain fund service fees have been waived so that a fund will not experience negative returns. All fee waivers are temporary and may be discontinued at any time without notice. V. Open Investment Window — Refers to the date range a plan participant may purchase CD Accounts associated with the published APRs and APYs. Investments will be accepted from the first through the last business day of the open investment window, which will generally run from the last business day of the previous month through the second to last business day of the current month. Amounts to be invested in CD Accounts are initially held in the Bank's Money Market Deposit Account ( "MMDA2), until the open investment window closes. Assets held in the MMDA will earn the Bank's MMDA rate and cannot be withdrawn until after the assets have been invested in the CD Account. At that time early withdrawal penalties could apply. vi. Certificate of Deposit Accounts (CD Accounts) Annual Percentage Rates (APRs) and Annual Percentage Yields (APYs) are valid for investments made into CD Accounts within the related open investment window period. The interest rate is guaranteed until the maturity date of the CD Account. The stated APY assumes that principal and interest remain on deposit until maturity. Withdrawals and fees may reduce earnings on the account. Please be advised that there may be associated penalties for withdrawals from a CD Account prior to the maturity date. Currently, no minimum opening deposit is required. For more information regarding CD Accounts, please contact Investor Services at 800 -669 -7400. vii. ICMA -RC's Annual CD Administrative Fee is assessed against assets invested in CD Accounts and reflected in the interest rate. The administrative fee may be raised or lowered for new CD Accounts but not for existing CD Accounts. No administrative fee is assessed while assets are invested in the MMDA pending investment in CD Accounts. For 1 -year CD Accounts, ICMA -RC's Annual CD Administrative Fee is 0.60 %. For 3 -year and 5 -year CD Accounts, ICMA -RC's Annual CD Administrative Fee is half of the gross rate offered by the Bank, with a maximum fee of 0.60 %. Fees may differ for some plans. viii. This VantageTrust fund invests solely in the shares of a single designated Vantagepoint or third -party mutual fund. ix. Returns provided by Morningstar, Inc.'" Copyright © 2012. All Rights Reserved. The information contained herein: (1) is proprietary to Morningstar and /or its content providers; (2) may not be copied or distributed; and (3) is not warranted to be accurate, complete or timely. Neither Morningstar nor its content providers are responsible for any damages or losses arising from any use of this information. ICMA -R( does not independently verify Morningstar data. X. The VantageTrust Retirement IncomeAdvantage Fund (the "Fund ") is offered through VantageTrust, a group trust sponsored by the VantageTrust Company, a New Hampshire institution. The Fund invests in a separate account under a group variable annuity issued by Prudential Retirement Insurance and Annuity Company (Prudential), CA COA #08003, Hartford, CT. Neither Prudential nor ICMA -RC guarantees the investment performance or return on contributions to Prudential's separate account. You should carefully consider the objectives, risks, charges, expenses and underlying guarantee features before purchasing this product. Like all variable investments, this Fund may lose value. Availability and terms may vary by jurisdiction; subject to regulatory approvals. Annuity contracts contain exclusions, limitations, reductions of benefits and terms for keeping them in force. Guarantees are based on Prudential's claims - paying ability. This annuity is issued under Contract form # GA- 2020- TGWB4- 0805 -RC. ICMA -RC provides recordkeeping services to your Plan and is the investment manager of the underlying Prudential separate account. Prudential or its affiliates may compensate ICMA -RC for providing these and related administrative services in connection with the Fund. Before electing the Spousal Benefit (if available) on behalf of any beneficiary not recognized as your spouse under Federal