| Return Reference | Explanation |
|---|---|
| FORM 990, PART VI, SECTION B, LINE 9: | THE VANGUARD GROUP, INC. 100 VANGUARD BLVD. MALVERN, PA 19355 |
| FORM 990, PART VI, SECTION A, LINE 8A | THE ORGANIZATION IS A VOLUNTARY EMPLOYEES' BENEFICIARY ASSOCIATION (VEBA) TRUST WHICH FUNDS SEVERAL EMPLOYEE BENEFIT PLANS THAT ARE SUBJECT TO THE FIDUCIARY GOVERNANCE AND OVERSIGHT RULES OF THE EMPLOYEE RETIREMENT INCOME SECURITY ACT OF 1974 (ERISA). AS SUCH, THE EMPLOYER, IN ITS CAPACITY AS THE SETTLOR OF THE VEBA TRUST AND PLAN SPONSOR/NAMED FIDUCIARY OF THE EMPLOYEE BENEFIT PLANS, IS THE GOVERNING BODY OF THE ORGANIZATION. THE EMPLOYER HAS DELEGATED THE ADMINISTRATION OF THE VEBA TO A COMMITTEE WHO IS AUTHORIZED TO ACT ON BEHALF OF THE GOVERNING BODY. ANY DOCUMENTATION OF COMMITTEE MEETINGS HELD OR ACTIONS UNDERTAKEN WITH RESPECT TO THE VEBA TRUST ARE RETAINED IN THE EMPLOYER'S RECORDS. |
| FORM 990, PART VI, SECTION B, LINE 11B | FORM 990 AND RELATED SCHEDULES ARE REVIEWED BY THE CONTROLLER, VICE PRESIDENT OF TALENT OPERATIONS, GENERAL COUNSEL AND CHIEF FINANCIAL OFFICER. AFTER THE REVIEWS ARE COMPLETE, A COPY IS PROVIDED TO THE GOVERNING BODY BEFORE THE RETURN IS FILED WITH THE INTERNAL REVENUE SERVICE. |
| FORM 990, PART VI, SECTION B, LINE 12 | THE ORGANIZATION IS A VOLUNTARY EMPLOYEES' BENEFICIARY ASSOCIATION (VEBA) TRUST WHICH FUNDS SEVERAL EMPLOYEE BENEFIT PLANS THAT ARE SUBJECT TO THE PROHIBITED TRANSACTION AND PARTY-IN-INTEREST RULES OF THE EMPLOYEE RETIREMENT INCOME SECURITY ACT OF 1974 (ERISA). AS SUCH, IT IS NOT NECESSARY FOR THE ORGANIZATION TO SEPARATELY ESTABLISH A CONFLICT OF INTEREST POLICY GIVEN THE PROTECTIONS AFFORDED TO PARTICIPANTS AND BENEFICIARIES UNDER ERISA. |
| FORM 990, PART VI, SECTION C, LINE 19 | THE ORGANIZATION IS A VOLUNTARY EMPLOYEES' BENEFICIARY ASSOCIATION (VEBA) TRUST WHICH FUNDS SEVERAL EMPLOYEE BENEFIT PLANS THAT ARE SUBJECT TO THE DISCLOSURE REQUIREMENTS OF THE EMPLOYEE RETIREMENT INCOME SECURITY ACT OF 1974 (ERISA). AS SUCH, ALL DISCLOSURES ARE MADE IN ACCORDANCE WITH THE REQUIREMENTS OF ERISA TO THOSE PARTIES WITH RIGHTS UNDER ERISA. |
| FORM 990, PART VI, SECTION B, LINE 13: | THE ORGANIZATION IS A VOLUNTARY EMPLOYEES' BENEFICIARY ASSOCIATION (VEBA) TRUST WHICH FUNDS SEVERAL EMPLOYEE BENEFIT PLANS THAT ARE SUBJECT TO THE CIVIL AND CRIMINAL ENFORCEMENT RULES OF THE EMPLOYEE RETIREMENT INCOME SECURITY ACT OF 1974 (ERISA). AS SUCH, IT IS NOT NECESSARY FOR THE ORGANIZATION TO SEPARATELY ESTABLISH A WHISTLEBLOWER POLICY GIVEN THE PROTECTIONS AFFORDED TO PARTICIPANTS AND BENEFICIARIES UNDER ERISA. |
| FORM 990, PART VI, SECTION B, LINE 14: | THE ORGANIZATION IS A VOLUNTARY EMPLOYEES' BENEFICIARY ASSOCIATION (VEBA) TRUST WHICH FUNDS SEVERAL EMPLOYEE BENEFIT PLANS THAT ARE SUBJECT TO THE RECORD RETENTION RULES OF THE EMPLOYEE RETIREMENT INCOME SECURITY ACT OF 1974 (ERISA). AS SUCH, IT IS NOT NECESSARY FOR THE ORGANIZATION TO SEPARATELY ESTABLISH A DOCUMENT RETENTION AND DESTRUCTION POLICY GIVEN THE PROTECTIONS AFFORDED TO PARTICIPANTS AND BENEFICIARIES UNDER ERISA. |
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