2010 YEAR-END DATA COLLECTION

1. 2010 YEAR-END DATA COLLECTION ESOP Processing Requirements Presented by: Maureen Hamblin, QPA, QKA Senior Consultant February 2011

2. AGENDA • Allocation Process and Timing • Proxy Process and Timing • ESOP Plan Restatements • Automatic Cashout Processing • Data Requirements • Pentegra Website • Next Year

3. ALLOCATION PROCESS & TIMING • All plans that do not utilize Pentegra Trust Company as their Trustee must provide Pentegra with the following, in good form, in order for Pentegra to begin the allocation process: • Share Release Form • 2010 Census Data File • 2010 Trust Statements

4. ALLOCATION PROCESS & TIMING • Share Release Form • Available on Plan Sponsor site, under Administration, Reports/Downloads, Share Release Form • Complete form and email to ESOP@Pentegra.com or fax to 914-694-6429 • This form is not required if Pentegra Trust Company is your Plan Trustee; confirm with your Account Representative if unsure • 2010 Census Data File • Download from Plan Sponsor site, under Administration, Reports/Downloads, Census Data File Download • 2010 Trust Statements • Email (in PDF format) to ESOP@Pentegra.com • Plans that use Pentegra Trust Company as Trustee do not need to supply copies to Pentegra

5. ALLOCATION PROCESS & TIMING • Once all required items are received by Pentegra in good form, the allocation process may begin • Pentegra will determine eligibility within two weeks of receipt of required information • Plan Sponsor must provide written approval of eligibility • Eligibility must be approved even if there are no shares to allocate

6. ALLOCATION PROCESS & TIMING • Within four weeks of Plan Sponsor approval of eligibility, Pentegra will provide allocation for Plan Sponsor approval • Plan Sponsor must provide written approval of allocation • Allocation must be approved even if there are no shares to allocate • Within five days of Plan Sponsor approval of allocation, Pentegra will provide 2010 participant statements to Plan Sponsor for distribution to participants • Once the allocation is complete, on-demand allocation reports and participant statements may be generated on the Plan Sponsor site

7. PROXY PROCESS & TIMING • All plans must provide Pentegra with the following, in good form, in order for Pentegra to begin the proxy process: • Proxy Voting Form • Available on Plan Sponsor site, under Administration, Forms/Manual, Proxy Voting Form • Complete form and email or fax to your Account Representative • Proxy process cannot begin until this form is received • A single Proxy Voting Form may be completed for ESOP and 401(k) stock plans • The Proxy Voting Form must be provided even if Pentegra Trust Company is your Plan Trustee

8. PROXY PROCESS & TIMING • Request for Pentegra Trust Company return envelopes • Applicable only if Pentegra Trust Company is your ESOP trustee • Applicable only if Pentegra Trust Company will be tallying the proxy votes for your ESOP • Indicate the number of envelopes requested clearly on the Proxy Voting Form • Proxy files will be provided two days after the record date

9. ESOP PLAN RESTATEMENTS • The IRS requires that qualified plans are restated according to a 5-year cycle • If your plan EIN ends in a “0” or “5”, your plan is a Cycle E plan and the document must be restated no later than January 31, 2011 • If your ESOP attorney has restated your ESOP document, you must provide Pentegra with the latest version of the document (electronic format preferred) • Email to your Plan Consultant • Include copies of latest IRS determination letter and trust agreement, as applicable • If you have not received a restated document from your ESOP attorney, confirm the plan is a Cycle E plan and the filing is necessary at this time

10. AUTOMATIC CASHOUT PROCESSING • Automatic Cashouts – depending on your plan, the Automatic Cashout limit may be $1,000 or $5,000 • Upon request, Pentegra will determine what terminated vested participants may be automatically “cashed out” in order to receive a distribution from the plan, without participant approval • Once you provide written approval and direction for Automatic Cashouts to be processed, Pentegra will process distributions for these participants, either as checks directly to the participant or IRA rollover • Normal billing fees apply to these distributions • Automatic Cashout determinations may not be made or processed until the 2010 annual allocation process has been completed and participant statements have been provided; Plan Sponsors must initiate the Automatic Cashout request