law, be aware that provisions of your plan or the Internal Revenue Code might prevent, limit or otherwise affect the ability of the beneficiary to receive the Spousal Benefit. Prudential, the Prudential logo, and the Rock symbol are service marks of the Prudential Insurance Company of America, Newark, NJ, and its related entities, registered in many jurisdictions worldwide. Note: Participants who are interested in the VantageTrust Retirement IncomeAdvantage Fund must first receive and read the Important Considerations document, before investing. xi. The fund is not a complete solution for all of your retirement savings needs. An investment in the fund includes the risk of loss, including near, at or after the target date of the fund. There is no guarantee that the fund will provide adequate income at and through an investor's retirement. Selecting the fund does not guarantee that you will have adequate savings for retirement. Returns for periods greater than one year are annualized. Page 5 of 6 303896 A-L The expense ratio for a "fund of funds" includes acquired fund fees and expenses, which are expenses incurred indirectly by the fund through its ownership in other mutual funds. A& Effective February 1, 2011, the VT Calvert Social Investment Equity Portfolio is now known as the VT Calvert Equity Portfolio. Av. T. Rowe Price® is o registered trademark of T. Rowe Price Group, Inc. - all rights reserved. Returns for periods greater than one year are annualized. Page 6 of 6 303896 PERFORMANCE RESULTS NATIONWIDE RETIREMENT SOLUTIONS Investment Performance Information - October 1. 2011 to December 31. 2011 The following are percentage changes in Net Assets (with capital gains and income dividends reinvested) for the funds under the Plan, for the respective periods ended 1213112011. The results shown represent past performance and do not represent expected future performance or experience. Past performance does not guarantee future results. Investment return and principal value of an investment will fluctuate so that an investor's shares, when redeemed, may be worth more or less than their original cost. Current performance may be lower or higher than the data quoted. Performance data current to the most recent month -end may be obtained by visiting: WWW.NATIONALDEFERRED.COM. Please consider the fund's investment objectives, risks, and charges and expenses carefully before investing. The prospectus contains this and other important information about the investment company. Prospectuses are available by calling (800)769 -4457. Read the prospectus carefully before investing. The rates of return do not reflect a maximum deduction of a 0.29% annual plan asset fee, which, if reflected, would reduce the performance shown. Please see other important disclosures at the end of this report. 4 QUARTERLY REPORT FOR CENT CTRA COSTA SANI 457 PLAN&TRUST Since Inception Gross Ticker Morningstar Average Annual Return Inception Adoption Expense Symbol Variable Investment Options Category 3 Month 1 Year 5 Year 10 Year Adoption Date Ratio Small -Cap Stocks DFSCX DFA US Micro Cap Small Blend 15.72% -3.25% -0.49% 7.05% 11.44% 12/23/81 0.52% BCSIX Brwn Cap Sm Co Inst Small Growth 9.53% 0.11% 8.62% 4.50% 10.76% 12/31/92 1.29% DSVRX Drey SmCap I (a) Small Value 19.51% - 14.19% -5.14% 4.74% 4.23% 04/01/98 1.25% NWUSX NW US SmCap Val Inst Svc Small Value 16.87% -6.15% N/A N/A 0.76% 12/21/07 1.76% International Stocks AEPGX AmFds EuroPacfc Gr A Foreign Large Blend 4.53% - 13.58% - 1.43% 6.56% 11.12% 04/16/84 0.82% TEMFX FnklnTmp Forgn A (a) Foreign Large Value 3.27% -12.71% - 2.16% 5.30% 10.75% 10/05/82 1.19% NWVSX NW Intl Val Inst Svc Foreign Large Value 6.50% - 17.68% N/A N/A - 13.59% 12/21/07 1.28% OPPAX Opp GIN A World Stock 6.45% -8.69% -1.68% 4.92% 11.23% 12/22/69 1.20% Mid -Cap Stocks GTAGX Invsco MdCap Cor Eq A Mid -Cap Blend 8.29% - 6.24% 1.83% 5.33% 10.44% 06/09/87 121% KAUFX Fed Kaufman R Mid -Cap Growth 8.27% - 13.78% - 1.41% 4.42% 11.23% 02/21/86 2.50% JAMCX JPM MidCap Value A Mid -Cap Value 13.49% 1.91% 1.52% 8.21% 11.52% 11/13/97 1.40% Large -Cap Stocks FGRIX Fid Gr Inc Large Blend 12.82% 1.39% -6.69% -1.48% 9.00% 12/30/85 0.72% AIVSX