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HomeMy WebLinkAboutExhibit A FR/SREXHIBIT A NIIAMI FIRE FIGHTERS' RELIEF AND PENSION FUND 11,3 -?(/6( MIAMI FIRE FIGHTERS' RELIEF AND PENSION FUND TABLE OF CONTENTS Section 1 Introduction 1 Section 2 Definitions 1 Section 3 Funding 11 Section 4 Participation 12 Section 5 Allocation To Accounts 13 Section 6 Benefits 15 Section 7 Administration 37 Section 8 Miscellaneous Provisions 41 MIAMI FIRE FIGHTERS' RELIEF AND PENSION FUND Section 1 Introduction The purpose of this ordinance is to implement the provisions of Chapter 19112, Acts of Florida, 1939 and Chapter 175, Florida Statutes, and to provide means whereby Fire Fighters of the City of Miami, Florida may receive benefits from the funds provided for that purpose by Chapter 19112, Acts of Florida,. 1939 and Chapter 175, Florida Statutes. The fund hereby created shall be in addition to any other pension plan of the City of Miami, Florida and nothing herein shall in any way affect the operation of, or the benefits under, any other pension plan of the City of Miami, Florida that presently exists. Section 2 Definitions The following words and phrases shall, for the purpose of this ordinance, have the meanings indicated below. (a) "Account" means the account credited with contributions under Section 3, eligible forfeiture contributions pursuant to Section 5, eligible rollover contributions pursuant to Section 3(e), and earnings on those contributions. (b) "Account Balance" means the value of the Account as of the last valuation date in the calendar year immediately preceding the distribution calendar year (valuation calendar year) increased by the amount of any contributions made and allocated or forfeitures allocated to the Account Balance as of dates in the valuation calendar year after the valuation date and decreased by distributions made in the valuation calendar year after the valuation date. The Account Balance for the valuation calendar year includes any amounts rolled over or 1 (c) transferred to the Plan either in the valuation calendar year or in the distribution calendar year if distributed or transferred in the valuation calendaryear. "Active Duty" means service for which an employee receives compensation as a Fire Fighter with Permanent Status in the Fire Department of the City. (d) "Annual Addition" means the following amounts credited to a Participant for a calendar year under this Plan: (I) Plan Contributions under Section 3(a); (II) Forfeitures under Section 5(b); (III) Similar contributions or amounts under such other plans deemed to be maintained by the Participant under the Code; and (IV) Any additional amounts required by regulations under Code section 415. (d) "Beneficiary" means any person, persons or entity designated by a Participant to receive any benefits payable in the event of the Participant's death. If no Beneficiary designation is in effect at the Participant's death, or if no person, persons or entity so designated survives the Participant, the Participant's surviving spouse, if any, shall be deemed to be the Beneficiary; otherwise the Beneficiary shall be the Participant's estate. ff . (e)-"Board" means the Board of Trustees named to supervise and administer the Fund, as provided in Section 7. (1)-"City" means the City of Miami, Florida, and the lands under its jurisdiction from time to time, as determined by law. (h) (g) !'Code" means the Internal Revenue Code of 1986, as from time to time amended. (h) "Compensation" means the remuneration paid a Fire Fighter for services rendered to the City. Compensation in excess of limitations set forth in Section 401(a)(17) of the Code shall be disregarded. (I) The Participant's Compensation contributed as employee -elective salary reductions or deferrals to any salary reduction, deferred compensation, or tax-sheltered annuity program authorized under the Internal Revenue Code shall be deemed to be the Compensation the member would receive if he or she were not participating in such program and shall be treated as Compensation for retirement purposes under this chapter. (II) The Participant's Compensation or Salary does not include: (1) any contributions (other than elective contributions described in Internal Revenue Code Sections 402(e)(3), 408(k)(6), 408(p)(2)(A)(i) or 457(b)) made by the Employer to a plan of deferred compensation (including a simplified employee pension described in Code Section 408(k) or a simple retirement account described in Code Section 408(p), and whether or not qualified) to the extent that the contributions are not includible in the gross income of the Participant for the taxable year in which contributed. In addition, any distributions from a plan of deferred compensation (whether or not qualified) are not considered Compensation, regardless of whether such amounts are includible in the gross income of the Participant when distributed. 3 (2) Any amounts that receive special tax benefits, such as premiums for group term life insurance (but only to the extent that the premiums are not includible in the gross income of the Participant and are not salary reduction amounts that are described in Code Section 125). (III) For any person who first becomes a Participant in any plan year beginning on or after January 1, 1996, Compensation for any plan year shall not include any amounts in excess of the Section 401(a)(17) limitation (as amended by the Omnibus Budget Reconciliation Act of 1993), which limitation of $150,000 shall be adjusted as required by federal law for qualified government plans and shall be further adjusted for changes in the cost of living in the manner provided by Internal Revenue Code Section 401(a)(17)(B). For any person who first became a member prior to the first plan year beginning on or after January 1, 1996, the limitation on Compensation shall be not less than the maximum compensation amount that was allowed to be taken into account under the plan as in effect on July 1, 1993, which limitation shall be adjusted for changes in the cost of living since 1989 in the manner provided by Internal Revenue Code Section 401(a)(17). (IV) Annual Compensation means Compensation paid during the Plan Year or such other consecutive 12-month period over which Compensation is otherwise determined under the Plan ("determination period"). The cost -of -living adjustment in effect for the calendar year applies to annual Compensation for the determination period that begins with or within such calendar year. Amounts under Code Section 125 exclude any amounts not available to a Participant in lieu of group health coverage (deemed Code Section 125 compensation). An amount will be treated as an amount under 4 Code Section 125 only if the Employer does not request or collect information regarding the Participants' other health coverage as part of the enrollment process for the health plan. (i)-"Credit" means, with respect to any Participant, each calendar month during which he is on Active Duty for at least 15 days. (k) (})-"Designated Beneficiary" means the individual who is designated by the Participant (or the Participant's surviving spouse) as the Beneficiary of the Participant's interest under the Fund and who is the designated beneficiary under § 401(a)(9) of the Code and § 1.401(a)(9)- 4 of the regulations. (11) (k) "Direct rollover" means a payment by the Fund to the eligible retirement plan specified by the Distributee. (I)-"Disabilitv" means total and permanent disability, as defined herein: (I) Total Disability means a situation where, if, in the opinion of the Board of Trustees, the Fire Fighter is wholly prevented from rendering useful and efficient service as a Fire Fighter; and (11) Permanent Disability means a situation where, in the opinion of the Board of Trustees, the Fire Fighter is likely to remain so disabled