0000950129-95-001164.txt : 19950914 0000950129-95-001164.hdr.sgml : 19950914 ACCESSION NUMBER: 0000950129-95-001164 CONFORMED SUBMISSION TYPE: S-8 PUBLIC DOCUMENT COUNT: 12 FILED AS OF DATE: 19950911 EFFECTIVENESS DATE: 19950930 SROS: NYSE FILER: COMPANY DATA: COMPANY CONFORMED NAME: STEWART INFORMATION SERVICES CORP CENTRAL INDEX KEY: 0000094344 STANDARD INDUSTRIAL CLASSIFICATION: TITLE INSURANCE [6361] IRS NUMBER: 741677330 STATE OF INCORPORATION: DE FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: S-8 SEC ACT: 1933 Act SEC FILE NUMBER: 033-62535 FILM NUMBER: 95572720 BUSINESS ADDRESS: STREET 1: 2200 W LOOP S STREET 2: STEWART TITLE BLDG CITY: HOUSTON STATE: TX ZIP: 77027 BUSINESS PHONE: 7138711100 S-8 1 STEWERT INFORMATION FORM S-8 1 AS FILED WITH THE SECURITIES AND EXCHANGE COMMISSION ON SEPTEMBER 11, 1995 Registration No. 33-__________ ================================================================================ SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549 ---------------------------- FORM S-8 REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933 ---------------------------- STEWART INFORMATION SERVICES CORPORATION (Exact name of registrant as specified in its charter) Delaware 74-1677330 (State or other jurisdiction of (I.R.S. Employer incorporation or organization) Identification Number) 1980 Post Oak Boulevard Houston, Texas 77056 (Address of Principal Executive Offices) (Zip Code) ---------------------------- STEWART TITLE GUARANTY COMPANY SALARY DEFERRAL PLAN AND TRUST (Full Title of the Plan) ---------------------------- MAX CRISP VICE PRESIDENT-FINANCE, SECRETARY AND TREASURER STEWART INFORMATION SERVICES CORPORATION 1980 Post Oak Boulevard Houston, Texas 77056 (713) 625-8100 (Name, address, including zip code, and telephone number, including area code, of agent for service) ---------------------------- Copy to: CHAMBERLAIN, HRDLICKA, WHITE, WILLIAMS & MARTIN Attention: Stephen M. Mason 1200 Smith Street, Suite 1400 Houston, Texas 77002 ----------------------------
============================================================================================================== Title of Amount to be Proposed Maximum Proposed Maximum Amount of Securities to be Registered(1) Offering Price per Aggregate Offering Registration Registered Share(2) Price(2) Fee(2) -------------------------------------------------------------------------------------------------------------- Common Stock, 249,825 $18.88 $4,716,696 $1,626.45 $1.00 par value shares per share
(1) Pursuant to Rule 416(c) under the Securities Act of 1933, as amended, this Registration Statement also covers an indeterminate amount of interests to be offered or sold pursuant to the employee benefit plan described herein. (2) The proposed maximum offering price is estimated pursuant to Rule 457(h) solely for the purpose of calculating the registration fee and is based upon the average of the high and low sales prices of a share of the Registrant's Common Stock on September 8, 1995 as reported on the New York Stock Exchange. 2 PART I INFORMATION REQUIRED IN THE SECTION 10(a) PROSPECTUS ITEM 1. PLAN INFORMATION. The information specified by Item 1 of Part I of Form S-8 is omitted from this filing in accordance with the provisions of Rule 428 under the Securities Act of 1933, as amended, and the introductory note to Part I of Form S-8. ITEM 2. REGISTRANT INFORMATION AND EMPLOYEE PLAN ANNUAL INFORMATION. The information specified by Item 2 of Part I of Form S-8 is omitted from this filing in accordance with the provisions of Rule 428 under the Securities Act of 1933, as amended, and the introductory note to Part I of Form S-8. I-1 3 PART II INFORMATION REQUIRED IN THE REGISTRATION STATEMENT ITEM 3. INCORPORATION OF DOCUMENTS BY REFERENCE. The documents set forth below are hereby incorporated by reference in this Registration Statement. All documents subsequently filed by Stewart Information Services Corporation, a Delaware corporation (the "Company") and the Stewart Title Guaranty Company Salary Deferral Plan and Trust (the "Plan") pursuant to Sections 13(a), 13(c), 14 and 15(d) of the Securities Exchange Act of 1934, as amended (the "Exchange Act"), prior to the filing of a post-effective amendment that indicates that the securities offered hereby have been sold or which deregisters the securities offered hereby then remaining unsold, shall be deemed to be incorporated by reference in this Registration Statement and to be a part hereof commencing on the respective dates on which such documents are filed. (1) The Company's Annual Report on Form 10-K for the fiscal year ended December 31, 1994. (2) All other reports filed by the Company or the Plan pursuant to Section 13(a) or 15(d) of the Exchange Act since the end of the fiscal year covered by the Annual Report referred to in (1) above. (3) The description of the Company's common stock, $1.00 par value (the "Common Stock"), contained in a registration statement on Form 8-A filed pursuant to the Exchange Act, including any amendment or report filed for the purpose of updating such description. ITEM 4. DESCRIPTION OF SECURITIES. Not Applicable. ITEM 5. INTERESTS OF NAMED EXPERTS AND COUNSEL. The financial statements and schedules of the Company as of December 31, 1994 and 1993, and for each of the years in the three-year period ended December 31, 1994, incorporated by reference in this Registration Statement have been so incorporated in reliance upon the reports of the following: KPMG Peat Marwick LLP; Price Waterhouse LLP; Perry-Smith & Co.; Ernst & Young LLP; Doshier, Pickens & Francis, P.C.; Jim S. Walker; Denton Wolter & Company, P.C.; Fancher & Company; M. Timothy O'Roark; Grant Bennett Accountants; McGee, Haza & Co.; Aaronson, White & Company; Edgar, Kiker & Cross, L.L.P.; and Ginny Sanders May, independent certified public accountants, incorporated by reference herein, and given on the authority of said firms as experts in accounting and auditing. The validity of the issuance of interests in the Plan registered hereby will be passed on by Chamberlain, Hrdlicka, White, Williams & Martin, counsel to the Company. II-1 4 ITEM 6. INDEMNIFICATION OF DIRECTORS AND OFFICERS. Article Eleventh of the Company's Certificate of Incorporation provides that no director of the Company will be personally liable to the Company or its stockholders for monetary damages for breach of fiduciary duty by such directors as a director; provided, however, that such article will not eliminate or limit liability of a director to the extent provided by applicable law (i) for any breach of the director's duty of loyalty to the Company or its stockholders, (ii) for acts or omissions not in good faith or which involve intentional misconduct or a knowing violation of the law, (iii) under Section 174 of the General Corporation Law of the State of Delaware (the "GCL"), or (iv) for any transaction from which the director derived an improper personal benefit. The effect of this provision is to eliminate the personal liability of a director to the Company and its stockholders for monetary damages for breach of his fiduciary duty as a director to the extent allowed under the GCL. If a director were to breach such duty in performing his duties as a director, neither the Company nor the stockholders could recover monetary damages from the director, and the only course of action available to the Company's stockholders would be equitable remedies such as an action to enjoin or rescind a transaction involving a breach of fiduciary duty. To the extent certain claims against directors are limited to equitable remedies, Article Fourteenth may reduce the likelihood of derivative litigation and may discourage stockholders or management from initiating litigation against directors for breach of their fiduciary duty. Additionally, equitable remedies may not be effective in many situations. If a stockholder's only remedy is to enjoin completion of the Board of Directors' action, this remedy would be ineffective if the stockholder does not become aware of a transaction until after it has been completed. In such a situation, it is possible that the stockholders and the Company would not have an effective remedy against the directors. Section 145 of the General Corporation Law of the State of Delaware empowers the Company to, and the Bylaws of the Company provide that it shall, indemnify any person who was or is a party or is threatened to be made a party to any threatened, pending or completed action, suit or proceeding by reason of the fact that he is or was a director, officer, employee or agent of the Company, or is or was serving at the request of the Company as a director, officer, employee or agent of another corporation, partnership, joint venture, trust or other enterprise, against expenses, judgments, fines and amounts paid in settlement actually and reasonably incurred by him in connection with such action, suit or proceeding if he acted in good faith and in a manner he reasonably believed to be in or not opposed to the best interests of the Company, and, with respect to any criminal action or proceeding, had no reasonable cause to believe his conduct was unlawful; except that, in the case of an action or suit by or in the right of the Company, no indemnification may be made in respect of any claim, issue or matter as to which such person shall have been adjudged to be liable to the Company unless and only to the extent that the Court of Chancery or the court in which such action or suit was brought shall determine that such person is fairly and reasonably entitled to indemnity for proper expenses. Delaware corporations are also authorized to obtain insurance to protect officers and directors from certain liabilities, including liabilities against which the corporation cannot II-2 5 indemnify its directors and officers. The Company currently has in effect a directors' and officers' liability insurance policy providing coverage for each director and officer in his capacity as such. ITEM 7. EXEMPTION FROM REGISTRATION CLAIMED. Not Applicable. ITEM 8. EXHIBITS.
Exhibit No. Description ----------- ----------- 4.1 Certificate of Incorporation of the Company, as amended (Exhibit 3.1 to the Company's Annual Report on Form 10-K for the year ended December 31, 1987, is incorporated by reference herein). 4.2 Bylaws of the Company, as amended. 4.3 The Stewart Title Guaranty Company Salary Deferral Plan and Trust, the Fifth Amendment and Restatement thereof. 4.4 Sixth Amendment of the Stewart Title Guaranty Company Salary Deferral Plan and Trust. 4.5 Seventh Amendment of the Stewart Title Guaranty Company Salary Deferral Plan and Trust. 4.6 Eighth Amendment of the Stewart Title Guaranty Company Salary Deferral Plan and Trust. 4.7 Ninth Amendment of the Stewart Title Guaranty Company Salary Deferral Plan and Trust. 4.8 Tenth Amendment of the Stewart Title Guaranty Company Salary Deferral Plan and Trust. 4.9 Eleventh Amendment of the Stewart Title Guaranty Company Salary Deferral Plan and Trust. 4.10 Twelfth Amendment of the Stewart Title Guaranty Company Salary Deferral Plan and Trust. 5.1 Opinion of Messrs. Chamberlain, Hrdlicka, White, Williams & Martin regarding the legality of the securities being registered. 23.1 Consents of independent accountants.
II-3 6 23.2 Consent of Counsel, Chamberlain, Hrdlicka, White, Williams & Martin, is set forth in the opinion included in the Registration Statement as Exhibit 5. 24.1 Power of Attorney (contained on page II-6 hereof).
