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Vanguard Managed Account Program Service …

Vanguard Managed Account Program Service agreement Service agreement I. Overview The Vanguard Managed Account Program (the Program ) is an advisory Service offered by Vanguard Advisers, Inc. (VAI), to participants in employer-sponsored retirement plans (referred to in this document as Members ) for which The Vanguard Group, Inc. ( Vanguard ) provides recordkeeping services . The Program is powered by software developed by Financial Engines Advisors (Financial Engines), an independent investment advisor unaffiliated with VAI or Vanguard . Members who enroll in the Program authorize the Program to: (1) select investments for their employer- sponsored retirement plan Account ( Account ) from the universe of investment alternatives authorized by their plan sponsor for inclusion in the company's retirement plan; and (2) manage the Account on an ongoing basis. References in this document to we and us mean the Program , and references to you and your . mean Members enrolled in the Program .

1 [VG_MA_ServiceAgmt_Privacy_CPY16075_04_2016] Vanguard® Managed Account Program Service Agreement Service agreement I. Overview The Vanguard Managed Account Program (the Program) is an advisory service offered by Vanguard

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