continuously and permanently from a cause other than is specified in Section 2(m)(III)(1). (III) A Fire Fighter will not be entitled to receive any Disability Retirement Benefit under Section 6(c) if the Disability is a result of: 5 (1) Excessive and habitual use by the Fire Fighter of drugs, intoxicants, or narcotics: (2) Injury or disease sustained by the Fire Fighter while willfully and illegally participating in fights, riots, or civil insurrections or while committing a crime; (3) Injury or disease sustained by the Fire Fighter while serving in any armed forces; or (4) Injury or disease sustained by the Fire Fighter after his or her employment has terminated. (IV) No Fire Fighter shall be permitted to retire due to Disability until he or she is examined by a duly qualified physician or surgeon, to be selected by the Board of Trustees for that purpose, and is found to be disabled in the degree and in the manner specified in Section 175.191, Florida Statutes. Any Fire Fighter retiring due to Disability may be examined periodically by a duly qualified physician or surgeon or board of physicians and surgeons, to be selected by the Board of Trustees for that purpose, to determine if such disability has ceased to exist. (m) "Distributed Participant" means any Participant who no longer has an account balance in the Fund and has no credit due for prior service. {n) "Distributee" means an employee or former employee. In addition, the employee's or former employee's surviving spouse are distributees with regard to the interest of the spouse or former spouse. 6 (o) "Distribution Calendar Year" means a calendar year for which a minimum distribution is required. For distributions beginning before the Participant's death, the first distribution calendar year is the calendar year immediately preceding the calendar year which contains the Participant's Required Beginning Date. For distributions beginning after the Participant's death, the first distribution calendar year is the calendar year in which distributions are required to begin under Section 6(h)(II)(2). The required minimum distribution for the Participant's first distribution calendar year will be made on or before the Participant's Required Beginning Date. The required minimum distribution for other distribution calendar years, including the required minimum distribution for the distribution calendar year in which the Participant's Required Beginning Date occurs, will be made on or before December 31 of that distribution calendar year. (p)-"DROP Participant" means any Participant who has elected to participate in the deferred retirement option program (DROP) from the City of Miami Fire Fighters' and Police Officers' Retirement Trust (FIPO). (q) "Eligible Retirement Plan" means any of the following types of plans that accept the distributee's eligible rollover distribution: (I) a qualified plan described in Section 401(a) of the Code; (II) an annuity plan described in Section 403(a) of the Code:, (III) an individual retirement account or individual retirement annuity described in Section 408(a) or 408(b) of the Code, respectively; (IV) an annuity contract described in Section 403(b) of the Code; and 7 (V) an eligible plan under Section 457(b) of the Code which is maintained by a state, political subdivision of a state, or any agency or instrumentality of a state or political subdivision of a state and which agrees to separately account for amounts transferred into such plan from this Fund. (r3—"Eligible Rollover Distribution" means any distribution of all or any portion of the balance to the credit of the distributee, except that an eligible rollover distribution does not include: (I) any distribution that is one of a series of substantially equal periodic payments (not less frequently than annually) made for the life (or life expectancy) of the distributee or the joint lives (or joint life expectancies) of the distributee and the distributee's designated beneficiary, or for a specified period of ten years or more; and (II) any distribution to the extent such distribution is required under Section 401(a)(9) of the Code; and (III) after-tax amounts unless such amount is transferred to an individual retirement account or individual retirement annuity described in Section 408(a) or 408(b) of the Code, respectively, or transferred to a defined contribution plan qualified under Section 401(a) of the Code that agrees to separately account for such amount. ft) "FIPO" means the City of Miami Fire Fighters' and Police Officers' Retirement Trust, a defined benefit plan established by the City of Miami, Florida. (s) "FIPO DROP Account" means a DROP account under FIPO. 8 (t)-'Fire Fighter" means anyone defined as a firefighter in Chapter Section 175.032, Florida Statutes, as amended. (u) "Fund" means the Miami Fire Fighters' Relief and Pension Fund, as provided for herein. (v) "Fund Year" means the calendar year, which shall be the fiscal year on which the Fund's records shall be kept. (yl (w) "Leave" means (I) any period during which an employee is absent due to (li) service in the uniformed services of the United States; `2i4) the birth or adoption of a child, or caring for a child, spouse or parent who has a serious health condition or (iii) his own serious health condition if Credit or Vesting Service, as the case may be, is required to be given for such periods under the Uniformed Services Employment and Reemployment Rights Act of 1994 or the Family and Medical Leave Act of 1993, respectively, and (II) any other period of leave as approved on a non-discriminatory basis by the Board. (x) "Life Expectancy" means the life expectancy as computed by use of the Single Life Table in § 1.401(aX(9)-9, Q&A-1, of the regulations. (aa) "Maximum Permissible Amount" means the maximum Annual Addition that may be contributed or allocated to a Participant's Account under the Plan for any calendar year in accordance with Treasury Regulation 1.415(c)-1(a)(1), which is the lesser of $40,000, as adjusted for cost -of -living under Code section 415(d) or 100% of a Participant's Compensation for such calendar year. (bb) (y) "Participant" means every Fire Fighter in Permanent Status. 9 (cc) (z) "Permanent Status" means employment as a Fire Fighter who has been regularly appointed, after serving a probationary period not to exceed two years, to a position which normally involves continuous year-round service. (dd) (aa) "Plan" means the Miami Fire Fighters' Relief and Pension Fund, as provided for herein. (ee) (cc) "Required Beginning Date" means the later of the April 1 following (i) the calendar year in which the Participant attains age 70'A or (ii) the calendar year in which the Participant terminates his employment. (ff) (dd) "State" shall mean the State of Florida. (gg) (ee) "Trustee" means any member of the Board. (hh) (ff) "Valuation Date" means the first business day of any calendar quarter and such other dates as the Board may deem necessary. ii (gg)-"Vesting Service" means, with respect to a Participant, each calendar month as a Participant for which he receives compensation from the City for at least 15 days; and each calendar month during which he is absent on a Leave for at least 15 days; provided, however, Vesting Service shall not include any Leave within the meaning of paragraph (k)(II) of Sep on 2 Section 2(x)(II) which exceeds five years. Section 3 Funding (a) Contributions. The City shall contribute to the Fund each year an amount equal to the amount it receives under the provisions of Chapter 175, Florida Statutes, as amended. The City shall make its contributions to the Fund as soon as possible but in no event later than 10 five days of its receipt of such amount. The City shall not be required to levy any additional taxes on its residents to make any contributions to the Fund. Notwithstanding