ITEM 9. UNDERTAKINGS. (a) The Company hereby undertakes: (1) To file, during any period in which offers or sales are being made, a post-effective amendment to this Registration Statement: (i) To include any prospectus required by Section 10(a)(3) of the Securities Act of 1933 (the "Act"); (ii) To reflect in the prospectus any facts or events arising after the effective date of the Registration Statement (or the most recent post-effective amendment thereof) which, individually or in the aggregate, represent a fundamental change in the information set forth in the Registration Statement; (iii) To include any material information with respect to the plan of distribution not previously disclosed in the Registration Statement or any material change to such information in the Registration Statement. (2) That, for the purpose of determining any liability under the Act, each such post-effective amendment shall be deemed to be a new registration statement relating to the securities offered therein, and the offering of such securities at that time shall be deemed to be the initial bona fide offering thereof. (3) To remove from registration by means of a post-effective amendment any of the securities being registered which remain unsold at the termination of the offering. (4) That, for purposes of determining any liability under the Act, each filing of the Company's annual report pursuant to Section 13(a) or Section 15(d) of the Securities Exchange Act of 1934 (the "Exchange Act") and each filing of the Plan's Annual Report pursuant to Section 15(d) of the Exchange Act that is incorporated by reference in the Registration Statement shall be deemed to be a new registration statement relating to the securities offered therein, and the offering of such securities at that time shall be deemed to be the initial bona fide offering thereof. II-4 7 (5) Insofar as indemnification for liabilities arising under the Act may be permitted to directors, officers and controlling persons of the Company pursuant to the foregoing provisions, or otherwise, the Company has been advised that in the opinion of the Securities and Exchange Commission such indemnification is against public policy as expressed in the Act and is, therefore, unenforceable. In the event that a claim for indemnification against such liabilities (other than the payment by the Company of expenses incurred or paid by a director, officer or controlling person of the Company in the successful defense of any action, suit or proceeding) is asserted by such director, officer or controlling person in connection with the securities being registered, the Company will, unless in the opinion of its counsel the matter has been settled by controlling precedent, submit to a court of appropriate jurisdiction the question whether such indemnification by it is against public policy as expressed in the Act and will be governed by the final adjudication of such issue. (6) The Company hereby undertakes that it will submit or has submitted the Plan and any amendments thereto to the Internal Revenue Service (the "IRS") in a timely manner and has made or will make all changes required by the IRS in order to qualify the Plan under Section 401(a) of the Internal Revenue Code. II-5 8 SIGNATURES Pursuant to the requirements of the Securities Act of 1933, the Registrant certifies that it has reasonable grounds to believe that it meets all of the requirements for filing on Form S-8 and has duly caused this Registration Statement to be signed on its behalf by the undersigned, thereunto duly authorized, in the City of Houston, and State of Texas, as of the 11th day of September, 1995. STEWART INFORMATION SERVICES CORPORATION By: /s/ MAX CRISP Max Crisp, Vice President-Finance, Secretary and Treasurer POWER OF ATTORNEY KNOW ALL MEN BY THESE PRESENTS, that each person whose signature appears below constitutes and appoints Max Crisp and Tannie L. Pizzitola, Jr., and each of them, to act as his true and lawful attorney-in-fact and agent, with full power of substitution and resubstitution, for him and in his name, place and stead, in any and all capacities, to sign any or all post-effective amendments to this Registration Statement, and to file the same with all exhibits thereto and other documents in connection therewith, with the Securities and Exchange Commission, granting unto said attorneys- in-fact and agents, and each of them, full power and authority to do and perform each and every act and thing requisite and necessary to be done, as fully to all intents and purposes as he might or could do in person, hereby ratifying and confirming all that said attorneys-in-fact and agents, or his substitute or substitutes or all of them may legally do or cause to be done by virtue thereof. Pursuant to the requirements of the Securities Act of 1933, this Registration Statement has been signed by the following persons in the capacities and on the date indicated.
Signature Title Date --------- ----- ---- /s/ CARLOSS MORRIS Co-chief executive officer September 11, 1995 CARLOSS MORRIS and Director (principal executive officer) /s/ STEWART MORRIS Co-chief executive officer September 11, 1995 STEWART MORRIS and Director (principal executive officer) /s/ C. M. HUDSPETH Director September 11, 1995 C. M. HUDSPETH
II-6 9 /s/ NITA B. HANKS Director September 11, 1995 NITA B. HANKS /s/ MAX CRISP Vice President - Finance, September 11, 1995 MAX CRISP Secretary, Treasurer and Director (principal financial and accounting officer)
Pursuant to the requirements of the Securities Act of 1933, the trustee (or other persons who administer the Plan) have duly caused the Registration Statement to be signed on its behalf by the undersigned, thereunto duly authorized, in the city of Houston, State of Texas, on September 11, 1995. TRUSTEE OF STEWART TITLE GUARANTY COMPANY SALARY DEFERRAL PLAN AND TRUST First Interstate Bank of Texas, N.A., Trustee By: /s/ JOHN J. KELLEY Name: Vice President & Trust Officer Title: John J. Kelley II-7 10 INDEX TO EXHIBITS
Exhibit No. Description ----------- ----------- 4.1 Certificate of Incorporation of the Company, as amended (Exhibit 3.1 to the Company's Annual Report on Form 10-K for the year ended December 31, 1987, is incorporated by reference herein). 4.2 Bylaws of the Company, as amended. 4.3 The Stewart Title Guaranty Company Salary Deferral Plan and Trust, the Fifth Amendment and Restatement thereof. 4.4 Sixth Amendment of the Stewart Title Guaranty Company Salary Deferral Plan and Trust. 4.5 Seventh Amendment of the Stewart Title Guaranty Company Salary Deferral Plan and Trust. 4.6 Eighth Amendment of the Stewart Title Guaranty Company Salary Deferral Plan and Trust. 4.7 Ninth Amendment of the Stewart Title Guaranty Company Salary Deferral Plan and Trust. 4.8 Tenth Amendment of the Stewart Title Guaranty Company Salary Deferral Plan and Trust. 4.9 Eleventh Amendment of the Stewart Title Guaranty Company Salary Deferral Plan and Trust. 4.10 Twelfth Amendment of the Stewart Title Guaranty Company Salary Deferral Plan and Trust. 5.1 Opinion of Messrs. Chamberlain, Hrdlicka, White, Williams & Martin regarding the legality of the securities being registered. 23.1 Consents of independent accountants.
11 23.2 Consent of Counsel, Chamberlain, Hrdlicka, White, Williams & Martin, is set forth in the opinion included in the Registration Statement as Exhibit 5. 24.1 Power of Attorney (contained on page II-6 hereof).
EX-4.2 2 BYLAWS OF THE COMPANY 1 EXHIBIT 4.2 BY-LAWS OF STEWART INFORMATION SERVICES CORPORATION ARTICLE I OFFICES SECTION 1.1. Registration office. The registered office of the corporation in the State of Delaware shall be in the City of Wilmington, County of New Castle, and the name of its registered agent shall be The Corporation Trust Company. SECTION 1.2. Other offices. The corporation may also have offices at such other places both within and without the State of Delaware as the Board of Directors may from time to time determine or the business of the corporation may require. ARTICLE II MEETINGS OF STOCKHOLDERS SECTION 2.1. Place of Meeting. All meetings of stockholders for the election of directors shall be held at such place, either within or without the State of Delaware, as shall be designated from time to time by the Board of Directors and stated in the notice of the meeting. SECTION 2.2. Annual Meeting. The annual meeting of stockholders shall be held at such date and time as shall be designated from time to time by the Board of Directors and stated in the notice of the meeting, SECTION 2.3. Voting List. The officer who has charge of 1 2 stock ledger of the corporation shall prepare and make, at least ten days before every meeting of stockholders, a complete list of the stockholders entitled to vote at the meeting, arranged in alphabetical order, and showing the address of each stockholder and the number of shares registered in the name of each stockholder. Such list shall be open to the examination of any stockholder, for any purpose germane to the meeting, during ordinary business hours, for a period of at least ten days prior to the meeting, either at a place within the city where the meeting is to be held, which place shall be specified in the notice, or if not so specified, at the place where the meeting is to be held. The list shall also be produced and kept at the time and place of the meeting during the whole time thereof, and may be inspected by any stockholder who is present. SECTION 2.4. Special Meeting. Special meetings of the stockholders, for any purpose or purposes, unless otherwise prescribed by statute or by the Certificate of Incorporation, may be called by the Chairman of the Board or by the President or by the Board of Directors or by written order of a majority of the directors and shall be called by the President or the Secretary at the request in writing of stockholders owning a majority in amount of the entire capital stock of the corporation issued and outstanding and entitled to vote. Such request shall state the purpose of the proposed meeting. The Chairman of the Board or the President or directors so calling, or the stockholders so requesting, any such meeting shall fix the time and any place, 2 3 either within or without the State of Delaware, as the place for holding such meeting. SECTION 2.5. Notice of Meeting. Written notice of the annual, and each special meeting of stockholders, stating the time, place and purpose or purposes thereof, shall be given to each stockholder entitled to vote thereat, not less than ten nor more than 60 days before the meeting. SECTION 2.6. Quorum. The holders of a majority of the stock issued and outstanding and entitled to vote thereat, present in person or represented by proxy, shall constitute a quorum at any meeting of stockholders for the transaction of business except at each election of directors and as otherwise provided by statute or by the Certificate of Incorporation. At each meeting of or the election of directors the holders of a majority of the Common Stock and the holders of a majority of the Class B Common Stock, issued and outstanding of each such class, and entitled to vote thereat, present in person or represented by proxy shall constitute a quorum. Notwithstanding the other provisions of the Certificate of Incorporation or these by-laws, the holders of a majority of the shares of capital stock entitled to vote thereat, present in person or represented by proxy, whether or not a quorum is present, shall have power to adjourn the meeting from time to time, without notice other than announcement at the meeting, until a quorum shall be present or represented. If the adjournment is for more than 30 days, or if after the adjournment a new record date is fixed for the adjourned meeting, a notice of the adjourned meeting shall be 3 4 given to each stockholder of record entitled to vote at the meeting. At such adjourned meeting at which a quorum shall be present or represented any business may be transacted which might have been transacted at the meeting as originally notified. SECTION 2.7. Voting. (a) Unless express provision of applicable statute, of the Certificate of Incorporation or of these by-laws shall provide to the contrary, at each meeting of stockholders each holder of capital stock of the Corporation shall be entitled to cast one vote for each share of capital stock registered in his or its name on the books of the Corporation on the record date for determination of stockholders entitled to notice of, and to vote at, such meeting on each matter properly submitted to stockholders at each meeting. If any stockholder entitled to vote at any meeting shall be present at such meeting and such stockholder shall abstain, whether in person or by proxy, from casting the vote or votes which he or it is entitled to cast at such meeting, such abstention shall not affect the determination of the presence of a quorum at such meeting. For all purposes of these by-laws, an abstention from voting on any matter properly submitted to stockholders at a meeting shall not be considered a vote cast for or against such matter. (b) Each stockholder having the right to vote shall be entitled to vote in person or by proxy appointed by an instrument in writing subscribed by stockholder, bearing a date not more than three years prior to voting, unless such instrument provides for a 4 5 longer period, and filed with the Secretary of the Corporation before, or at the time of, the meeting. If such instrument shall designate two or more persons to act as proxies, unless such instrument shall provide to the contrary, a majority of such persons present at any meeting at which their powers thereunder are to be exercised shall have and may exercise all of the powers of voting or giving consents thereby conferred, or if only one be present, then such powers may be exercised by that one, or if any even number attend and a majority do not agree on any particular issue, each proxy so attending shall be entitled to exercise such powers in respect to the same portion of the shares as he is of the proxies representing such shares. (c) When a quorum is present at any meeting of stockholders, a majority of the shares voted in person or by proxy shall decide any question brought before such meeting, unless the question is one upon which, by express provision of applicable statute, of the Certificate of Incorporation or of these by-laws, a different vote is required, in which case such express provision shall govern and control the decision of such question. (d) When a quorum is present at any meeting of stockholders at which the Board of Directors is to be elected, the stockholders shall elect such directors by a plurality of the shares voted in person or by proxy. All votes for election of directors that are cast in person shall be cast by written ballot. SECTION 2.8. Consent of Stockholders. Whenever the vote 5 6 of stockholders at a meeting thereof is required or permitted to be taken for or in connection with any corporate action by any provision of the statutes, the meeting and vote of stockholders may be dispensed with if all the stockholders who would have been entitled to vote upon the action if such meeting were held shall consent in writing to such corporate action being