1 APPENDIX PLAN LOAN POLICY To the extent permitted by the Investment Arrangements in which the Plan assets are invested, Buckingham Browne & Nichols School DC Retirement Plan permits loans to be made to Participants pursuant to a written loan policy. All references to Participants in this loan policy include Participants and their Beneficiaries or any alternate payee with respect to the Plan provided that t he borrower must qua lify as a "party in interest" as defined by ERISA Section 3(14). All current employees of the Employer and certain former Employees qualify as parties in interest. The Individual Agreements governing the investment options that you selected for your Plan c ontributions may contain additional limits on when you can take a loan. Please review both the following information in this Loan Policy and your annuity contracts or custodial agreements before requesting a loan. Contact your Employer or the investment v e ndor if you have questions regarding your loan options. The Plan Administrator is authorized to administer the Participant loan policy. All applications for loans will be made by a Participant to the Plan Administrator (or the Plan Administrator's delegat e) on forms which the Plan Administrator will make available for such purpose. 1 . LOAN APPLICATION/BORROWER QUALIFICATION  Loans are available to Participants on a reasonably equivalent basis. However, if you terminate employment, you will generally not be entitled to obtain a loan. A Participant must apply for each loan with an application which specifies the amount of the loan desired and the requested duration for the loan. The Plan Administrator may request additional information before approving a l oan.  All loan applications will be considered by the Plan Administrator within a reasonable time after the Participant makes forma l application.  The loan will be treated as a directed investment of the borrower's Account. 2 . LOAN LIMITATIONS. With regard to any loan made pursuant to this loan policy, the following rule(s) and limitation(s) will apply, in addition to such other requirements set forth in the Plan:  Loans to a Participant will not be approved in an amount which exceeds 50% of his or her nonforfeitable account balance. The maximum aggregate dollar amount of loans outstanding to any Participant may not exceed $50,000, reduced by the excess of the Participant's highest outstanding Participant loan balance during the 12 - month period endin g on the date of the loan over the Participant's current outstanding Participant loan balance on the date of the loan. Loans from a TIAA Annuity other than an RPL loan are further limited to: (a) 45% of the combined accumulation s attributable to the fund ing vehicle(s) under your retirement p lan; or (b) 90% of the CREF and TIAA Real Estate accumulation attributable to participation under this Plan for Retirement Loan (RL) loans, or (c) 90% of your TIAA Annuity accumulation attributable to participation u nder this Plan for a Group Supplemental Retirement Annuity (GSRA) loan.  No loan in an amount less than $1,000 will be granted to any Participant for any single loan.  A Participant can have 3 loan(s) currently outstanding from the Plan. However, if this loan limitation exceeds three, and your loan is an RPL loan, you may not have more than three loans at any one time.  Loan refinancing is not permitted. 3 . ACCOUNT RESTRICTIONS. With regard to loans made pursuant to this loan policy (s ubject to the investment arrangements), the following rules apply:  Loans may only be made from accounts attributable to:  Pre - tax Elective Deferrals  Rollovers from other plans 4 . EVIDENCE AND TERMS OF LOAN. The Plan Administrator will document every loan in the form of a promissory note signed by the Participant for the face amount of the loan, according to the following:  Any loan granted or renewed under this policy will bear a reasonable rate of interest.

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