anything in this subsection (a) to the contrary, premium to the contrary in this subsection (a), premium tax revenues received in calendar year 2013 in the amount of $3,380,875, and premium tax revenue received in calendar year 2014 in the amount of $3,380,875, shall be transferred from the Fund to the City of Miami Fire Fighters' and Police Officers' Retirement Trust ("FIPO") to reduce the City's annual required contribution to FIPO for the 2012-2013 and 2013-2014 plan years. Provided, if the actual amount of premium tax revenues received in calendar year 2013 or 2014 is less than $3,530,875, then the actual amount received less the administrative cost of the Fund shall be transferred to FIPO to reduce the City's annual required contribution to FIPO for the 2012-2013 and 2013-2014 plan years, respectively. The transfer of premium tax revenues provided in the preceding sentences shall occur within ten days following the date the premium tax revenues are received by the Fund, and in no event later than October 31, 2013 for the 2012-2013 plan year and September 30, 2014 for the 2013-2014 plan year. In the event the transfer of premium tax revenues provided above is not approved by the Florida Division of Retirement, contributions to FIPO shall be increased by a percentage of firefighter payroll that equals $3,380,875, annually for each year that the transfer of premium tax revenues is not approved and premium tax revenues equal to $3,380,875 shall be transferred from the Fund to FIPO and used to reduce the employee contribution back to the current level. Payment of Costs, Expenses and Fees. All costs, expenses and fees of administering the Fund shall be paid from the assets of the Fund in such fashion as the Board shall determine. 11 (c) Exclusive Benefit Rule. No part of the corpus or income of the Fund shall be used for, or diverted to, purposes other than for the exclusive benefit of Participants and other persons entitled to benefits under the Fund and paying the expenses of the Fund not paid directly by any other party. No person shall have any interest in, or right to, any part of the earnings of the assets of the Fund, or any right in, or to, any part of the assets held under the Fund, except as and to the extent expressly provided in this ordinance. (d) Custody of Fund Assets. The Board shall hold all assets of the Fund in trust solely for use in paying the benefits provided by this ordinance and paying the expenses of the Fund as described in paragraph (b) of this Section 3 Section 3(b). The Board shall deposit all assets of the fund held in cash in a National or State chartered financial institution whose deposits are Federally insured. The Board shall keep all securities and evidences of ownership of other assets of the Fund in a safe deposit box or shall deposit them with a corporate custodian. Current inventories of such securities and other assets shall be kept as a part of the permanent records of the Board, which will be audited annually by a Certified Public Accountant. Section 4 Participation. (a) Participation. An Account shall be established for each Participant on the effective date of this ordinance and for each Fire Fighter who attains Permanent Status subsequent to the (b)_ Termination of Participation. Every Fire Fighter who becomes a Participant shall remain a Participant until his Account is fully distributed to him. If a former Fire Fighter on the reemployment register due to a layoff is rehired within three years of his layoff, the Board 12 may, in its sole discretion, give him credit for his prior Vesting Service; provided, however, the Board shall exercise its discretion in a uniform and non-discriminatory manner with respect to all persons similarly situated. Section 5 Allocation To Accounts (a) Allocation of Contributions. As of each Valuation Date, all contributions made by the City since the preceding Valuation Date shall be allocated among the Participants' Accounts. The allocation shall be made solely in the proportion the total number of months of Credit accrued by each Participant in the immediately preceding calendar year bears to the total months of Credit of all Participants in that calendar year with no credit given on account of a Participant's seniority, rank or Compensation. (b) Allocation of Forfeitures. As of the last Valuation Date in each Fund Year, and at such other Valuation Dates as the Board may determine, all amounts forfeited under pas (a) and (d) of Section 6 Section 6(a) and Section 6(e -) since the preceding date as of which forfeitures were allocated shall be prorated and credited to the Accounts of the individual Participants in the same manner as the City's contributions allocated under paragraph (a) of this Section 5 Section 5(a). (c) Allocation of Accounts. A Participant may elect, in a time and manner determined by the Board, to allocate under paragraphs (a) and (b) of this Section 5 and such portion of his existing Account as the Board may, in its sole discretion, determine, to a separate investment account established by the Board pursuant to paragrapl (e)TTI of Section 7 Section i(�.(e)(-II). Any allocations 13 made pursuant to this paragraph (c) Section 5(c) shall become effective as of the first Valuation Date after the expiration of any notice period established by the Board. (d) Allocation of Investment Gains. The Board shall value the Fund's assets as of each Valuation Date and shall allocate to the Account of each Participant his share of the increase or decrease in the fair market value of the Fund's assets. If a separate investment account has been established by the Board pursuant to paragraph (o)IT) of Section 7 Section 4-7(,e)(-I�, it shall be valued separately from the rest of the Fund and the Board shall allocate to the Account of each Participant his share of the increase or decrease in the fair market value of the separate investment account's assets. The Participant's share of the increase or decrease in the fair market value of the Fund or the separate investment account shall bear the same ratio to the total amount of the increase or decrease in the Fund or the separate investment account, as the case may be, as the value of the portion of the Participant's Account invested in the Fund or the separate investment account bears to the total value of the Fund or the separate investment account, as the case may be. (e) Allocations After Termination. Except as otherwise provided in this paragraph (e) Section 5(e), no amounts shall be credited to a Participant's Account under paragraph (a) and (b) of this Section 5 Section 5(a) and Section 5(b) after he ceases to be on Active Duty. However, until completely distributed to him, the Account of a Participant not on Active Duty shall continue to be invested as part of the Fund and shall continue to share in the investment gains and losses of the Fund in accordance with the provisions of paragraph (d) of this Section 5 Section 5(d). A Participant shall continue to receive allocations of contributions and forfeitures under paragraphs (a) and (b) of this Section 5 Section 5(a) and Section 5(b) after 14 (f) (g) he ceases to be on Active Duty if such contributions and forfeitures are attributable to a period when he was on Active Duty. Determination of Account Value. Whenever an event requires the determination of the value of a Participant's Account, the value shall be computed as of the Valuation Date coincident with or immediately following the date of the determination. Maximum Allocation Limitation. Notwithstanding any provision of this ordinance to the contrary, the Maximum Permissible Amount allocated to the Participant's Account for any calendar year under the provisions of paragraphs (a` and (b` of ths Sectio 5 Section 5(a) and Section 5(b) shall not exceed the limitations set forth in