taken; or if the Certificate of Incorporation authorizes the action to be taken with the written consent of the holders of less than all the stock who would have been entitled to vote upon the action if a meeting were held, then on the written consent of the stockholders having not less than such percentage of the number of votes as may be authorized in the Certificate of Incorporation; provided that in no case shall the written consent be by the holders of stock having less than the minimum percentage of the vote required by statute for the proposed corporate action, and provided that prompt notice must be given to all stockholders of the taking of corporate action without a meeting and by less than unanimous consent. SECTION 2.9. Voting of Stock of Certain Holders. Shares standing in the name of another corporation, domestic or foreign, may be voted by such officer, agent or proxy as the by-laws of such corporation may prescribe, or in the absence of such provision, as the Board of Directors of such corporation may determine. Shares standing in the name of a deceased person may be voted by the executor or administrator of such deceased person, either in person or by proxy. Shares standing in the name of a guardian, conservator or trustee may be voted by such fiduciary, either in 6 7 person or by proxy, but no such fiduciary shall be entitled to vote shares held in such fiduciary capacity without a transfer of such shares into the name of such fiduciary. Shares standing in the name of a receiver may be voted by such receiver. A stockholder whose shares are pledged shall be entitled to vote such shares, unless in the transfer by the pledgor on the books of the corporation, he has expressly empowered the pledgee to vote thereon, in which case only the pledgee, or his proxy, may represent the stock and vote thereon. SECTION 2.10. Treasury Stock. The corporation shall not vote, directly or indirectly, shares of its own stock owned by it; and such shares shall not be counted in determining the total number of outstanding shares. SECTION 2.11. Fixing Record Date. The Board of Directors may fix in advance a date, not exceeding 60 days preceding the date of any meeting of stockholders, or the date for payment of any dividend or distribution, or the date for the allotment of rights, or the date when any change, or conversion or exchange of capital stock shall go into effect, or a date in connection with obtaining a consent, as a record date for the determination of the stockholders entitled to notice of, and to vote at, any such meeting and any adjournment thereof, or entitled to receive payment of any such dividend or distribution, or to receive any such allotment of rights, or to exercise the rights in respect of any such change, conversion or exchange of capital stock, or to give such consent, and in such care such stockholders and only such 7 8 stockholders as shall be stockholders of record on the date so fixed shall be entitled to such notice of, and to vote at, any such meeting and any adjournment thereof, or to receive payment of such dividend or distribution, or to receive such allotment of rights, or to exercise such rights, or to give such consent, as the case may be, notwithstanding any transfer of any stock an the books of the corporation after any such record date fixed as aforesaid. ARTICLE III BOARD OF DIRECTORS SECTION 3.1. Powers. The business and affairs of the corporation shall be managed by its Board of Directors, which may exercise all such powers of the corporation and do all such lawful acts and things as are not by statute or by the Certificate of Incorporation or by these by-laws directed or required to be exercised or done by the stockholders. SECTION 3.2. Number, Election and Term. The number of directors which shall constitute the whole Board shall be NINE. Unless such number if fixed by express provision of the statutes or the Certificate of Incorporation, in which case such express provision shall govern and control, the number of directors shall from time to time be fixed and determined by the directors and shall be set forth in the notice of any meeting of stockholders held for the purpose of electing directors. The directors shall be elected at the annual meeting of stockholders, except as provided in Section 3.3, and each director elected shall hold office until his successor shall be elected and shall qualify. Directors need 8 9 not be residents of Delaware or stockholders of the corporation. SECTION 3.3. Vacancies, Additional Directors and Removal From Office. if any vacancy occurs in the members of the Board of Directors elected by the holders of Common stock caused by death, resignation, retirement, disqualification or removal from office of any such director, or otherwise, or if any new directorship to be elected by the holders of Common stock is created by an increase in the authorized number of directors, a majority of the directors then in office elected by the holders of Common stock, though less than a quorum, or a sole remaining such director, may choose a successor or fill the newly created directorship; and a director so chosen shall hold office until the next annual election and until his successor shall be duly elected and shall qualify, unless sooner displaced, if any vacancy occurs in the members of the Board of Directors elected by the holders of Class B Common stock caused by death, resignation, retirement, disqualification or removal from office of any such director, or otherwise, or if any new directorship to be elected by the holders of Class B Common stock is created by an increase in the authorized number of directors, a majority of the directors then in office elected by the holders of Class B Common stock, though less than a quorum, or a sole remaining such director, may choose a successor or fill the newly created directorship; and a director so chosen shall hold office until the next annual election and until his successor shall be duly elected and shall qualify, unless sooner displaced. A director may be removed either for or without cause at any special 9 10 meeting of stockholders duly called and held for such purpose except that only the stockholders entitled to vote for any such director may vote for the removal of such director. SECTION 3.4. Regular Meeting. A regular meeting of the Board of Directors shall be held each year, without other notice than this by-law, at the place of, and immediately following, the annual meeting of stockholders; and other regular meetings of the Board of Directors shall be held each year, at such time and place as the Board of Directors may provide, by resolution, either within or without the State of Delaware, without other notice than such resolution. SECTION 3.5. Special Meeting. A special meeting of the Board of Directors may be called by the Chairman of the Board or by the President and shall be called by the Secretary on the written request of any two directors. The Chairman or President so calling, or the directors so requesting, any such meeting shall fix the time and any place, either within or without the State of Delaware, as the place for holding such meeting. SECTION 3.6. Notice of Special Meeting. Written notice of special meetings of the Board of Directors shall be given to each director at least 48 hours prior to the time of such meeting; provided however, in instances where notice of such meeting is given orally, by telephone or telegraph, such notice need be given only 24 hours prior to such meeting. Any director may waive notice of any meeting. The attendance of a director at any meeting shall constitute a waiver of notice of such meeting for the purpose of 10 11 objecting to the transaction of any business because the meeting is not lawfully called or convened. Neither the business to be transacted at, nor the purpose of, any special meeting of the Board of Directors need be specified in notice or waiver of notice of such meeting, except that notice shall be given of any proposed amendment to the by-laws if it is to be adopted at any special meeting or with respect to any other matter where notice is required by statute. SECTION 3.7. Quorum and Vote Required. Six of the nine members of the Board of Directors shall constitute a quorum for the transaction of business at any meeting of the Board of Directors, and the act of all of the directors shall be the act of the Board of Directors, except as may be otherwise specifically provided by statute, by the Certificate of Incorporation or by these by-laws. If a quorum shall not be present at any meeting of the Board of Directors, the directors present thereat may adjourn the meeting from time to time, without notice other than announcement at the meeting, until a quorum shall be present. SECTION 3.8. Action Without Meeting. Unless otherwise restricted by the Certificate of Incorporation or these by-laws, any action required or permitted to be taken at any meeting of the Board of Directors, or of any committee thereof as provided in Article IV of these by-laws, may be taken without a meeting, if a written consent thereto is signed by all members of the Board or of such committee, as the case may be, and such written consent is filed with the minutes of proceedings of the Board or committee. 11 12 SECTION 3.9. Compensation. Directors, as such, shall not be entitled to any stated salary for their services unless voted by the stockholders or the Board of Directors; but by resolution of the Board of Directors, a fixed sum and expenses of attendance, if any, may be allowed for attendance at each regular or special meeting of the Board of Directors or any meeting of a committee of directors. No provision of these by-laws shall be construed to preclude any director from serving the corporation in any other capacity and receiving compensation therefor. SECTION 3.10. Nomination of Directors to be Elected by Holders of Common Stock. Only persons who are nominated in accordance with the following procedures are eligible for election as directors by the holders of the Common Stock of the corporation. Nominations of persons for election by the holders of Common Stock to the Board of Directors of the corporation may be made at a meeting of stockholders, by or at the direction of the Board of Directors, by any nominating committee or person appointed to make nominations by the Board of Directors, or by any holder of Common Stock of the corporation entitled to vote for the election of directors at the meeting who complies with the notice procedures set forth in this section, Nominations, if made by a stockholder of the corporation shall be made pursuant to timely notice in writing addressed to the secretary of the corporation. To be timely, a stockholder's notice shall be delivered to or mailed and received at the principal executive offices of the Corporation not less than 60 days nor more than 120 days prior to the meeting at 12 13 which directors are to be elected by the holders of Common Stock. In the event that less than 30 days notice or prior public disclosure of the date of the meeting is given or made to stockholders, notice by the stockholder to be timely must be received no later than the close of business on the seventh day following the day on which notice of the date of the meeting was mailed or public disclosure was made. A stockholder's notice shall set forth: (a) as to each person whom the stockholder proposes to nominate for election or reelection as a director (i) the name, age, business address and residence address of the person, (ii) the principal occupation or employment of the person, (iii) the class and number of shares of stock of the corporation which are beneficially owned by the person and (iv) any other information relating to the person that would be required to be disclosed in solicitations for proxies for election of Directors pursuant to Regulation 14A under the Securities Exchange Act of 1934, as amended, or any successor rule; and (b) as to the stockholder giving the notice (i) the name and record address of the stockholder and (ii) the class and number of shares of the corporation which are beneficially owned by the stockholder. The corporation may require any proposed nominee to furnish additional information as reasonably required by the corporation to determine the eligibility of the proposed nominee to serve as a director of the corporation, No person shall be eligible for election as a director of the corporation by the holders of Common Stock of the corporation unless nominated in accordance with the procedures set 13 14 forth in this section. The presiding officer at the meeting shall, if the facts warrant, determine and declare to the meeting that a nomination was not made in accordance with the foregoing procedure, and following such determination, the defective nomination shall be disregarded. SECTION 3.11. Advisory Directors. The Board of Directors may elect from one (1) to nine (9) (as it may decide) Advisory Members of the Board of Directors who may meet with the Board of Directors at such Board Meeting to which they are invited by the Chairman of the Board, or the President or Executive Vice President (it being realized that there may be meetings not deemed important enough to warrant time and travel expense of all or a part of the Advisory Members), and give the Board of Directors the benefit of their advice and counsel. The Advisory Members of the Board of Directors may be elected at any regular or special meeting of the Board of Directors. The Advisory Members of the Board of Directors shall receive the same fee for attending a meeting that a Director receives and shall be paid their travel expenses, if any, incurred in attending meetings of the Board of Directors. No such payment shall preclude any Director from serving the corporation in any other capacity and receiving compensation therefor. ARTICLE IV COMMITTEE OF DIRECTORS SECTION 4.1. Designation, Powers and Name. The Board of Directors may, by resolution passed by a majority of the whole 14 15 Board, designate one or more committees, including, if they shall so determine, an Executive Committee, each such committee to consist of two or more of the directors of the corporation. The committee shall have and may exercise such of the powers of the Board of Directors in the management of the business and affairs of the corporation as may be provided in such resolution. The committee may authorize the seal of the corporation to be affixed to all papers which may require it. The Board of Directors may designate one or more directors as alternate members of any committee, who may replace any absent or disqualified member at any meeting of such committee. In the absence or disqualification of any member of such committee or committees, the member or members thereof present at any meeting and not disqualified from voting, whether or not he or they constitute a quorum, may unanimously appoint another member of the Board of Directors to act at the meeting in the place of any such absent or disqualified member. Such committee or committees shall have such name or names and such limitations of authority as may be determined from time to time by resolution adopted by the Board of Directors. SECTION 4.2. Minutes. Each