AmFds invmt Co Am A Large Blend 10.49% -1.76% - 0.86% 3.48% 11.95% 01/02/34 0.61% NBSRX NeuBer Soc Resp Inv Large Blend 10.71% -2.90% 0.49% 5.13% 7.94% 03/16/94 0.95% VINIX Vngrd Inst Indx Inst Large Blend 11.81% 2.09% - 0.22% 2.94% 8.34% 07/31/90 0.04% VFINX Vngrd 500 Indx Fnd (a) Large Blend 11.78% 1.97% - 0.33% 2.82% 10.36% 08/31176 0.17% NWFAX NW Fund A Large Blend 12.20% 0.18% - 2.33% 2.17% 9.29% 05/11/33 1.09% TWCUX AmCent Ultra Inv (a) Large Growth 10.19% 1.19% 2.53% 1.82% 10.84% 11/02/81 1.00% FCNTX Fid Contra Large Growth 8.29% -0.12% 2.58% 6.96% 12.03% 05/17/67 0.92% FMAGX Fid Magellan Large Growth 8.06% - 11.55% -3.34% - 0.14% 15.97% 05/02/63 0.60% FDFFX Fid Indpndnc (a) Large Growth 8.93% - 10.85% 0.50% 3.99% 10.86% 03/25/83 0.92% AGTHX AmFds Gr Fd Am A Large Growth 8.55% 4.89% -0.59% 3.62% 13.19% 11130/73 0.68% JANSX Jns Fd T Large Growth 7.89% -5.88% -0.07% 1.36% 11.99% 02/05/70 1.00% JARTX Jns Frty S Large Growth 7.61% -7.32% 1.29% 4.71% 8.75% 05/01/97 1.20% VWUSX Vanguard US Growth Fd IS Large Growth 9.66% -0.68% 0.48% 0.04% 9.73% 01/06/59 0.48% VPMCX Vngrd Prm Cap Inv Large Growth 10.48% - 1.84% 2.34% 5.34% 12.80% 11/01/84 0.45% TWCIX AmCent Set Inv (a) Large Growth 9.88% 1.42% 2.83% 1.65% 11.94% 06/30/71 1.01% TWCGX AmCent Gr Inv (a) Large Growth 10.47% - 0.90% 3.16% 2.93% 13.20% 06/30/71 1.00% FEQIX Fid Eq Inc Large Value 12.54% -4.68% -3.40% 2.47% 11.22% 05/16/66 0.69% KDHAX DWS VS Strat Val A Large Value 11.81% -2.28% -6.08% 1.16% 9.73% 03/18/88 1.21% VWNFX Vngrd Wndsr II Inv Large Value 12.81% 2.70% -1.36% 4.22% 10.19% 06/24/85 0.35% AWSHX AmFds Wshngtn Mut Inv A Large Value 11.63% 7.05% 0.08% 3.75% 11.69% 07/31/52 0.63% NW LgCap Gr (n) N/A 8.00% -3.03% N/A N/A -0.89% 04/27/07 0.95% Balanced VWNNX Vngrd Wisly Inc Inv (a) Conservative Allocation 6.11% 9.63% 6.04% 6.66% 10.16% 07/01/70 0.28% FPURX Fid Puritan Moderate Allocation 6.25% 0.67% 1.81% 4.92% 10.94% 04/16/47 0.60% AMECX AmFds Inc Fd Am A Moderate Allocation 8.47% 5.58% 1.68% 6.22% 11.25% 11/30/73 0.58% VWELX Vngrd Wington Inv Moderate Allocation 8.22% 3.85% 3.46% 6.17% 8.14% 07/01/29 0.30% TWBIX AmCent Bat Inv (a) Moderate Allocation 7.94% 5.43% 2.75% 4.55% 7.71% 10/20/88 0.91% 4 QUARTERLY REPORT FOR CENT CTRA COSTA SANI 457 PLAN&TRUST PERFORMANCE RESULTS Investment Performance Information - October 1, 2011 to December 31, 2011 FEE DISCLOSURES The Standardized illustration represents performance based on a $10,000 hypothetical investment, and reflects the deduction of the following fees: denotes a Fee of 0.00% Gross expense ratios represent the fund's total operating expenses expressed as a percentage of the assets held in the fund. For more information about gross expense ratios, read the fund's prospectus. Some mutual funds may impose a short term trade fee. Some funds may be subject to a trade restriction policy. Please read the underlying prospectus carefully. Nationwide Retirement Solutions receives administrative reimbursement fee payments of up to 0.80% of assets from Nationwide Bank for administration and record- keeping services of bank products. For additional information, please visit www.nrsforu.com. FOOTNOTES a) These funds are not open to new participants. b) These funds are designed to provide diversification and asset allocation across several types of investments and asset classes, primarily by investing in underlying funds. Therefore, in addition to the fund's expenses, you are indirectly paying a proportionate share of the applicable fees and expenses of the underlying funds. j) Nationwide Investor Destinations Funds are designed to provide diversification and asset allocation. They do this by investing in several types of investments and asset classes. So, in addition to the expenses of the Investor Destinations Fund, you pay a proportionate share of the expenses of the underlying funds. 