DCRP and VCRP Safe Harbor Notice

This notice covers important information about Georgetown University’s Defined Contribution Retirement Plan (DCRP) and Voluntary Contribution Retirement Plan (VCRP) (each a “Plan” and together, the “Plans”). This notice is provided to faculty and staff eligible to participate in the DCRP (“DCRP-Eligible Employees”), as well as certain beneficiaries. More information about who is a DCRP-Eligible Employee may be found the summary plan description for the DCRP.

All DCRP-Eligible Employees can participate in the VCRP upon hire. There is a phased waiting period before DCRP-Eligible Employees are eligible to participate in, or receive full University contributions under, the DCRP. Certain exceptions to the waiting period may apply.

The notice covers these points:

• When the Plans’ automatic enrollment and increase features apply to you;
• How you can change your employee contributions;
• What amounts the University will contribute to your DCRP account;
• When your Plan accounts are vested;
• How your Plan contributions may be invested and how you can change your investment elections.

The Plans’ Automatic Enrollment

Phase One: Upon hire, DCRP-Eligible Employees are automatically enrolled in the VCRP, unless they elect a different deferral rate (or elect not to defer at all). Under the VCRP’s automatic enrollment feature, the University deducts 3% of your eligible pay each pay period, deposits that amount as a pre-tax contribution to your VCRP account, and invests that amount in the TIAA LifeCycle Index Fund most appropriate for your age (see “Investment of Plan Contributions” below). The automatic enrollment feature will apply to your first paycheck if administratively feasible and, if not, to your second paycheck. You may opt out of the VCRP’s auto enrollment feature, increase or decrease your contribution amount, or change your investment funds (including investment company) at any time. If you want your election to apply to your firstpaycheck, you must make your election at least one week before your first pay day. To make any of these changes, you must log in to the Georgetown Management System (GMS) at http://gms.georgetown.edu and complete a Retirement Savings Change. Your change(s) will apply to your next paycheck if made at least one week before the pay day or, if not, the next following pay day.

Beginning on January 1, 2024, if you are deferring less than 3% of your eligible pay as of the first day of each Plan Year, you will be automatically enrolled in the VCRP at a rate of 3% of your eligible pay for the first pay date in Plan Year. As with the initial automatic enrollment, you may opt out of the auto-enrollment, or elect to defer a different amount.

The VCRP’s automatic enrollment feature will terminate and any separately elected employee contributions to VCRP will also end as you enter Phase Two. If you wish to recommence or continue making contributions to the VCRP after its automatic enrollment feature and any separate deferral election terminates, you must make a new VCRP Salary Reduction Election once your participation in the DCRP commences (on or after your first full year of service).

Phase Two: After one year of service, DCRP-Eligible Employees are automatically enrolled in the DCRP, unless they elect a different deferral rate (or elect not to defer at all). Under the DCRP’s automatic enrollment feature, the University deducts 3% of your eligible pay each pay period, deposits that amount as a pre-tax contribution to your DCRP account, and invests that amount in the TIAA LifeCycle Index Fund most appropriate for your age (see “Investment of Plan Contributions” below). The DCRP’s automatic enrollment feature will apply upon your completion of one year of service. You will receive a separate notice before your automatic enrollment in the DCRP. You may opt out of the DCRP’s auto enrollment feature, decrease the automatic contribution amount, or change your investment funds (including investment company) at any time by logging into GMS as described in the Phase One section above. During Phase Two, you are eligible to receive a University Match Contribution of up to 5% of eligible pay. If you terminate the DCRP’s automatic enrollment feature by opting out or decreasing the automatic contribution amount, you must make a new DCRP Salary Reduction Election if you want to reinstate or increase your employee contribution amount for the remainder of that Plan Year.