committee of directors shall keep regular minutes of its proceedings and report the same to the Board of Directors when required. SECTION 4.3. Compensation. Members of special or standing committees may be allowed compensation for attending committee meetings, if the Board of Directors shall so determine. ARTICLE V 15 16 NOTICE SECTION 5.1. Methods of Giving Notice. Whenever under the provisions of the statutes, the Certificate of Incorporation or these by-laws, notice is required to be given to any director, member of any committee or stockholder, such notice shall be in writing and delivered personally or mailed to such director, member or stockholder; provided that in the case of a director or a member of any committee such notice may be given orally or by telephone or telegram. If mailed, notice to a director, member of a committee or stockholder shall be deemed to be given when deposited in the United States mail first class in a sealed envelope, with postage thereon prepaid, addressed, in the case of a stockholder, to the stockholder at the stockholder's address as it appears on the records of the corporation or, in the case of a director or a member of a committee, to such person at his business address. If sent by telegraph, notice to a director or member of a committee shall be deemed to be given when the telegram, so addressed, is delivered to the telegraph company. SECTION 5.2. Written Waiver. Whenever any notice is required to be given under the provisions of the statutes, the Certificate of Incorporation or these by-laws, a waiver thereof in writing, signed by the person or persons entitled to said notice, whether before or after the time stated therein, shall be deemed equivalent thereto. ARTICLE VI OFFICERS 16 17 SECTION 6.1. Officers. The officers of the corporation are Chairman of the Board and Co-Chief Executive Officer, a President and Co-Chief Executive Officer, a Senior Executive Vice President-Assistant Chairman, a Senior Executive Vice President-Assistant President, one or more Vice Presidents, any one or more which may be designated an Executive Vice President and/or Senior Vice President, a Vice President-Finance, a Secretary, a Treasurer and a Controller. The Board of Directors may by resolution create the office of Vice Chairman of the Board and define the duties of such office. The Board of Directors may appoint such other officers and agents including Assistant Vice Presidents, Assistant Secretaries and Assistant Treasurers, as it shall deem necessary, who shall hold their offices for such terms and shall exercise such powers and perform such duties as shall be determined by the Board. Any two or more offices, other than the offices of President and Secretary, may be held by the same person. No officer shall execute, acknowledge, verify or countersign any instrument on behalf of the corporation in more than one capacity, if such instrument is required by law, by these by-laws or by any act of the corporation to be executed, acknowledged, verified or countersigned by two or more officers. The Chairman of the Board and Co-Chief Executive Officer and the President and Co-Chief Executive Officer shall be elected from among the directors. With the foregoing exceptions, none of the other officers need be a director, and none of the officers need be a stockholder of the corporation. 17 18 SECTION 6.2. Election and Term of Office. The officers of the corporation shall be elected annually by the Board of Directors at its first regular meeting held after the annual meeting of stockholders or as soon thereafter as conveniently possible. Each officer shall hold office until his successor shall have been chosen and shall have qualified or until his death or the effective date of his resignation or removal, or until he shall cease to be a director in the case of the Chairman of the Board and Co-Chief Executive Officer and the President and Co-Chief Executive Officer. SECTION 6.3. Removal and Resignation. Any officer or agent elected or appointed by the Board of Directors may be removed with cause by the affirmative vote of the Board of Directors whenever, in its judgment, the best interests of the corporation shall be served thereby, but such removal shall be without prejudice to the contractual rights, if any, of the person so removed. Any officer may resign at any time by giving written notice to the corporation. Any such resignation shall take effect at the date of the receipt of such notice or at any later time specified therein, and unless otherwise specified therein, the acceptance of such resignation shall not be necessary to make it effective. SECTION 6.4. Vacancies. Any vacancy occurring in any office of the corporation by death, resignation, removal or otherwise, may be filled by the Board of Directors for the unexpired portion of the term. 18 19 SECTION 6.5. Salaries. The salaries of all officers and agents of the corporation shall he fixed by the Board of Directors or pursuant to its direction; and no officer shall be prevented from receiving such salary by reason of his also being a director. SECTION 6.6. Chairman of the Board and Co-Chief Executive Officer. The Chairman of the Board and Co-Chief Executive Officer shall preside at all meetings of the Board of Directors or of the stockholders of the corporation. In the Chairman's absence, or at the election of the President and Co-Chief Executive Officer and the Chairman of the Board and Co-Chief Executive Officer, such duties shall be attended to by the President and Co-Chief Executive Officer. The Chairman of the Board and the President shall formulate and submit to the Board of Directors or the Executive Committee matters of general policy for the corporation and shall perform such other duties as usually appertain to the office or as may be prescribed by the Board of Directors or the Executive Committee. The Chairman of the Board and Co-Chief Executive Officer shall, with the President and Co-Chief Executive Officer, be the principal executive officer of the corporation and, subject to the control of the Board of Directors, shall in general supervise and control the business and affairs of the corporation. The Chairman of the Board and Co-Chief Executive Officer, acting with the President and Co-Chief Executive Officers shall have the power to appoint and remove subordinate officers, agents and employees, except those elected or appointed by the Board of Directors. The Chairman of the Board and Co-Chief Executive 19 20 Officer, acting with the President and Co-Chief Executive Officer, shall keep the Board of Directors and the Executive Committee fully informed and shall consult them concerning the business of the corporation. Either or both may sign with the Secretary or any other officer of the corporation thereunto authorized by the Board of Directors, certificates for shares of the corporation and any deeds, bonds, mortgages, contracts, checks, notes, drafts or other instruments which the Board of Directors has authorized to be executed, except in cases where the signing and execution thereof has been expressly delegated by these by-laws or by the Board of Directors to some other officer or agent of the corporation, or shall be required by law to be otherwise executed. Either or both the Chairman of the Board and the President shall vote, or give a proxy to any other officer of the corporation to vote, all shares of stock of any other corporation (except that the Board of Directors shall vote, or give a proxy to one or more member(s) of the Board to vote, all shares of the stock of Stewart Title Guaranty Company) standing in the name of the corporation and in general they shall perform all other duties normally incident to the office of the Chairman of the Board and Co-Chief Executive Officer and President and Co-Chief Executive Officer, and such other duties as may be prescribed by the stockholders, the Board of Directors or the Executive Committee from time to time. In the absence of the President and Co-Chief Executive Officer, or in the event such officer is unable or refuses to act, the Chairman of the Board and Co-Chief Executive Officer shall perform the duties and 20 21 exercise the powers of the President and Co-Chief Executive Officer. If the office of the President is vacant, the Chairman of the Board shall be the Chief Executive Officer. SECTION 6.7. President and Co-Chief Executive Officer. The President and Co-Chief Executive Officer shall, with the Chairman of the Board and Co-Chief Executive Officer, be the principal executive officer of the corporation and subject to the control of the Board of Directors, shall in general supervise and control the business and affairs of the corporation. In the absence of the Chairman of the Board and Co-Chief Executive Officer, the President and Co-Chief Executive Officer shall preside at all meetings of the Board of Directors and of the Stockholders. The President and Co-Chief Executive Officer, acting with the Chairman of the Board and Co-Chief Executive Officer, shall have the power to appoint and remove subordinate officers, agents and employees, except those elected or appointed by the Board of Directors. The President and Co-Chief Executive Officer, acting with the Chairman of the Board and Co-Chief Executive Officer, shall keep the Board of Directors and the Executive Committee fully informed and shall consult them concerning the business of the corporation. Either or both may sign with the Secretary or any other officer of the corporation thereunto authorized by the Board of Directors, certificates for shares of the corporation and any deeds, bonds, mortgages, contracts, checks, notes, drafts or other instruments which the Board of Directors has authorized to be executed, except in cases where the signing and execution thereof 21 22 has been expressly delegated by these by-laws or by the Board of Directors to some other officer or agent of the corporation, or shall be required by law to be otherwise executed. Either or both the Chairman of the Board and the President shall vote, or give a proxy to any other officer of the corporation to vote, all shares of stock of any other corporation (except that the Board of Directors shall vote, or give a proxy to one or more member(s) of the Board to vote, all shares of the stock of Stewart Title Guaranty Company) standing in the name of the corporation and in general they shall perform all other duties normally incident to the office of President and Co-Chief Executive Officer and Chairman of the Board and Co-Chief Executive Officer and such other duties as may be prescribed by the stockholders, the Board of Directors or the Executive Committee from time to time, In the absence of the Chairman of the Board and Co-Chief Executive Officer, or in the event such officer is unable or refuses to act, the President and Co-Chief Executive Officer shall perform the duties and exercise the powers of the Chairman of the Board and Co-Chief Executive Officer. If the office of the Chairman of the Board is vacant, the President shall be the Chief Executive Officer. SECTION 6.8. Vice President. in the absence of the President and Co-Chief Executive Officer and the Chairman of the Board and Co-Chief Executive Officer, or in the event both are unable or refuse to act, either or both the Senior Executive Vice President-Assistant Chairman and the Senior Executive Vice President-Assistant President (or in the event both such offices 22 23 are vacant or both such officers are unable or refuse to act, the Vice President-Finance) shall perform the duties and exercise the powers of the President and Co-Chief Executive Officer and the Chairman of the Board and Co-Chief Executive Officer. In the event the offices of both Chairman and President are vacant, the Senior Executive Vice President-Assistant Chairman shall perform the duties and exercise the powers of the Chairman and Co-Chief Executive Officer and the Senior Executive Vice President-Assistant President shall perform the duties and exercise the powers of the President and Co-Chief Executive Officer. Any Vice President may sign, with the Secretary or Assistant Secretary, certificates for shares of the corporation. The Vice Presidents shall perform such other duties as from time to time may be assigned to them by the Chairman, the President, the Board of Directors or the Executive Committee. SECTION 6.9. Secretary. The Secretary shall (a) keep the minutes of the meetings of the stockholders, the Board of Directors and committees of directors; (b) see that all notices are duly given in accordance with the provisions of these by-laws and as required by law; (c) be custodian of the corporate records and of the seal of the corporation, and see that the seal of the corporation or a facsimile thereof is affixed to all certificates for shares prior to the issue thereof and to all documents, the execution of which on behalf of the corporation under its seal is duly authorized in accordance with the provisions of these by-laws; (d) keep or cause to be kept a register of the post office address 23 24 of each stockholder which shall be furnished by such stockholder; (e) sign with the President, or an Executive Vice President or Vice President, certificates for shares of the corporation, the issue of which shall have been authorized by resolution of the Board of Directors; (f) have general charge of the stock transfer books of the corporation; and (g) in general, perform all duties normally incident to the office of Secretary and such other duties as from time to time may be assigned to him by the President, the Board of Directors or the Executive Committee. SECTION 6.10. Treasurer. If required by the Board of Directors, the Treasurer shall give a bond for the faithful discharge of his duties in such sum and with such surety or sureties as the Board of Directors shall determine. He shall have charge and custody of and be responsible for all funds and securities of the corporation; receive and give receipts for monies due and payable to the corporation from any source whatsoever and deposit all such monies in the name of the corporation in such banks, trust companies or other depositories as shall be selected in accordance with the provisions of Section 7.3 of these by-laws, and in general, perform all duties normally incident to the office of Treasurer and such other duties as from time to time may be assigned to him by the President, the Board of Directors or the Executive Committee. SECTION 6.11. Controller. The Controller shall prepare, or cause to be prepared, for submission at each regular meeting of the Board of Directors, at each annual meeting of the stockholders, 24 25 and at such other times as may be required by the Board of Directors, the President or the Executive Committee, a statement of financial condition of the corporation in such detail as may be required; and in general, perform all the duties incident to the office of Controller and such other duties as from time to time may be assigned to him by the President, the Board of Directors or the Executive Committee. SECTION 6.12. Assistant Secretary or Treasurer. The Assistant Secretaries and Assistant Treasurers shall, in general, perform such duties as shall be assigned to them by