1) The Target Destination Funds invest in a wide variety of underlying funds to help reduce investment risk. So in addition to the expenses of the Target Destination Funds, you pay a proportionate share of the expenses of the underlying funds. Like other funds, Target Destination Funds are subject to market risk and loss. Loss of principal can occur at any time, including before, at or after the target date. There is no guarantee that target date funds will provide enough income for retirement. n) The Nationwide Large Cap Growth Portfolio is not a mutual fund. Its performance cannot be tracked in newspapers or through other public resources. You can find more information and track the Portfolio's performance via your plan's website, www.nationaideferred.com. WWW.NATIONALDEFERRED.COM Questions? Call us! (800)769 -4457 5 Since Inception Gross Ticker Morningstar Average Annual Return Inception Adoption Expense Symbol Variable Investment Options Category 3 Month 1 Year 5 Year 10 Year Adoption Date Ratio Bonds KHYAX DWS Hi Inc A High Yield Bond 6.73% 4.02% 5.45% 7.59% 9.13% 01/26/78 0.96% ABNDX AmFds Bd Fd Am A Intermediate -Tenn 1.13% 6.30% 3.52% 4.93% 8.38% 05/28/74 0.59% Bond CMPIX Pmcpl Inv Inc A (a) Intermediate -Term 2.08% 5.58% 6.68% 6.23% 8.08% 12/15/75 0.91% Bond VBTSX Vngrd Ttl Bd Mkt Indx Sgnl Intermediate -Term 0.97% 7.69% 6.48% N/A 6.50% 09/01/06 0.11% Bond Short-Term Investments CMPGX Prncpl Inv GovtHiQultyBd A (a) Intermediate 0.71% 5.81% 5.77% 4.87% 7.14% 05104/84 0.94% Government Stable Value Fund B (') N/A 0.44% 1.95% 3.21% N/A N/A Asset Allocation NDMSX NW Inv Dest Mod Aggr Svc 0) Aggressive Allocation 7.91% -2.20% 0.00% 4.03% 2.04% 03/30/00 0.88% NDCSX NW Inv Dest Cnsry Svc 0) Conservative Allocation 2.48% 2.88% 3.21% 3.82% 3.61% 03/30/00 0.90% NSDCX NW Inv Dest Mod Cnsry Svc 0) Conservative Allocation 4.56% 1.95% 2.59% 4.13% 3.39% 03/30/00 0.89% NDASX NW Inv Dest Aggr Svc 0) Large Blend 9.17% -4.10% -1.31% 3.75% 1.26% 03/30/00 0.89% NSDMX NW Inv Dest Mod Svc 0) Moderate Allocation 6.17% -0.10% 1.33% 4.04% 2.76% 03/30/00 0.87% NWRSX NW Rtrmt Inc Inst Svc (b) Retirement Income 2.18% - 0.61% N/A N/A 2.32% 08/29/07 0.88% NWESX NW Dest 2015 Inst Svc (1) Target Date 2011 -2015 4.35% - 1.31% N/A N/A 0.33% 08/29/07 0.89% NWFSX NW Dest 2020 Inst Svc (1) Target Date 2016 -2020 5.14% -1.61% N/A N/A 0.18% 08/29/07 0.88% NWHSX NW Dest 2025 Inst Svc (1) Target Date 2021 -2025 6.04% -2.53% N/A N/A -0.16% 08/29/07 0.88% NWESX NW Dest 2030 Inst Svc (1) Target Date 2026 -2030 7.21% -3.18% N/A N/A -0.78% 08/29/07 0.89% NWLSX NW Dest 2035 Inst Svc (1) Target Date 2031 -2035 8.02% -3.52% N/A N/A -1.31% 08/29/07 0.90% NWMSX NW Dest 2040 Inst Svc (1) Target Date 2036 -2040 8.27% 4.24% N/A N/A -1.97% 08129/07 0.90% NWNSX NW Dest 2045 Inst Svc (1) Target Date 2041 -2045 8.43% -4.27% N/A N/A -2.07% 08/29/07 0.89% NWOSX NW Dest 2050 Inst Svc (1) Target Date 2050+ 8.22 % -4.61% N/A N/A -1.99% 08/29/07 0.90% Market Indices Total Return Average Annual Return 3 month 1 Year 5 Year 10 Year Barclays Capital Aggregate Bond Index 1.12% 7.84% 6.50% 5.78% MS Europe, Australia, Far East Index 3.33% - 12.14% -0.72% 4.67% Russell 2000 Index 15.47% -4.18% 0.15% 5.62% Standard & Poor's 500 Stock Index 11.82% 2.11% -0.25% 2.92% Standard & Poor's Mid Cap 400 Index 12.98% -1.73% 3.32% 7.04% Three Month Treasury Bill Index 0.01% 0.08% 1.36% 1.85% FEE DISCLOSURES The Standardized illustration represents performance based on a $10,000 hypothetical investment, and reflects the deduction of the following fees: denotes a Fee of 0.00% Gross expense ratios represent the fund's total operating expenses expressed as a percentage of the assets held in the fund. For more information about gross expense ratios, read the fund's prospectus. Some mutual funds may impose a short term trade fee. Some funds may be subject to a trade restriction policy. Please read the underlying prospectus carefully. Nationwide Retirement Solutions receives administrative reimbursement fee payments of up to 0.80% of assets from Nationwide Bank for administration and record- keeping services of bank products. For additional information, please visit www.nrsforu.com. FOOTNOTES a) These funds are not open to new participants. b) These funds are designed to provide diversification and asset allocation across several types of investments and asset classes, primarily by investing in underlying funds. Therefore, in addition to the fund's expenses, you are indirectly paying a proportionate share of the applicable fees and expenses of the underlying funds. j) Nationwide Investor Destinations Funds are designed to provide diversification and asset allocation. They do this by investing in several types of investments and asset classes. So, in addition to the expenses of the Investor Destinations Fund, you pay a proportionate share of the expenses of the underlying funds. 