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Roth IRA Conversion Kit

This document outlines the process and considerations for converting a Vanguard mutual fund traditional IRA to a Roth IRA, including tax implications and eligibility criteria. It provides guidance on whether conversion is advisable based on individual circumstances and offers a conversion form for completion. Additionally, it emphasizes the importance of consulting a tax advisor and provides resources for further assistance.

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CCM
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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0% found this document useful (0 votes)
35 views42 pages

Roth IRA Conversion Kit

This document outlines the process and considerations for converting a Vanguard mutual fund traditional IRA to a Roth IRA, including tax implications and eligibility criteria. It provides guidance on whether conversion is advisable based on individual circumstances and offers a conversion form for completion. Additionally, it emphasizes the importance of consulting a tax advisor and provides resources for further assistance.

Uploaded by

CCM
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd

What’s inside:

• Can you—or should


you—convert to a
Roth IRA? Converting to a Vanguard
mutual fund Roth IRA
• Important information
about taxes
• Form
For converting a Vanguard mutual fund traditional/rollover IRA, SIMPLE IRA,
or SEP-IRA to a Vanguard mutual fund Roth IRA

By converting your existing IRA to a Roth IRA, you’ll be able to make tax-free
qualified withdrawals after age 59½ provided that your account has been open
at least five years. You’ll also avoid the required minimum distribution (RMD)
rules that apply to other types of IRAs. Keep in mind, however, that you’ll
likely owe income tax on the amount you convert.
To help determine whether converting to a Roth IRA is a good idea for you:
• Review the information on the next page.
• Use our convenient Roth IRA conversion calculator. Go to [Link]/
shouldiconvert and select Estimate the benefits & costs of a Roth
conversion.
• Discuss your situation with a qualified tax advisor.
Note: If you have a Vanguard Brokerage IRA, you’ll need to complete the
Roth IRA Conversion Kit for Brokerage Accounts (download at [Link]/
serviceforms) instead.

Complete your conversion online


You don’t have to fill out the enclosed form. Convert to a new Vanguard mutual
fund Roth IRA online. Simply log on to your account at [Link] and
select Add another account, then follow the steps to open a new Roth. Be
sure to choose exchange as your method of funding. To convert to an existing
Vanguard Roth IRA, simply log on, locate your IRA, and select Exch.

Questions?
If you need assistance, call us at 800-662-2739.
Can you—or should you—convert to a Roth IRA?
Converting may be a good idea if Converting may not be wise if
• You expect to be in the same or a higher tax • You expect your tax rate to be lower in retirement.
bracket in retirement.
• The amount you’re converting would push you
• You have a long time horizon. into a higher income tax bracket.
• You can pay the tax on the converted assets • You’d have to dip into your retirement assets
from sources other than your IRA, such as to pay the tax bill for the conversion.
from regular taxable accounts.
• You expect to need the assets you’re converting
within five years.

Important information about taxes


Minimizing taxes
Since you’ll likely owe income tax on the amount you convert, you may want to consider converting just a part
of—rather than all of—your existing IRA balance to minimize your tax burden.

If you’re age 70½ or older


You must take your RMD for the year of the conversion before you can convert your existing IRA to
a Roth IRA.

Preparing and filing your income tax return


 he conversion amount will be reported to you in two ways: Form 1099-R (for the amount distributed from your
T
existing IRA) and Form 5498 (for the amount contributed to your Roth IRA). To determine the taxable portion to
include when filing your federal tax return, refer to the instructions for Form 8606 (available online at [Link]) or
consult a qualified tax advisor.

Withdrawing assets
• Withdrawals of your converted amount are tax-free; however, converted amounts withdrawn within five years
of the conversion are subject to a 10% penalty unless an exception applies.
• Different rules apply to earnings on your conversion amount. You can generally withdraw earnings without
taxes or penalties if you’re age 59½ or older and it’s been at least five years since your first Roth IRA
contribution or conversion.

Converting nondeductible contributions


If you’ve ever made nondeductible contributions to any of your traditional IRAs:
• You’ll need Form 8606 from the years in which you made those nondeductible contributions in order to
determine the taxes owed (if any) on your conversion.
• A portion of your conversion amount—based on the percentage of your total IRA assets that are nondeductible
contributions—won’t be subject to tax.
For example, if the amount of nondeductible contributions in all of your IRAs equals 20% of your total IRA assets,
then 20% of the amount you convert is nontaxable and 80% is taxable. This is true regardless of whether your
conversion is made only from IRAs to which you made deductible contributions. These same rules apply if you
have after-tax amounts from an employer-sponsored plan that you’ve rolled into your existing IRA.
Form RICA

Clear All

Vanguard IRA to Vanguard


Roth IRA Conversion Form
Effective September 2016 Questions?
Use this form to authorize a conversion from a Vanguard mutual Call 800-662-2739.
fund-only traditional/rollover IRA, SIMPLE IRA, or SEP-IRA to a Vanguard To complete this form online, go to
mutual fund-only Roth IRA. To complete the conversion online, without [Link]/serviceforms.
using this form, follow the instructions on the cover of this form.
Important:
• If you previously converted to a Roth IRA and subsequently
recharacterized all or a portion of your assets back to a traditional IRA, the
IRS places restrictions on when that amount can be reconverted to a Roth
IRA. You may not reconvert until January 1 of the year following the
conversion or 30 days after the recharacterization, whichever is later.
Amounts converted are generally included in your gross income. You
should consult a qualified tax professional about this transaction before
you authorize it.
• If you’re age 70½ or older by December 31 of the current year, you must
take your required minimum distribution (RMD) for the year of the
conversion before you can convert your existing IRA to a Roth IRA.
Print in capital letters and use black ink.

1. Account owner information


If the account owner isn’t of legal adult age for the state in which he or she resides (18 for most states,
19 in Alabama and Nebraska, and 21 in Mississippi), the account will require a custodian, who must
complete Section 2.

Provide the full, Name first, middle initial, last


legal name. >
Birth date mm/dd/yyyy E-mail address optional

Daytime phone area code, number, extension Evening phone area code, number, extension
If you’ve applied
for an SSN or
ITIN but haven’t Social Security number (SSN) or individual taxpayer ID number (ITIN)
received it, enter the >
date on which
you applied.
Citizenship Tax residency

■ U.S. ■ Resident alien ■ Nonresident alien* ■ U.S. ■ Other


You must complete
this entire section. > Country of citizenship if not U.S. Country of tax residence if not U.S.

*If you’re a nonresident alien, you must complete an IRS Form W-8 electronically to certify your tax status, and to claim treaty benefits if
applicable. We’ll mail you instructions for completing the electronic Form W-8 once your account has been established.

1 of 10
Form RICA

Mailing address
Street or P.O. box

City, state, zip Country if not U.S.

Street address A P.O. box or rural route isn’t acceptable; address can be military APO or FPO.
This is required if it’s Street
different from the
mailing address or if > City, state, zip Country if not U.S.
the mailing address
is a P.O. box.

2. Custodian information Complete this section if you’re converting to a new Roth IRA for a minor.

Provide the full, Name first, middle initial, last


legal name. >
Birth date mm/dd/yyyy E-mail address optional

Daytime phone area code, number, extension Evening phone area code, number, extension
If you’ve applied for
an SSN or ITIN but Social Security number or individual taxpayer ID number
haven’t received it, >
enter the date on
which you applied.

Citizenship Tax residency

■ U.S. ■ Resident alien ■ Nonresident alien ■ U.S. ■ Other


You must complete
this entire section. > Country of citizenship if not U.S. Country of tax residence if not U.S.

Mailing address
Street or P.O. box

City, state, zip Country if not U.S.

Street address A P.O. box or rural route isn’t acceptable; address can be military APO or FPO.
This is required if it’s Street
different from the
mailing address or if > City, state, zip Country if not U.S.
the mailing address
is a P.O. box.

Return ALL pages of this form, even if some sections are left blank.

2 of 10
Form RICA

3. Required minimum distribution (RMD) information


Will you reach age 70½ or older this year? Check one.

■ No. Skip to Section 4.

■ Yes. Whether you’re making a total or partial conversion, your RMD amount for
the year is NOT eligible to be converted and must be taken prior to the conversion.
If you haven’t satisfied your RMD for the current year and you’d like Vanguard to distribute
your RMD prior to this conversion, you have three options to do so:
• Online. Log on to your account at [Link]. From the My Accounts dropdown,
select Account maintenance, then Required minimum distributions (RMD) to make
your selections.
• By phone. Call us at 800-662-2739.
• By mail. Complete the RMD Service Kit (available by searching “RMD Service” online at
[Link]/serviceforms) and mail it to us along with this form.

4. IRA(s) you want to convert


Check one.

■ Total conversion. Convert all assets in the IRA listed below. If you need more space to list
additional accounts, photocopy this page.
Traditional/Rollover IRA, SIMPLE IRA, or SEP-IRA account number

■ Partial conversion. Convert the following assets only. List the dollar amount or the
percentage of shares of each fund you want to convert. Be sure to use the same option for all
funds. If you need more space to list additional funds, either photocopy this section or attach
a separate sheet.
Fund number Traditional/Rollover IRA, SIMPLE IRA, or SEP-IRA account number Dollar amount or percentage

$ .0%
Fund number Traditional/Rollover IRA, SIMPLE IRA, or SEP-IRA account number Dollar amount or percentage

$ .0%
Fund number Traditional/Rollover IRA, SIMPLE IRA, or SEP-IRA account number Dollar amount or percentage

$ .0%

Total dollar amount if applicable

Return ALL pages of this form, even if some sections are left blank.

3 of 10
Form RICA

5. Account to receive your converted assets


Check and complete Option A, B, or C.

■ Option A. Convert assets into my existing Vanguard Roth IRA, account number
, and allocate to the same funds being converted in Section 4.
In order to receive the assets, new funds will be opened in the Roth IRA unless they’re already
established. You may exchange into different funds after the conversion is completed. Skip to
Section 6.

■ Option B. Convert assets into a new Vanguard Roth IRA and allocate to the same funds
being converted in Section 4. All fund choices and allocations will remain the same.

Check one, then skip to Section 6.

■ Establish my existing IRA account options in the new Roth IRA.


■ Don’t establish my existing IRA account options in the new Roth IRA. Once the
conversion is complete, you can log on to [Link] to establish account options on your
new Roth IRA.

■ Option C. Convert assets into a new Vanguard Roth IRA and allocate among different
funds, as directed in the table below.
Check one, then provide your fund allocations below.

■ Establish my existing IRA account options in the new Roth IRA.


■ Don’t establish my existing IRA account options in the new Roth IRA. Once the
conversion is complete, you can log on to [Link] to establish account options on your
new Roth IRA.

Refer to the enclosed fund prospectus(es) or visit [Link] /mutualfunds for fund names,
numbers, and minimum investment requirements.
• If you checked Total conversion in Section 4, you must provide percentages below and the
total fund allocation must equal 100%.
• If you checked Partial conversion in Section 4 and provided . . .
– Dollar amounts. You must provide your fund allocations in dollar amounts (equal to the total
provided in Section 4).
– Percentages. You must provide percentages below and the total fund allocation must equal 100%.
• If you don’t specify any funds, or if you don’t meet the minimum investment for a fund, that money will
be invested in Vanguard Federal Money Market Fund. If you list funds but don’t provide dollar amounts
or percentages, your investment will be divided equally among the funds you indicate.

Fund name Fund number Exact amount or percentage


$ .0%
Fund name Fund number Exact amount or percentage
Be sure you meet
each fund’s minimum $ .0%
investment (for most > Fund name Fund number Exact amount or percentage
funds, it’s $3,000).
$ .0%
Fund name Fund number Exact amount or percentage
$ .0%
Note: We charge a $20 annual account service fee for each Vanguard fund Total
with a balance of less than $10,000 in an account. We’ll withdraw the fee
directly from the fund accounts each June. This fee doesn’t apply if you sign $ or 100.0%
up for account access on [Link] and choose electronic delivery of
statements, confirmations, and Vanguard fund reports and prospectuses.
This fee also doesn’t apply to Flagship Select, Flagship, Voyager Select, or
Voyager clients.

Return ALL pages of this form, even if some sections are left blank.

4 of 10
Form RICA

6. Income tax withholding election


Important: You may want to seek tax advice before you authorize this conversion. At year-end,
Vanguard will send both you and the IRS a tax form detailing the amount of your distribution and any
tax withholding that has been applied.
• By converting your existing IRA to a Roth IRA, you’re making a taxable distribution from your
existing IRA.
• You may be subject to penalty taxes if federal and state taxes are due and either your estimated
tax payments or the amount of tax you have withheld is insufficient under IRS rules or your
state’s rules.
• Your combined withholding for federal and state taxes can’t exceed 100% of your distribution.
• If you choose to withhold federal tax, the amount withheld won’t be converted and may
be subject to taxes and early withdrawal penalties.

Federal income tax withholding


Conversions of traditional/rollover, SIMPLE, and SEP-IRAs are subject to federal tax withholding
at a rate of 10% unless you check the Don’t withhold box or specify a higher amount below.

Special rules for addresses outside the U.S.


If your account is registered to an address outside the U.S. or your payment is being directed
outside the U.S., we’re required to presume your tax status to be foreign and withhold 30%
federal income tax from your distribution unless one of the following applies:
• You’re a U.S. person (including a resident alien) and we have a valid IRS Form W-9 on
file. We’re required to withhold 10% federal income tax from your distribution. You can’t
elect out of federal income tax withholding for distributions delivered outside the U.S.
• You’re not a U.S. person and we have on file a valid IRS Form W-8 on which you’ve
claimed tax treaty benefits. If you’re eligible for a reduced withholding rate based on a
tax treaty your country has with the U.S., you may claim the reduced rate by completing
Form W-8, including the section titled “Claim of Tax Treaty Benefits,” and providing either
your U.S. taxpayer identification number (TIN) or your foreign TIN. If your claim is valid, the
reduced rate will be applied.
If you have an address outside the U.S. and aren’t sure whether we have a Form W-9 or W-8
on file for your account, please call us. We’ll provide you with further instructions for completing
either a paper Form W-9 or an electronic Form W-8.

■ Don’t withhold federal income tax from my IRA distributions.

■ Withhold at a rate of %. The rate must be at least 10%.

Return ALL pages of this form, even if some sections are left blank.

5 of 10
Form RICA

State income tax withholding


Vanguard will apply withholding for your state as you instruct below. If you have questions regarding
state withholding, contact your tax advisor or your state’s taxing authority. If you aren’t a resident
of one of the following states, skip to Section 7.

Residents of Iowa, Kansas, Maine, If federal tax is withheld, state tax withholding is
Massachusetts, Nebraska, and Oklahoma mandatory. Vanguard will automatically withhold
the minimum required by your state unless you
specify a higher amount below.

Residents of Arkansas, California, If federal tax is withheld, state tax withholding


Delaware, Michigan, North Carolina, is mandatory unless you specifically elect not
Oregon, and Vermont to have state tax withheld. Vanguard will
automatically withhold the minimum required by
your state unless you either check the Don’t
withhold box or specify a higher amount below.
Residents of Mississippi If federal tax is withheld, state tax withholding
is mandatory if your distribution is subject to
the federal early withdrawal penalty. Vanguard
will automatically withhold the minimum
required by Mississippi unless you specify a
higher amount below.
Residents of Indiana, Louisiana, Maryland, State tax may be withheld regardless of your
Missouri, Montana, New Jersey, New federal withholding election. Vanguard will
Mexico, New York, Utah, and Wisconsin follow your state withholding instructions as
indicated below. If no box is checked, we won’t
withhold.

Provide your Vanguard will use the address of record on your account to determine State of residence
state of residence, > state withholding requirements. If the state listed on your account isn’t
if applicable. your legal state of residence, provide that information here.

Check one. If no box is checked, we won’t withhold.

■ Don’t withhold state income tax from my IRA distribution.

■ Withhold my state’s minimum requirement.

■ Withhold this amount: or


We’ll withhold at least your state’s minimum requirement. % $

Return ALL pages of this form, even if some sections are left blank.

6 of 10
Form RICA

7. Beneficiaries for this account Skip this section if you have an existing Vanguard Roth IRA.

If you choose to complete this section, we’ll apply the new designation(s) to all your Roth IRAs.

Primary beneficiaries Check all that apply.