the Secretary or the Treasurer, respectively, or by the President, the Board of Directors or the Executive Committee. The Assistant Secretaries and Assistant Treasurers shall, in the absence of the Secretary or Treasurer, respectively, perform all functions and duties which such absent officers may delegate, but such delegation shall not relieve the absent officer from the responsibilities and liabilities of his office. The Assistant Secretaries may sign, with the President or a Vice President, certificates for shares of the corporation, the issue of which shall have been authorized by a resolution of the Board of Directors. The Assistant Treasurers shall respectively, if required by the Board of Directors, give bonds for the faithful discharge of their duties in such sums and with such sureties as the Board of Directors shall determine. ARTICLE VII CONTRACTS, CHECKS AND DEPOSITS SECTION 7.1. Contracts. Subject to the provisions of 25 26 Section 6.1, the Board of Directors may authorize any officer, officers, agent or agents, to enter into any contract or execute and deliver any instrument in the name of and on behalf of the corporation, and such authority may be general or confined to specific instances. SECTION 7.2. Checks, etc. All checks, demands, drafts or other orders for the payment of money, notes or other evidences of indebtedness issued in the name of the corporation, shall be signed by such officer or officers or such agent or agents of the corporation, and in such manner, as shall be determined by the Board of Directors. SECTION 7.3. Deposits. All funds of the corporation not otherwise employed shall be deposited from time to time to the credit of the corporation in such banks, trust companies or other depositories as the Board of Directors may select. ARTICLE VIII CERTIFICATES OF STOCK SECTION 8.1. Issuance. Each stockholder of this corporation shall be entitled to a certificate or certificates showing the number of shares of stock registered in his name on the books of the corporation. The certificates shall be in such form as may be determined by the Board of Directors, shall be issued in numerical order and shall be entered in the books of the corporation as they are issued. They shall exhibit the holder's name and number of shares and shall be signed by the President or a Vice President and by the Secretary or an Assistant Secretary. 26 27 If any certificate is countersigned (1) by a transfer agent other than the corporation or any employee of the corporation, or (2) by a registrar other than the corporation or any employee of the corporation, any other signature on the certificate may be a facsimile. If the corporation shall be authorized to issue more than one class of stock or more than one series of any class, the designations, preferences and relative participating, optional or other special rights of each class of stock or series thereof and the qualifications, limitations or restrictions of such preferences and rights shall be set forth in full or summarized on the face or back of the certificate which the corporation shall issue to represent such class of stock; provided that, except as otherwise provided by statute, in lieu of the foregoing requirements there may be set forth on the face or back of the certificate which the corporation shall issue to represent such class or series of stock, a statement that the corporation will furnish to each stockholder who so requests the designations, preferences and relative, participating, optional or other special rights of each class of stock or series thereof and qualifications, limitations or restrictions of such preferences and rights. All certificates surrendered to the corporation for transfer shall be cancelled and no new certificate shall be issued until the former certificate for a like number of shares shall have been surrendered and cancelled, except that in the case of a lost, stolen, destroyed or mutilated certificate a new one may be issued therefor upon such terms and with such indemnity, if any, to the corporation as the Board of 27 28 Directors may prescribe. Certificates shall not be issued representing fractional shares of stock. SECTION 8.2. Lost Certificates. The Board of Directors may direct a new certificate or certificates to be issued in place of any certificate or certificates theretofore issued by the corporation alleged to have been lost, stolen or destroyed, upon the making of an affidavit of that fact by the person claiming the certificate of stock to be lost, stolen or destroyed. When authorizing such issue of a new certificate or certificates, the Board of Directors may, in its discretion and as a condition precedent to the issuance thereof, require the owner of such lost, stolen or destroyed certificate or certificates, or his legal representative, to advertise the same in such manner as it shall require or to give the corporation a bond in such sum as it may direct as indemnity against any claim that may be made against the corporation with respect to the certificate or certificates alleged to have been lost, stolen or destroyed, or both. SECTION 8.3. Transfers. Upon surrender to the corporation or the transfer agent of the corporation of a certificate for shares duly endorsed or accompanied by proper evidence of succession, assignment or authority to transfer, it shall be the duty of the corporation to issue a new certificate to the person entitled thereto, cancel the old certificate and record the transaction upon its books. Transfers of shares shall be made only on the books of the corporation by the registered holder thereof, or by his attorney thereunto authorized by power of 28 29 attorney and filed with the Secretary of the corporation or the Transfer Agent. SECTION 8.4. Registered Stockholders. The corporation shall be entitled to treat the holder of record of any share or shares of stock as the holder in fact thereof and, accordingly, shall not be bound to recognize any equitable or other claim to or interest in such share or shares on the part of any other parson, whether or not it shall have express or other notice thereof, except as otherwise provided by the laws of the State of Delaware. ARTICLE IX DIVIDENDS SECTION 9.1. Declaration. Dividends upon the capital stock of the corporation, subject to the provisions of the Certificate of Incorporation, if any, may be declared by the Board of Directors at any regular or special meeting, pursuant to law. Dividends may be paid in cash, in property or in shares of capital stock, subject to the provisions of the Certificate of Incorporation. SECTION 9.2. Reserve. Before payment of any dividend, there may be set aside out of any funds of the corporation available for dividends such sum or sums as the Board of Directors from time to time, in their absolute discretion, think proper as a reserve or reserves to meet contingencies, or for equalizing dividends, or for repairing or maintaining any property of the corporation, or for such other purpose as the Board of Directors shall think conclusive to the interest of the corporation, and the 29 30 Directors may modify or abolish any such reserve in the manner in which it was created. ARTICLE X INDEMNIFICATION SECTION 10.1. Third Party Actions. The Corporation shall indemnify any person who was or is a party or is threatened to be made a party to any threatened, pending or completed action, suit or proceeding, whether civil, criminal, administrative or investigative (other than an action by or in the right of the corporation) by reason of the fact that he is or was a director, officer, employee or agent of the corporation, or is or was serving at the request of the corporation as a director, officer, employee or agent of another corporation, partnership, joint venture, trust or other enterprise, against expenses (including attorneys' fees), judgments, fines and amounts paid in settlement actually and reasonably incurred by him in connection with such action, suit or proceeding if he acted in good faith and in a manner he reasonably believed to be in or not opposed to the best interests of the corporation, and with respect to any criminal action or proceeding, had no reasonable cause to believe his conduct was unlawful. The termination of any action, suit or proceeding by judgment, order, settlement or conviction, or upon a plea of nolo contendere or its equivalent, shall not, of itself, create a presumption that the person did not act in good faith and in a manner which he reasonably believed to be in or not opposed to the best interests of the corporation, and with respect to any criminal action or 30 31 proceeding, had reasonable cause to believe that his conduct was unlawful. SECTION 10.2. Actions by or in the Right of the Corporation. The corporation shall indemnity any person who was or is a party or is threatened to be made a party to any threatened, pending or completed action or suit by or in the right of the corporation to procure a judgment in its favor by reason of the fact that he is or was a director, officer, employee or agent of the corporation, or is or was serving at the request of the corporation as a director, officer, employee or agent of another corporation, partnership, joint venture, trust or other enterprise against expenses (including attorneys' fees) actually and reasonably incurred by him in connection with the defense or settlement of such action or suit if he acted in good faith and in a manner he reasonably believed to be in or not opposed to the best interests of the corporation and except that no indemnification shall be made in respect of any claim, issue or matter as to which such person shall have been adjudged to be liable for misconduct in the performance of his duty to the corporation unless and only to the extent that the Court of Chancery or the court in which such action or suit was brought shall determine upon application that, despite the adjudication of liability but in view of all the circumstances of the case, such person is fairly and reasonably entitled to indemnity for such expenses which the Court of Chancery or such other court shall deem proper. SECTION 10.3. Determination of Conduct. The 31 32 determination that an officer, director, employee or agent, has met the applicable standard of conduct set forth in Sections 10.1 and 10.2 (unless indemnification is ordered by a court) shall be made (1) by the Board of Directors by a majority vote of a quorum consisting of Directors who were not parties to such action, suit or proceeding, or (2) if such quorum is not obtainable, or even if obtainable a quorum of disinterested directors so directs, by independent legal counsel in a written opinion, or (3) by the stockholders. SECTION 10.4. Payment of Expenses in Advance. Expenses incurred in defending a civil or criminal action, suit or proceeding shall be paid by the corporation in advance of the final disposition of such action, suit or proceeding as authorized by the Board of Directors upon receipt of an undertaking by or on behalf of the director, officer, employee or agent to repay such amount if it shall ultimately be determined that he is not entitled to be indemnified by the corporation as authorized in this Article X. SECTION 10.5. Indemnity Not Exclusive. The indemnification and advancement of expenses provided hereunder or granted pursuant hereto shall not be deemed exclusive of any other rights to which those seeking indemnification or the advancement of expenses may be entitled under any other by-law, agreement, vote of stockholders or disinterested directors or otherwise, both as to action in his official capacity and as to action in another capacity while holding such office. The indemnification and advancement of expenses provided hereunder or granted pursuant 32 33 hereto shall, unless otherwise provided when authorized or ratified, continue as to a person who has ceased to be a director, officer, employee or agent and shall inure to the benefit of the heirs, executors and administrators of such a person. ARTICLE XI MISCELLANEOUS SECTION 11.1. Seal. The corporate seal shall have inscribed thereon the name of the corporation, and the words "Corporate Seal, Delaware." The seal may be used by causing it or a facsimile thereof to be impressed or affixed or otherwise reproduced. SECTION 11.2. Books. The books of the corporation may be kept (subject to any provision contained in the statutes) outside the State of Delaware at the offices of the corporation at Houston, Texas, or at such other place or places as may be designated from time to time by the Board of Directors. ARTICLE XII AMENDMENT These by-laws may be altered, amended or repealed at any regular or special meeting of the Board of Directors if (i) notice of such alteration, amendment or repeal is contained in the notice of such meeting and (ii) such alteration, amendment or repeal is approved by a majority vote of the directors elected by the holders of the Common Stock and a majority vote of the directors elected by the holders of Class B Common Stock; with each such class of directors voting separately. 33 EX-4.3 3 SALARY DEFERRAL PLAN 1 EXHIBIT 4.3 EFFECTIVE DATE: January 1, 1986 PLAN YEAR END: December 31 2 STEWART TITLE GUARANTY COMPANY SALARY DEFERRAL PLAN AND TRUST TABLE OF CONTENTS
Page ---- ARTICLE I. DEFINITIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.1 Account . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.2 Act . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.3 Actual Contribution Percentage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.4 Actual Deferral Percentage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 1.5 Administrative Committee . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 1.6 Affiliated Company . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 1.7 Aggregate Account . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 1.8 Annual Additions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 1.9 Authorized Leave of Absence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 1.10 Beneficiary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 1.11 Break-in-Service . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 1.12 Code . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 1.13 Considered Compensation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 1.14 Deferral Contribution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 1.15 Determination Date . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 1.16 Effective Date . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 1.17 Eligible Employee . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 1.18 Employee . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 1.19 Employer . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 1.20 Employer Matching Contribution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 1.21 Employer Real Property . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 1.22 Employer Stock . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 1.23 Entry Dates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 1.24 Excess Aggregate Contributions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 1.25 Excess Contributions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 1.26 Family Member . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 1.27 Forfeiture . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 1.28 Highly Compensated Eligible Employee . . . . . . . . . . . . . . . . . . . . . . . . . . 13 1.29 Hour of Service . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 1.30 Key Employee . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 1.31 Marketable Obligation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 1.32 Member . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 1.33 Non-Key Employee . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 1.34 Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 1.35 Plan Year . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 1.36 Qualified Nonelective Contributions . . . . . . . . . . . . . . . . . . . . . . . . . . 19 1.37 Qualifying Employer Security . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 1.38 Retired Member . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 1.39 Signatory Company . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 1.40 Total Permanent Disability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