1) The Target Destination Funds invest in a wide variety of underlying funds to help reduce investment risk. So in addition to the expenses of the Target Destination Funds, you pay a proportionate share of the expenses of the underlying funds. Like other funds, Target Destination Funds are subject to market risk and loss. Loss of principal can occur at any time, including before, at or after the target date. There is no guarantee that target date funds will provide enough income for retirement. n) The Nationwide Large Cap Growth Portfolio is not a mutual fund. Its performance cannot be tracked in newspapers or through other public resources. You can find more information and track the Portfolio's performance via your plan's website, www.nationaideferred.com. WWW.NATIONALDEFERRED.COM Questions? Call us! (800)769 -4457 5 CENTRAL CONTRA COSTA SANITARY DISTRICT DCP i PLAN SUMMARY STATEMENT THE PAGE 7 OF 12 HARTFORD OCTOBER 1, 201 1 - DECEMBER 31, 201 1 GROUP NUMBER: 0107605 PERFORMANCE INVESTMENT CHOICES FOR PERIOD ENDING DECEMBER 31, 201 1 8 An investment in the Fund is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Although the Fund seeks to preserve the value of your investment at $1.00 per share, it is possible to lose money by investing in the Fund. Average Total Return Annual Total Return* Since Inception Month 3 Mo. YTD 1 Yr. 3 Yr. 5 Yr. 10 Yr. Incept. Date SPECIALTY 101 Htfd HC HLS2,' 1.37% 7.35% 8.27% 8.27% 12.29% 2.16% 5.46% N/A 05/01/2000 106 Invesco Leisure' -0.54% 7.77% -4.19% -4.19% 15.14% -2.93% 2.72% N/A 02/07/1984 108 Invesco Technology' -2.39% 6.63% -3.48% -3.48% 22.45% 1.69% -0.62% N/A 02/07/1984 116 MFS Utilities' 1.17% 8.42% 6.32% 6.32% 16.87% 4.83% 9.89% N/A 02/14/1992 INTERNATIONAL/GLOBAL 126 AmCent Intl Growth -2.35% 4.93% - 12.06% - 12.06% 10.07% -3.14% 3.37% N/A 05/09/1991 900 Htfd Glbl Res HLS2 -1.38% 7.27% -9.51% -9.51% 14.08% N/A N/A -2.10% 01/31/2008 13 Htfd Int Opps HLS2 -2.51% 5.22% - 14.19% - 14.19% 9.27% -0.91% 5.67% N/A 07/02/1990 075 Janus Overseas2.3 -6.01% 0.21% - 33.09% - 33.09% 12.06% -3.42% 7.00% N/A 05/02/1994 051 Janus Worldwide 2.3 -2.47% 5.24% - 14.06% - 14.06% 10.83% -4.05% -0.28% N/A 05/15/1991 121 Putnam Global Equity' -1.72% 9.08% -5.09% -5.09% 10.37% -4.49% 2.21% N/A 09/01/1967 050 Putnam Intl Growth'' -3.47% 4.88% - 17.19% - 17.19% 8.70% -3.42% 4.81% N/A 01/08/1995 SMALL CAP 82 Htfd Sml Company HLSS -1.98% 9.48% -3.60% -3.60% 15.46% 0.77% 5.66% N/A 08/09/1996 271 Invesco SC Growths -0.92% 12.01% -1.48% -1.48% 18.50% 2.47% 3.97% N/A 10/18/1995 s 058 Mgrs AMG Skyline SEP' 3.17% 19.77% -2.29% - 2.29% 23.26% 0.09% 7.11% N/A 02/09/1993 MID CAP 099 Frkln SmMd Cap Grwths•6 -2.67% 12.36% -5.13% -5.13% 20.18% 2.09% 3.61% N/A 02/14/1992 103 Htfd MidCap HLS° -1.08% 11.73% -8.15% -8.15% 13.90% 1.86% 6.87% N/A 07/14/1997 I� :i 071 Janus Enterprise 6.3 -0.86% 10.14% -2.11% -2.11% 20.54% 3.84% 5.86% N/A 09/01/1992 LARGE CAP 085 AmCent Equity Income 2.55% 10.55% 3.31% 3.31% 9.33% 1.14% 5.44% N/A 08101/1994 066 AmCent Inc & Growth 1.35% 11.93% 2.76% 2.76% 11.22% -2.27% 2.47% N/A 12/17/1990 i 057 AmCent Value 2.63% 12.32% 0.33% 0.33% 10.58% -1.34% 4.00% N/A 09/01/1993 11 AmCentury Ultra -1.53% 10.12% 0.94% 0.94% 16.59% 2.28% 1.57% N/A 11/02/1981 053 DWS Growth & Income -0.48% 11.11% -0.41% -0.41% 14.93% -1.30% 1.71% N/A 11/13/1984 i 091 Drey Third Century -0.96% 9.80% 0.12% 0.12% 14.84% 1.14% 0.93% N/A 08/31/1999 054 FA Growth & Income 2.12% 12.56% 0.82% 0.82% 13.02% -1.40% 1.42% N/A 12/31 /1996 026 FA Growth Opps -1.71% 7.69% 1.49% 1.49% 22.33% -0.03% 1.86% N/A 11118/1987 012 Htfd Cap App HLS -0.58% 9.05% - 11.63% - 11.63% 14.27% -1.15% 5.54% N/A 04/02/1984 29 Htfd Div & Grwth HLS 17 Htfd Index HLS 2.08% 0.98% 12.32% 11.65% 1.06% 1.56% 1.06% 1.56% 12.38% 13.51% 0.65% -0.76% 4.75% 2.33% N/A N/A 03/08/1994 05/01/1987 14 Htfd Stock HLS 2.16% 13.10% -1.34% -1.34% 16.84% - 0.90% 1.70% N/A 08/31 /1977 1. 