Those you designate as your primary beneficiaries will be first to inherit your IRA assets upon
your death. Indicate the percentages of your assets to be distributed to the designated primary
beneficiaries upon your death. The minimum percentage you can leave to a beneficiary is 1% and
the total to all beneficiaries must equal 100%.

My spouse If completing this section, check only one of these options.

■ To the person named here


Name first, middle initial, last Birth date mm/dd/yyyy
Check only one %
option; don’t check > or
both boxes.
■ To the person I’m married to at the time of my death
If you select this option, your assets will be distributed to whoever is your spouse
at that time. You don’t need to provide a name.
%
Descendants or individuals

■ To my descendants who survive me, per stirpes


If you select one of Your assets will be divided equally among your children. If a child is deceased, the
these designations,
entire portion due to that child will be divided equally among his or her children (if any).
don’t list the names > This designation excludes stepchildren and stepgrandchildren.
or your descendants/ %
grandchildren below.
■ Equally to my grandchildren who survive me
%

■ To the following named individual(s):


Name of individual first, middle initial, last Birth date mm/dd/yyyy
%
Attach a separate Name of individual first, middle initial, last Birth date mm/dd/yyyy
sheet if you want to >
list more individuals. %
Trusts
■ To the trustee of an existing trust created under an agreement
Name of trust Date of trust mm/dd/yyyy
This applies to %
existing trusts only;
you can’t create a >
trust with this form. ■ To the trustee of a trust created under my last will
Name of trust or section of will
%
Other
■ Organization or charity Provide name.
If you check this
%
box, indicate the ■ My estate
percentage, then >
%
skip to Section 8.
If the percentages don’t total 100%, Vanguard Total
will allocate equal percentages totaling 100%. > 100%

Return ALL pages of this form, even if some sections are left blank.

7 of 10
Form RICA

Secondary beneficiaries Check all that apply.


Those you designate as your secondary beneficiaries will inherit your assets only if there are no
surviving primary beneficiaries upon your death. Indicate the percentages of your assets to be
distributed to the designated secondary beneficiaries upon your death. The minimum percentage
you can leave to a beneficiary is 1% and the total to all beneficiaries must equal 100%.

My spouse If completing this section, check only one of these options.

■ To the person named here


Name first, middle initial, last Birth date mm/dd/yyyy

Check only one %


option; don’t check > or
both boxes.
■ To the person I’m married to at the time of my death
If you select this option, your assets will be distributed to whoever is your spouse
at that time. You don’t need to provide a name.
%

Descendants or individuals
■ To my descendants who survive me, per stirpes
If you select one of
these designations, Your assets will be divided equally among your children. If a child is deceased, the
don’t list the names > entire portion due to that child will be divided equally among his or her children (if any).
or your descendants/ This designation excludes stepchildren and stepgrandchildren. %
grandchildren below.
■ Equally to my grandchildren who survive me
%

■ To the following named individual(s):


Name of individual first, middle initial, last Birth date mm/dd/yyyy
%
Attach a separate Name of individual first, middle initial, last Birth date mm/dd/yyyy
sheet if you want to >
list more individuals. %

Trusts
■ To the trustee of an existing trust created under an agreement
Name of trust Date of trust mm/dd/yyyy
This applies to %
existing trusts only;
you can’t create a >
trust with this form. ■ To the trustee of a trust created under my last will
Name of trust or section of will
%

Other
■ Organization or charity Provide name.
%
■ My estate
%

If the percentages don’t total 100%, Vanguard Total


will allocate equal percentages totaling 100%. > 100%

You must sign on page 9.

8 of 10
Form RICA

8. Authorization of account owner Read carefully before signing.

Important information about opening a new account. The Vanguard Group, Inc. (Vanguard),
and Vanguard Marketing Corporation are required by federal law to obtain from each
person who opens an account certain personal information—including name, street
address, and date of birth—that will be used to verify identity. If you don’t provide us with
this information, we won’t be able to open the account. If we’re unable to verify your identity,
Vanguard reserves the right to close your account or take other steps we deem reasonable.

I hereby adopt or reaffirm my prior adoption of the Vanguard Traditional and Roth IRA Custodial
Account Agreement (CAA) that is incorporated herein by reference and that I acknowledge having
received and read. I further acknowledge having received and read the Vanguard Traditional and Roth
IRA Disclosure Statement and a prospectus for each Vanguard fund I elected under this form.
I agree to the terms and conditions established by Vanguard Fiduciary Trust Company, the custodian
of my IRA, for an IRA beneficiary designation. If, for any reason, I do not have a beneficiary at the
time of my death, my beneficiary will be what is stated as the default under the CAA in effect at the
time of my death.
I certify that any reconversion request meets the applicable IRS timing restrictions. If I have elected
to have the conversion assets placed into an existing Roth IRA, I understand that beneficiary
designations currently in place on my existing Roth IRA will remain in effect unless I have completed
Section 7 of this Vanguard IRA to Vanguard Roth IRA Conversion Form.

If I am a U.S. citizen, a U.S. resident alien, or a representative of a U.S. entity, I certify


under penalties of perjury that:
1. The taxpayer ID number I have given on this form is correct (or I am waiting for a
number to be issued to me).
2. I am not subject to backup withholding because (a) I am exempt from backup withholding,
or (b) I have not been notified by the Internal Revenue Service (IRS) that I am subject to
backup withholding as a result of a failure to report all interest or dividends, or (c) the IRS
has notified me that I am no longer subject to backup withholding.
Important: Cross out item 2 if You have been notified by the IRS that You are currently
subject to backup withholding because You have failed to report all interest or dividends
on Your tax return.
3. I am a U.S. citizen or other U.S. person (as defined by the IRS in its Form W-9 instructions).
4. The Foreign Account Tax Compliance Act (FATCA) code(s) entered on this form (if any)
indicating that I am exempt from FATCA reporting is correct.
If I am not a U.S. person, I will complete the appropriate Form W-8 electronically to certify my
foreign status, including my FATCA status, and to claim treaty benefits if applicable.
The IRS does not require Your consent to any provision of this document other than the
certification required to avoid backup withholding.

Sign and date here. Signature of owner or custodian Date mm/dd/yyyy


If the IRA owner
is a minor, the > X
custodian identified in
Section 2 must sign.
Vanguard Fiduciary Trust Company Title

Officer

Print Form Only

Return ALL pages of this form, even if some sections are left blank.

9 of 10
Print Entire Kit
Form RICA

Mailing information
Keep a copy of your completed form for your records.
Mail your completed form and any attached information in the enclosed postage-paid envelope.

If you don’t have Vanguard


a postage-paid > P.O. Box 1110
envelope, mail to: Valley Forge, PA 19482-1110

Vanguard
For overnight
delivery, mail to: > 455 Devon Park Drive
Wayne, PA 19087-1815

© 2016
The Vanguard Group, Inc.
All rights reserved.

RICA 092016

10 of 10
P.O. Box 1110
Valley Forge, PA 19482-1110

Connect with Vanguard® > [Link] > 800-662-2739

© 2015 The Vanguard Group, Inc. All rights reserved.

PPS254CV 092015
The Vanguard Traditional IRA,
SEP-IRA, and Roth IRA
Disclosure Statement and Custodial Account Agreement
Contents
Vanguard Traditional and Roth IRA Disclosure Statement
Section I—Revocation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Section II—Establishment of your account . . . . . . . . . . . . . . . . . . . 1
Section III—Contributions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
Section IV—Transfers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
Section V—Rollover contribution . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Section VI—Conversions to a Roth IRA . . . . . . . . . . . . . . . . . . . . . . 8
Section VII—Taxation of distributions . . . . . . . . . . . . . . . . . . . . . . . 9
Section VIII—Methods of distribution . . . . . . . . . . . . . . . . . . . . . . 11
Section IX—Simplified employee pension. . . . . . . . . . . . . . . . . . . 12
Section X—Income tax returns . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
Section XI—Prohibited transactions. . . . . . . . . . . . . . . . . . . . . . . . 13
Section XII—Other information . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

Vanguard Traditional and Roth IRA Custodial Account Agreement


Article I—Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
Article II—Contributions to Account . . . . . . . . . . . . . . . . . . . . . . . 16
Article III—Investment of Account. . . . . . . . . . . . . . . . . . . . . . . . . 17
Article IV—Distribution of Account . . . . . . . . . . . . . . . . . . . . . . . . 18
Article V—Transfers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
Article VI—Reporting, disclosure, and fees . . . . . . . . . . . . . . . . . . 23
Article VII—Amendment, termination, and assignment . . . . . . . . 23
Article VIII—Miscellaneous . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
Vanguard Traditional and Roth IRA Disclosure Statement
Introduction 4. Prohibitions against life insurance and commingling.
No part of your IRA assets may be invested in life
This Disclosure Statement describes the general
insurance contracts, nor may your IRA assets be
requirements and features of both a traditional and a
commingled with other property except in a common
Roth IRA, as well as the specific features of the Vanguard
trust fund or common investment fund.
Traditional and Roth IRA Custodial Account Agreement. This
Disclosure Statement is provided in accordance with Internal 5. Distribution rules. Your IRA must comply with certain
Revenue Service (IRS) regulations. (Where the requirements minimum distribution requirements, which are described
for a traditional and a Roth IRA are the same, this Disclosure in Section VIII. (No age 70½ distribution requirements
Statement refers to both types of accounts as an “IRA.”) apply for Roth IRAs.)
B. Tax consequences of traditional IRA
Section I In general, the federal income tax consequences of
Revocation establishing a traditional IRA are the following:
You may revoke your Vanguard IRA® at any time within 1. Tax-deferred earnings. Earnings and gains on your
seven days after it is established by mailing or delivering a traditional IRA contributions will not be subject to federal
written notice of revocation to Vanguard, P.O. Box 2600, income taxes until they are actually distributed.
Valley Forge, PA 19482-2600. Any notice of revocation will be
deemed mailed on the date of postmark (or if sent by certified 2. Deductible contributions. You may be permitted to
or registered mail, the date of certification or registration) make contributions to your traditional IRA that are
if it is deposited in the U.S. Postal Service in an envelope deductible for federal income tax purposes in an amount
or other appropriate wrapper, first-class postage prepaid, up to the lesser of the contribution limit in effect for
properly addressed. Upon revocation, you will be entitled to a such year or 100% of your current-year compensation.
full refund of your entire IRA contribution without adjustment You are permitted to make deductible traditional IRA
for administrative expenses, sales commissions (if any), contributions if neither you nor your spouse is an active
or fluctuations in market value. If you have any questions participant in an employer-maintained retirement plan, or
concerning your right of revocation, please call 800-662-2739 if your adjusted gross income for the taxable year does
during normal business hours. not exceed certain dollar limits. To the extent that your
traditional IRA contributions are not deductible, they
may be treated as “nondeductible contributions” that
Section II must be reported on your federal income tax return. See
Establishment of your account Section III[D] for more information.
A. Statutory requirements 3. Taxable distributions. Distributions from your traditional
An IRA is a trust or custodial account established for the IRA will generally be taxable as ordinary income in the
exclusive benefit of you and your beneficiaries. The Internal year of receipt, with the exception that if you have
Revenue Code of 1986, as amended, provides for several made any nondeductible contributions or after-tax
types of IRAs, including a “traditional” IRA and a “Roth” rollover contributions to your traditional IRA, part of
IRA. You must clearly designate on the forms establishing your traditional IRA distributions may be treated as a
your IRA that your account is either a traditional IRA or a nontaxable return of your nondeductible traditional IRA
Roth IRA. An IRA must be created by a written document contributions or after-tax rollover contributions. Any
that meets all of the following requirements: distributions you receive from your traditional IRA prior
to age 59½ may be subject to an additional 10% tax
1. Bank trustee or custodian. An IRA must be established
(although exceptions may apply—see Section VII[C]).
with a qualified trustee or custodian, such as Vanguard
You must start receiving certain minimum distributions
Fiduciary Trust Company, which is a bank or other
from your traditional IRA beginning by April 1 of the year
person approved by the IRS. You cannot be your own
following the year in which you attain age 70½ (see
trustee or custodian.
Section VIII[B]).
2. Cash contributions up to annual contribution limit. All
4. Tax-free rollovers. You may be eligible to make a
contributions to your IRA, excluding rollover or conversion
rollover contribution to your traditional IRA of cash
contributions as described in Sections V and VI, must be
or other assets you receive from another individual
made in cash. The total amount of contributions, other
retirement plan or employer-maintained retirement
than rollover or conversion contributions, for any taxable
plan. In addition, you may be eligible to roll over the
year to your traditional and Roth IRAs may not exceed
taxable amount you withdraw from your traditional IRA
the contribution limit in effect for such taxable year as
to another individual retirement plan or an employer-
described in Section III[A].
maintained retirement plan. See Sections V and VI for
3. Nonforfeitability. The balance of your IRA account must more information.
be fully vested and nonforfeitable at all times.

1
5. State taxes. The state tax consequences of your Section III
traditional IRA will vary from state to state. You
are strongly encouraged to consult a tax advisor to Contributions
determine the state tax consequences of establishing a A. Amount and timing of traditional and Roth IRA
traditional IRA. contributions
Maximum annual contributions to all IRAs. The total
C. Tax consequences of a Roth IRA
amount of contributions to all of your IRAs (both traditional
In general, the federal income tax consequences of and Roth IRAs) for any taxable year (excluding any rollover
establishing a Roth IRA are the following: or conversion contributions as described in Sections V and
1. Tax-deferred earnings. Earnings on contributions to a VI) may not exceed the lesser of the contribution limit in
Roth IRA will accumulate on a tax-deferred basis and effect for such taxable year as described below or 100%
may ultimately be tax-free if the earnings are part of of your compensation for the taxable year. If you reach
a “qualified distribution.” (A “qualified distribution” is age 50 before the close of the tax year for which you
generally a distribution made to you after age 59½ and are making a contribution, your annual contribution limit
after you have held your Roth IRA account at least five is increased by $1,000 as described below. In addition,
years [see paragraph 3, below].) the maximum contribution permitted under a Roth IRA is
phased out to $0 for individuals earning above a certain
2. Nondeductible contributions. Contributions to a Roth level of adjusted gross income (see Section III[C]).
IRA are not deductible for federal income tax purposes.
The annual IRA contribution limits for 2014 and 2015 are
3. “Qualified” distributions are completely tax-free. shown below.
A distribution from a Roth IRA will be tax-free for
Maximum annual contribution Maximum annual contribution
federal income tax purposes as long as it is a “qualified
Individuals under age 50 Individuals age 50 or older
distribution.” A qualified distribution is a distribution from
a Roth IRA: (1) made after a five-year holding period, and $5,500 $6,500
(2) made after age 59½, due to death or disability, or for The contribution limit will be periodically adjusted for cost-of-living
the first $10,000 of “qualified first-time home purchase increases in $500 increments.
expenses.” See Section VII[B] for more details.
Definition of compensation. For purposes of the IRA
4. “Nonqualified” distributions are tax- and penalty-free contribution limits, your compensation includes all wages,
return of contributions first; taxable earnings last. salaries, tips, professional fees, bonuses, and other
Any distribution that is not a qualified distribution (for amounts you receive for providing personal services,
example, a distribution taken before you hold your Roth and any earned income from self-employment. It does
IRA for five years) is first considered a tax- and penalty- not include earnings and profits from property such as
free distribution of your contributions to your Roth IRA. dividends, interest, or capital gains, or amounts received
Once an amount equaling the cumulative contributions as a pension or annuity, or as deferred compensation. Your
to your Roth IRA has been recovered tax-free, all further compensation includes any taxable alimony or separate
distributions that are not qualified distributions will be maintenance payments you may receive under a decree of
subject to both ordinary income tax and possibly an divorce or separate maintenance. Compensation includes
additional 10% penalty tax (if you are under age 59½). nontaxable combat pay received by a member of the U.S.
See Section VII[B] for more details. Armed Services.