i 3 1.41 Transferred . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 1.42 Trust . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 1.43 Trust Fund . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 1.44 Trustee . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 1.45 Year of Service . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 ARTICLE II. EMPLOYEES ENTITLED TO PARTICIPATE . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 2.1 Eligibility to Participate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 2.2 Participation Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 2.3 Participation and Service Upon Reemployment . . . . . . . . . . . . . . . . . . . . . . 24 2.4 Full Participation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 2.5 Transferred Employee . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 2.6 Certification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 2.7 Notice to Employees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 ARTICLE III. CONTRIBUTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 3.1 Deferral Contributions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 3.2 Employer Matching Contributions and Employer Contributions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 3.3 Actual Deferral Percentage Test . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 3.4 Time of Payment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 3.5 Administrative Committee to Prescribe Rules Governing Deferral Contributions . . . . . . . . . . . . . . . . . . . . . . . . . . 35 3.6 Prohibition Against Reversion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 3.7 Excess Deferral Contributions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 3.8 Actual Contribution Percentage Test . . . . . . . . . . . . . . . . . . . . . . . . . . 37 ARTICLE IV. ALLOCATION TO ACCOUNTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 4.1 Certification by the Signatory Company . . . . . . . . . . . . . . . . . . . . . . . . . 40 4.2 Separate Account Maintained for Each Member . . . . . . . . . . . . . . . . . . . . . . 40 4.3 Allocation of Deferral Contribution to Members Account . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 4.4 Allocation of Employer Matching Contributions and Employer Contribution to Members' Accounts . . . . . . . . . . . . . . . . . . . . 41 4.5 Allocation of Trust Fund Income . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42 4.6 Valuation of Trust Fund . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43 4.7 Special Allocation Upon Termination, Partial Termination or Complete Discontinuance of Employer Matching Contribution . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
ii 4 4.8 Entry of Adjustments to Each Member's Account . . . . . . . . . . . . . . . . . . . . . . . . 44 4.9 Accounts for Transferred Members . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 4.10 Rights in Trust Assets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 4.11 Application of Forfeitures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 ARTICLE V. LIMITATIONS ON ANNUAL ADDITIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 5.1 Limitation Under this Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 5.2 Limitation in Event of Member's Participation in Defined Benefit Plan and Defined Contribution Plan . . . . . . . . . . . . . . . . . . . . . 46 5.3 Disposition of Excessive Annual Additions . . . . . . . . . . . . . . . . . . . . . . . . . . 47 5.4 Combining of Plans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48 5.5 Transition Fraction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49 5.6 Right of Reversion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49 ARTICLE VI. RETIREMENT AND DESIGNATION OF BENEFICIARY . . . . . . . . . . . . . . . . . . . . . . . . . . 50 6.1 Normal Retirement Date . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 6.2 Designation of Beneficiary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50 ARTICLE VII. VESTING OF MEMBERS' INTERESTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52 7.1 Vesting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52 7.2 Death . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53 7.3 Retirement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53 7.4 Disability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54 7.5 Termination of Employment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 55 7.6 Disposition of Unvested Amounts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57 7.7 Circumstances Rendering Vesting Schedule Inapplicable . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58 ARTICLE VIII. CLAIMS FOR PLAN BENEFITS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59 8.1 Application for Benefits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59 8.2 Processing of Claim . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60 8.3 Notification to Claimant of Decision . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60 8.4 Review Procedure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61 8.5 Decision on Review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61 8.6 Disputed Benefits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62
iii 5 ARTICLE IX. DISTRIBUTIONS FROM TRUST FUNDS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62 9.1 Occasions for Distributions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62 9.2 Consent to Distribution; Special Rules Upon Reemployment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63 9.3 Manner of Distributions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65 9.4 Time of Distributions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66 9.5 Mandatory Distributions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66 9.6 Distribution to Minors or Persons under Disability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68 9.7 Community Property Interests - Interest of Spouse of Member in the Event of Divorce . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68 ARTICLE X. TOP HEAVY PROVISIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69 10.1 Determination of Top Heavy Plan Status . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60 10.2 Determination of Super Top Heavy Plan Status . . . . . . . . . . . . . . . . . . . . . . . . . . 70 10.3 Aggregate Account . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70 10.4 Aggregation Group . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71 10.5 Top Heavy Plan Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72 10.6 Allocations to Non-Key Employees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72 ARTICLE XI. OTHER QUALIFIED PLANS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 74 11.1 Transfers from Other Qualified Plans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 74 11.2 Transfers to Other Qualified Plans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 75 ARTICLE XII. ADMINISTRATIVE COMMITTEE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 75 12.1 Appointment, Resignation and Removal . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 75 12.2 Rights, Powers and Authority . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 76 12.3 Administration . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77 12.4 Annual Audit of Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 78 12.5 Chairman and Secretary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79 12.6 Quorum and Voting Majority . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79 12.7 Limitation on Voting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79 12.8 Delegation of Rights, Powers and Duties . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80 12.9 Liability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80 12.10 Compensation and Expense . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80 12.11 Bonds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81 12.12 Indemnity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81 12.13 Reporting and Disclosure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 82 12.14 Statement to Members . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 83 12.15 Signatory Company to Supply Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 83
iv 6 ARTICLE XIII. TRUSTEE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84 13.1 Acceptance and Holding of Funds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84 13.2 Responsibility for Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84 13.3 Resolutions of Board of Directors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85 13.4 Judicial Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85 13.5 Dealings with Third Parties . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 86 13.6 Annual Accounting by Trustee . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 86 13.7 Preparation of Statement to Members . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87 13.8 Resignation of Trustee . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87 13.9 Removal of Trustee . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88 13.10 Appointment of Successor Trustee . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88 13.11 Trustee's Compensation and Expenses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88 13.12 Bonds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 90 13.13 Indemnity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 90 13.14 Appointment of Investment Manager . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91 ARTICLE XIV. INVESTMENT POWERS OF TRUSTEE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 92 14.1 Standards; Prudent Man Rule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 92 14.2 Powers of Trustee . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 92 14.3 Prohibited Transactions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 94 14.4 Investment of Contributions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 96 ARTICLE XV. LOANS TO MEMBERS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 97 15.1 No Plan Loans . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 97 ARTICLE XVI. AMENDMENT AND TERMINATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98 16.1 Amendment - General . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98 16.2 Amendments Necessary to Comply with Intentions of Signatory Companies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99 16.3 Termination with Respect to Signatory Company Without Establishment of a Successor Plan . . . . . . . . . . . . . . . . . . . . . . . . . . 99 16.4 Continuation of Plan and Trust by Successor . . . . . . . . . . . . . . . . . . . . . . . . . . 101 ARTICLE XVII. CONTINUANCE OF PLAN BY SUCCESSOR . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 101 17.1 Adoption of Plan by Successor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 101
v 7 ARTICLE XVIII. MERGER OF PLAN OR TRANSFER OF PLAN ASSETS . . . . . . . . . . . . . . . . . . . . . . . . . 102 18.1 Transfer, Consolidation or Merger with Another Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 102 ARTICLE XIX. ADOPTION OF PLAN BY A SIGNATORY COMPANY . . . . . . . . . . . . . . . . . . . . . . . . . . . 102 19.1 Method of Adoption . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 102 19.2 Withdrawal from the Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 103 ARTICLE XX. RECOVERY OF EMPLOYER CONTRIBUTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 104 20.1 Initial Approval by Internal Revenue Service . . . . . . . . . . . . . . . . . . . . . . . . 104 20.2 Conditioned on Deductibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 106 ARTICLE XXI. MISCELLANEOUS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 106 21.1 Plan is a Voluntary Undertaking by the Signatory Company . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 106 21.2 Benefit Provided Solely by the Trust Fund . . . . . . . . . . . . . . . . . . . . . . . . . . 106 21.3 Nonalienation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 106 21.4 Applicable Law . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108 21.S Construction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108 21.6 Reference to Code or Act Sections . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108 21.7 Binding Agreement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109 21.8 No Joint Venture Implied . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109 21.9 Copies of Plan Available . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109 21.10 Titles and Headings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109 21.11 Counterparts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 109 21.12 Severability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 110 21.13 Agent for Service of Legal Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 110 21.14 Withholding; Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 110 21.15 Single Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 111