1125 Inv Diversified Div 1.59% 10.37% -0.46% -0.46% 12.18% 0.63% N/A 3.15% 12/31/2001 s 052 Janus Twenty' -1.17% 8.07% -8.42% -8.42% 11.78% 1.85% 4.61% N/A 04/30/1985 115 MA Inv Grwth Stck -2.16% 8.21% 1.07% 1.07% 17.28% 2.45% 1.82% N/A 01/02/1935 845 MFS Core Equity -0.17% 10.83% -1.35% -1.35% 15.13% 0.45% 3.27% N/A 01/02/1996 326 Putnam MultiCap Gr -1.82% 11.41% -5.24% -5.24% 14.04% -0.85% 1.37% N/A 08/31/1990 CENTRAL CONTRA COSTA 9 SANITARY DISTRICT DCP PLAN SUMMARY STATEMENT THE!& PAGE s of 12 HARTFORD OCTOBER 1, 201 1 - DECEMBER 31, 201 1 GROUP NUMBER: 0107605 PERFORMANCE INVESTMENT CHOICES FOR PERIOD ENDING DECEMBER 31, 201 1 BENCHMARK INDICES FOR PERIOD ENDING DECEMBER 31, 201 1 Total Return Average Annual Total Return Average 3 Mo. YTD 1 Yr. 3 Yr. 5 Yr. 10 Yr. S &P 500 Index' Total Return 11.82% Annual Total Return* 2.11% Since Inception 1.29% Month 3 Mo. YTD 1 Yr. 3 Yr. 5 Yr. 10 Yr. Incept. Date ASSET ALLOCATION /BALANCED 016 Cal VPSRI Bal Prt -0.23% 6.32% 4.30% 4.30% 13.38% 0.47% 2.80% N/A 09/02/1986 088 Dreyfus LT G &I 0.88% 7.91% 3.22% 3.22% 10.96% 2.21% 3.95% N/A 03/31/1995 025 FA Balanced 0.58% 6.11% 0.95% 0.95% 12.95% 1.09% 3.17% N/A 01/06/1987 19 Htfd Advisers HLS 1.85% 8.94% 1.60% 1.60% 13.88% 1.39% 2.90% N/A 03/31/1983 079 Janus Balanced' 0.78% 7.86% 1.06% 1.06% 10.43% 4.58% 5.45% N/A 09/01/1992 BOND 886 DR INT TRM 1 1.23% 0.67% 7.04% 7.04% 10.81% 5.88% 5.35% N/A 02102/1996 18 Htfd TotRet Bond HLS 1.29% 1.12% 6.72% 6.72% 9.50% 4.78% 5.22% N/A 08/31/1977 902 Htfd US Gov Sec HLS 0.54% 0.87% 4.61% 4.61% 3.75% 2.88% 3.33% N/A 03/24/1987 114 MFS High Income' 2.72% 6.19% 3.87% 3.87% 20.56% 4.86% 6.71% N/A 02/17/1Mh 59 Putnam HY Advantage' 2.65% 5.96% 2.89% 2.89% 19.84% 6.07% 8.00% N/A 03/25/ STABLE VALUE /MONEY MARKET 22 Htfd Money Mkt HLS' -0.02% -0.06% -0.25% -0.25% -0.23% 1.16% 1.52% N/A 06/30/1980 General (Declared Rate) Account Information: 1 st 0 2012: 4.00% The Declared Rate set forth above is credited through the close of the calendar year on contributions received during the designated calendar quarter. For contributions received prior to January 1, 2012, the Declared Rate is 4.00 %. Rates quoted are effective annual yields. BENCHMARK INDICES FOR PERIOD ENDING DECEMBER 31, 201 1 Market indices have been provided for comparison purposes only. The indices represented are not illustrative of the performance of any investment option offered through The Hartford's retirement programs. These indices are unmanaged and are not available for direct investment 1 S &P is an index which measures broad -based changes in stock market conditions based on the average performance of 500 widely held common stocks. 2 The Barclay's Capital Government /Corporate Bond Index, an unmanaged list of U.S. Treasury/Agency and investment grade corporate debt securities, is used as a general measure of performance of fixed income securities. 3 NASDAQ is a computerized system that provides brokers and dealers with price quotations for securities traded over the counter as well as for many NYSE listed securities. Total Return Average Annual Total Return Month 3 Mo. YTD 1 Yr. 3 Yr. 5 Yr. 10 Yr. S &P 500 Index' 1.02% 11.82% 2.11% 2.11% 14.11% -0.25% 2.92% BarCap Gov/Corp Indx2 1.29% 1.18% 8.74% 8.74% 6.60% 6.55% 5.85% NASDAQ' -0.58% 7.86% -1.80% -1.80% 18.21% 1.52% 2.94% Market indices have been provided for comparison purposes only. The indices represented are not illustrative of the performance of any investment option offered through The Hartford's retirement programs. These indices are unmanaged and are not available for direct investment 1 S &P is an index which measures broad -based changes in stock market conditions based on the average performance of 500 widely held common stocks. 2 The Barclay's Capital Government /Corporate Bond Index, an unmanaged list of U.S. Treasury/Agency and investment grade corporate debt securities, is used as a general measure of performance of fixed income securities. 