5. Rollovers. You may be eligible to make a rollover Repayment of qualified reservist distribution. If you
contribution to your Roth IRA of cash or other assets receive a qualified reservist distribution from an IRA,
you receive from another Roth IRA or from a designated 401(k), or 403(b) plan, you may repay the amount of
Roth account in a 401(k) or 403(b) plan. In addition, you the distribution at any time during the two-year period
may be eligible to roll over the amount you withdraw beginning on the day after the end of your active duty
from your Roth IRA to another Roth IRA. See Section V period or by August 17, 2008, if later. Such repayment
for more details. contributions are not subject to the annual IRA contribution
limits described above. No deduction is permitted for
6. Conversions. If you are not a married individual filing repayment contributions.
a separate tax return, you may roll over or “convert”
a traditional IRA into a Roth IRA. Distributions from IRA for your spouse. If both you and your spouse earn
an eligible retirement plan can be rolled over (i.e., compensation for a taxable year, you may each make
“converted”) directly to a Roth IRA (subject to the same contributions to a traditional or Roth IRA up to the lesser
income limits as traditional to Roth IRA conversions). of the contribution limit in effect for such taxable year or
100% of your compensation for the taxable year, although
7. State taxes. The state tax consequences of your Roth your Roth IRA contribution limit may be phased out based
IRA will vary from state to state. You are strongly on your adjusted gross income for the year (see Section
encouraged to consult a tax advisor to determine the III[C]). In addition, under a special rule for spousal IRAs
state tax consequences of establishing a Roth IRA. (explained in Section III[E]), contributions of up to the
contribution limit in effect for such taxable year may be

2
made to either a traditional IRA or, subject to the adjusted compensation are generally fully deductible (regardless of
gross income phase-out discussed in Section III[C], a your level of adjusted gross income).
Roth IRA of a spouse, regardless of the income level of
Phase-out of deduction if you participate in an
the spouse, provided the married couple files a joint tax
employer plan. If you are an active participant in an
return and has total compensation at least equal to their
employer-maintained retirement plan for a taxable year,
combined IRA contributions.
your traditional IRA deduction is phased out as your
Contributions in cash. All contributions to your traditional adjusted gross income approaches the upper limits of the
or Roth IRA (other than rollover contributions as described applicable “phase-out range.” The phase-out ranges for
in Section V) must be made in cash, check, or by electronic joint and single filers are as follows:
transfer. If you wish to use shares of a previously Joint filers Single filers
established Vanguard fund account for your annual IRA Year Phase-out range Phase-out range
contribution, you must first redeem the amount of shares
2014 $96,000–$116,000 $60,000–$70,000
you wish to invest, and then use the cash proceeds as
your IRA contribution. 2015 $98,000–$118,000 $61,000–$71,000

Contributions up to the date your return is due The dollar limits above will be periodically adjusted for cost-of-living
increases in $1,000 increments.
(April 15). You may make contributions to your traditional
or Roth IRA for a taxable year at any time during the year, Formula for deduction phase-out for active participants.
either periodically or in a lump sum, or in the next year, up As stated on the previous page, if you are an active
to the due date for filing your federal income tax return for participant in an employer-maintained retirement plan for
the taxable year, not including extensions. For taxpayers a taxable year, your traditional IRA deduction limit for the
who file on a calendar-year basis, the latest date for any year is phased out as your adjusted gross income exceeds
year is April 15 of the following year. If you do not inform the applicable adjusted gross income threshold for the
the Custodian of the year for which an IRA contribution is tax year. This phase-out is accomplished as follows: Your
made, the Custodian will assume that the contribution is maximum traditional IRA deduction is reduced by an
made for the year in which it is received. amount, rounded down to the nearest $10, that bears the
same ratio to the maximum deductible amount as your
Only Roth IRA contributions permitted after age 70½. If
“excess” adjusted gross income for the taxable year bears
you are otherwise eligible, you are permitted to make Roth
to $10,000 for single filers or $20,000 for joint filers.
IRA contributions even after you have attained age 70½.
You are not permitted to make traditional IRA contributions Deduction limit for spouse. If you are married and file a
(either deductible or nondeductible) for the year you attain joint return, and neither you nor your spouse is an active
age 70½ and any subsequent years (other than rollover participant in an employer-maintained retirement plan, the
contributions as described in Section V). traditional IRA contributions for each spouse for the taxable
year will be fully deductible regardless of the level of your
Maximum contributions not required. You do not have
combined adjusted gross income.
to contribute to your traditional or Roth IRA every year, nor
are you required to make the maximum contribution for If you are married and file a joint return and both you and
any year. However, if you decide in any year not to make your spouse are active participants in employer-maintained
the maximum IRA contribution, you may not make up the retirement plans, the traditional IRA deduction limit for
missed contribution amount in later years. For both the each spouse for the taxable year is phased out as your
Vanguard traditional and Roth IRAs, there is a minimum combined adjusted gross income exceeds the applicable
initial contribution required when you establish your threshold (see the joint filer phase-out range above).
account, as described in Section XII[D].
If you are married and file a joint return and you are an
B. Traditional IRA: Deductible contributions active participant in an employer-maintained retirement
Contributions to your traditional IRA may be deductible plan, but your spouse is not, a higher adjusted gross
in whole or in part for federal income tax purposes, as income phase-out will apply for your spouse’s (but not
determined by the rules summarized below. Contributions your) deduction limit. The traditional IRA deduction limit for
to a Roth IRA are not deductible for federal income your spouse, who is not an active participant, is phased
tax purposes. You should contact your tax advisor to out if your combined adjusted gross income for the taxable
determine the deductibility of IRA contributions for state year falls between $150,000 and $160,000, as adjusted for
income tax purposes. cost-of-living increases (i.e., $181,000–$191,000 for 2014
and $183,000–$193,000 for 2015). The deduction limit
Fully deductible contributions if you do not participate for you—the active participant in an employer-maintained
in an employer plan. If neither you nor your spouse is plan—is phased out as your combined adjusted gross
an active participant in an employer-maintained retirement income for the tax year exceeds the applicable threshold
plan, your annual traditional IRA contributions up to the (see the joint filer phase-out range above).
lesser of the contribution limit in effect for the taxable year
(as described in Section III[A]) or 100% of current-year

3
Special rules for married couples filing separate returns. described in Section III[A] or 100% of your compensation
If you are a married individual filing a separate return and for the taxable year (less any amount you also contribute to
you or your spouse is an active participant in an employer- a traditional IRA). Furthermore, your Roth IRA contribution
maintained retirement plan, the deduction for your traditional maximum is phased out as your adjusted gross income
IRA contributions will be phased out as your adjusted gross approaches the upper limits of the applicable “phase-out
income for the taxable year increases from $0 to $10,000. range.” The applicable phase-out ranges are as follows:
However, if you and your spouse did not live together at
• If you are single—your phase-out range is adjusted gross
any time during the taxable year, your filing status will
income of between $114,000 and $129,000 for 2014;
be considered to be single for traditional IRA deduction
and $116,000 and $131,000 for 2015.
purposes, and your traditional IRA deduction limit will be
determined without regard to whether your spouse is an • If you are married filing jointly—your phase-out range
active participant in an employer retirement plan. is adjusted gross income of between $181,000 and
$191,000 for 2014; and $183,000 and $193,000 for 2015.
Active participant defined. For purposes of the traditional
IRA deduction limits, you are considered an active • If you are married filing separately—your phase-out
participant in an employer-maintained retirement plan for a range is adjusted gross income of between $0 and
taxable year if you participate in a qualified pension, profit- $10,000. However, if you and your spouse did not live
sharing, stock bonus, or annuity plan (including a Keogh together at any time during the taxable year, your filing
or 401(k) plan), a tax-sheltered annuity plan under Section status will be considered to be single for Roth IRA
403(b) of Internal Revenue Code, a simplified employee contribution purposes.
pension (SEP) plan, or a government plan (but not an
eligible deferred compensation plan under Section 457(b) The dollar limits above for single filers and married filing
of the Code) during any part of the plan year ending with jointly will be periodically adjusted for cost-of-living
or within the taxable year. The determination of whether increases in $1,000 increments.
you are an active participant in an employer-maintained Formula for contribution phase-out. As your adjusted
retirement plan is made without regard to whether your gross income approaches the upper limit of the phase-
rights under the plan are nonforfeitable or vested. Under a out ranges described above, your Roth IRA contribution
defined contribution plan, you are generally considered an limit for the year is phased out to $0. This phase-out
active participant if any employer contribution or forfeiture is accomplished as follows: Your maximum Roth IRA
is allocated to your account during the taxable year. Under a contribution is reduced by an amount, rounded down to
defined benefit plan, you are considered an active participant the nearest $10, that bears the same ratio to the maximum
if you are not excluded by the plan’s eligibility requirements IRA contribution limit in effect for the taxable year as
during any part of the plan year ending with or within your your “excess” adjusted gross income for the taxable year
taxable year. However, if you have not satisfied the plan’s bears to $15,000 ($10,000 in the case of a joint return or a
minimum age or service conditions required for participation, married individual filing a separate return).
you are not considered an active participant in the plan.
The Form W-2 you receive from your employer each year Adjusted gross income (AGI) for Roth IRA contribution
should indicate whether you are an active participant in an phase-out purposes. For purposes of the Roth IRA
employer-maintained retirement plan. contribution phase-out, your adjusted gross income is
determined as it is for determining the traditional IRA
Adjusted gross income. For purposes of the traditional deduction limit for active participants (see Section III[B]),
IRA deduction limits, your adjusted gross income is except that your adjusted gross income is reduced by
calculated by taking into account any taxable Social (1) any deductible traditional IRA contributions you may
Security benefits and taxable IRA distributions you may make for the taxable year, and (2) any amount included in
receive for the year. However, your adjusted gross gross income as a result of a traditional IRA to Roth IRA
income is not reduced by any deductible traditional IRA “conversion” discussed in Section VI.
contributions you may make for the taxable year, employer-
provided adoption assistance that is otherwise not taxable, Minimum contribution limit of $200. There is a special
or proceeds of U.S. Savings Bonds used for higher- rule providing that if your adjusted gross income for Roth
education expenses that are otherwise not taxable. IRA contribution phase-out purposes is within the “phase-
out range,” your Roth IRA contribution limit is never less
Minimum deduction limit of $200. There is a special rule than $200.
providing that if your adjusted gross income for any taxable
year is within the “phase-out range,” your traditional IRA D. Traditional IRA: Nondeductible contributions
deduction limit is never less than $200. You may wish to make “nondeductible contributions” to
your traditional IRA to the extent that you are not eligible to
C. Roth IRA: Maximum annual contribution make either deductible traditional IRA contributions or Roth
The maximum contribution permitted under a Roth IRA IRA contributions (or if you do not wish to make deductible
(excluding any rollover or conversion contributions as traditional IRA contributions). Remember, however,
described in Sections V and VI) is generally the lesser that the total amount of deductible and nondeductible
of the contribution limit in effect for the taxable year as contributions to all of your traditional and Roth IRAs for any