vi 8 FIFTH AMENDMENT AND RESTATEMENT OF THE STEWART TITLE GUARANTY COMPANY SALARY DEFERRAL PLAN AND TRUST THIS FIFTH AMENDMENT AND RESTATEMENT of the Stewart Title Guaranty Company Salary Deferral Plan (the "Plan") and Trust is made this 7th day of May, 1992 to be effective (except as otherwise indicated) as of the 1st day of January, 1989, by Stewart Title Guaranty Company (the "Corporation") of Houston, Texas and First Interstate Bank of Texas, N.A., a banking institution (hereinafter sometimes called the "Trustee") of Houston, Texas. W I T N E S S E T H: WHEREAS, on December 31, 1986, the Corporation previously adopted the Plan and Trust for the sole and exclusive benefit of its Employees and their Beneficiaries, effective January 1, 1986; and WHEREAS, the Plan was previously amended on May 18, 1986 effective January 1, 1987, subsequently amended on February 26, 1988 effective January 1, 1986, amended on April 5, 1989 effective January 1, 1989, and amended May 30, 1989 effective May 31, 1989; WHEREAS, the Corporation, through the action of its Board of Directors, wishes to amend and restate the Plan effective the date set forth above so it may continue to qualify under Sections 401(a) and 401(k) of the Code and Treasury Regulations under Section 401(k) of the Code, and the Trust continues to remain exempt under the Section 501(a) of the Code and the Plan and Trust comply with the Act. 9 NOW, THEREFORE, pursuant to the provisions of Article XV, Section 15.1 of the Plan, the Plan is hereby amended and restated as follows: This document contains the provisions of the Plan as amended effective January 1, 1989 except as otherwise indicated. Unless expressly stated otherwise herein, each amended provision will be applicable only with respect to persons in employment status on the indicated effective date of the particular amended provision in question. The rights (if any) of all other persons will be determined by the provisions of the Plan as previously in effect, except as may otherwise be specifically provided hereby or by future amendments to the Plan. ARTICLE I. Definitions Unless the context reasonably requires a broader, narrower or different meaning, as used herein the following words and phrases shall have the meanings set forth below: 1.1 "Account" means, with respect to a Member, the ledger account showing such Member's interest in the Trust Fund. 1.2 "Act" means the Employee Retirement Income Security Act of 1974, as amended. 1.3 "Actual Contribution Percentage" means, with respect to a specified group of Eligible Employees, the average of the ratios (expressed as a percentage, rounded to the nearest one-hundredth percent) calculated separately for each Eligible Employee in such group of: -2- 10 (a) the sum of the following contributions paid under the Plan on behalf of each such Eligible Employee for such Plan Year (i) Employer Matching Contributions or any other matching contributions that are not Qualified Nonelective Contributions; (ii) any after-tax employee contributions (including any Excess Contributions that are recharacterized pursuant to the provisions of Article III, Section 3.3(2) of the Plan); (iii) Qualified Nonelective Contributions specifically designated for this purpose; and (iv) Deferral Contributions specifically designated for this purpose; to (b) the Eligible Employee's Considered Compensation for such Plan Year. For purposes of subsection (a)(i) above, "matching contribution" shall mean (I) any Employer contribution made to the Plan on behalf of an Eligible Employee on account of an after-tax employee contribution made by such employee, (II) any Employer contribution made to the Plan on behalf of an Eligible Employee on account of such Employee's Deferral Contribution, and (III) any forfeitures allocated on the basis of after-tax employee contributions, Deferral Contributions or matching contributions. With respect to any Highly Compensated Eligible Employee who is eligible to participate in two or more plans of the Corporation or an Affiliated Company to which matching contributions, employee contributions or both are made, all such contributions on behalf of such Highly Compensated Eligible Employee must be aggregated for purposes of determining such Employee's Actual Contribution Percentage. -3- 11 1.4 "Actual Deferral Percentage" means, with respect to a specified group of Eligible Employees for each Plan Year, the average of the ratios (expressed as a percentage, rounded off to the nearest one-hundredth percent) calculated separately for each Eligible Employee in such group of: (a) the amount of Deferral Contributions (including any Excess Deferrals as defined in Article III, Section 3.7 of the Plan and paid under the Plan), and any Qualified Nonelective Contributions on behalf of each such Eligible Employee for such Plan Year; to (b) the Eligible Employee's Considered Compensation for such Plan Year. With respect to any Highly Compensated Eligible Employee who participates in two or more cash or deferred arrangements of the Corporation or Affiliated Company, this ratio shall be calculated by treating all such cash or deferred arrangements as one cash or deferred arrangement. The actual deferral ratio of an Eligible Employee, with respect to whom neither a Deferral Contribution nor a Qualified Nonelective Contribution is made, is zero. For the purpose of determining the Actual Deferral Percentage of a Highly Compensated Eligible Employee who is subject to the family aggregation rules of Code Section 414(q)(6) because such Member is either a "five percent owner" of the Corporation or one of the ten (10) Highly Compensated Eligible Employees paid the greatest amount of compensation (as defined under Code Section 415) during the Plan Year, the following shall apply: (1) The combined Actual Deferral Percentage for the family group (which shall be treated as one Highly Compensated Eligible Employee) shall be the greater of: (i) the Actual Deferral Percentage determined by -4- 12 aggregating elective contributions, compensation (as defined in Code Section 414(s)), and amounts treated as elective contributions of all eligible Family Members who are Highly Compensated Eligible Employees without regard to family aggregation; and (ii) the Actual Deferral Percentage determined by aggregating elective contributions, compensation (as defined in Code Section 414(s)), and amounts treated as elective contributions of all eligible Family Members (including Highly Compensated Eligible Employees). However, in applying the $200,000 limit to compensation (as defined in Code Section 414(s)), Family Members shall include only the affected Employee's spouse and any lineal descendants who have not attained age nineteen (19) before the close of the Plan Year. (2) Elective contributions, compensation (as defined in Code Section 414(s)), and amounts treated as elective contributions of all Family Members shall be disregarded for purposes of determining the Actual Deferral Percentage of the non-Highly Compensated Eligible Employee group except to the extent taken into account in paragraph (1) above. (3) If an employee is required to be aggregated as a member of more than one family group in a plan, all Eligible Employees who are members of those family groups that include the employee are aggregated as one family group in accordance with paragraphs (1) and (2) above. (4) Except as provided in paragraph (1) above, "Family Member" means, with respect to an affected Member, such Member's spouse, such Member's lineal descendants and ascendants and their spouses, as described in Code Section 414(q)(6)(B). Paragraphs (1) through (4) above shall be administered in accordance with Prop. Reg. Section 1.401(k)-l(g)(8)(iii) or its successor. Qualified Nonelective Contributions and Employer Matching Contributions may be treated as Deferral Contributions for purposes of determining a Member's Actual Deferral Percentage only if such Qualified Nonelective Contributions and Employer Matching Contributions (1) are nonforfeitable when made, and (2) are subject to the same distribution restrictions that apply to Deferral Contributions, without regard to whether they are actually taken -5- 13 into account as Deferral Contributions for such purpose. Qualified Nonelective Contributions and/or Employer Matching Contributions may be treated as Deferral Contributions only if the conditions described in Prop. Reg. Section 1.401(k)-1(b)(3) or its successor are satisfied. 1.5 "Administrative Committee" means the committee appointed by the Corporation to administer the Plan. 1.6 "Affiliated Company" or "Affiliated Companies" means a corporation or other organization which is a member of any controlled group of corporations, trades or businesses (as defined in Sections 414(b) and 414(c) of the Code, except that the phrase "fifty percent (50%) or more" shall be substituted for the phrase "at least 80 percent" each place it appears in Section 1563(a)(1) of the Code) or is a member of an affiliated service group (as defined in Section 414(m) of the Code). 1.7 "Aggregate Account" means, with respect to each Member, the value of the Account maintained on behalf of such Member, including all amounts attributable to Deferral Contributions, Employer Contributions, Employer Matching Contributions and any after-tax employee contributions. 1.8 "Annual Additions" means the sum credited to a Member's Account for any "limitation year" of (1) Employer contributions, (2) employee contributions as determined under Sections 415(c)(2), 415(l) and 419A(d)(2) of the Code, (3) forfeitures, if any, (4) amounts allocated, after March 31, 1984, to an individual medical account as defined in Section 415(1)(1) of the Code which is part of a pension or annuity plan maintained by the Employer and -6- 14 (5) amounts derived from contributions paid or accrued after December 31, 1985, in taxable years ending after such date, which are attributable to post-retirement medical benefits allocated to the separate account of a key employee (as defined in Section 419A(d)(3) of the Code) under a welfare benefit plan (as defined in Section 419(e) of the Code) maintained by the Employer. The percentage limitation referred to in Article V, Section 5.1(b) shall not apply to: (1) any contribution for medical benefits (within the meaning of Section 419A(f)(2) of the Code) after separation from service which is otherwise treated as an "Annual Addition", or (2) any amount otherwise treated as an "Annual Addition" under Section 415(1)(1) of the Code. 1.9 "Authorized Leave of Absence" means the following periods of absence: (a) Absence due to accident, sickness or pregnancy as long as the Employee is continued on the employment rolls of the Signatory Company and remains eligible to return to work upon his recovery; (b) Absence due to membership in the Armed Forces of the United States (but if such absence is not pursuant to orders issued by the Armed Forces of the United States, only if with the consent of the Signatory Company) provided that each such Employee shall apply for reinstatement in the employment of the Signatory Company within ninety (90) days after honorable discharge or after release to inactive duty, as the cave may be; or (c) Absence due to an approved leave of absence granted by a Signatory Company pursuant to established practices applied in a consistent and nondiscriminatory manner, provided each such Employee shall, prior to the expiration of such leave of absence, apply for reinstatement in the employment of the Signatory Company. 1.10 "Beneficiary" or "Beneficiaries" means such natural person or persons, or trustee of a trust for the benefit of a -7- 15 natural person or persons, as may be determined pursuant to the provisions of Article VI, Section 6.2 hereof. For purposes of determining whether the Plan is a Top Heavy Plan, a Beneficiary of a deceased Member shall be considered as either a Key Employee or a Non-Key Employee, depending upon whether such deceased Member was classified as a Key Employee or Non-Key Employee. 1.11 "Break-in-Service" with respect to an Employee means any Plan Year during which such Employee completes five hundred (500) or fewer Hours of Service. Solely for the purpose of determining whether a Member has incurred a one-year Break-in-Service, Hours of Service shall be recognized for "maternity and paternity leaves of absence." A "maternity or paternity leave of absence" shall mean, an absence from work for any period by reason of the Employee's pregnancy, birth of the Employee's child, placement of a child with the Employee in connection with the adoption of such child, or any absence for the purpose of caring for such child for a period immediately following such birth or placement. For this purpose, Hours of Service shall be credited for the computation period in which the absence from work begins, only if credit therefore is necessary to prevent the Employee from incurring a one-year Break-in-Service, or, in any other case, in the immediately following computation period. The Hours of Service credited for a "maternity or paternity leave of absence" shall be those which would normally have been credited but for such absence, or, in any case in which the Administrative Committee is unable to determine such hours normally credited, eight (8) Hours of Service per day. The total Hours of Service required to be credited for a "maternity or -8- 16 paternity leave of absence" shall not exceed Five Hundred One (501). No Hours of Service will be credited for a "maternity or paternity leave of absence" unless the Employee furnishes to the Administrative Committee such timely information as it may reasonably require to substantiate the length and nature of such absence. Notwithstanding the foregoing, the severance from service date of an employee who is absent from service beyond the first anniversary of the first date of absence by reason of a maternity or paternity absence described in Section 410(a)(5)(E)(i) or Section 411(a)(6)(E)(i) of the Code is the second anniversary of the first date of such absence. The period between the first and second anniversaries of the first date of absence from work is neither a period of service nor a period of severance. 1.12 "Code" means the Internal Revenue Code of 1986, as amended. 1.13 "Considered Compensation" means, as to each Eligible Employee, all compensation otherwise paid or accrued to him after he has become eligible for the Plan by the Signatory Company during the Plan Year, including regular salary, hourly base pay, overtime pay, contractual bonuses, bonuses derived by formula, commissions, discretionary bonuses and Deferral Contributions, but excluding any Employer Contributions or any Employer Matching Contributions under this Plan and other contingent compensation. For Plan Years beginning on or after January l, 1990 (or a later date permitted by Treasury regulations) for purposes of calculating the Actual Deferral Percentage and Actual Contribution Percentage, Considered -9- 17 Compensation shall be taken into account for the entire Plan Year of each Eligible Employee without regard to whether that Employee was eligible to participate in the Plan for the entire Plan Year. For purposes of Article V of the Plan, Considered Compensation shall not include the following: (a) Employer contributions to a plan of deferred compensation which are not included in the Employee's gross income for the taxable year in which contributed or employer contributions under a simplified employee pension plan to the extent such contributions are deductible by the Eligible Employee, or any distributions from a plan of deferred compensation; (b) Amounts realized from the exercise of a non-qualified stock option, or when restricted stock (or property) held by the Employee either becomes freely transferable or is no longer subject to a substantial risk of forfeiture; (c) Amounts realized from the sale, exchange or other disposition of stock acquired under a qualified stock option; and (d) Other amounts which received special tax benefits, or contributions made by the Employer (whether or not under a salary reduction agreement) towards the purchase of an annuity described in Section 403(b) of the Code (whether or not the amounts are actually excludable from the gross income of the Employee). Considered Compensation shall be limited to two hundred thousand dollars ($200,000) or such greater amount as may be determined pursuant to Section 416(d) or Section 401(a)(17) of the Code. In determining an Employee's Considered Compensation the rules of Section 414(q)(6) of the Code shall apply, except that the term "family" as used therein shall include only the Employee's spouse and any of the Employee's lineal descendants who have not attained age nineteen (19) on or before the last day of the Plan Year. -10- 18 1.14 "Deferral Contribution" means the amount each Member elects to have the Signatory Company pay to the Trustee on behalf of such Member pursuant to Article III, Section 3.1 of this Plan. 1.15 "Determination Date" means, with respect to any Plan Year, (a) the last day of the preceding Plan Year, or (b) in the case of the first Plan Year, the last day of such Plan Year. 1.16 "Effective Date" of this Plan means January 1, 1986. The effective date of this Fifth Amendment and Restatement is January 1, 1989, except as otherwise set forth in Appendix A hereto. 