Section 415 of the Code and any regulations issued thereunder. Section 6 Benefits A Participant shall receive a benefit from the Fund upon his termination of employment, disability, retirement or death in accordance with this Section 6. However, no Participant shall receive a benefit from the Fund in excess of the amount credited to his Account. (a) Termination of Employment. Except as otherwise provided in this Section 6, if a Participant terminates his employment with the Fire Department for any reason whatsoever prior to completing nine years of Vesting Service, he shall receive a benefit equal to the vested portion of his Account determined as follows: Years of Vesting Service Vested Portion of Account Less than 3 years 25% 3 years but less than 6 years 50% 15 (b) 6 years but less than 9 years 75% 9 or more years 100% The portion of the Participant's Account which is not vested on his termination of employment shall be forfeited and allocated to the Accounts of all remaining Participants in accordance with the provisionsof paragraph (b) of Section 5 Section 5(b). Notwithstanding the foregoing, a Participant shall be 100% vested in, and have a non -forfeitable right to, his entire Account f on the termination of the Fund or the complete discontinuation of the City's contributions to the Fund, (ii) upon attainment of "normal retirement age" as such term is defined in Section 411(a)(8) of the Code and (iii) in any eligible rollover contributions made to the Fund pursuant to paragraph (j) of Section 6 Section 6(i). Death. If a Participant dies before payment of his benefits begin, the Participant shall be deemed to be 100% vested in his entire Account and the entire amount of his Account shall be paid to his Beneficiary. The. Board may requireand rely upon such proof of death and such evidence of the right of any Beneficiary or other person to receive the value of the Account of a deceased Participant as the Board may deem proper and its determination of the right of that Beneficiary or other person to receive payment shall be conclusive. (c) Retirement or Disability. A Participant who retires by reason of length of service or disability under any other pension plan of the City shall receive the entire amount of his Account. (d) Forfeiture for Cause. 16 al Notwithstanding anything in this ordinance to the contrary, if a Participant is convicted of a specified offense, the provisions of ChapterSection 112.3173, Florida Statutes, as amended, from time to time., shall apply and he shall forfeit all rights to receive a benefit from the Fund in accordance with the provisions of such ChapterSection. For purposes of this paragraph (d) Section 6(d), "convicted" and "specified offense" shall have the meanings given to them in ChapterSection 112.3173. ICI In addition, upon conviction of any violation in which a Participant or beneficiary willfully and knowingly makes, or causes to be made, or assists, conspires with, or urges another to make, or causes to be made, any false, fraudulent, or misleading oral or written statement or withhold or conceal material information to obtain any benefit under the Plan, the provisions of Section 175.195, Florida Statute& as amended, shall apply and a Participant or beneficiary receiving funding under this Plan may, in the discretion of the Board of Trustees, be required to forfeit the right to receive any or all benefits to which the person would otherwise be entitled under this Plan. For purposes hereunder, "conviction" means a determination of guilt that is the result of a plea or trial, regardless of whether adjudication is withheld. (e) Form of Benefit. A Participant shall receive his benefit in a single lump sum unless he elects to take it in one of the following optional forms: al Equal annual payments over a period, designated by the Participant, not to exceed the life expectancy of the last to survive of the Participant and his Beneficiary. In the event the Participant dies before all installments have been paid, the remaining 17 balance in his Account shall be paid in an immediate lump sum to his Beneficiary, if still living, or if the Participant does not have a Beneficiary or if the Beneficiary has predeceased the Participant, to the Participant's estate. Uponwritte„ regue t of the portion of his unpaid Account after payment of the benefit has commenced. Notwithstanding the foregoing, if the value of the Participant's Account does not exceed $1,000, the vested value of the Participant's Account shall be paid from the Plan pursuant to this Section 6 in a lump -sum. The value of the Participant's vested Account for purposes of this Section 6(e)(I) shall be determined by including rollover contributions (and earning allocable thereto) within the meaning of Code Section 402(c), 403(a)C4), 403(b)(8), 408(d)(3)(a)(ii), and 457(e)(16). al A combination of a lump sum and annual installments as provided in sub 4) Section 6(e)(I) above. A written notice of election to receive payments in an optional form must be filed with the Board upon a form prescribed by the Board, and must be sworn to by the person entitled to receive such monies. Upon written request of the Participant (or his Beneficiary in the event of the Participant's death), the Board may permit the Participant (or his Beneficiary, as the case may be) to withdraw all or any portion of his unpaid Account after payment of the benefit has commenced. The Board may, upon written request by the Participant, or by a dependent when authorized by either a Participant or Beneficiary, authorize the Fund to withhold from the annual payments those funds that are necessary to pay for benefits being received through the City; to pay the certified bargaining agent of the City; or to make any 18 payments for child support or alimony. The Board may, upon written request of the Participant, recognize elections made pursuant to Section 845 of the Pension Protection Act of 2006 or otherwise. Payment of Benefits. Benefits under this Section 6 shall be payable as soon as possible following the Valuation Date coincident with or next following the Participant's termination of employment with the Fire Department unless the Participant elects, in a time and manner determined by the Board, either (i) to have his benefits commence as of a later Valuation Date or (ii) to transfer up to his vested balance (determined in accordance with paragraph (a) of this Sectio„ 6 Section 6(a)) prior to the Participant's termination of employment for the sole purpose of purchasing credited service in the City of Miami Fire Fighters' and Police Officers' Retirement Trust pursuant to paragraph {g) of this Section 6 Section 6(g). However, in no event shall benefits commence after the first Valuation Date coincident with or immediately following the later of the Participant's -Required Beginning Date under 65th Section 6(h) or his termination of employment with the Fire Department. Payment of a Participant's Account as provided in this Section 6 shall be in full settlement of all claims of a Participant against the Fund. Purchase of Credited Service. Upon approval of the Board of Trustees of the City of Miami Fire Fighters' and Police Officers' Retirement Trust, a Participant shall be permitted to purchase credited service in, and in accordance with the provisions of, that trust, prior to the Participant's termination of employment using benefits paid by the Fund under paragraph-(4) of this Section 6 Section 6(f). 