Each January 1st, if you are deferring less than 3% of your eligible pay as of the first day of each Plan Year, you will be automatically enrolled in the DCRP at a rate of 3% of your eligible pay for the first pay date in the new Plan Year. As with the initial automatic enrollment, you may opt out of the auto-enrollment, or elect to defer a different amount. As explained below, eligibility to earn University Core Contributions is not dependent on whether you defer your own pay to the Plans.

Phase Three: After you complete two years of service, the University will begin depositing, on a pay period basis, a non-elective University Core Contribution of 5% of your eligible pay to your DCRP account. If you are contributing less than 3% to the DCRP in Phase 2 then you will be set up to contribute 3% to the DCRP at the start of Phase 3. Within each Plan Year, if you terminate the DCRP’s automatic enrollment feature by opting out or decreasing the automatic contribution amount during Phase Three, you must make a new DCRP Salary Reduction Election if you want to reinstate or increase your employee contribution amount to receive the maximum University Match Contribution. The automatic enrollment feature will recommence each January.

Automatic Increase: On January 1, if you are deferring at least 3% of your eligible pay in the DCRP as of December 31, 2024 but not deferring into the VCRP, you will be automatically enrolled in the VCRP at a rate of 1% of your eligible pay. If, on December 31, you are deferring 3% of your eligible pay in the DCRP and also deferring some portion of your eligible pay to the VCRP, then your deferral to the VCRP will be increased by 1% of your eligible pay in January.

Following this initial automatic enrollment (or increase) on January 1, thereafter on the first pay of each Plan Year, your rate of deferral in the VCRP will be automatically increased by 1% of your eligible pay, until you reach a maximum deferral rate of 12% of your eligible pay in the VCRP (for a total rate of 15% of your eligible pay in the two Plans). Automatic Escalation will not apply to those who are already contributing up to the annual IRS contribution limit or who are in Phase One of the DCRP Waiting Period.

If you elected to contribute a whole dollar amount to the VCRP (rather than a percentage of your eligible pay), the automatic increase feature will increase your deferral up to the next whole percentage rate. For example, if your eligible pay in the first pay period of the Plan Year is $2,350 and you chose to defer $200 each pay check (which is 8.5% of your eligible pay), then your deferral would be automatically increased to 9% of your eligible pay for each pay period.

As with automatic enrollment, you may opt out of this automatic increase feature, decrease the automatic contribution amount, or change your investment funds (including investment company) at any time by logging into GMS as described in the Phase One section above. The automatic escalation feature will recommence each January.

If Phased Waiting Period is Waived: If you qualify, and are approved, for a waiver of the Phased Waiting Period, you will be automatically enrolled in the DCRP’s automatic enrollment feature and are eligible to receive a University Match Contributions as described in the Phase Two section above. The University will also deposit on a pay period basis, a non-elective University Core Contribution of 5% (7% for those participants hired prior to January 1, 1996) of your eligible pay to your DCRP account as described in the Phase Three section above. As described in both sections, you may opt out of the DCRP’s auto enrollment and escalation features, decrease the automatic contribution amount, or change your investment funds (including investment company) at any time by logging into GMS.

Eligible Pay

Generally, your eligible pay for determining the amount of your deferrals, the University Match Contribution, and the University Core Contribution is your total compensation paid to through payroll, plus your pre-tax deferrals to the DCRP and VCRP, the University’s code section 457(b) plan, flexible spending accounts, cafeteria plan or qualified transportation fringe benefit plans; however, the following are excluded:

• Taxable fringe benefits
• Deferrals or distributions under any nonqualified deferred compensation plans
• Unused vacation leave paid on termination of employment
• Personal compensation, lump sum compensation, or academic payments that are Qatar earnings, and
• University contributions to any retirement plan.

Your eligible pay under the DCRP is limited to $255,000 in 2025. While that compensation limit does not apply under the VCRP, your total deferrals to the DCRP and VCRP in a calendar year cannot exceed the IRS dollar limit on deferrals for such year.

Eligible pay for your first year of participation under either the VCRP or DCRP will be measured for the portion of your initial Plan Year that you are eligible.