11. DATA REQUIREMENTS • All plans must provide complete data for current plan participants, as well data for any employees that have not met the participation requirements • The Census Data File Download will include all data we have on file for current plan participants. Plan sponsors must provide data for any new participants as well as report the following for current participants each year: • Termination Date • Hours • ESOP Plan Salary • Percentage of Stock Ownership • Officer Status • Family Members

12. DATA REQUIREMENTS • ESOP with Pentegra 401(k) Plan • A single Census Data File Download may be run for the ESOP and 401(k) plans • Run the Census Data File Download for your 401(k) plan; this file will include a column for ESOP Plan Salary (usually after the last 401(k) column) • ESOP Plan Salary may differ from Box 1 W2 compensation used for 401(k) ADP/ACP testing. IF your ESOP plan salary differs from Box 1, you must supply both types of salary.

13. DATA REQUIREMENTS • ESOP with no Pentegra 401(k) Plan • If you have any other plan(s) with Pentegra, but no 401(k) plan administered by Pentegra, the Census Data File Download must be run for your ESOP in addition to any data you supply separately for other plans

14. DATA REQUIREMENTS • Additional Items (as applicable) • If your ESOP considers partial-year ESOP compensation, you must add it as a separate column • Name this column “Partial Year ESOP Plan Salary” • If an employee is excluded from your ESOP, but is not excluded from receiving your 401(k) plan matching contribution, you must add this as a separate column • Name this column “ESOP Excluded Status” • Update Date of Birth and Date of Hire that are blank for any current participants • Include Date of Birth and Date of Hire (plus all other applicable fields) for any new employees

15. DATA REQUIREMENTS • ESOP data should include all employees who were paid during 2010 (include any employee who received a W2 for 2010, even if they terminated or did not meet plan eligibility or allocation requirements) • Hours should be included for all employees • Indicate 0 for less than 500 (do not leave blank) • Include hours even if the employee terminated during 2010 • If a participant terminated in a prior plan year, but no Date of Termination is included in the Census Data File Download, update the Date of Termination

16. PENTEGRA WEBSITE • All Plan Sponsor representatives should have a username and password for the Plan Sponsor site • Contact your Account Representative if you need additional logins • You can confirm who has website access via the Contact Us section of the Plan Sponsor site • Each plan has a separate username and password • Make sure you can accept messages from YourAdvantage@Pentegra.com to ensure the most up to date information • Work with your internal IT Dept • Contact your Account Representative

17. PENTEGRA WEBSITE • www.pentegra.com • Login/Plan Sponsor • Administration • Reports/Downloads • Instructions to Upload/Download Census Data File • Census Data File Download • ESOP Processing Requirements • Share Release Form • Important Dates • 5500 Information and Timing • Administrative Reports • Employee Data • Forms/Manual • Proxy Voting Form • Proxy Process Overview Guidelines • Reliance Dividend Procedures • File Uploads

18. PENTEGRA WEBSITE • Activity • Demographics • Basic Data • Addresses • Learning Center • Annual Limitations • SAS 70 Report • Contact Us • Pentegra Contact Information • Plan Consultant • Account Representative • Compliance Analyst

19. NEXT YEAR • Contact your Account Representative with any ESOP processing questions • If your accountants require an estimated ESOP allocation for certain Highly Compensated Employees (HCEs), request from your Account Representative at least 30 days prior to due date. • Email distribution requests (PDF format preferred) • Contact your Plan Consultant with any ESOP plan design questions or changes • Plan amendments are required for any plan changes (prior to effective date of change) • Annual ESOP plan review • Your ESOP Compliance Analyst will work with you on the ESOP Form 5500 and audit requirements • Most ESOP audit items are available for download from the Plan Sponsor and Reliance websites

20. NEXT YEAR • Plan Sponsors must distribute Summary Plan Description (SPD) to all participants, for any plans that have been restated. • Plan Sponsors must distribute Summary Annual Report (SAR) to all participants upon completion of Form 5500 • Your ESOP is a valuable benefit! Educate employees about the plan via employee education webcasts or meetings