19 (h) Required Distributions. In no event shall the provisions of this ordinance operate so as to allow the distribution of a Participant's Account to begin after the later of the April 1 he terminates his employment on after (the Participant's Required Beginning Date4-as such term is defined in Section 2(ee). In the event a Participant is required to begin receiving elect to receive payments while in service in accordance with option (I) or (II) as follows: (1) A Participant may receive one lump sum payment on or before his required beginning ual lump sum -payments -thereafter -of satisfy-the-minimum-distfibutien-Fequirements-ef-Seetien-40-1-(a)(9)-ef-the-Cede the Participant and his Beneficiary. Such life expectancy will not be recalculated. An election under this paragraph (h) shall be made by a Participant by giving written notice to the Board within the 90 day period prier to his required beginning date. Upon the in accordance with the provisions of this Section 6. In the event a Participant fails to make (II) above. distributions from the Fund shall conform to the regulations issued tinder Section 101(a)(9) 20 Code. Further, such regulations shall override any provision of this ordinance that is ine nsi to t „ itl, Section '10 (a(o) eft a Cod0 or after January 1, 2007, the Plan will apply t '101(a)(9) that were proposed on January 17, 2001. (I) With respect to distributions made for distribution calendar years beginning on and after January ,, 2007, tIle Plan , ,:l appl„ the ,,, ,,, distr;b„to,, r mentn of Section '101(a)(9) of the Code in accordance with the regulations under Section 401(a)(9) that wcrc (B), as follows: (A) One lump sum payment en or before the Participant's required beginning .sate a ,a t^ hie entire Account balance. or Eu) n „nual ents ^f the .,, ,nt „ t,, satisfy the rements of Section 101(a)(9) of the Code. With respect to distribution calendar years commencing on and after January 1, 2007,n c nt Gh ll tt, be e to f. o (1) the quotient obtained by dividing the Participant's Accounts by the di-sst rvution- perio--n^r--cntl'e-Uniforrm r—nrretime—Table—s t f rth Se tie 21 (2) if the Participant% sole designated beneficiary for the distribution calendar year is the Participant's spousc, the quotient obtained by dividing the forth in Section 1.101(a)(9) 9 of the Treasury regulatiens, using the An election under this Section shall be made by a Participant by giving written notice to the Board within the 90 day period prior to his required beginning datc. The Lion ^72 a de T tho t . Panic t f i t� ke �tHi�9$eS-{-�f-��cxvrr�s-vrtl3$-�vu�� u�-mcrpc'arrzzzirs-co�nmcv abeam n n Code and Section 1.101(a)(9) 1, Q&A '1 of the Treasury regulations. (ii) "Distribution calendar year" means a calendar year for which a 11 1 11 1 s Accounts of the last Val„ntio., Date r. the c lender . iediately preceding the -distribution calendar year ("valuation calendar year") incre :red by he a unt of contributions made and allocated or f rfeitaFes allocated to thc Participant's Accounts as of dates in the valuation calendar year after such last Valuation Date and decreased by distributions made in the valuation calen yeaar a 'er suc t-31eluaton Dates. TTe—rPa tieipa ''s Aeeeunts for year if distrib„ter? or transf rred in the valuation calendar ,mar beginning with the first distribution calendar year and up to and including the distribution calendar year that includes the Participant's date of death. established by thc Board pursuant to paragraph (e)(II) of Section 7 and the value of constitute an annuity starting date for purposes of Sectiox 72 of the Code. In the nde aoaerda ee with the proviniona cif Subaeetie (ll)(B) above 23 The provisions of Section 401(a)(9) of the Code -and the regulations thereunder shall (i) General Rules (1) Notwithstanding any other provision of this Fund, all distributions from the Fund shall conform to the requirements of Section 401(a)(9) of the Code, including the incidental death benefit provisions of Section 401(a)(9)(G) of the Code. Such requirements shall be administered in accordance with the regulations issued under Section 401(a)(9) of the Code. (2) Effective Date. The provisions of this Section 6(i) will apply for purposes of determining required minimum distributions for calendar years beginning with the 2003 calendar year. (3) TEFRA Section 242(b)(2) Elections. Notwithstanding the other provisions of this Section 6(h), distributions may be made under a designation made before January 1, 1984, in accordance with section 242(b)(2) of the Tax Equity and Fiscal Responsibility Act (TEFRA) and the provisions of the Plan that relate to section 242(b)(2) of TEFRA. (II) Time and Manner of Distribution. (1) Required Beginning Date. The Participant's entire interest will be distributed, or begin to bedistributed, to the Participant no later than the Participant's Required Beginning Date. 24 (2) Death of Participant Before Distributions Begin. If the Participant dies before distributions begin, the Participant's entire interest will be distributed, or begin to be distributed, no later than as follows: (a) If the Participant's surviving spouse is the Participant's sole designated beneficiary, then distributions to the surviving spouse will begin by December 31 of the calendar year immediately following the calendar year in which the Participant died, or by December 31 of the calendar year in which the Participant would have attained age 70 1/2, if later. (b) If the Participant's surviving spouse is not the Participant's sole designated beneficiary, then distributions to the designated beneficiary will begin by December 31 of the calendar year immediately following the calendar year in which the Participant died. (c) If there is no designated beneficiary as of September 30 of the year following the year of the Participant's death, the Participant's entire interest will be distributed by December 31 of the calendar year containing the fifth anniversary of the Participant's death. (d) If the Participant's surviving spouse is the Participant's sole designated beneficiary and the surviving spouse dies after the Participant but before distributions to the surviving spouse begin, this Section 6(h)(II)(2), other than Section 6(h)(II)(2)(a), will apply as if the surviving spouse were the Participant. For purposes of this Section 6(h)(II)(2) and Section 6(h)(IV)(2) unless Section 6(h)(II)(2)(d) applies, distributions are considered to begin on the participant's Required Beginning Date. If Section 6(h)(II)(2)(d) applies, distributions are considered to begin on the date distributions are required to begin to the surviving spouse under Section 6(h)(II)(2)(a). If distributions under an annuity purchased from an insurance company irrevocably commence to the Participant before the Participant's Required Beginning Date (or to the Participant's surviving spouse before the date distributions are required to begin to the surviving spouse under Section 6(h)(H)(2)(a)) the date distributions are considered to begin is the date distributions actually commence. (3) Forms of Distribution. Unless the Participant's interest is distributed in the form of an annuity purchased from an insurance company or in a single sum on or before the Required Beginning Date, as of the first distribution calendar year distributions will be made in accordance with Section 6(h)(III) and Section 6(h)(IV)(2). If the Participant's interest is distributed in the form of an annuity purchased from an insurance company, distributions thereunder will be made in accordance with the requirements of Section 401(a)(9) of the Code and the Treasury regulations. (III) Required Minimum Distributions During Participant's Lifetime. 