4
taxable year may not exceed the lesser of the contribution limit is reduced by an amount that bears the same ratio to
limit in effect for the taxable year or 100% of your the contribution limit in effect for the taxable year as your
compensation for the year. combined adjusted gross income over $150,000, as adjusted
for cost-of-living increases (i.e., $181,000 for 2014), bears to
Tax advantage of nondeductible contributions. The
$10,000. Thus, for example, the deduction for contributions
primary tax benefit associated with nondeductible
to a spousal traditional IRA for 2014 would be eliminated if
contributions to a traditional IRA is that the earnings and
your combined adjusted gross income exceeds $191,000,
gains on these contributions will not be subject to federal
although nondeductible traditional IRA contributions could
income tax until they are actually distributed to you.
still be made.
Election to treat deductible contributions as
Contributions after age 70½ to traditional IRAs. You may
nondeductible contributions. You are permitted to
make contributions to a traditional IRA for your spouse
elect to treat your traditional IRA contributions, which
even after you reach age 70½ provided your spouse has
would otherwise be deductible for any taxable year, as
not yet attained age 70½. However, you may not make
nondeductible contributions. You may wish to make such
contributions to a traditional IRA for your spouse (other
an election, for example, if you have no taxable income for
than rollover contributions described in Section V) for the
the year after taking into account other deductions or tax
year your spouse reaches age 70½ or any subsequent
credits, and you are not eligible for a Roth IRA contribution.
year. Distributions from the account do not have to begin
Designation of nondeductible contributions. until April 1 of the calendar year following the calendar year
Your designation of traditional IRA contributions as in which the spouse for whom the account is maintained
nondeductible contributions for a taxable year is to be reaches age 70½. With the exception of the contribution
made by filing Form 8606, Nondeductible IRAs, with limitations, all rules that apply to a traditional IRA generally
your federal income tax return for the taxable year. apply to the traditional IRA for a spouse.
Nondeductible traditional IRA contributions for a taxable
Roth IRA contributions for spouse. The amount of
year may be made at any time during the taxable year, or
permitted contributions to a spousal Roth IRA is generally
in the next year, up to the due date for filing your federal
determined by the rules discussed in Section III[C]. Thus,
income tax return for the taxable year, not including
if you are married filing a joint tax return, the spousal
extensions. If you file an amended return, you may change
Roth IRA contribution limit in effect for the taxable year
your designation of your traditional IRA contributions from
is reduced by an amount that bears the same ratio to the
deductible contributions to nondeductible contributions
contribution limit in effect as your combined adjusted
or vice versa (although such a change may result in an
gross income over $150,000, as adjusted for cost-of-living
increased or different tax liability).
increases (i.e., $181,000 for 2014), bears to $10,000.
E. Spousal IRAs For example, the contributions to a spousal Roth IRA
If your spouse has little or no income, your spouse may for 2014 would be eliminated if your combined adjusted
still be eligible to establish and contribute to an IRA under a gross income exceeds $191,000, although nondeductible
special rule for spousal IRAs. To qualify for this rule, you and traditional IRA contributions could still be made. Keep in
your spouse must file a joint return for the taxable year. mind that Roth IRA contributions on behalf of a spouse
may be made regardless of whether you or your spouse is
IRA contributions up to limit in effect. Under the over age 70½.
special rule for spousal IRAs, contributions may be made
to your spouse’s traditional or Roth IRA for any taxable F. Return of IRA contributions
year in an amount up to the lesser of: (1) the contribution Withdrawal of IRA contributions by the date your return
limit in effect for the taxable year, or (2) the combined is due. If you make a contribution to your IRA for a taxable
compensation of you and your spouse for the taxable year, year, you may withdraw the contribution amount and the
less the amount of any contributions you made to your IRA earnings thereon at any time prior to the due date for filing
for the taxable year. your federal income tax return, including extensions, for
the taxable year for which the contribution was made, or
Deductibility of contributions for spouse. The such later date as prescribed by the IRS. If the excess (and
deductibility of contributions to a traditional IRA for a any earnings) is removed prior to the applicable deadline,
spouse is generally determined by the rules discussed in the return of the contribution will not be includible in your
Section III[B]. Thus, for example, if neither you nor your gross income as an IRA distribution. However, the earnings
spouse is an active participant in an employer-maintained on the contribution will be taxable income in the year in
retirement plan, contributions to a spousal traditional IRA which the contribution was made and may possibly be
are fully deductible. However, if your spouse is an active subject to the 10% tax on early distributions if you are
participant in an employer-maintained retirement plan, your under age 59½ (see Section VII[C]).
spouse’s IRA deduction limit for the taxable year is phased
out as your combined adjusted gross income for the tax G. Recharacterization of IRA contributions
year exceeds the applicable threshold provided in the chart You may elect to recharacterize all or part of a regular
in Section III[B]. contribution or conversion contribution (i.e., treat a
contribution made to one IRA (the “First IRA”) as made to
If you participate in an employer-maintained retirement
plan and your spouse does not, the spousal deduction
5
a different type of IRA (the “Second IRA”). You may wish year. Under this procedure, you are not required to withdraw
to recharacterize a contribution because, for example, you any earnings attributable to the excess contribution.
realize you were not eligible to make the IRA contribution
Applying excess contribution to subsequent year. You
or for tax-planning reasons. For example, you may wish to
may also eliminate an excess contribution from your IRA
recharacterize a contribution to a Roth IRA into a contribution
in a subsequent year by not contributing the maximum
to a traditional IRA because you decide that you want the tax
amount for that year and applying the excess contribution
deduction available for a traditional IRA contribution.
to the subsequent year’s contribution. You may be
A recharacterization is accomplished by requesting, in a entitled to a deduction for the amount of the excess
form and manner acceptable to the Custodian, a trustee- contribution that is applied in the subsequent year provided
to-trustee transfer of the contribution made to the First you did not previously deduct the excess contribution
IRA, adjusted for gains and losses, to the Second IRA. The (or if the deduction you claimed was disallowed by the
recharacterized amount is treated as having been originally IRS). However, if you incorrectly deducted an excess
contributed to the Second IRA on the same date and (in contribution in a closed taxable year (i.e., one for which the
the case of a regular contribution) for the same taxable period to assess a deficiency has expired), the amount of
year that the contribution was made to the First IRA. The the excess contribution cannot be deducted again in the
recharacterization is permissible only if the contribution subsequent year in which it is applied.
could have been made originally to the Second IRA. The
recharacterization must be accomplished by the due date Section IV
(including extensions) of your federal income tax return for
the year for which the original contribution was made, or Transfers
such later date as prescribed by the IRS. This section discusses options for carrying out a trustee-to-
trustee asset transfer of your existing IRA to another IRA
You can recharacterize a Roth IRA conversion contribution
of the same type (e.g., a transfer from traditional IRA to
back to a traditional IRA and then reconvert the
traditional IRA). For a discussion of recharacterizations of
recharacterized amount to a Roth IRA again, subject to
contributions to a different type of IRA, rollover options, and
certain timing restrictions (see Section VI[B]).
the option to “convert” your traditional IRA to a Roth IRA, see
H. Excess contributions to traditional or Roth IRA Sections III[G], V, and VI, respectively.
Generally, an excess contribution is the amount of any A. Tax-free transfer from existing IRA to Vanguard IRA
contributions to your traditional or Roth IRA (other than a
In order to give you greater investment flexibility, you
proper rollover or conversion contribution as described in
are permitted to transfer IRA assets directly from one
Sections V and VI) for a taxable year that exceeds your IRA
trustee or custodian to another on a tax-free basis. If you
contribution limit for the taxable year. An excise tax equal
already have an IRA with another trustee or custodian,
to 6% of the amount of any excess contribution will be
you may authorize a direct transfer of your IRA assets to
assessed for the year for which the excess contribution
a Vanguard IRA without paying taxes, subject to the rules
is made and for each subsequent year until the excess
and restrictions of your existing account. Transfers are only
amount is eliminated.
permitted between the same type of IRA plans (i.e., from a
Return of excess contribution by the date your return traditional IRA to traditional IRA or from a Roth IRA to Roth
is due. If you make an excess contribution to your IRA IRA). You may make such a transfer as often as you wish.
for a taxable year, you may withdraw the contribution Such a transfer of assets is not tax-deductible.
and the earnings thereon prior to the due date for filing
B. Tax-free transfer from Vanguard IRA
your federal income tax return, including extensions, or
such later date as may be prescribed by the IRS. If this If you so direct in a form and manner acceptable to the
withdrawal is made by the applicable deadline, the return Custodian, the Custodian will transfer all or any portion
of the contribution will not be subject to the 6% excise tax of the assets held in your Vanguard IRA directly to the
on excess contributions (assuming the contribution is not trustee or custodian of another IRA established on your
deducted on your return). behalf, provided the trustee or custodian certifies that it
will accept the direct transfer of assets and will deposit
Return of excess contribution after tax return due date. the transferred assets in the same type of IRA established
If you make an excess contribution to your IRA for a taxable on your behalf. Transfers are only permitted between
year and you withdraw the excess contribution after the the same type of IRA plans (i.e., from a traditional IRA to
due date for filing your federal income tax return (including traditional IRA or from a Roth IRA to Roth IRA).
extensions), the returned excess contribution will not be
includible in your gross income as an IRA distribution (subject C. Transfer incident to divorce
to possible premature distribution penalties) if (1) your total All or any portion of your IRA assets may be transferred
IRA contributions for the year did not exceed the contribution to a separate IRA for the benefit of your former spouse
limit in effect for the taxable year, and (2) you did not deduct pursuant to a divorce decree or written instrument incident
the excess contribution on your return (or if the deduction to divorce. The transfer will not result in a taxable increase
you claimed was disallowed by the IRS). However, you must for you or your former spouse. After the transfer, your
pay the 6% excise tax on the excess contribution for each former spouse will be considered the Owner of the IRA
taxable year that it was still in your IRA at the end of the mentioned for his or her benefit.
6
Section V After-tax contributions. If a portion of your eligible rollover
distribution from an employer’s plan represents a return
Rollover contribution of after-tax contributions, you may roll over your after-tax
A. Rollover from existing IRA to a Vanguard IRA contributions to a traditional IRA. If you elect to roll over
If you receive a distribution of assets from an existing after-tax contributions, it is your responsibility to keep
IRA, you may make a rollover contribution of all or part of track of these after-tax rollover amounts and to report
the assets you receive tax-free to a Vanguard IRA. Except such rollover amounts in accordance with IRS guidelines.
in the case of a “conversion” from a traditional IRA to a Once you roll after-tax amounts into a traditional IRA, those
Roth IRA, rollovers are only permitted between the same amounts cannot later be rolled into an employer plan.
type of IRA plans (i.e., from a traditional IRA to traditional
Direct rollover option. If you will be entitled to receive an
IRA or from a Roth IRA to Roth IRA). The rollover must be
eligible rollover distribution from an eligible employer plan,
completed within 60 days after you receive the distribution
you may elect to have the plan roll over all or any part of
from your existing IRA. You are limited to one such tax-free
your distribution directly to your Vanguard traditional IRA
rollover within a one-year period (beginning on the date you
as a tax-free rollover contribution on your behalf. If you
receive the IRA distribution, not on the date you make the
elect this direct rollover option, no federal income taxes
rollover contribution). You cannot make a tax-free rollover
will be withheld from your distribution to the extent it is
if you have already made a rollover from any of your IRAs
transferred directly to your Vanguard traditional IRA. The
in the preceding one-year period. IRA conversions are
plan administrator of your employer’s plan must give you
not taken into account for purposes of this limit. You may
an explanation of your direct rollover option and the other
not roll over any minimum distribution amounts you are
tax rules affecting your eligible rollover distribution.
required to receive from your traditional IRA upon attaining
age 70½ (see Section VIII[B]). Payment option; 20% withholding. If you elect to have
an eligible rollover distribution from an employer’s qualified
Note: A tax-free transfer of funds as described in Section
retirement plan paid directly to you, your distribution will
IV[A] is not a rollover (since you do not actually receive
be subject to 20% federal income tax withholding. You
any distribution from your IRA). Rather it is a direct
will still have the option of making a tax-free rollover
transfer of your IRA funds from one trustee or custodian
contribution of your eligible rollover distribution to a
to another that is not affected by the 12-month waiting
Vanguard traditional IRA within 60 days of receipt of your
period applicable to IRA rollovers.
distribution. You may roll over any amount up to 100% of
If your distribution consists of property other than cash, your eligible rollover distribution (including an amount equal
you must roll over to your new IRA the same property you to the 20% that was withheld by coming up with additional
received from your old IRA. If you wish to make a rollover money to make up for the withheld amount).
contribution of property other than cash to your Vanguard
Rollover of property. If you receive an eligible rollover
IRA, you must obtain the prior approval of the Custodian.
distribution from an employer retirement plan that consists
B. Rollover from employer retirement plan to Vanguard of property other than cash, you may be permitted to roll
traditional IRA over the property received to your traditional IRA. As an
Eligible rollover distribution from employer’s retirement alternative, you may sell the property received and roll over
plan to traditional IRA. If you receive an “eligible rollover the cash proceeds to your traditional IRA, in which case
distribution” from an “eligible employer plan,” other than a no gain or loss will be recognized on the sale if the entire
designated Roth account, you may make a tax-free rollover proceeds are rolled over. If you wish to make an in-kind
contribution of the distribution to a Vanguard traditional rollover contribution of property other than cash to your
IRA. An “eligible employer plan” includes a plan qualified Vanguard traditional IRA, you must obtain the prior approval
under section 401(a) of the Code (including a 401(k), of the Custodian.
pension, profit-sharing, defined benefit, or stock bonus Rollover by surviving spouse. A surviving spouse of
plan), a governmental 457 plan, a 403(a) annuity plan, or a deceased employee may be permitted to make a tax-
a 403(b) plan. An “eligible rollover distribution” generally free rollover contribution to a traditional IRA of all or any
includes any distribution or withdrawal from an eligible portion of an eligible rollover distribution from an employer
employer plan other than: retirement plan upon the employee’s death.
(1) A distribution that is part of a series of periodic Rollover by nonspouse beneficiary. A nonspouse
payments over a specified period of ten years or more, designated beneficiary of a deceased employee may be
or over your life (or life expectancy), or over the joint permitted to make a direct rollover to an inherited IRA of
lives (or joint life and last survivor expectancy) of you an eligible rollover distribution upon the employee’s death
and your designated beneficiary; (if permitted under the deceased employee’s plan).
(2) Any portion of a distribution that represents a required
minimum distribution to you after age 70½; or
(3) A hardship distribution.

7
Rollover pursuant to divorce or similar proceedings. If portion of the assets you receive from your Vanguard
you are eligible to receive an eligible rollover distribution traditional IRA within 60 days of receipt to an eligible
from an employer’s qualified retirement plan pursuant to employer plan that accepts such rollovers. If any portion
a “qualified domestic relations order” (within the meaning of a distribution from your traditional IRA represents a
of Section 414(p) of the Internal Revenue Code) resulting return of nondeductible contributions or after-tax rollover
from divorce or similar proceedings, you may have all or contributions, such portion cannot be rolled over into an
part of the distribution rolled over to your traditional IRA on eligible employer plan. You cannot roll over any minimum
a tax-free basis. distribution amount you are required to receive from a
Vanguard traditional IRA (see Section VIII[B]). Distributions
Separate traditional IRA account for certain rollovers
from a Roth IRA are not permitted to be rolled over into
from qualified plans. If you were born before January 1,
a designated Roth account under an employer plan. You
1936, and you receive an eligible rollover distribution from
should seek competent tax advice concerning IRA rollovers
an employer’s qualified retirement plan, you may prefer
to employer retirement plans.
to roll over the distribution into a separate traditional IRA
(frequently called a “rollover” or “conduit” IRA) to which
no annual IRA contributions are made. In this manner, if Section VI
you later roll over the assets to a new employer’s qualified Conversions to a Roth IRA
retirement plan you preserve any special tax treatment,
A. Traditional IRA to Roth IRA conversion: General Rules
such as ten-year averaging, that may be available on lump-
sum distributions from the qualified plan. If you are age 70½ or older, you must satisfy your required
minimum distribution for the tax year prior to making a
C. Rollover from a designated Roth account under an conversion contribution for such year. The conversion will
employer plan to a Vanguard Roth IRA be treated as a taxable distribution from your traditional IRA
Eligible rollover distribution from designated Roth and a subsequent conversion contribution to a Roth IRA.
account. If you receive an eligible rollover distribution Distributions from your traditional IRA will be includible in
from a designated Roth account under a 401(k) or 403(b) your gross income in the year of the distribution (except
plan, you may roll over all or part of the distribution to a for the portion of the distribution that represents a tax-
Vanguard Roth IRA. You cannot subsequently roll over free return of your nondeductible contributions or after-tax
from a Roth IRA back to a designated Roth account under rollover contributions) but will not be subject to the 10%
an employer plan. additional tax on early distributions, regardless of whether
you are under age 59½.
Five-year holding period. The holding period does
not carry over from the designated Roth account to the B. Recharacterization
Roth IRA. Assets that are rolled over from a designated An amount that is converted from a traditional IRA to a
Roth account to a Roth are subject to the five-year Roth IRA may be recharacterized back to a traditional IRA.
holding period applicable to the Roth IRA for purposes of An amount that is recharacterized back to a traditional
determining a qualified distribution. (See Section VII[B] for IRA may not be reconverted to a Roth IRA prior to
more information on the five-year holding period.) January 1 of the taxable year following the taxable
Roth IRA ordering rules. For purposes of the Roth IRA year of the conversion, or 30 days from the date of the
ordering rules described in Section VII[B], the entire recharacterization, whichever is later.
amount of any qualified distribution rolled over from a C. Conversions of SEPs and SIMPLE accounts
designated Roth account is treated as contributions to the Accounts held in a SEP-IRA or a SIMPLE IRA may be
Roth IRA. In the case of a nonqualified distribution from a converted to a Roth IRA. However, a conversion of a
designated Roth account, the portion of the rollover that SIMPLE IRA is permissible only after the expiration of
represents Roth basis is treated as contributions to the the initial two-year holding period. (See your SIMPLE IRA
Roth IRA and any remaining amount is treated as earnings. materials for more details.)
If only a portion of a nonqualified distribution from a
designated Roth account is rolled over, the amount rolled D. Employer plan to a Roth IRA
over is treated as consisting first of the portion of the You can roll over (i.e., “convert”) a distribution from an
distribution that represents earnings. eligible employer plan (other than a designated Roth
account) directly to a Roth IRA. If applicable, you must
D. Rollovers from a Vanguard IRA
satisfy your required minimum distribution for the tax year
If you withdraw assets from your Vanguard IRA, you may prior to rolling a distribution from an eligible employer
roll over on a tax-free basis all or any portion of the assets plan directly to a Roth IRA. In general, such rollover will
you receive within 60 days of receipt to another IRA of the be taxable in the year of the distribution (except for any
same type. You are limited to one such tax-free rollover portion of the distribution that represents a return of
within a one-year period regardless of the number of IRAs after-tax contributions) but will not be subject to the 10%
you own. You cannot make a tax-free rollover from one additional tax on early distributions, regardless of whether
IRA to another if you have already made a rollover from any you are under age 59½. Please consult a tax advisor or
of your IRAs in the preceding one-year period. You may refer to IRS Publication 590 for more information.
also roll over on a tax-free basis all or part of the taxable

8
Section VII Distributions rolled into an eligible employer plan.
The maximum amount of a traditional IRA distribution
Taxation of distributions that you can roll over into an eligible retirement plan
A. Traditional IRA: Tax treatment of distributions (other than an IRA), to the extent the plan permits rollover
In general, distributions from your traditional IRA are contributions, cannot exceed the portion of your traditional
included in your gross income in the year of receipt. IRA distribution that would otherwise be taxable (without
Exceptions to this rule include any distribution that is regard to the rollover). The portion of a distribution from
properly rolled over to another individual retirement your traditional IRA that represents a return of after-tax
arrangement or employer retirement plan as described in rollover contributions or nondeductible contributions
Section V, or any return or transfer of an IRA contribution is not eligible to be rolled over into an employer plan.
as described in Section III[F], [G], and [H] and Section If you roll over all or a portion of a distribution from a
IV. In addition, distributions from a traditional IRA that traditional IRA into an eligible employer plan (such as a
contains “nondeductible contributions” (see Section 401(k) plan, governmental 457 plan, or 403(b) plan), the
III[D]) or after-tax rollover contributions (see Section formula described above for determining the taxable and
V[C]) are treated partly as a nontaxable return of the nontaxable portion of a distribution will not apply. Instead,
nondeductible traditional IRA contributions or after-tax the portion of the distribution that is rolled over to an
rollover contributions, and partly as a taxable distribution eligible employer plan (other than an IRA) is attributable
of traditional IRA earnings and any deductible IRA first to amounts other than after-tax rollovers and
contributions, as explained below. nondeductible contributions. Therefore, you may roll over
a distribution from your traditional IRA to the extent the
Ordinary income taxation. Distributions from your amount distributed does not exceed the taxable amount
traditional IRA that are included in gross income will be (e.g., deductible contributions and earnings) of all of your
taxed as ordinary income. Traditional IRA distributions IRAs. You may wish to consult your tax advisor before
are not eligible for the special tax treatment accorded to rolling over a distribution into an eligible employer plan.
certain lump-sum distributions from qualified retirement
plans, such as forward averaging taxation. Note: If you roll over a portion of a traditional IRA
distribution to an eligible employer plan, the formula used
Distribution of nondeductible traditional IRA to determine the taxable portion of any withdrawal you
contributions. To the extent any distribution from your receive during or subsequent to the year of the rollover
traditional IRA represents a return of your nondeductible must be adjusted in accordance with IRS guidelines.
contributions (see Section III[D]) or after-tax rollover
contributions, the distribution will be treated as a tax- B. Roth IRA: Tax treatment of distributions
free return of basis. If you withdraw an amount from Ordering rules. Distributions from your Roth IRA are
a traditional IRA during a taxable year and you have treated as made in the following order:
previously made nondeductible contributions or after-tax (1) From regular contributions;
rollover contributions to a traditional IRA, then the amount
excluded from income for the taxable year is the portion (2) From conversion contributions on a first-in, first-out
of the amount withdrawn that bears the same ratio to basis; and
the amount withdrawn as your aggregate nondeductible (3) From earnings.
traditional IRA contributions and after-tax rollover
For this purpose, all distributions for each year are
contributions bear to the aggregate balance of all your
considered together, and all of your Roth IRA accounts are
traditional IRAs as of the end of the year, plus the amount
treated as one account.
of the withdrawal. For these purposes, all traditional IRAs
maintained on your behalf, including traditional rollover Tax-free “qualified distributions.” Distributions from your
IRAs and SEPs, are required to be aggregated, and all Roth IRA that are “qualified distributions” are not included
distributions in a given year are treated as one distribution. in your gross income and are generally not subject to the
additional 10% penalty tax on early distributions. A qualified
Example: An individual withdraws a total amount of
distribution from your Roth IRA is a distribution that is both
$3,000 from several traditional IRAs during a taxable year.
(1) made after a five-year holding period (see details, below)
At the end of the taxable year, the aggregate balance of
and (2) described by any one of the following:
all traditional IRAs maintained by the individual is $21,000,
and the aggregate amount of nondeductible contributions
not previously withdrawn by the individual is $4,000.
The amount of the individual’s $3,000 traditional IRA
withdrawal excludible from income is $500 (or $4,000 ÷
$24,000 x $3,000), and the remaining $2,500 is taxable.