Pre-Tax Contributions

Pre-tax contributions are deducted from your eligible pay before federal and most state income taxes are applied, which means that your current taxable income is reduced by the amount of your pre-tax contributions. Instead, you pay income taxes on your contributions (and any investment returns) when withdrawn from your Plan accounts. Note that pre-tax contributions are subject to Social Security and Medicare (FICA) taxes when deferred, but later distributions are not subject to FICA taxes.

Roth After-Tax Contributions

You can also make Roth contributions to the VCRP. Roth contributions are subject to both income and FICA taxes when made. However, if certain conditions are met, distributions from a Roth account (including of investment returns) are not subject to any tax.

Changing the Amount You Contribute to the Plan

You can change your contribution rate at any time. If you want to contribute more or less to your Plan account than would be provided on an automatic basis, or make Roth contributions to VCRP, you can make such an election by selecting Change Retirement Savings on the Georgetown Management System(GMS) website at http://gms.georgetown.edu.

The maximum annual employee contribution you can make to the DCRP is 3% of your eligible pay not to exceed $255,000, for a maximum deferral to the DCRP each year of$7,650. You can contribute amounts in excess of 3% of your eligible pay to the VCRP, up to the maximum annual amount set by the IRS. The maximum annual amounts increases once you attain age 50. These limits can be found on the Benefits website, benefits.georgetown.edu.

University Match Contributions

Upon entering Phase Two of the DCRP, the University will match your employee contribution at the rate of 1.66 2/3rds percent for each 1% of your eligible pay you defer to the DCRP from each paycheck, for a maximum possible match of 5% of your eligible pay each pay date (not to exceed $12,750 in match per Plan Year due to the annual compensation limit of $255,000).

Based on your employee contribution, you would receive a matching contribution from the University with respect to a paycheck as illustrated below:

GU contributes 5% of your eligible pay if you contribute 3%
GU contributes 3.34% of your eligible pay if you contribute 2%
GU contributes 1.67% of your eligible pay if you contribute 1%
GU contributes 0% of your eligible pay if you contribute 0%

To maximize your University Match Contribution, you must make employee contributions equal to at least 3% of your eligible pay for each pay period. If you choose not to contribute for a pay period, you will receive no matching contributions for that pay period. Similarly, if you defer less than 3% for a pay period, you will not receive the full match for that pay period. The maximum University Match Contribution you can receive is $12,750 per year ($255,000 multiplied by 5%).

The University Match Contribution is intended to be a safe harbor matching contribution as described in Section 401(m)(11) of the Internal Revenue Code. The University may amend the Plan, at any time during the Plan Year, to reduce or eliminate the safe harbor matching contribution. If the University amends the Plan to reduce or eliminate the matching contribution during the Plan Year, then the University will provide you a supplemental notice and the suspension or reduction will not apply until at least 30 days after that notice is provided.

University Core Contributions

In Phase Three of the DCRP, the University makes a contribution on your behalf whether or not you make employee contributions. This contribution is called the “University Core Contribution” and is equal to 5% of your eligible pay not to exceed $255,000. The maximum University Core Contribution you can receive is $12,750 per year ($255,000 multiplied by 5%). Once you are in Phase Three, your combined employee contribution and University contributions can total up to 13% of earnings.

Vesting of Plan Contributions

You are immediately fully vested in your employee contributions as well as your University Match and Core Contributions and any investment returns thereon. To be fully vested means that your Plan contributions and any investment returns will always belong to you, and you will not lose them even if your employment with the University terminates.

Even though you are vested in your Plan accounts, there are restrictions on when you may withdraw funds from your Plan accounts. Generally, you may withdraw funds from your DCRP and VCRP accounts only after you terminate your employment with the University. However, you may withdraw funds from your DCRP account if you have attained age 59 ½ and experience a hardship, and from your VCRP account upon attaining age 59½, on account of a hardship, or through the loan option at TIAA. Your beneficiary is entitled to any amounts remaining in your Plan accounts upon your death. These restrictions may be important to you in deciding how much, if any, to contribute to the Plans.