1l) Amount of Required Minimum Distribution For Each Distribution Calendar Year. During the Participant's lifetime, the minimum amount that will be distributed for each distribution calendar year is the lesser of: 26 (a) the quotient obtained by dividing the Participant's account balance by the distribution period in the Uniform Lifetime Table set forth in Section 1.401(a)(9)-9 of the Treasury regulations, using the Participant's age as of the Participant's birthday in the distribution calendar year; or (b) if the Participant's sole designated beneficiary for the distribution calendar year is the Participant's spouse, the quotient obtained by dividing the Participant's account balance by the number in the Joint and Last Survivor Table set forth in Section 1.401(a)(9)-9 of the Treasury regulations, using the Participant's and spouse's attained ages as of the Participant's and spouse's birthdays in the distribution calendar year. (2) Lifetime Required Minimum Distributions Continue Through Year of Participant's Death. Required Minimum Distributions will be determined under this Section 6(h)(III) beginning with the first distribution calendar year and up to and including the distribution calendar year that includes the Participant's date of death. (IV) Required Minimum Distributions After Participant's Death: (1) Death On or After Date Distributions Begin (a) Participant Survived by Designated Beneficiary. If the Participant dies on or after the date distributions begin and there is a designated 27 beneficiary, the minimum amount that will be distributed for each distribution calendar year after the year of the Participant's death is the quotient obtained by dividing the Participant's account balance by the longer of the remaining life expectancy of the Participant or the remaining life expectancy of the Participant's designated beneficiary, determined as follows: (1) The Participant's remaining life expectancy is calculated using the age of the Participant in the year of death, reduced by one for each subsequent year. (2) If the Participant's surviving spouse is the Participant's sole designated beneficiary, the remaining life expectancy of the surviving spouse is calculated for each distribution calendar year after the year of the Participant's death using the surviving spouse's age as of the spouse's birthday in that year. For distribution calendar years after the year of the surviving spouse's death, the remaining life expectancy of the surviving spouse is calculated using the age of the surviving spouse as of the spouse's birthday in the calendar year of the spouse's death, reduced by one for each subsequent calendar year. (3) If the Participant's surviving spouse is not the Participant's sole designated beneficiary, the designated beneficiary's remaining life expectancy is calculated using the age of the beneficiary in the year following the year of the Participant's death, reduced by one for each subsequent year (b) No Designated Beneficiary. If the Participant dies on or after the date distributions begin and there is no designated beneficiary as of September 30 of the year after the year of the Participant's death, the minimum amount that will be distributed for each distribution calendar year after the year of the Participant's death is the quotient obtained by dividing the Participant's account balance by the Participant's remaining life expectancy calculated using the age of the Participant in the year of death, reduced by one for each subsequent year. (2) Death Before Date Distributions Begin. (a) Participant Survived by Designated Beneficiary. If the Participant dies before the date distributions begin and there is a designated beneficiary, the minimum amount that will be distributed for each distribution calendar year after the year of the Participant's death is the quotient obtained by dividing the Participant's account balance by the remaining life expectancy of the Participant's designated beneficiary, determined as provided in Section 6(h)(IV)(1). (b) No Designated Beneficiary. If the Participant dies before the date distributions begin and there is no designated beneficiary as of September 30 of the year following the year of the participant's death, distribution of the Participant's entire interest will be completed by December 31 of the calendar year containing the fifth anniversary of the Participant's death. (c) Death of Surviving Spouse Before Distributions to Surviving Spouse Are Required to Begin. If the Participant dies before the date distributions begin, the Participant's surviving spouse is the Participant's sole designated beneficiary, and the surviving spouse dies before distributions are required to begin to the surviving spouse under Section 6(h)(II)(2)(a), this Section 6(h)(IV)(2) will apply as if the surviving spouse were the Participant. (V) Election to Apply 5-Year Rule to Distributions to Designated Beneficiaries. If the Participant dies before distributions begin and there is a designated beneficiary., distribution to the designated beneficiary is not required to begin by the date specified in Section 6(h)(II)(2), but the Participant's entire interest will be distributed to the designated beneficiary by December 31 of the calendar year containing the fifth anniversary of the Participant's death. If the Participant's surviving spouse is the Participant's sole designated beneficiary and the surviving spouse dies after the Participant but before distributions to either the Participant or the surviving spouse begin, this election will apply as if the surviving spouse were the Participant. (VI) Election to Allow Participants or Beneficiaries to Elect 5-Year Rule. Participants or beneficiaries may elect on an individual basis whether the 5-year rule or the life expectancy rule in Section 6(h)(II)(2) and Section 6(h)(IV)(2) of the Plan applies to distributions after the death of a Participant who has a designated beneficiary. The 30 election must be made no later than the earlier of September 30 of the calendar year in which distribution would be required to begin under Section 6(h)(II)(2), or by September 30 of the calendar year which contains the fifth anniversary of the Participant's (or, if applicable, surviving spouse's) death. If neither the Participant nor beneficiary makes an election under this paragraph, distributions will be made in accordance with Section 6(h)(II)(2) and Section 6(h)(IV)(2) and, if applicable, the elections in Section 6(h)(V) above. (VII) Election to Allow Designated Beneficiary Receiving Distributions Under 5-Year Rule to Elect Life Expectancy Distributions. A designated beneficiary who is receiving payments under the 5-year rule may make a new election to receive payments under the -life -expectancy -rule -until -December 31, 2-003 provided-4hat-all ounts4hat would have been required to be distributed under the life expectancy rule for all distribution calendar years before 2004 are distributed by the earlier of December 31, 2003 or the end of the 5-year period. (VIII) TEFRA Section 242(b)(2) Elections (1) Notwithstanding the other requirements of this article distribution on behalf of any employee who has made a designation under § 242(b)(2) of the Tax Equity and Fiscal Responsibility Act (a "section 242(b)(2) election") may be made in accordance with all of the following requirements (regardless of when such distribution commences): (a) The distribution by the plan is one which would not have disqualified such plan under § 401(a)(9) of the Internal Revenue Code as in effect prior to amendment by the Deficit Reduction Act of 1984. (b) The distribution is in accordance with a method of distribution designated by the employee whose interest in the plan is being distributed or, if the employee is deceased, by a beneficiary of such employee. (c) Such designation was in writing, was signed by the employee or the beneficiary, and was made before January 1, 1984. (d) The employee had accrued a benefit under the plan as of December 31, 1983. (e) The method of distribution designated by the employee or the beneficiary specifies the time at which distribution will commence, the period over which distributions will be made, and in the case of any distribution upon the employee's death, the beneficiaries of the employee listed in order of priority. (2) A distribution upon death