9
(1) Made on or after the date you reach age 59½; to the ordinary income tax on the distribution. (Thus, the
(2) Made to your designated beneficiary after your death; 10% penalty tax does not apply to the tax-free portion
of any distributions you receive from your IRAs.) The
(3) Made because of your permanent disability; or
additional tax may also apply if you are deemed to receive
(4) A “qualified first-time homebuyer” distribution a distribution from your IRA before age 59½ as a result of
(subject to a $10,000 lifetime limit). Qualified first- borrowing from your IRA or pledging your IRA as security
time homebuyer distributions are distributions used to for a loan, as described in Section XI. The law also imposes
pay for certain acquisition costs (including the cost of a tax equal to 10% of any distribution from a Roth IRA
acquiring, constructing, or reconstructing a residence, attributable to conversion contributions within the separate
and reasonable settlement, financing, or other five-year holding period for conversion amounts.
closing costs) of a principal residence for a first-time
homebuyer, including you, your spouse, or any children, The additional 10% tax will not be imposed, however, on
grandchildren, or ancestors of you or your spouse. Such the following types of distributions from your traditional or
distribution must be used within 120 days after it is Roth IRA:
received. You are considered a first-time homebuyer • Distributions after you reach age 59½.
if you (and, if married, your spouse) have not owned a
• Distributions attributable to your total and permanent
principal residence during the two-year period ending on
disability.
the date of acquisition.
• Distributions made to your designated beneficiary after
Nonqualified distributions first considered tax-free
your death.
return of contributions. If a Roth IRA distribution is not a
“qualified distribution” as just described, the distribution • Distributions that are part of a series of substantially
will be treated for tax purposes as first a tax-free return equal periodic payments (not less frequently than
of your Roth IRA contributions (see “ordering rules” on annually) made for your life or life expectancy, or for
previous page). To the extent a nonqualified distribution, the joint lives or life expectancies of you and your
when added to all of your previous Roth IRA distributions beneficiary.
(whether qualified or nonqualified), is attributable to • Distributions you receive to the extent such distributions
earnings (see “ordering rules”), it will be fully taxable. do not exceed the amount of your deductible medical
expenses for the taxable year.
Five-year holding period for Roth IRA distributions.
In order for your Roth IRA distributions to be “qualified • Distributions you receive following termination of
distributions,” you must have held your Roth IRA for at least employment to the extent such distributions do not
five years prior to the distribution. This five-year holding period exceed the amount of medical insurance premiums
is generally measured by counting five years beginning with you paid for yourself, spouse, and dependents for the
the earlier of the first year for which your first regular Roth taxable year, provided that you have received at least
IRA contribution relates (not necessarily the year in which 12 consecutive weeks of unemployment compensation
your first regular Roth IRA contribution is made) or the first during the current or prior taxable year.
year in which you made a conversion contribution. • Distributions to pay for qualified higher-education
expenses. Qualified higher-education expenses include
Separate five-year holding period for conversions.
tuition, fees, books, supplies, equipment, and room and
A separate five-year holding period applies with respect
board required for enrollment or attendance for you, your
to the portion of a distribution that is properly allocable
spouse, your children, or your grandchildren at an eligible
to a traditional-to-Roth IRA conversion or a rollover from
postsecondary educational institution.
an eligible employer plan (other than a designated Roth
account) to a Roth IRA. For this portion of a distribution, • Distributions up to $10,000 used to pay for acquisition
the five-year period starts with the year in which the costs (including the cost of acquiring, constructing, or
conversion (or rollover) contribution was made (which reconstructing) of a principal residence for a first-time
may be later than the year for which your first Roth IRA homebuyer, including you, your spouse, or any children,
contribution was made). Even though the distribution of grandchildren, or ancestors of you or your spouse. Such
amounts attributable to the conversion (or rollover) may distribution must be used within 120 days after it is
not be subject to income tax, they are subject to a 10% received. You are considered a first-time homebuyer
penalty tax if made during the five-year holding period (see if you (and, if married, your spouse) have not owned a
Section VII[C]). principal residence during the two-year period ending
on the date of acquisition. The aggregate amount
C. Additional 10% tax on early distributions from of distributions you may take under this first-time
traditional IRAs and Roth IRAs homebuyer exception for the year of the distribution and
Your IRA is intended to provide you with retirement all prior years is $10,000.
income. For this reason, the law generally imposes a • Distributions that are qualified reservist distributions. If
nondeductible additional tax if you receive a distribution you were a member of a reserve component and you
from either your traditional IRA or Roth IRA, unless certain were called to active duty after September 11, 2001, and
exceptions apply. This additional tax is equal to 10% of before December 31, 2007, for a period of 179 days or
the taxable amount of the distribution and is in addition more, distributions made after the date you were called

10
to active duty and before the close of your active duty April 1 of the following year. You must receive the required
period are considered qualified reservist distributions. minimum distribution amount from your traditional IRA for
• Distributions made on account of an IRS levy. each calendar year thereafter by December 31 of that year.
Penalty tax on insufficient distributions. A 50% excise
Section VIII tax may be imposed if the amount actually distributed from
Methods of distribution your traditional IRA beginning after you attain age 70½ is
less than the minimum amount required to be distributed.
A. Distributions in general
The 50% tax is imposed on the difference between the
Under either a Vanguard traditional IRA or Roth IRA, amount actually distributed from your traditional IRA and
you may elect to have all or a portion of your account the amount required to be distributed. This penalty tax may
distributed in one or a combination of the following ways: be waived in certain cases provided you can establish to
(1) A partial payment. the satisfaction of the IRS that the deficit in the amount
distributed was due to reasonable error and you are taking
(2) A lump-sum payment. steps to remedy the problem.
(3) Monthly, quarterly, semiannual, or annual installment C. Distribution upon death for traditional IRAs and Roth IRAs
payments over a period not extending beyond your life If you die prior to the complete distribution of your
expectancy or the joint and last survivor life expectancy account, the remaining balance in your Vanguard IRA
of you and your designated beneficiary. (either traditional or Roth IRA) will be distributed to your
The method of distribution you select for your traditional designated beneficiary, upon request in a form and manner
IRA must comply with the minimum distribution acceptable to the Custodian, over a period selected by your
requirements described in Section VIII[B]. You may beneficiary subject to the requirements stated below. In
request a distribution from your Vanguard IRA in a form general, distributions your beneficiary receives from your
and manner acceptable to the Custodian. IRA that are included in gross income will be taxed as
ordinary income.
Distributions in cash or in kind. Distributions from the
Vanguard IRA will generally be made in cash, unless you General rule for Roth IRAs and where required
notify the Custodian in writing that you wish to have distributions had not begun from traditional IRAs. For
a designated portion of your IRA assets distributed in all Roth IRAs and for traditional IRAs where a required
kind. However, any assets in your Vanguard IRA that distribution of your account had not commenced prior to
cannot be sold by the Custodian for cash in the ordinary your death, the general rule is that the balance of your
course of business shall automatically be distributed to Vanguard IRA must be distributed to your designated
you in kind. beneficiary over his or her life expectancy starting by
December 31 of the calendar year following the year of
B. Traditional IRA: Age 70½ minimum distributions your death, or if your sole beneficiary is your surviving
Commencement of distribution at age 70½. You must spouse, by the later of December 31 of the calendar year
begin receiving distributions from your traditional IRA following the year of your death or December 31 of the
no later than April 1 of the calendar year following the calendar year in which you would have attained age 70½.
calendar year in which you attain age 70½. No age 70½ Instead of applying the general rule described above, your
distribution requirements apply for Roth IRAs. beneficiary may elect to apply the “five-year rule,” under
which your beneficiary must distribute the entire balance
Minimum amount required to be distributed. The
of your account by December 31 of the calendar year that
minimum amount required to be distributed from your
contains the fifth anniversary of your death. If you do not
traditional IRA for each calendar year, beginning with the
have a beneficiary, or your beneficiary is not an individual
year in which you attain age 70½, is determined by dividing
(your estate, or a charity, for example), distributions must
the entire amount in your account as of December 31 of
generally be made in accordance with the five-year rule.
the preceding calendar year by the applicable distribution
However, if your beneficiary is a trust and the trust meets
period. In most cases, the applicable distribution period
certain requirements, the beneficiaries of the trust may
is determined using the IRS’s Uniform Lifetime Table.
be treated as designated beneficiaries for the purpose
However, if your spouse is your sole beneficiary for the
of determining the applicable distribution period. See
entire year, the applicable distribution period is the longer
IRS Publication 590 or consult your tax advisor for more
of the distribution period determined using the Uniform
information on the special trust rules.
Lifetime Table, or the joint life expectancy of you and your
spouse determined using the Joint Life and Last Survivor Where age 70½ minimum distributions from traditional
Table. See the Vanguard Traditional and Roth IRA Custodial IRA had already begun. If required minimum distributions
Account Agreement and IRS Publication 590, Individual from your traditional IRA had already commenced prior
Retirement Arrangements (IRAs), for more details including to your death, the balance of your Vanguard traditional
the life expectancy tables used to calculate required IRA must be distributed to your designated beneficiary
minimum distribution amounts. You must receive the over his or her life expectancy, or if longer, over your
required minimum distribution amount from your traditional remaining life expectancy, starting by December 31 of
IRA for the calendar year in which you attain age 70½ by

11
the calendar year following the year of your death. If you Vanguard traditional IRA will generally equal 10% of
do not have a beneficiary, or your beneficiary is not an the amount of the distributions. Upon a request for
individual, distributions must be made over your remaining a distribution under the Vanguard traditional IRA, the
life expectancy. If your beneficiary is a trust and the Custodian will notify the recipient of his or her right to
trust meets certain requirements, the beneficiaries of elect not to have withholding apply (or to revoke any
the trust may be treated as designated beneficiaries for prior election). If the distribution is delivered outside the
the purpose of determining the applicable distribution United States, you may not elect out of federal income tax
period. See IRS Publication 590 or consult a tax advisor withholding. State income tax may be withheld from your
for more information about the special trust rules. For IRA distributions, if applicable.
these purposes, minimum distributions are considered to
If you are a nonresident alien, the amount of federal
have begun prior to your death only if distributions were
income tax required to be withheld is 30% of the amount
made on or after April 1 of the calendar year following the
of the distribution. You may not elect out of withholding.
calendar year in which you attained age 70½.
If you are eligible to claim a reduced withholding rate under
Exception where surviving spouse is sole beneficiary. a tax treaty, you must send a valid Form W-8BEN prior to
An exception to the preceding two rules is that if the sole the distribution.
beneficiary of your Vanguard IRA is your surviving spouse,
your spouse may elect to treat your Vanguard IRA as his Section IX
or her own IRA. Your surviving spouse may elect to treat
your Vanguard IRA as his or her own IRA either by making Simplified employee pension
contributions to the IRA (including a rollover contribution) A simplified employee pension, or “SEP,” is a special
or by not taking required minimum distributions from traditional IRA plan that permits employers to make
the IRA as the IRA beneficiary in accordance with the deductible contributions to the separate traditional IRAs
rules summarized in this Section VIII[C]. In the case of established for their employees. If your employer has adopted
a traditional IRA, if your surviving spouse makes the a SEP, your employer may make deductible SEP contributions
election to treat your Vanguard IRA as his or her own IRA, directly to your Vanguard traditional IRA each year in an
your spouse would be required to satisfy any minimum amount up to the lesser of $40,000 (as adjusted for cost-of-
distribution requirements as the traditional IRA owner in living increases) or 25% of your current-year compensation.
accordance with the rules summarized in Section VIII[B].
Exclusion from gross income. The amount of SEP
Designation of beneficiary. Under a Vanguard IRA, you contributions made by your employer to your traditional IRA
may designate one or more individuals or entities (such will be excludible from your gross income provided it does
as a trust) as your beneficiary. You may also select other not exceed the deduction limit described above. In addition,
beneficiary designations deemed acceptable by the you may make your own annual contributions to either your
Custodian. You will initially designate your beneficiary by traditional or Roth IRA each year up to the lesser of the
completing the Adoption Agreement for the Vanguard IRA. contribution limit in effect for the taxable year or 100% of
You may subsequently change or revoke your beneficiary current-year compensation.
designation at any time by notifying the Custodian in a
form and manner acceptable to the Custodian. If you fail Determination of compensation. For purposes of the 25%
to designate a beneficiary or if your designated beneficiary of compensation limit that applies to SEP contributions,
(or each of your designated beneficiaries) predeceases you, you may take into account only the amount of your current-
your beneficiary will be your surviving spouse or, if you year compensation from the employer making the SEP
have no surviving spouse, your estate. contribution. In addition, you may not include the amount
of the SEP contribution in the determination of your
D. Federal estate and gift taxation compensation. The maximum amount of compensation that
Gift tax consequences. Your designation of a beneficiary may be taken into account on behalf of any SEP participant is
(or beneficiaries) to receive distributions from your IRA subject to an indexed limit ($260,000 for 2014 and $265,000
upon your death will not be considered a transfer of for 2015).
property for federal gift tax purposes.
Self-employed individuals. Any sole proprietor or
Estate tax consequences. Generally, amounts remaining partnership may be eligible to establish a SEP and make
in your IRA after your death will be included in your gross deductible SEP contributions to the separate traditional
estate for federal estate tax purposes. You are encouraged IRAs established by the sole proprietor or partners (as
to consult with a financial planner or tax advisor when well as to the traditional IRAs of any common-law
considering the estate tax consequences of your IRA assets. employees). In the case of a self-employed individual,
the term “compensation” includes the individual’s earned
E. Income tax withholding income from self-employment, reduced by the amount
The Internal Revenue Code requires the withholding of deductible retirement plan contributions.
of federal income tax on distributions from a traditional
IRA unless the recipient affirmatively elects not to
have withholding apply. The amount of federal income
tax required to be withheld on any payment under the