3 NASDAQ is a computerized system that provides brokers and dealers with price quotations for securities traded over the counter as well as for many NYSE listed securities. HARTFORD FEE SCHEDULE Helen Lai Group # : 107605 02/24/2012 Page 1 of 4 Fees Important Information about your Investment Choices WILL BE REPLACED BY REPORT ENDING 12/31/2011 For the Period Ending 01/31/2012 International /Global AmCent Intl Growth Underlying Total Invest Annual Mortality, Expense Total Fees Received by The Investment Choice Fund Mg 12b -1 Other Htfd GlbI Res HLS and Fees & Hartford from 0.11% Share Fee Fee Ex p Underlying Admin Charges Underlying Fundst" 0.78% Class -0.04% 0.74% 0.25% F.O.E.t Chargett Janus Overseas S Specialty 0.25% 0.30% 1.19% 0.25% 1.44% .5 Janus Worldwide T Invesco Leisure INV 0.72% 0.25% 0.39% 1.36% 0.25% 1.61% .6 Invesco Technology INV 0.43% 0.23% 0.87% 1.53% 0.25% 1.78% .6 Htfd HC HLS IA 0.85% 0.00% 0.05% 0.90% 0.25% 1.15% .25 MFS Utilities A 0.60% 0.25% 0.22% 1.07% 0.25% 1.32% .65 International /Global AmCent Intl Growth INV 1.50% 0.00% -0.15% 1.35% 0.25% 1.60% .35 Htfd GlbI Res HLS IA 0.90% 0.00% 0.11% 1.01% 0.25% 1.26% .25 Htfd Int Opps HLS IA 0.78% 0.00% -0.04% 0.74% 0.25% 0.99% .25 Janus Overseas S 0.64% 0.25% 0.30% 1.19% 0.25% 1.44% .5 Janus Worldwide T 0.52% 0.00% 0.45% 0.97% 0.25% 1.22% .3 Putnam Global Equity A 0.85% 0.25% 0.30% 1.40% 0.25% 1.65% .5 Putnam Intl Growth A 1.08% 0.25% 0.26% 1.59% 0.25% 1.84% .5 Small Cap Invesco SC Growth INV 0.88% 0.25% 0.12% 1.25% 0.25% 1.50% .6 Htfd Sml Company HLS IA 0.78% 0.00% -0.05% 0.73% 0.25% 0.98% .25 Mgrs AMG Skyline SEP 0.90% 0.00% .0.43% 1.33% 0.25% 1.58% .4 Mid Cap Frkln SmMd Cap Grwth A 0.63% 0.25% 0.12% 1.00% 0.25% 1.25% 0.25 %+ .10% + $12/participant file : / /C: \DOCUME-1 \hl70863 \LOCALS -I \Temp \ISOOXYIH.htm 2/24/2012 Htfd MidCap HLS IA Janus Enterprise T Large Cap 0.94% Inv Diversified Div INV AmCent Equity Income INV AmCent Inc & Growth INV AmCentury Ultra INV AmCent Value INV Drey Third Century A DWS Growth & Income S FA Growth & Income T FA Growth Opps T Htfd Cap App HLS IA Htfd Div & Grwth HLS IA Htfd Index HLS IA Htfd Stock HLS IA Janus Twenty T MFS Core Equity A MA Inv Grwth Stck A Putnam MultiCap Gr A Asset Allocation /Balanced Cal VPSRI Bal Prt 1.00% Dreyfus LT G &I R FA Balanced T Htfd Advisers HLS IA Janus Balanced T Bond 1.39% DR INT TRM I A Htfd TotRet Bond HLS IA Htfd US Gov Sec HLS IA MFS High Income A Putnam HY Advantage A 0.66% 0.00% 0.03% 0.69% 0.25% 0.94% .25 0.64% 0.00% 0.34% 0.98% 0.25% 1.23% .3 0.60% 0.17% 0.10% 0.87% 0.25% 1.12% .6 1.00% 0.00% -0.04% 0.96% 0.25% 1.21% .35 0.81% 0.00% -0.12% 0.69% 0.25% 0.94% .25 1.00% 0.00% 0.00% 1.00% 0.25% 1.25% .35 1.00% 0.00% 0.01% 1.01% 0.25% 1.26% .35 0.75% 0.00% 0.64% 1.39% 0.25% 1.64% .5 0.37% 0.00% 0.27% 0.64% 0.25% 0.89% .3 0.20% 0.50% 0.59% 1.29% 0.25% 1.54% .6 0.30% 0.50% 0.45% 1.25% 0.25% 1.50% .6 0.78% 0.00% -0.11% 0.67% 0.25% 0.92% .25 0.78% 0.00% -0.10% 0.68% 0.25% 0.93% .25 0.30% 0.00% 0.05% 0.35% 0.25% 0.60% .25 0.53% 0.00% -0.03% 0.50% 0.25% 0.75% .25 0.64% 0.00% 0.30% 0.94% 0.25% 1.19% .3 0.65% 0.25% 0.28% 1.18% 0.25% 1.43% .65 0.33% 0.25% 0.27% 0.85% 0.25% 1.10% .65 0.70% 0.25% 0.27% 1.22% 0.25% 1.47% .5 0.70% 0.00% 0.21% 0.91% 0.25% 1.16% .15 0.75% 0.00% 0.31% 1.06% 0.25% 1.31% .25 0.15% 0.50% 0.55% 1.20% 0.25% 1.45% .6 0.68% 0.00% -0.03% 0.65% 0.25% 0.90% .25 0.55% 0.00% 0.24% 0.79% 0.25% 1.04% .3 0.45% 0.00% 0.43% 0.88% 0.25% 1.13% .5 0.46% 0.00% 0.05% 0.51% 0.25% 0.76% .25 0.45% 0.00% 0.03% 0.48% 0.25% 0.73% .25 0.46% 0.25% 0.22% 0.93% 0.25% 1.18% .65 0.72% 0.25% 0.07% 1.04% 0.25% 1.29% .5 Page 2 of 4 file: / /C: \DOCUME- 1 \h170863 \LOCALS -1 \Temp \ISOOXYIH.htm 2/24/2012 Page 3 of 4 Stable Value /Money Market Htfd Money Mkt HLS IA 0.40% 0.00% 0.08% 0.48% 0.25% 0.73% You should carefully consider the investment objectives, risks, charges and expenses of The Han'ford's group variable annuities and their underlying funds before investing. This and other information can be hound in the prospectus or disclosure documents, where applicable. To obtain the applicable disclosure documents or underlying fund prospectuses call 1- 800 - 255 -2464. Read them carefully before you invest or send money. This table shows only the asset -based fees, charges and expenses associated with the investment choices of the group variable