Investment of Plan Contributions

The Plans allows participants and beneficiaries to direct the investment of their Plan contributions, i.e., employee contributions, University Match Contributions and University Core Contributions. If you do not provide investment instructions, Plan contributions are automatically invested in the Plans’ qualified default investment option and remain invested in the qualified default investment option until you direct otherwise. To make a choice regarding the investment of your Plan contributions, you may do so by electing your preferred retirement plan investment company (Fidelity, TIAA, Vanguard) in GMS (http://gms.georgetown.edu) and then contacting the company to specify your fund allocations.

TIAA LifeCycle Index Fund

If you do not select an investment company for your Plan contributions, your Plan contributions to both the DCRP and VCRP are automatically invested in an age appropriate TIAA LifeCycle Index Index Fund. The default fund election will remain in effect until you select other investment options.

TIAA LifeCycle Index Funds, also known as Target Date funds, consist of a series of target retirement date funds in five-year increments where you select the fund that most closely matches your retirement year, e.g. a LifeCycle Index 2040 Fund is for an investor planning to retire in or around 2040. If your investments are defaulted to the TIAA LifeCycle Index Fund, your investments will be placed in the fund that most closely matches the year of your 65th birthday. They are professionally managed and automatically adjust over time—relieving you of the need to make investment, allocation, and rebalancing decisions every year.

TIAA LifeCycle Index Funds aim for an age appropriate investment over time while maintaining a diversified, risk managed exposure across a wide range of asset classes. By providing exposure to equities during early periods of retirement savings, the LifeCycle Index Funds are designed to provide opportunities for asset growth and favorable risk adjusted returns. As retirement approaches, the gradual increase in fixed-income investments, up to and during the target retirement period, addresses investor’s need for increased stability of principal over shorter savings horizons. The ongoing allocation to equities during retirement is designed to strike a balance between the need for both current income and continued growth throughout retirement years.

The TIAA LifeCycle Index Funds are intended to be one of the “qualified default investment alternatives” as described in Section 404(c)(5) of the Employee Retirement Income Security Act (ERISA) and ERISA Regulation Section 2550.404c-5. Specific information, including a description of the fund’s investment objectives, risk and return characteristics, fees, and expenses, can be found in the attached QDIA notice from TIAA.

If you select either Fidelity or Vanguard as the investment company for your Plan contributions, but do not select specific investment funds with that company, then your Plan contributions will be automatically invested in an age appropriate Target Date fund with the applicable company. Specific information, including a description of the funds’ investment objectives, risk and return characteristics, fees, and expenses, can be found in the attached QDIA notices from Fidelity and Vanguard.

Change How Your Plan Contributions are Invested

If your Plan contributions are automatically invested in a TIAA LifeCycle Index you have the option at any time to change the investment of your future and past Plan contributions, subject to each investment’s trading restrictions and any purchase fees (if applicable). If you do nothing, your Plan contributions will continue to be invested in a TIAA LifeCycle Index Fund.

To make investment changes or to learn more about the Plans’ investment options log on to your account at www.tiaa.org/georgetown, or call TIAA at 1-800-842-2888.

Designate Your Beneficiary

To view or change your beneficiary designation, contact your investment company. Until you designate a beneficiary, your designation will default to your estate if you are unmarried, and to your spouse if you are married.

You may apply for a waiver of the waiting period if (1) your last employer was an academic institutions (colleges, universities, non-profit research institutes) where they received employer contributions or accrued benefits under that institution’s retirement plan within the last 12 months; (2) you are working outside the United States, are entitled to receive local benefits, but elect instead to receive benefits under the DCRP; or (3) if you previously worked for Georgetown University, participated in DCRP or GURP, and are subsequently rehired by Georgetown within the last five years. Learn more at benefits.georgetown.edu/dcrpwaiting.