12
Contributions after age 70½. SEP contributions may be Section XI
made to your IRA by your employer even after you have
attained age 70½. Prohibited transactions
Generally, a prohibited transaction is any improper use of your
Elective deferrals. Prior to January 1, 1997, certain employers IRA. Examples of prohibited transactions include borrowing
were permitted to establish a Salary Reduction SEP under money from your account or selling property to the account.
which employees could make elective deferrals—or “pre-tax”
salary reduction contributions—up to an indexed dollar limit Effect on IRA. Generally, if you engage in a prohibited
each year. However, employers can no longer establish Salary transaction, your IRA will lose its tax-exempt status, and you
Reduction SEPs after December 31, 1996 (although Salary will be required to include the entire value of the account in
Reduction SEPs in existence before January 1, 1997, can your gross income. If your account is disqualified before you
continue to receive contributions and cover new employees). reach age 59½, you may also be required to pay the 10%
additional tax on early distributions referred to in Section
VII[C].
Section X
Income tax returns Pledging your IRA as security. Pledging your IRA as security
for a loan will cause the portion pledged to be treated as a
If you are eligible to make deductible contributions to your distribution to you, includible in gross income and subject to
traditional IRA, you may claim your deduction for traditional the 10% additional tax on early distributions if you are under
IRA contributions on your federal income tax return (Form age 59½.
1040 or Form 1040A) even if you do not itemize deductions.
Each year, the Custodian will send you IRS Form 5498, Investment in collectibles. If your IRA is invested in
showing your preceding-year IRA contributions. If you collectibles, the amount invested will be considered a
make nondeductible contributions to your traditional IRA distribution to you in the year of investment. For this reason,
for a taxable year, or if you receive any distributions from the Vanguard IRA specifically precludes investments in
your IRA during a taxable year that includes nondeductible collectibles, which include art works, rugs, antiques, metals,
contributions, you will be required to provide certain gems, stamps, coins (but not certain gold, silver, and platinum
information concerning these transactions on Form 8606, coins issued by the United States or gold, silver, platinum,
to be included with your federal income tax return for the or palladium bullion), alcoholic beverages, and certain other
taxable year. If you make after-tax rollover contributions to tangible personal property.
your traditional IRA, you should report such contributions in
accordance with IRS guidelines. Section XII
Penalty taxes. If one or more of the following situations Other information
occur, you may be required to file Form 5329, Additional
A. The Custodian
Taxes on Qualified Plans (Including IRAs) and Other Tax-
Favored Accounts, with the IRS: The Custodian of your Vanguard IRA is Vanguard Fiduciary
Trust Company, a trust company incorporated under
(1) Payment of a 6% excise tax because of an excess Pennsylvania banking laws. Vanguard Fiduciary Trust
contribution. Company is a wholly owned subsidiary of The Vanguard
(2) Payment of a 10% additional tax because of an early Group, Inc., of Valley Forge, Pennsylvania. The Vanguard
distribution before age 59½. Group will perform certain administrative services in
connection with the Vanguard IRA, for which The Vanguard
(3) Payment of a 50% excise tax because of an insufficient
Group may be reimbursed at cost by Vanguard Fiduciary
distribution from your IRA after age 70½.
Trust Company.
Form 5329 need not be filed if the only activity in your IRA for
B. Amendments
the year consisted of proper (i.e., nonpenalized) contributions
and distributions. If Form 5329 must be filed, it should be The Custodian is specifically authorized to make any
attached to your federal income tax return or should be filed amendments to the Vanguard IRA necessary to comply
separately if you are not required to file a federal income tax with the applicable provisions of the Internal Revenue
return. Code and any other such amendments as the Custodian
deems appropriate. The Custodian will inform you of
Distributions. When you receive distributions from your any such amendments. Notice of amendments may be
Vanguard IRA, the Custodian will send you the required provided electronically, provided that you have consented
tax form (Form 1099-R). If you are a nonresident alien, the to electronic delivery thereof.
Custodian will send you Form 1042-S.
C. Vanguard IRA investments
Your Vanguard IRA may be invested in shares of the
mutual funds offered by The Vanguard Group, Inc. (the
“Vanguard funds”), or in other types of investments that
the Custodian and/or any Vanguard affiliate may permit
to be available investments under the Vanguard IRA from
time to time.

13
Directed investments. Your Vanguard IRA will be
invested and reinvested solely in accordance with your
directions (or, following your death, the directions of your
designated beneficiary). You may change your investment
directions at any time by notifying the Custodian in writing
or by telephone.
Reinvestment of earnings. All dividends and capital
gains received on shares of a Vanguard fund held in
your Vanguard IRA that are permitted to be reinvested
in additional shares of the Vanguard fund shall, in the
absence of investment directions by you to the contrary,
be automatically reinvested in additional shares of the
Vanguard fund. Otherwise, any distribution of earnings
received with respect to assets held in your account
shall be reinvested solely in accordance with investment
directions furnished by you.
Growth in value. The growth in value of your Vanguard
IRA will depend on the investment decisions made by you
and is neither guaranteed nor projected.
D. Vanguard IRA minimums
Minimum contributions. For both the Vanguard traditional
and Roth IRAs, the minimum initial contribution for each
Vanguard fund established for an IRA is the minimum
set forth in each fund’s prospectus. However, certain
Vanguard funds may require higher minimum contributions
as set forth in their prospectuses.
E. Custodial fees and other expenses
Vanguard may charge reasonable custodial fees with
respect to the establishment and maintenance of your
Vanguard IRA at any time during the calendar year. Each
Vanguard fund is subject to an account service fee that is
described in the fund’s prospectus.
F. Vanguard fund information
For complete information about the account service
fees, advisory fees, and other expenses as well as
the method of calculating the price per share for each
Vanguard fund you may select for your Vanguard IRA, you
should read the fund’s prospectus. You may choose to
use Vanguard Brokerage Services® to invest your Vanguard
IRA directly in stocks, bonds, or options. A schedule of
the brokerage commissions to be charged under Vanguard
Brokerage Services will be furnished to you when you
establish your account.
G. IRS approval
The form of your Vanguard IRA has been approved by the
IRS. IRS approval is a determination only as to the form
and does not represent a determination of the merits of
the Vanguard IRA. For more information, please refer to
IRS Publication 590 or contact the IRS.

14
Vanguard Traditional and Roth IRA Custodial
Account Agreement
Introduction 1.9 Custodian means Vanguard Fiduciary Trust Company, a
trust company incorporated under Pennsylvania banking
By executing the Adoption Agreement, the Investor hereby
laws, or any successor thereto.
establishes a traditional individual retirement account
(Traditional IRA) as described in Section 408(a) of the Code or 1.10 Investor means the individual who has adopted the
a Roth individual retirement account (Roth IRA) as described Agreement by executing the Adoption Agreement.
in 408A of the Code, in order to provide for retirement or for (This term does not include a Beneficiary who opens an
the support of his or her Beneficiary after death. account after the Investor’s death.)
Article I 1.11 Descendants means all descendants of all generations
Definitions of an individual.
The following terms when used herein with initial capital 1.12 Grandchildren means descendants in the second
letters shall be defined as follows: generation below the individual, including those born
within or out of wedlock, and those legally adopted by
1.1 Account means the custodial account established
Children of the Investor. This term excludes stepchildren
by the Investor to which contributions may be made
and foster children.
in accordance with the terms and conditions of this
Agreement. All assets of the Account shall be held by 1.13 Issue means all descendants of all generations of an
the Custodian for the exclusive benefit of the Investor or, individual.
following his or her death, the Beneficiary.
1.14 Per Stirpes means a way of dividing the Account as
1.2 Adopted Person means a person adopted through the follows: The Account shall be divided into as many
legal process of the United States and/or any state, equal shares as there are surviving descendants in the
commonwealth, or possession of the United States. generation nearest to the decedent that contains at least
An Adopted Person shall be considered to be the one surviving descendant and deceased descendants in
descendant or issue of the adopting person. the same generation who left surviving descendants, if
any. The share of each deceased descendant who leaves
1.3 Adoption Agreement means the agreement executed
surviving descendants is divided in the same manner,
by the Investor in which the Investor designated the
with the subdivision repeating until the property is fully
Account as a Traditional IRA or a Roth IRA for purposes
allocated among surviving descendants. A descendant
of adopting the Agreement. The Adoption Agreement
who dies before the decedent and who leaves no
shall be considered an integral part of the Agreement as
surviving descendants is disregarded.
if set forth fully herein.
1.15 Roth IRA means an individual retirement account as
1.4 Agreement means the Vanguard Traditional and Roth
described in section 408A of the Code.
IRA Custodial Account Agreement as set forth herein,
including the provisions set forth in the Adoption 1.16 SEP Contribution means a contribution on behalf
Agreement and any Beneficiary designation filed with of the Investor by his or her employer under a simplified
and acceptable to the Custodian, as each such document employee pension as described in Section 408(k) of
may be amended from time to time. the Code.
1.5 Authorized Party means the executor, administrator, 1.17 Successor Beneficiary means the persons or entities
or personal representative of the Investor’s estate, designated in accordance with Article 4.4 entitled to
the trustee of a trust Beneficiary, or any other person receive any undistributed amount credited to the Account
deemed appropriate by the Custodian to act on behalf of at the time of the Beneficiary’s death.
the Investor’s Account after the Investor’s death.
1.18 Traditional IRA means an individual retirement account
1.6 Beneficiary means the persons or entities designated in or annuity as described in section 408(a) of the Code.
accordance with Article 4.4 to receive any undistributed
1.19 Vanguard means The Vanguard Group, Inc., a
amount credited to the Account at the time of the
Pennsylvania corporation, or any successor thereto.
Investor’s death, as well as persons or entities entitled to
roll over a distribution from an eligible retirement plan of 1.20 Vanguard Funds means one or more of the regulated
a deceased employee into an inherited IRA, as permitted investment companies or mutual funds that are members
under Section 402(c)(11) of the Code. of The Vanguard Group, and that the Custodian permits to
be available investments under this Agreement.
1.7 Children means descendants in the first generation
below the individual, including those born within or out of
wedlock, and those legally adopted by the individual. This
term excludes stepchildren and foster children.
1.8 Code means the Internal Revenue Code of 1986, as
amended from time to time, or any successor statute.
15
Article II (or head of household) the maximum annual
Contributions to Account contribution is phased out between modified AGI
of $95,000 and $110,000; for a married Investor
2.1 General limitations. Contributions may be made by or
who files jointly (or qualifying widower), between
on behalf of the Investor to the Account for any taxable
modified AGI of $150,000 and $160,000; and for
year subject to the limitations set forth below.
a married Investor who files separately, between
(a) Regular contributions. Except in the case of a modified AGI of $0 and $10,000. If the Investor’s
rollover contribution to a Traditional IRA (as permitted modified AGI is in the phase-out range, the
under Code Sections 402(c), 402(e)(6), 403(a)(4), maximum regular Roth IRA contribution for the
403(b)(8), 403(b)(10), 408(d)(3), and 457(e)(16), an taxable year is rounded up to the next multiple
employer SEP contribution as described in Code of $10 and is not reduced below $200. The dollar
section 408(k), a qualified rollover contribution to a amounts will be adjusted by the Secretary of the
Roth IRA, or a recharacterized contribution described Treasury for cost-of-living increases under Code
in Code section 408A(d)(6), all contributions to the section 408A(C)(3). Such adjustments will be in
Account by or on behalf of the Investor shall be made multiples of $1,000.
in cash, and the total of such contributions to all of (ii) Contributions to both Roth and traditional IRAs.
the Investor’s IRAs shall not exceed the lesser of the If the Investor makes contributions to both Roth
Investor’s compensation (as defined in Article 2.6) or IRAs and Traditional IRAs for a taxable year, the
the applicable amount defined in (b) below. However, maximum regular contributions that can be made to
notwithstanding the dollar limits on contributions, all of the Investor’s Roth IRAs for that taxable year
an Investor may make a repayment of a qualified is reduced by the regular contributions made to the
reservist distribution described in Code section 72(t) Investor’s non-Roth IRAs for the taxable year.
(2)(G) during the two-year period beginning on the
d) Qualified rollover contributions to Roth IRA.
day after the end of the active duty period or by
A “qualified rollover contribution” is a rollover
August 17, 2008, if later.
contribution of a distribution from an IRA that meets
(b) Applicable amount. The applicable amount is the requirements of Code section 408(d)(3), except
determined under (i) or (ii) below. the one-rollover-per-year rule of Code section 408(d)(3)
(B) does not apply if the rollover contribution is from
(i) If the Investor is under age 50, the applicable an IRA other than a Roth IRA (a “non-Roth IRA”). For
amount is $5,000 for any taxable year beginning in taxable years beginning after 2005, a qualified rollover
2008 and years thereafter. After 2008, the $5,000 contribution includes a rollover from a designated
amount will be adjusted by the Secretary of the Roth account described in Code section 402A; and
Treasury for cost-of-living increases under Code for taxable years beginning after 2007, a qualified
section 219(b)(5)(D). Such adjustment will be in rollover contribution also includes a rollover from an
multiples of $500. eligible retirement plan described in Code section
(ii) If the Investor is age 50 or older, the applicable 402(c)(8)(B). A rollover from an eligible retirement
amount under paragraph (i) above is increased by plan other than a Roth IRA or a designated Roth
$1,000 for any taxable year beginning in 2006 and account cannot be made to a Roth IRA if, for the year
years thereafter. the amount is distributed from the other plan, (i) the
(iii) If the individual was a participant in a 401(k) plan Investor is married and files a separate return, (ii)
of a certain employer in bankruptcy described the Investor is not married and has modified AGI in
in Code section 219(c)(5)(C), then the applicable excess of $100,000, or (iii) the Investor is married and
amount under paragraph (i) above is increased together the Investor and the Investor’s spouse have
by $3,000 for taxable years beginning after 2006 modified AGI in excess of $100,000. For purposes
and before 2010 only. An individual who makes of the preceding sentence, a husband and wife are
contributions under this paragraph (iii) may not also not treated as married for a taxable year if they have
make contributions under paragraph (ii). lived apart at all times during the taxable year and file
separate returns for the taxable year. For taxable years
(c) Income limits for Roth IRA contributions. If (i) and/ beginning after 2009, the limits in this paragraph do
or (ii) below apply, the maximum regular contribution not apply to qualified rollover contributions.
that can be made to all of the Investor’s Roth IRAs
for a taxable year is the smaller of the amount 2.2 Recharacterization. A regular contribution to one type
determined under (i) or (ii). of IRA can be recharacterized pursuant to the rules
in Section 1.408A-5 of the Regulations as a regular
(i) Regular Roth contributions. The maximum contribution to another type of IRA. A regular contribution
regular contribution that can be made to all of to a non-Roth IRA that is recharacterized to a Roth IRA is
an Investor’s Roth IRAs for the taxable year is subject to the limits in Article 2.1(c) above.
gradually reduced to $0 between certain levels of
modified adjusted gross income (modified AGI), as
defined in Article 2.7 below. For a single Investor

16
2.3 Rollover contributions. The Custodian may accept “compensation” shall include any amount includible
rollover contributions within the meaning of Sections in the individual’s gross income under Code Section
402(c), 403(a)(4), 403(b)(8), 403(b)(10), 408(d)(3), 457(e) 71 with respect to a divorce or separation instrument
(16), or 408A(e) of the Code that consist of cash or of described in Subparagraph (A) of Code Section 71(b)(2).
such other assets that are acceptable to the Custodian In the case of a married individual filing a joint return,
and that are permissible investments under Section the greater compensation of his or her spouse is treated
408(a) of the Code. Before making a rollover contribution, as his or her own compensation, but only to the extent
the Investor shall provide any information the Custodian that such spouse’s compensation is not being used for
may require, in a form and manner acceptable to the purposes of the spouse making a contribution to a Roth
Custodian. The Custodian shall be under no obligation IRA or a deductible contribution to a traditional IRA.
to accept any rollover contribution consisting of assets Compensation includes nontaxable combat pay received
other than cash. The Investor shall have the sole by a member of the U.S. Armed Services.
responsibility for determining whether any contribution to
2.7 Modified adjusted gross income (modified AGI). For
the Account qualifies as a rollover contribution.
purposes of Articles 2.1(c) and (d) above, an Investor’s
2.4 SEP Contributions. SEP Contributions may be made modified AGI for a taxable year is defined in Code Section
to a traditional IRA on behalf of the Investor by his or 408A(c)(3)(C)(i) and does not include any amount included
her employer for any taxable year in an amount not to in gross income as a result of a rollover from an eligible
exceed the amount provided in Section 408(j) of the retirement plan other than a Roth IRA (a “conversion”).
Code or any successor statutory provision thereto for
2.8 Timing of contributions. For purposes of Article 2.1,
such taxable year. Before making any SEP Contribution,
any contribution to the Account by the Investor shall
the Investor shall execute such forms as the Custodian
be deemed to have been made on the last day of the
may require to certify that the Investor is covered under
preceding taxable year if the contribution is made on
a simplified employee pension (as described in Section
account of such taxable year and is made not later than
408(k) of the Code) established by his or her employer
the date prescribed by law for filing the Investor’s federal
and to provide other information as the Custodian may
income tax return for such taxable year (not including
reasonably request. The Investor shall have the sole
any extensions thereof). The Investor shall have the sole
responsibility for determining whether any contribution to
responsibility for determining whether any contribution
the Account qualifies as a SEP Contribution.
to the Account is deductible for federal income tax
2.5 SIMPLE contributions. No contributions will be purposes.
accepted under a SIMPLE IRA plan established by any
2.9 Responsibility of Custodian and Vanguard. Neither
employer pursuant to Code section 408(p). Also, no
the Custodian nor Vanguard shall have any responsibility
transfer or rollover of funds attributable to contributions
for determining whether any contribution by or on behalf
made by a particular employer under its SIMPLE IRA
of the Investor to the Account qualifies as a Rollover
plan will be accepted from a SIMPLE IRA; that is, an IRA
Contribution or SEP Contribution, or whether any
used in conjunction with a SIMPLE IRA plan, prior to the
contribution to the Account is deductible by the Investor
end of the two-year period beginning on the date the
for federal income tax purposes.
individual first participated in that employer’s SIMPLE
IRA plan. Article III
2.6 Compensation. For purposes of 2.1 above, Investment of Account
compensation is defined as wages, salaries, professional
3.1 Investment of contributions. The Custodian shall invest
fees, or other amounts derived from or received for
and reinvest all contributions to the Account in accordance
personal services actually rendered (including, but
with the investment directions of the Investor as set
not limited to commissions paid to salespersons,
forth in the Adoption Agreement or in any subsequent
compensation for services on the basis of a percentage
investment directions furnished by the Investor pursuant
of profits, and commissions on insurance premiums, tips,
to Article 3.2. If the Custodian receives any contribution
and bonuses) and includes earned income, as defined
to the Account with respect to which the Investor has not
in Section 401(c)(2) (reduced by the deduction the self-
furnished investment instructions or if the Investor has
employed individual takes for contributions made to a
furnished investment instructions which, in the opinion
self-employed retirement plan). For purposes of this
of the Custodian, are unclear, incomplete, or otherwise
definition, Section 401(c)(2) shall be applied as if the
not in good order, the Custodian may request additional
term trade or business for purposes of Section 1402
investment instructions from the Investor. Pending receipt
of the Code included service described in Subsection
of such investment instructions, the Custodian may (i)
(c)(6). Compensation does not include amounts derived
hold all or a portion of the contribution amount uninvested,
from or received as earnings or profits from property
(ii) invest all or a portion of the contribution amount in a
(including but not limited to interest and dividends) or
Vanguard Money Market Fund, or (iii) return all or a portion
amounts not includible in gross income. Compensation
of the investment amount to the Investor without liability
also does not include any amount received as a pension
for loss of income or appreciation pending receipt of
or annuity or as deferred compensation. The term
proper investment directions.