annuity contract. Please refer to the product prospectus or disclosure documents, as applicable, for information on other fees and charges that may apply to your plan's contract such as a contingent deferred sales charge, annual maintenance fee, and other fees or charges, if applicable. Copyright 2012 Morningstar, Inc. All Rights Reserved. The information contained herein: (1) is proprietary to Morningstar and /or its content providers; (2) may not be copied or distributed; and (3) is not warranted to be accurate, complete, or timely. Neither Morningstar nor its content providers are responsible for any damages or losses arising from any use of this information. t These are the Total Annual Fund Operating Expenses for each underlying fund as of its year -end. Total Annual Fund Operating Expenses are the expenses that are deducted from fund assets, including management fees, Rule 12b -1 distribution and /or service fees, and other expenses. Actual fees and expenses for the underlying funds vary daily. As a result, the fees and expenses for any given day may be greater or less than the Total Annual Fund Operating Expenses listed above in the table. More detail concerning each underlying fund's fees and expenses is contained in the prospectus for each fund. tt The Hartford deducts the mortality, expense risk and administrative charge from the assets of the Separate Account on a daily basis at the annual rate shown above. If the mortality, expense risk and administrative charge under a Contract is insufficient to cover actual costs incurred by us, we will bear the loss. If the mortality, expense risk and administrative charge exceeds these costs, we will keep the excess as profit. We may use these profits, as well as fees and payments received from the fund families, for any proper corporate purpose, including, among other things, payment of sales expenses, including our expenses of paying compensation to broker - dealers, financial institutions and other persons for selling the Contracts. We expect to make a profit from the mortality, expense risk and administrative charge. ttt The Hartford receives these fees and payments with respect to the underlying funds that are offered as investment choices to your Plan through the Contract. We consider these fees and payments, among a number of other factors, when deciding to include a fund in the menu of Funds that we offer through the Contract. We receive these fees and payments under agreements between The Hartford and the principal underwriters, transfer agents, investment advisors and /or other entities related to the Funds. These fees and payments may include asset based sales compensation and service fees under distribution and /or servicing plans adopted by funds pursuant to Rule 12b -1 under the Investment Company Act of 1940. They may also include administrative service fees and additional payments, expense reimbursements and compensation sometimes referred to as "revenue sharing" payments. We receive these fees and payments for our own account and expect to make a profit on the amount of the fees and payments that exceed our own expenses, including our expenses of paying compensation to broker - dealers, financial institutions and other persons for selling the Contracts. Some of the funds are part of our own affiliated family of funds. In addition to any fees and payments The Hartford may receive with respect to those funds, one or more of our affiliates receives compensation from the funds, including among other things a management fee and Rule 12b -1 fees from the funds. 02011 Morningstar, Inc. All Rights Reserved. The information contained herein: (1) is proprietary to Morningstar and /or its content providers; (2) may not be copied or distributed; and (3) is not warranted to be accurate, complete or timely. Neither Morningstar nor its content providers are responsible for any damages or losses arising from any use of this information. file : / /C: \DOCUME- 1\hl70863 \LOCALS-1 \Temp \ISOOXYIH.htm 2/24/2012 Page 4 of 4 Hartford Life Insurance Company 1 Griffin Road North " Windsor, CT 06095 file: / /C: \DOCUME- 1 \h170863 \LOCALS-1 \Temp \ISOOXYIH.htm 2/24/2012