will not be covered by this transitional rule unless the information in the designation contains the required information described above with respect to the distributions to be made upon the death of the employee. (3) For any distribution which commences before January 1, 1984, but continues 14) after December 31, 1983, the employee, or the beneficiary, to whom such distribution is being made, will be presumed to have designated the method of distribution under which the distribution is being made if the method of distribution was specified in writing and the distribution satisfies the requirements in Section 6(h)(VIII)(1)(a) and (e). If a designation is revoked, any subsequent distribution must satisfy the requirements of § 401(a)(9) of the Code and the regulations thereunder. If a designation is revoked subsequent to the date distributions are required to begin, the plan must distribute by the end of the calendar year following the calendar year in which the revocation occurs the total amount not vet distributed which would have been required to have been distributed to satisfy § 401(a)(9) of the Code and the regulations thereunder, but for the section 242(b)(2) election. For calendar years beginning after December 31, 1988, such distributions must meet the minimum distribution incidental benefit requirements. Any changes in the designation will be considered to be a revocation of the designation. However, the mere substitution or addition of another beneficiary (one not named in the designation) under the designation will not be considered to be a revocation of the designation, so long as such substitution or addition does not alter the period over which distributions are to be made under the designation, directly or indirectly (for example, by altering the relevant measuring life). (51 In the case in which an amount is transferred or rolled over from one plan to another plan, the rules in § 1.401(a)(9)-8, Q&A-14 and Q&A-15, shall apply. (j) Direct Rollover of Certain Distributions. Notwithstanding any provision of this wee Fund to the contrary that would otherwise limit a Distributee's election under this par-agfapil Section 6(j), a Distributee may elect, at the time and in the manner prescribed by the Board, to have any portion of an Eligible Rollover Distribution paid directly by the Fund to an Eligible Retirement Plan specified by the Distributee in a Direct Rollover. balance to the credit of the distributee, -except that an eligible rollover distribution does not include any distribution to the extent such distribution is required under Sectien-1O1(a)() -o€-the-Code,, and -he portion of di tribution that is not .ludible e; (II) "Eligible retirement plan" means an individual retirement account described in secctien-408(a) o e Cod d tirem � desepil d tion c.� ca-iiiuri�k cznei�i-zscJcrrvcar-in�cacron '108(b) of the Code, an annuity plan described in section 403(a) of the Code, or a individual retirement a ,ity. (III) "Distributee" means an employee or former employee. In addition, the employee's the-spouset and 34 (IV) "Direct rollover" means a payment by the Fund to the eligible -retirement plan specified by the distributee. in a Direct Rollover. k(� (k). Death of Retired or Separated Participant. Upon the death of a Retired or Separated Participant, such Participant's surviving spouse shall have all the distribution options that were available to the Retired or Separated Participant pursuant to this Section 6. f (I) Loans and/or Hardship Distributions. Loans and/or distributions on account of hardship shall not be permitted under the Plan. : (m) Claims Procedures. (I) Filing a Claim for Plan Distributions. A Participant or Beneficiary who has been denied a request for a distribution and desires to make a claim for the Vested portion of his or her Account shall file a request (either in writing or in any other form permitted under rules promulgated by the IRS and acceptable to the Board of Trustees) with the Board of Trustees. If such request is required in writing, such request must be made on a form provided or acceptable to the Board of Trustees for such purpose. The request shall set forth the basis of the claim. The Board of Trustees is authorized to conduct such examinations as may be necessary to facilitate 35 the payment of any benefits to which the Participant or the Beneficiary may be entitled under the terms of the Plan. (II) Denial of a Claim. Whenever a claim for a Plan distribution submitted in accordance with this Section 6(1) by any Participant or Beneficiary has been wholly or partially denied, the Board of Trustees must furnish such Participant or Beneficiary notice (either in writing or in any other form promulgated by the IRS and acceptable by the Board of Trustees) of the denial as soon as administratively practicable after the original claim was filed. The notice shall set forth the specific reasons for the denial., specific reference to pertinent Plan provisions on which the denial is based, a description of any additional information or material needed to perfect the claim, an explanation of why such additional information or material is necessary and an explanation of the procedures for appeal. (III) Remedies Available. The Participant or Beneficiary shall have sixty (60) days from receipt of the denial notice in which to make written application for review by the Board of Trustees. The Participant or Beneficiary may request that the review be .in the nature of a hearing. The Participant or Beneficiary shall have the right to representation, to review pertinent documents and to submit comments in writing (or in any other form permitted under rules promulgated by the IRS). The Board of Trustees shall issue a decision on such review within a reasonable time after receipt of an application for review as provided for in this Section 6(1). Upon a decision unfavorable to. the Participant or Beneficiary, such Participant or Beneficiary shall be entitled to bring such actions in law or equity as may be necessary or appropriate to clarify his or her rights to benefits under the Plan. 36 Section 7 Administration (a) Board of Trustees. There is hereby created a Board of Trustees of the Miami Fire Fighter's Relief and Pension Fund. The Board shall consist of three Participants in the Fund to be elected by Participants, the Fire Chief, and a fifth member appointed by the Participants elected as Trustees. Trustees shall be elected to serve as Trustee for a three year term. The fifth Trustee appointed to the Board shall serve for a term of one year. The Board shall annually elect from its membership a Chairman and a Secretary and a Treasurer. The Chairman, when present, shall preside at all meetings. The Secretary shall keep complete minutes of all proceedings of the Board. The Treasurer shall supervise the books and records which record the receipts and disbursements of the Fund and the inventory of assets of the Fund. The Treasurer shall report at each quarterly meeting, and at such other times as the Board may determine, the assets and liabilities of the Fund as of the date of such meeting. Any and all acts and decisions of the Board, except for the appointment of the fifth Trustee, shall be by at least three affirmative votes of the Board, a quorum being present. Three or more Trustees shall constitute a quorum. Trustees shall receive no compensation for their service as such. (b) Elections. All elections of Fire Fighters to the Board shall be by secret written ballot. Only Participants shall be eligible for nomination and election to the Board and shall be eligible to vote in such elections. Notice of each election shall be given at least two weeks prior to the date upon which such elections shall be held. (c) Meetings. The Board will hold regular meetings at least quarterly or more often as determined