17
3.2 Investment directions; available investments. The proportionately the same manner as shares timely
Investor or, following his or her death, the Beneficiary, voted by such fund’s other shareholders. By directing
shall be permitted at all times to direct, or retain an that assets of the Account be invested in a Vanguard
agent, investment advisor, or manager to direct the Fund, the Investor or Beneficiary shall be deemed to
Custodian as to the investment or reinvestment of the have acknowledged receipt of the current prospectus
assets of the Account. All such investment directions for such Vanguard Fund.
shall be made in a form or manner acceptable to the
Custodian. Assets of the Account may be invested Article IV
in shares of one or more of the Vanguard Funds or Distribution of Account
in other investments that are eligible for acquisition 4.1 General requirements.
under Section 408(a) or 408A of the Code and that
the Custodian and/or any Vanguard affiliate permits to (a) Notwithstanding any provision of this Agreement
be available investments under this Agreement. U.S.- to the contrary, the distribution of the Investor’s
domiciled Vanguard funds generally are not available for interest in the Account shall be made in accordance
sale to Investors that reside outside of the United States. with the requirements of Code Sections 408(a)(6) (as
All investments of the Account shall be registered in modified by Section 408A(c)(5) for Roth IRAs), and
the name of the Custodian or its nominee, or shall be the regulations thereunder, the provisions of which
retained unregistered or in a form permitting transfer are incorporated herein by reference. The Custodian
by delivery, provided that the books and records of the shall distribute the balance of the Account to the
Custodian shall at all times show such investments to be Investor or, after his or her death, the Beneficiary,
part of the Account. at such times and in such manner as the Investor or
Beneficiary shall direct, subject to the requirements
3.3 Prohibitions concerning life insurance, collectibles, set forth below.
and commingling. Notwithstanding any provision of this
Agreement to the contrary, no assets of the Account will (b) Method of distribution. The Investor, or after his
be invested in life insurance contracts or in collectibles or her death, the Beneficiary, may elect to have all
(within the meaning of Section 408(m) of the Code), nor or any portion of the Account distributed in one or a
will assets of the Account be commingled with other combination of the following ways:
property except in a common trust fund or common (1) A partial payment.
investment fund (within the meaning of Section 408(a)(5)
(2) A lump-sum payment.
of the Code).
(3) Monthly, quarterly, semiannual or annual
3.4 Responsibility of Custodian and Vanguard installment payments provided that the method
(a) Investments in general. In making any investment of distribution satisfies the minimum distribution
or reinvestment of the assets of the Account, requirements of Article 4.2.
the Custodian shall be fully entitled to rely on the
investment directions furnished to it by the Investor The Investor’s or Beneficiary’s request must be made
or Beneficiary in accordance with the terms and in a form and manner acceptable to the Custodian.
conditions of this Agreement, and shall be under The Investor or Beneficiary may change his or her
no duty to make any inquiry or investigation with designated method of distribution upon proper
respect thereto. The Investor hereby acknowledges notification to the Custodian.
that neither the Custodian nor Vanguard undertakes to (c) Distribution in kind. All distributions from the
render any investment advice in connection with this Account shall be made in cash, with the exception
Agreement, and that the assets of the Account are that the Investor or Beneficiary may elect to have
to be invested, reinvested, and controlled exclusively all or any portion of the distribution made in kind, in
by the Investor or, following his or her death, the which case the Custodian shall transfer such specific
Beneficiary in accordance with the terms and assets as the Investor or Beneficiary may direct into
conditions of this Agreement. the name of the Investor or Beneficiary, and with the
(b) Vanguard Fund shares. The Custodian shall be further exception that any assets held in the Account,
responsible for delivering to the Investor or, following which cannot be sold by the Custodian for cash in the
his or her death, the Beneficiary, all shareholder ordinary course of business for purposes of making
notices, reports, and proxies relating to Vanguard distributions from the Account, shall be distributed to
Fund shares held in the Account. The Custodian shall the Investor or Beneficiary in kind.
vote any such shares at shareholder meetings of 4.2 Lifetime minimum distribution requirements
the Vanguard Funds in accordance with instructions
received from the Investor or Beneficiary. By (a) Traditional IRA
establishing (or by having established) the Account, (i) Required beginning date. The entire value of
the Investor hereby directs the Custodian to vote the account of the Investor for whose benefit
any Vanguard Fund shares held in the Account for the Account is maintained must commence to
which no timely voting instructions are received in be distributed no later than the first day of April

18
following the calendar year in which the Investor such life expectancy determined using the age of
attains age 70½ (the Investor’s “required beginning the Beneficiary as of his or her birthday in the year
date”) over the life of the Investor or the lives of following the year of the Investor’s death, or, if
the Investor and his or her designated Beneficiary. elected, in accordance with paragraph (a)(iii) below.
(ii) Annual minimum amount. The amount to be (ii) If the Investor’s sole designated Beneficiary is the
distributed each year, beginning with the calendar Investor’s surviving spouse, the entire interest
year in which the Investor attains age 70½ and must be distributed, starting by December 31 of
continuing through the year of death, may not the calendar year following the calendar year of
be less than the amount determined by dividing the Investor’s death (or by the end of the calendar
the value of the IRA (as determined under Article year the Investor would have attained age 70½,
4.3(c) as of the end of the preceding year by the if later), over such spouse’s life, or, if elected,
distribution period in the Uniform Lifetime Table in in accordance with paragraph (a)(iii) below. If
Q&A-2 of Section 1.401(a)(9)-9 of the Income Tax the surviving spouse dies before distributions
Regulations, using the Investor’s age as of his or are required to begin, the remaining interest
her birthday in the year. However, if the Investor’s must be distributed, starting by December 31
sole designated Beneficiary is his or her surviving of the calendar year following the calendar
spouse and such spouse is more than ten years year of the spouse’s death, over the spouse’s
younger than the Investor, then the distribution designated Beneficiary’s remaining life expectancy
period is determined under the Joint and Last determined using such Beneficiary’s age as of
Survivor Table in Q&A-3 of Section 1.401(a)(9)-9 of his or her birthday in the year following the death
the Income Tax Regulations, using the ages as of of the spouse, or, if elected, in accordance with
the Investor’s and spouse’s birthdays in the year. paragraph (a)(iii) below. If the surviving spouse
(iii) Timing of minimum distributions. The required dies after distributions are required to begin, any
minimum distribution for the year the Investor remaining interest will be distributed over the
attains age 70½ can be made as late as April spouse’s remaining life expectancy determined
1 of the following year. The required minimum using the spouse’s age as of his or her birthday in
distribution for any other year must be distributed the year of the spouse’s death.
no later than December 31 of that calendar year. (iii) If there is no designated Beneficiary, or if
(iv) Aggregation of IRAs. The Investor may satisfy applicable by operation of paragraph (a)(i) or (a)(ii)
the distribution requirements under Section 408(a) above, the remaining interest must be distributed
(6) of the Code by receiving a distribution from one by the end of the calendar year containing the
IRA that is equal to the amount required to satisfy fifth anniversary of the Investor’s death (or of
the minimum distribution requirements for two or the spouse’s death in the case of the surviving
more IRAs in accordance with Q&A-9 of Section spouse’s death before distributions are required to
1.408-8 of the Income Tax Regulations. begin under paragraph (a)(ii) above).
(iv) The amount that must be distributed under
(b) Roth IRA. No amount is required to be distributed
paragraphs (a)(i) or (ii) above is the amount
from a Roth IRA prior to the death of the Investor for
determined by dividing the value of the IRA as of
whom the account was originally established.
the end of the preceding year by the remaining
4.3 Distributions upon death: Traditional and Roth IRAs. life expectancy specified in such paragraph.
In the event the Investor dies prior to the complete Life expectancy is determined using the Single
distribution of the Account, the remaining balance of the Life Table in Q&A-1 of Section 1.401(a)(9)-9 of
Account will be distributed to the Beneficiary at such the Income Tax Regulations. If distributions are
time and in such manner as the Beneficiary shall direct, being made to a surviving spouse as the sole
in a form and manner acceptable to the Custodian, designated Beneficiary, such spouse’s remaining
subject to the following rules: life expectancy for a year is the number in the
Single Life Table corresponding to such spouse’s
(a) Traditional IRAs where investor dies before age in the year. In all other cases, remaining life
required beginning date and all Roth IRAs. For expectancy for a year is the number in the Single
traditional IRAs where the Investor dies before his Life Table corresponding to the Beneficiary’s age
or her required beginning date and for all Roth IRAs, in the year specified in paragraph (a)(i) or (ii) and
the Investor’s interest must be distributed at least as reduced by one for each subsequent year.
rapidly as follows:
(b) Traditional IRAs where investor dies on or after
(i) If the designated Beneficiary is someone other required beginning date. If the Investor dies on
than the Investor’s surviving spouse, the entire or after the required beginning date, the remaining
interest must be distributed, starting by December portion of his or her interest in the Traditional IRA
31 of the calendar year following the calendar year must be distributed at least as rapidly as follows:
of the Investor’s death, over the remaining life
expectancy of the designated Beneficiary, with

19
(i) If the designated Beneficiary is someone the Investor’s death who remain Beneficiaries as
other than the Investor’s surviving spouse, the of September 30 of the calendar year following the
remaining interest must be distributed over the Investor’s death.
remaining life expectancy of the designated
(e) Spousal election. If the sole designated Beneficiary
Beneficiary, with such life expectancy determined
is the Investor’s surviving spouse, the spouse may
using the Beneficiary’s age as of his or her
elect to treat the IRA as his or her own. This election
birthday in the year following the year of the
will be deemed to have been made if such surviving
Investor’s death, or over the period described in
spouse makes a contribution to the IRA or fails to
paragraph (b)(iii) below if longer.
take required distributions as a Beneficiary.
(ii) If the Investor’s sole designated Beneficiary is the
Investor’s surviving spouse, the remaining interest 4.3A Required minimum distribution service.
must be distributed over such spouse’s life or over Vanguard may, but shall not be required to, offer a
the period described in paragraph (b)(iii) below if service for Investors and/or Beneficiaries providing
longer. Any interest remaining after such spouse’s calculation or calculation and distribution of required
death must be distributed over such spouse’s minimum distributions (“RMD Service”). Any such
remaining life expectancy determined using the service shall be provided under the terms and
spouse’s age as of his or her birthday in the year conditions set forth in a Service Agreement, as such
of the spouse’s death, or, if the distributions are may be amended from time to time. By enrolling in
being made over the period described in paragraph the RMD Service, the Investor and/or Beneficiary
(b)(iii) below, over such period. shall be deemed to have consented to such terms
(iii) If there is no designated Beneficiary or if and conditions of such Service Agreement, including
applicable by operation of paragraph (b)(i) or (b)(ii) any amendments thereto effective after the date of
above, the remaining interest must be distributed enrollment in the RMD Service.
over the Investor’s remaining life expectancy
determined in the year of the Investor’s death. 4.4 Designation of Beneficiary

(iv) The amount to be distributed each year under (a) General rules. The Investor may designate from time
paragraph (b)(i), (ii), or (iii), beginning with the to time any person or persons, entities, such as a
calendar year following the calendar year of trust, or other recipient acceptable to the Custodian
the Investor’s death, is the amount determined as his or her primary and/or contingent Beneficiaries.
by dividing the value of the IRA as of the end To be entitled to receive any undistributed amounts
of the preceding year by the remaining life credited to the Account at the Investor’s death, any
expectancy specified in such paragraph. Life person or persons designated as a Beneficiary must
expectancy is determined using the Single Life be alive and any entity designated as a Beneficiary
Table in Q&A-1 of Section 1.401(a)(9)-9 of the must be in existence at the time of the Investor’s
Income Tax Regulations. If distributions are death. The surviving primary Beneficiaries shall be
being made to a surviving spouse as the sole first entitled to receive any undistributed amounts
designated Beneficiary, such spouse’s remaining credited to the Account at the Investor’s death. If
life expectancy for a year is the number in the the Investor has designated more than one primary
Single Life Table corresponding to such spouse’s Beneficiary, the Beneficiaries shall be entitled to
age in the year. In all other cases, remaining life receive any undistributed amount credited to the
expectancy for a year is the number in the Single Account at the time of the Investor’s death in the
Life Table corresponding to the Beneficiary’s or proportions indicated by the Investor. In the event
Investor’s age in the year specified in paragraph that the Investor has not indicated the proportions to
(b)(i), (ii), or (iii) and reduced by one for each which multiple Beneficiaries may be entitled or has
subsequent year. indicated percentages that do not exactly equal 100%,
(c) Value of IRA. The “value” of the IRA includes the payment will be made to the surviving Beneficiaries
amount of any outstanding rollover, transfer, and in equal shares. Except as described in the next
recharacterization under Q&A-7 and Q&A-8 of Section sentence, if any primary Beneficiary has not survived
1.408-8 of the Income Tax Regulations. the Investor, that Beneficiary’s share of the Investor’s
Account will be divided proportionately among the
(d) Designated Beneficiary for minimum distribution surviving primary Beneficiaries. Notwithstanding
purposes The “designated Beneficiary” for purposes anything to the contrary in this paragraph 4.4(a), if the
of determining the distribution period for required Investor has indicated that any Beneficiary designation
minimum distributions after the Investor’s death is made on a Per Stirpes basis and the deceased
is determined in accordance with Section 1.401(a) primary Beneficiary has surviving Issue, the share
(9)-4 of the Income Tax Regulations. In general, of the deceased primary Beneficiary shall be divided
the Investor’s designated Beneficiary for required into equal shares for each such surviving Issue. In the
minimum distribution purposes is determined based event that there are no surviving primary Beneficiaries
on the Beneficiaries designated as of the date of at the time of the Investor’s death, the contingent

