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Excessive Trading Policy

Frequent Trading Is Detrimental to the WDC and Its Participants.


Excessive trading is generally defined as purchase and sale transactions by a participant that occur with such frequency and/or in such an amount as to materially affect the fund's ability to meet its investment objective as judged by the fund. It has a detrimental effect on a mutual fund because it disrupts the management of investment options and increases the fund's trading costs. These costs are passed along to all mutual fund shareholders. It can also have a negative impact on the fund by reducing its overall investment returns. To protect shareholders, many mutual fund companies have reserved the right to delay or reject trades and impose fees and trading restrictions for a variety of reasons, including excessive trading.


In January 2003, the Deferred Compensation Board approved an excessive trading policy, which states that all WDC accounts are subject to trading limitations and restrictions imposed by fund companies. The Board and the WDC's recordkeeping firm, Empower Retirement, updated the WDC's excessive trading procedures in May 2006. These procedures are followed when a mutual fund company suspects that excessive trading may have occurred. If Empower Retirement is contacted by a fund company that suspects a WDC participant is engaging in excessive trading, Empower Retirement will provide the fund company with the recent trading activity of the participant. Such information is kept confidential. If the fund company determines the participant is engaging in excessive trading, the WDC will request that the participant cease the excessive trading. Any participant who is notified of an excessive trading problem and does not comply may be restricted from executing future trades through the WDC Web site or via the telephone.


Excessive trading or market timing in your WDC account disrupts management of investment options, increases expenses and negatively affects performance to the detriment of other investors. Many investment providers to the WDC have adopted underlying restrictions and limitations with respect to transfers into and withdrawals from their investment options.


All participant and beneficiary accounts are subject to such restrictions or limitations. In the event that an investment provider identifies a participant or beneficiary account in violation, the Department shall direct the Plan Administrator to take the appropriate action to cause this practice to cease.


To review the specific excessive trading rules for your funds, please click here to read the fund prospectus. Please consider the investment objectives, risks, fees and expenses carefully before investing. For this and other important information, you may obtain prospectuses for mutual funds and/or disclosure documents from your registered WDC representative. Prospectuses can also be obtained online under the Investment tab. For a Self-Directed Brokerage Account prospectus, contact Charles Schwab at (888) 393-7272. Read prospectuses carefully before investing.


Questions?

Contact the local WDC office at (877) 457-WDCP (9327).

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