by the Board. Special meetings may be called by the Chairman and Secretary or 37 by any three Trustees. Ten days written notice of a special meeting shall be given in writing to all Trustees, which notice shall contain the purpose, date, time and place of the special meeting. If any Trustee fails to attend two consecutive meetings of the Board without cause, as determined by the Board, his membership on the Board shall be terminated. Written notice of his termination shall be given to the Trustee whose membership is thus terminated. (d) Replacement of Board Members. If at any time between elections a vacancy occurs on the Board for any reason whatsoever, the remaining Trustees, by majority vote, shall fill the vacancy. The new Trustee so chosen shall serve until the next election of the Board of Trustees, at which time a new Trustee shall be elected to serve the remainder of the term of the Trustee whose position became vacant. (e) Powers of the Board. The Board shall have the power and authority as follows: (I) To invest and reinvest the assets of the Fund and keep them invested, without distinction between principal and income, in stocks, bonds, stock options, option contracts of any type, contracts for the immediate or future delivery of financial instruments and other property, or other securities or certificates of participation or shares of any mutual investment company, trust or fund, or deposits which bear a reasonable rate of interest, or term life, annuity or investment contracts issued by an insurance company, or other property of any kind, real or personal, tangible or intangible, as a prudent man would do under like circumstances with due regard for the purpose of this Fund. Notwithstanding anything to the contrary in this Section 7(e), the Board shall be governed by State laws relating to the investments of fiduciary funds when investing the Fund's assets. 38 (II) To establish one or more separate investment accounts within the Fund. The Board shall transfer to each such separate investment account such portion of the Fund's assets as the Participants direct in accordance with the provisions of paragraph (c) of Section 5 Section 5(c). The Board shall invest and reinvest the assets which have been allocated to a separate investment account in accordance with the investment guidelines, objectives and restrictions which have been established by the Board for that separate investment account. (III) To keep such amounts of cash as it, in its sole discretion, shall deem necessary or advisable as part of the Fund. (IV) To approve disbursements, pay claims, and authorize payments from the Fund by warrants signed by at least three Trustees. (V) To construe and interpret the provisions of this ordinance including, but not limited to, determination of an individual's eligibility to participate in the Fund, the right and amount of any. benefit payable under the Fund and the date on which any individual ceases to be a Participant. The determination of the Board as to the interpretation of this ordinance or any disputed question shall be conclusive and final to the extent permitted by applicable law. (VI) To promulgate necessary rules respecting (i) the operation and administration of the Fund and the transaction of its business and (ii) the elections of Trustees, not in conflict with the wording or clear intent of this ordinance. (VII) To authorize expenditures in connection with preliminary research, and for technical, legal, consulting and accounting services; to contract for employees necessary to the general 39 administration of the Fund and to employ legal counsel, auditors and others necessary to the proper administration of the Fund. (VIII) To appoint from their number such committees with such powers as they shall determine and to allocate among themselves all or such portion of their duties under this ordinance as they, in their sole discretion, shall decide. (IX) To take or do any other actions or things permitted to be taken or done by trustees under any applicable State law. Bonding. All persons, including Trustees and employees, who sign checks or handle money, securities or other assets of the Fund shall be bonded by a qualified surety. Limitation of Liability and Indemnification. The Trustees and any officer, employer or agent of the Trustees or of the Fund shall not incur any liability individually or on behalf of any other individuals or on behalf of the Board or the Fund for any act or failure to act, made in good faith in relation to the Fund or the assets of the Fund. To the extent permitted by applicable law and the assets of the Fund, the Trustees and the officers, employees and agents of the Board and the Fund shall be indemnified from the assets of the Fund against any and all liabilities arising by reason of any act, or failure to act, in relation to the Fund or the assets of the Fund, including, without limitation, expenses reasonably incurred in the defense of any claim relating to the Fund or the assets of the Fund and amounts paid in any compromise or settlement relating to the Fund or the assets of the Fund, except for actions or failures to act made in bad faith. 40 Section 8 Miscellaneous Provisions (a) Nonalienation of Benefits. The benefits provided by the Fund shall not be subject to garnishment, attachment, execution of any other legal process. (b) City's Responsibilities. The City shall have no responsibility for the operation of the Fund except those specified herein and shall bear no expense in connection therewith. (c) Facility of Payment. If the Board shall find that a Participant or other person entitled to a benefit is unable to care for his affairs or is a minor, or is legally incapacitated, the Board may direct that any benefit due him shall be paid to his duly appointed legal representative. Any payment so made shall be a complete discharge of the liabilities of the Fund for that benefit. (d) Information. Each Participant, Beneficiary or other person entitled to a benefit, before any benefit shall be payable to him or on his account under the Fund, shall file with the Board the information that it shall require to establish his rights and benefits under the Plan. (e) Amendment. The provisions of this ordinance and the Fund are intended to meet the requirements of a qualified profit sharing plan under Section 401(a) of the Code and to be tax-exempt under Section 501(a) of the Code. Should any changes be required to the ordinance for the ordinance or the Fund to comply or to continue to comply with the provisions of Sections 401(a) and 501(a) of the Code, the Board shall prepare a statement for the City describing the changes and the City shall, after reviewing the Board's statement, make any such required changes to the ordinance. 41 (fl Termination. The Plan may be terminated by the City, subject to full compliance with all applicable federal, state and local laws and regulations. Written notice of the termination and effective date thereof shall be given to the Participants and Beneficiaries and any vendors providing services to the Plan. Until all of the Plan assets havebeen distributed, the Plan will be kept in full compliance with current laws and regulations by making appropriate amendments to the Plan and by taking such other measures as may be required. Upon termination of the Plan, each Participant shall become 100% vested in his or her Account and the balance shall be non -forfeitable. The balance of each Participant's Account will be distributed in a lump sum as soon as administratively practicable following the effective date of the Plan's termination. (g) USERRA. Notwithstanding any provision of this plan to the contrary, contributions, benefits and service credit with respect to qualified military service will be provided in accordance with Code section 414(u). 42