20
Beneficiaries, in the order indicated by the Investor behalf of the minor. Any person or entity representing
(secondary, tertiary, etc.), shall be entitled to receive his authority to act on behalf of a minor shall submit
any undistributed amount credited to the Account at such information and documentation to authenticate
the time of the Investor’s death and shall succeed to such authority as the Custodian shall reasonably
the rights of a primary Beneficiary in accordance with request. The minor Beneficiary’s representative
this Agreement. If multiple contingent Beneficiaries may be the guardian, conservator, or other legal
at the same level become entitled to any amounts representative of such minor Beneficiary, the natural
credited to the Account, distribution shall be made in parent of such Beneficiary (provided that if the minor’s
the same manner as if the Beneficiaries were multiple parents are divorced, the Custodian may deem only
primary Beneficiaries. If no Beneficiary designation the parent having legal custody of the minor to be
is in effect, or if there are no surviving Beneficiaries, authorized to act on behalf of the minor), a custodian
at the time of the Investor’s death, the Beneficiary appointed for such Beneficiary under a Uniform Gift
shall be the Investor’s surviving spouse, if any. If to Minors Act, Uniform Transfers to Minors Act, or
the Investor has no surviving spouse, the Investor’s similar act, a person appointed by the Investor to act
Beneficiary shall be the Investor’s estate. as an authorized person for such minor Beneficiary
with respect to the Account in a writing filed with the
Any Beneficiary designation by the Investor shall
Custodian or in the Investor’s last will and testament
be made in a form and manner prescribed by or
as admitted to probate or trust document as to which
acceptable to the Custodian and shall be effective
the Investor is grantor, or any person having control or
only when received by the Custodian during the
custody of such minor Beneficiary.
Investor’s lifetime. The Investor may change or
revoke his or her Beneficiary designation at any time Any minor Beneficiary shall be deemed to be a minor
prior to his or her death by making a new Beneficiary until the later of such Beneficiary reaching (1) the age
designation with the Custodian. Any such change will of majority under the law of the state of the minor’s
revoke all prior Beneficiary designations submitted domicile with respect to the right to own mutual
to the Custodian in their entirety. Investor agrees funds and other investments or (2) a later age for
that in the event of a dispute as to the Beneficiary termination of minor status, but in no event later than
of the Account, the Custodian, in its discretion, age 25, as designated by the Investor in a Beneficiary
may rely upon an order of a court of competent designation accepted by the Custodian with respect
jurisdiction determining the beneficiary provided to the Account.
that, all interested parties (1) had notice of and an
(c) Marital trusts. The Investor or, as permitted by law,
opportunity to participate in the court proceeding,
the spousal Beneficiary following the death of the
or (2) executed an agreement resolving the dispute.
Investor, may designate as Beneficiary a trust for the
The Custodian reserves the right to ask a court of
benefit of the surviving spouse intended to satisfy
competent jurisdiction to resolve any beneficiary
the conditions of Sections 2056(b) (pertaining to
dispute and to recover its costs of doing so, including
qualified terminable interest property trusts or “QTIP”
reasonable attorneys’ fees, from the Account.
trusts) or 2056A (pertaining to qualified domestic
Unless the Investor has indicated otherwise on the
trusts or “QDOT” trusts) of the Code (collectively,
Beneficiary designation, any designation of a Spouse
referred to as “marital trusts”). To the extent such
by name or by relationship shall be deemed revoked
QTIP or QDOT trust is a Beneficiary of the Account,
by the divorce of the Investor and such Beneficiary;
the following provisions shall apply until the earlier of
provided that no such revocation shall be deemed
the death of the surviving spouse or the termination
final until documentary evidence of such divorce, in
of the Account: (1) all of the income of the Account
form and substance acceptable to Custodian, shall
shall be payable to the marital trust or directly to the
have been provided to Custodian, following the
surviving spouse, at the direction of the trustee of
investor’s death, and Custodian shall not be liable
the marital trust, at least annually or at such more
for any payment or transfer made to a Beneficiary in
frequent intervals as may be directed by the trustee
the absence of such documentation. For purposes of
of the marital trust, and (2) no person, other than
this Agreement, divorce shall mean a final decree of
the surviving spouse, shall have the right to assign
divorce, annulment, or dissolution of the marriage in
any part of the Account to any person other than the
effect in any jurisdiction.
marital trust or the surviving spouse.
(b) Minors. If upon the death of the Investor, a Beneficiary
(d) Rights of primary Beneficiaries upon investor’s
known to the Custodian to be a minor is entitled to
death. In addition to rights otherwise conferred upon
receive any undistributed assets of the Account, the
Beneficiaries under this Agreement, all individual
Custodian may, in its absolute discretion, transfer
Beneficiaries shall be entitled to designate Successor
assets to an inherited Account for the benefit of
Beneficiaries of their inherited Account. Any
the minor Beneficiary. So long as the Beneficiary is
Successor Beneficiary designation by the Beneficiary
a minor, such inherited Account shall be controlled
shall be made in accordance with the provisions of
by such person or persons demonstrated to the
paragraph (a) above. If a Beneficiary dies after the
Custodian’s satisfaction to be authorized to act on

21
Investor but prior to receipt of the entire interest in obligation, including tax obligations, of the Investor
the Account and has Successor Beneficiaries, the or any Beneficiary. The mere acceptance of any
Successor Beneficiaries shall succeed to the rights of Beneficiary designation submitted by an Investor
the Beneficiary. If a Beneficiary dies after the Investor shall not limit the Custodian’s rights or increase its
but prior to receipt of the entire interest in the responsibilities under this Agreement and under
Account and no Successor Beneficiary designation is law. The Custodian is fully entitled to rely on
in effect at the time of the Beneficiary’s death, the any instructions or representations made by the
beneficiary shall be the Beneficiary’s estate. Upon Beneficiary or the Authorized Party with respect to
instruction to the Custodian, each multiple Beneficiary any of the responsibilities identified in this Article
may receive his, her, or its interest as a separate 4.5(c). The Investor agrees that the Custodian and
account, within the meaning of Regulation Section Vanguard shall have no liability for, and shall be fully
1.401(a)(9)-8, Q&A-3, to the extent permissible by indemnified against, any cost or damage they incur
law. The trustee of a trust Beneficiary shall exercise in connection with their good-faith reliance upon
the rights of such trust Beneficiary. such representations.
4.5 Responsibility of Custodian and Vanguard (d) Additional information. The Custodian reserves
the right to request such additional information and
(a) Identification of Beneficiaries. The Custodian shall
documentation from the Investor, the Beneficiary, or
not be responsible for determining the identity or
the Authorized Party as the Custodian deems may
interest of any Beneficiary designated by relationship
be needed in respect of establishment, maintenance,
to the Investor. The Custodian is fully entitled to rely
and distribution of the Account.
on any representations made by the Authorized Party
or, if applicable, the Beneficiaries, with respect to the Article V
identity of the Beneficiaries of the Account, and shall
Transfers
be under no duty to make any inquiry or investigation
thereto. The Custodian and Vanguard have no 5.1 Transfers to Account. Assets held on behalf of the
responsibility to locate or notify any Beneficiary or Investor in another individual retirement account may be
the personal representative of the Investor or any transferred by the trustee or custodian thereof directly
Beneficiary of the existence of the Account. It is to the Custodian, in a form or manner acceptable to
the responsibility of the Beneficiary or personal the Custodian, to be held in the Account on behalf
representative of the Investor or of the Beneficiary to of the Investor under this Agreement. Transfers are
notify the Custodian of the death of the Investor or generally only permitted between the same type of
Beneficiary, and to provide the Custodian with such IRA plans (e.g., traditional IRA to traditional IRA) or, if
documentation as the Custodian deems necessary made after the Investor’s death, to another inherited
to transfer ownership of the Account. The Investor IRA of the same type from or in the name of the same
agrees that the Custodian and Vanguard shall have no decedent. In accepting any such direct transfer of
liability for, and shall be fully indemnified against, any assets, the Custodian assumes no responsibility for the
cost or damage they incur in connection with their tax consequences of the transfer, the responsibility for
good-faith reliance upon such representations. which rests solely with the Investor or the Beneficiary,
as the case may be.
(b) Distributions. In making any distribution from the
Account, the Custodian shall be fully entitled to rely 5.2 Transfers from Account. If so directed by the Investor,
upon the directions of the Investor or, following his or in the event of a transfer made after the Investor’s
or her death, the Beneficiary, and shall be under death by the Beneficiary, in a form or manner acceptable
no duty to make any inquiry or investigation with to the Custodian, the Custodian shall transfer assets
respect thereto. The Custodian shall not have any held in the Account directly to the trustee or custodian
responsibility to make any distribution, including of another individual retirement account established on
a required minimum distribution, until it receives behalf of the Investor or the Beneficiary, as the case
such directions in form and manner acceptable to may be. Transfers are generally only permitted between
Custodian. Neither the Custodian nor Vanguard shall the same types of IRA plans (e.g., traditional IRA to
have any responsibility for the timing, propriety, or tax traditional IRA) or, if made after the Investor’s death,
consequences of any distribution from the Account, to another inherited IRA of the same type from or in
which matters shall be the exclusive responsibility of the name of the same decedent. In making any such
the Investor or Beneficiary, as the case may be. direct transfer of assets, the Custodian assumes no
responsibility for the tax consequences of the transfer,
(c) Further obligations. The Custodian shall not the responsibility for which rests solely with the Investor
be responsible for (1) the interpretation of any or the Beneficiary, as the case may be.
formula clause or trust provision contained in any
Beneficiary designation filed with the Custodian, 5.3 Transfers incident to divorce. All or any portion of the
(2) the determination of the legal effect of any Investor’s interest in the Account may be transferred to
disclaimer or renunciation made by any Beneficiary a former spouse pursuant to a divorce decree or written
to the Account, or (3) the enforcement of any legal instrument incident to divorce as provided in Section

22
408(d)(6) of the Code, in which event the transferred delivery of the Agreement and any and all amendments
portion of the Account shall be held as a separate thereto. The Investor (or following the Investor’s death,
individual retirement account for the benefit of such the Beneficiary) shall be deemed to consent to any
spouse in accordance with the terms and conditions of such amendment if he or she fails to object thereto by
this Agreement. notifying the Custodian, in a form and manner acceptable
to the Custodian, within 30 calendar days from the date
Article VI the notice is delivered, to terminate the Agreement.
Reporting, disclosure, and fees The terms of the Agreement in effect at the death of
6.1 Information by Investor. The Investor shall furnish the the Investor or the Beneficiary, as the case may be, will
Custodian with all information as may be necessary for control the disposition of the assets.
the Custodian to prepare any reports required pursuant to 7.2 Resignation or removal of Custodian. The Custodian
Section 408(i) of the Code and the regulations thereunder. may resign at any time upon 30 days’ written notice
6.2 Annual reports by Custodian. The Custodian shall render to the Investor (or, following the Investor’s death, the
an annual report to the Investor, on or before January Beneficiary), which notice may be waived by the Investor
31 of each calendar year, containing all information with (or, following the Investor’s death, the Beneficiary),
respect to the preceding calendar year as is required to be and may be removed by the Investor (or, following the
furnished pursuant to Section 408(i) of the Code and the Investor’s death, the Beneficiary) at any time upon 30
regulations thereunder and such information concerning days’ written notice to the Custodian (which notice may
required minimum distributions as is prescribed by the be waived by the Custodian). Upon such resignation or
Commissioner of Internal Revenue. In addition, the removal, the Investor shall appoint a successor custodian
Custodian shall submit all other reports to the IRS and the under this Agreement. The successor custodian shall be
Investor (or, following his or her death, the Beneficiary) as a bank or other person qualified to serve as trustee of
may be prescribed by the IRS. an individual retirement account under Section 408(a)(2)
of the Code. Upon receipt by the Custodian of written
6.3 Fees and expenses. acceptance of such appointment by the successor
(a) Custodian fees. The Custodian shall be entitled custodian, the Custodian shall transfer to the successor
to such reasonable fees with respect to the custodian the assets of the Account and all necessary
establishment and maintenance of the Account records pertaining thereto, after reserving such
as are established by it from time to time, and to reasonable amount as it deems necessary for payment
reimbursement for all reasonable expenses incurred of its fees and expenses. If within 30 days after the
by it in the management of the Account. The Custodian’s resignation or removal, or such longer time
Custodian may change its fees payable under this as the Custodian may agree to, the Investor (or, following
Agreement at any time upon notice to the Investor. the Investor’s death, the Beneficiary) has not appointed
The Custodian shall be entitled to reimbursement for a successor custodian, the Custodian may terminate this
costs, including attorney’s fees and other expenses, Agreement in accordance with Article 7.3.
related to the Account. 7.3 Termination. The Investor may at any time terminate
(b) Investment management and advisory fees. this Agreement by delivering to the Custodian a written
Notwithstanding anything contained herein to the notice of termination. The Custodian may terminate
contrary, the Investor may authorize the direct this Agreement in the event the Investor (or, following
payment of investment management and/or advisory the Investor’s death, the Beneficiary) fails to appoint
fees from the Account to the Custodian or other third a successor custodian under circumstances described
party provided that the Account is solely liable for the in Article 7.2. Upon termination of the Agreement, the
payment of such fees. assets in the Account shall be distributed to the Investor
in a lump-sum payment of cash or in kind.
Article VII
7.4 Assignment of Agreement. The Custodian reserves the
Amendment, termination, and assignment right to assign and/or delegate any and all of its rights
7.1 Amendment. The Custodian is authorized to amend and obligations under this Agreement to an affiliate of
the Agreement in any respect and at any time (including the Custodian without the prior approval of the Investor
retroactively) to comply with the applicable provisions of or Beneficiary.
the Code and the regulations thereunder. The Custodian
is also authorized to amend this Agreement to reflect Article VIII
any other changes to the terms of this Agreement that Miscellaneous
the Custodian deems appropriate. Any such amendment 8.1 Exclusive benefit and nonforfeitability. The Account is
to the Agreement shall be deemed effective upon the established for the exclusive benefit of the Investor or,
delivery of notice of the amendment to the Investor following his or her death, the Beneficiary. The interest
(or following the Investor’s death, the Beneficiary). of the Investor (or following the Investor’s death, the
Notice may be provided electronically, provided that the Beneficiary) in the balance of the Account shall at all
Investor or the Beneficiary has consented to electronic times be nonforfeitable.

23
8.2 Prohibition against assignment of Account. Except
as may otherwise be provided in Article 5.3 or 8.3, no
interest, right, or claim in or to any part of the Account or
any payment therefrom shall be assignable, transferable,
or subject to sale, mortgage, pledge, hypothecation,
commutation, anticipation, garnishment, attachment,
execution, or levy of any kind, and the Custodian shall
not recognize any attempt to effect any of the preceding,
except to the extent required by law.
8.3 Escrow Account. The Account may serve as an escrow
arrangement to hold restricted distributions from defined
benefit plans in accordance with an escrow agreement
received by, and acceptable to, the Custodian in its
sole discretion. Distributions from such Account will
be restricted in accordance with the terms of the
escrow agreement.
8.4 Prohibited transactions. The Investor (or following the
Investor’s death, the Beneficiary) shall not engage in any
transaction with respect to the Account that is prohibited
under Section 4975 of the Code and which, under
Section 408(e)(2) of the Code, would cause the Account
to no longer qualify as an individual retirement account.
8.5 Governing law. This Agreement shall be governed,
administered, and enforced according to the laws of the
Commonwealth of Pennsylvania, except to the extent
preempted by federal law.
8.6 Agreement controls. In the event of any discrepancy
between this Agreement and any other document or
instrument filed with Vanguard in respect of the Account,
the terms of this Agreement shall control. Except with
respect to section 4.5(c), the terms of any Beneficiary
designation accepted by the Custodian shall control
over the terms of this printed Agreement to the extent of
any inconsistency.
8.7 Simultaneous death and slayer statutes. In the event
that the order of the deaths of the Investor and any
primary Beneficiary or on inherited Accounts, of the
Beneficiary and any primary Successor Beneficiary,
cannot be determined or are deemed to have occurred
simultaneously under the law of the state of Investor’s or
Beneficiary’s domicile, as the case may be, the survivor
shall be that person who is determined to survive in
accordance with the law of that state at the time of
the Investor’s or Beneficiary’s death, as the case may
be. In the event that the death of the Investor or any
Beneficiary is the result of criminal act involving any other
Beneficiary, Vanguard may look to the law of the state
of domicile, including any slayer or similar statute, to
determine the rights of the Beneficiaries to the assets in
the Account.

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