1.17 "Eligible Employee" means an Employee who has satisfied the eligibility requirements of Article II, Section 2.1. and attained his Entry Date. 1.18 "Employee" means any person who is now or shall hereafter become employed by a Signatory Company but excluding independent contractors, self-employed persons or employees who are nonresident aliens deriving no earned income (constituting income earned from sources within the United States) from a Signatory Company. 1.19 "Employer" means the Corporation and any Signatory Company or Affiliated Company, and shall include all trades and businesses, whether or not incorporated, which are either under common control as determined under Sections 414(b) and 414(c) of the Code (as modified in Section 1.4 above) or an affiliated service group as determined under Section 414(m) of the Code, and any other entity required to be aggregated pursuant to the regulations under Section 414(o) of the Code. -11- 19 1.20 "Employer Matching Contribution" and "Employer Contribution" means the amount contributed (if any) by the respective Signatory Companies on behalf of each Member which is equal to a percentage of such Member's Deferral Contribution and Considered Compensation, respectively. Any Employer Matching Contribution or Employer Contribution intended to qualify under Section 401(k) of the Code and intended to be included in the calculation of the Actual Deferral Percentage shall also be designated as a Qualified Nonelective Contribution. 1.21 "Employer Real Property" means real property (and related personal property) which is leased to a Signatory Company or to an Affiliated Company of any such Signatory Company. 1.22 "Employer Stock" means an equity security (preferred or common, voting or nonvoting) issued by a Signatory Company or by an Affiliated Company of any such Signatory Company. 1.23 "Entry Dates" for each Plan Year are January 1, April 1, July 1 and October 1, of such Plan Year. 1.24 "Excess Aggregate Contributions" means, with respect to any Plan Year, the excess of: (a) the aggregate amount of the after-tax employee contributions and Employer Matching Contributions that are not designated as Qualified Nonelective Contributions (and any qualified nonelective contribution or elective contribution such as a Deferral Contribution which are taken into account in computing the Actual Contribution Percentage) actually made on behalf of Highly Compensated Eligible Employees for such Plan Year, over (b) the maximum amount of contributions permitted under the Actual Contribution Percentage Test for such Plan Year, as determined under the provisions of Article III, Section 3.8 hereof. -12- 20 1.25 "Excess Contributions" means, with respect to any Plan Year, the excess of: (a) the sum of the Deferral Contributions and Qualified Nonelective Contributions made on behalf of Highly Compensated Eligible Employees for such Plan year, over (b) the maximum amount of contributions permitted under the Actual Deferral Percentage test for such Plan Year, as determined under the provisions of Article III, Section 3.3 hereof. 1.26 "Family Member" unless defined differently elsewhere in this Plan, means with respect to an affected Member such Member's lineal descendants and ascendants and their spouses, as described in Code Section 414(q)(6)(B). 1.27 "Forfeiture" means the nonvested balance of an Employee's Account which is forfeited in accordance with Article VII, Section 7.6 of the Plan because of termination from employment prior to full vesting. 1.28 "Highly Compensated Eligible Employee" means an Eligible Employee who performed services for the Employer during the "determination year" and is in one or more of the following groups: (a) during the "determination year" or "look-back year" was a five-percent owner of the Employer, as defined in Section 416 of the Code and the regulations issued thereunder; (b) received compensation during the "look-back year" from the Employer in excess of $75,000 (or such other amount in effect under Section 414(q)(1)(B) of the Code); (c) received compensation during the "look-back year" from the Employer in excess of $50,000 (or such other amount in effect under Section 414(q)(1)(C) of the Code) and was in the top-paid group of employees for such Plan Year. An Employee is in the "top-paid group" of employees for any Plan Year if such Employee is in the group consisting of the top twenty percent (20%) of -13- 21 Employees when ranked on the basis of compensation paid during such Plan Year. For purposes of determining the "top-paid group" of Employees for any Plan Year, Section 414(q)(8) of the Code and Q & A 9(b) of Treas. Reg. Section 1.414(q)-1T shall apply to exclude certain employees; or (d) was during the "look-back year" an officer of the Employer (as defined in Section 416 of the Code and the regulations issued thereunder) and received compensation greater than one hundred fifty percent (150%) of the amount in effect under Section 415(c)(1)(A) for such Plan Year. Notwithstanding the preceding sentence, for purposes of this subsection (d) the following rules shall apply: (1) the number of officers taken into account for any year shall not exceed the lesser of (A) fifty (50) employees; or (B) the greater of three (3) employees or ten percent (10%) of employees; and (2) if no officer of the Employer received compensation greater than one hundred fifty percent (150%) of the amount in effect under Section 415(c)(1)(A) of the Code for such Plan Year, then the highest paid officer of the Employer shall be treated as having received such amount of compensation. (e) were in the group consisting of the one hundred (100) Eligible Employees paid the greatest compensation during the "determination year" and were also described in (b), (c) or (d) above when these paragraphs are modified to substitute "determination year" for "look-back year" as discussed below. The "determination year" shall be the Plan Year for which testing is being performed, and the "look-back year" shall be the immediately preceding twelve-month period or (if the Employer elects pursuant to Q & A 14 of Treas. Reg. Section 1.414(q)-1T) the calendar ending with or within the determination year. For purposes of this Section, "compensation" shall be defined under Section 414(q)(7) of the Code and the regulations thereunder. -14- 22 There will be attributed to any five percent (5%) owner or any of the ten (10) most highly compensated Eligible Employees any compensation paid to, contributions made by or on behalf of, or benefits provided for any family member of such five percent (5%) owner or highly compensated Eligible Employee, pursuant to Section 414(g)(6) of the Code and the regulations thereunder. "Family Member" for purposes of the preceding sentence means the spouse and the lineal ascendants and descendants (and spouses of such ascendants and descendants) of any employee or former employee. A former employee shall be treated as a Highly Compensated Eligible Employee if such former employee was a Highly Compensated Eligible Employee as defined herein at the time he separated from service or at any time after attaining age fifty-five (55). Except as provided by Section 416(i) of the Code, an Employee's status as a Highly Compensated Eligible Employee is to be determined by reference to the controlled group of corporations as provided in Section 414(b) of the Code, and employers aggregated under Sections 414(b), (c), (m) or (o) are treated as a single employer. Notwithstanding the preceding paragraph, an Employee who was not a Highly Compensated Eligible Employee, as defined in subsections (b), (c) or (d), for the immediately preceding Plan Year shall not be treated as a Highly Compensated Eligible Employee, as defined in subsections (b), (c) or (d), for the current Plan Year unless such Employee is a member of the group consisting of the one hundred (100) Employees paid the highest Considered Compensation during the current Plan Year. -15- 23 1.29 "Hour of Service" means a time of service determined under regulations prescribed by the Secretary of Labor. For purposes of this determination, "Hours of Service" shall include each hour for which an Employee is directly or indirectly paid by the Signatory Company for performance of duties and for reasons other than performance of duties such as vacation, holidays, sickness, disability, lay-off, Authorized Leaves of Absence, and similar paid periods; and each hour for which back pay, irrespective of mitigation of damages, has been either awarded or agreed to by a Signatory Company. All "Hours of Service" shall be credited to the Employee for the computation period or periods in which the duties were performed or, in cases where the Employee is paid for reasons other than the performance of duties, pursuant to the procedures outlined in Department of Labor Regulation Section 2530.200b-2(b) and (c); provided, however, where back pay has been either awarded or agreed to by the Signatory Company, such hours shall be credited to the Employee for the computation period or periods to which the award or agreement pertains rather than the computation period in which the award, agreement or payment is made. 1.30 "Key Employee" means any Employee or former Employee (and any Beneficiary of a Employee or former Employee) who, at any time during the Plan Year or any of the preceding four (4) Plan Years, is: (a) an officer of the employer (as defined in Section 416 of the Code and the regulations issued thereunder) having annual compensation greater than one hundred fifty percent (150%) of the amount in effect under Section 415(c)(1)(A) of the Code for any such Plan -16- 24 Year. Only incorporated employers will be considered as having officers; (b) one of the ten Employees owning (or considered as owning within the meaning of Section 318 of the Code) the largest interests in all employers required to be aggregated under Code Sections 414(b), 414(c), and 414(m). However, an Employee shall not be considered a top ten owner for a Plan Year under the preceding sentence if the Employee earns less than $30,000 in annual compensation (or such other amount adjusted in accordance with Section 415(c)(1)(A) of the Code) as in effect for the calendar year in which the Determination Date falls. For this purpose, if two Employees have the same such interest, the Employee having the greater Considered Compensation shall be treated as having the larger interest; (c) a "five percent owner" of the employer. For this purpose "five percent owner" means any person who owns (or is considered as owning within the meaning of Section 318 of the Code) more than five percent (5%) of the outstanding stock of the employer or stock possessing more than five percent (5%) of the total combined voting power of all stock of the employer. In determining the ownership percentage, employers which would otherwise be aggregated under Sections 414(b), 414(c) and 414(m) of the Code shall be treated as separate employers; or (d) a "one percent owner" of the employer having an annual compensation from the employer of more than $150,000. For this purpose "one percent owner" means any person who owns (or is considered owning within the meaning of Section 318 of the Code) more than one percent (1%) of the outstanding stock of the employer or stock possessing more than one percent (1%) of the total combined voting power of all stock of the employer. In determining the ownership percentage, the employers which would otherwise be aggregated under Sections 414(b), 414(c), and 414(m) of the Code shall be treated as separate employers. However, in determining whether an individual has compensation of more than $150,000, compensation from each employer required to be aggregated under Sections 414(b), 414(c) and 414(m) of the Code shall be aggregated. In addition, for Plan Years beginning after December 31, 1984, if a Member or Former Member has not performed any services for any Employer maintaining the Plan at any time during the five (5) year period ending on the Determination Date, the Aggregate Account for -17- 25 such Member or Former Member shall not be taken into account for the purposes of determining whether this Plan is a Top Heavy or Super Top Heavy Plan under Article X, Section 10.1 or 10.2. 1.31 "Marketable Obligation" means a bond, debenture, note, certificate, or other evidence of indebtedness, referred to as an "obligation", if: (a) Such obligation is acquired: (1) On the market (A) At the price of the obligation prevailing on a national securities exchange which is registered with the Securities and Exchange Commission; or (B) If the obligation is not traded on such a national securities exchange, at a price not less favorable to the Plan than the offering price for the obligation as established by current bid and asked prices quoted by persons independent of the issuer; (2) From an underwriter, at a price (A) Not in excess of the public offering price for the obligation as set forth in a prospectus or offering circular filed with the Securities and Exchange Commission; and (B) At which a substantial portion of the same issue is acquired by persons independent of the issuer; or (3) Directly from the issuer, at a price not less favorable to the Plan than the price paid currently for a substantial portion of the same issue by persons independent of the issuer; (b) Immediately following acquisition of such obligation: -18- 26 (1) Not more than twenty-five percent (25%) of the aggregate amount of obligations issued in such issue and outstanding at the time of acquisition is held by the Plan; and (2) At least fifty percent (50%) of the aggregate amount referred to in subparagraph (1) is held by persons independent of the issuer; and (c) Immediately following acquisition of the obligation, not more than twenty-five percent (25%) of the assets of the Plan is invested in obligations of the Signatory Company or an Affiliated Company of the Signatory Company. 1.32 "Member" or "Members" means an Eligible Employee or Eligible Employees who elects or elect to participate in the Plan during the Plan Year. 1.33 "Non-Key Employee" is an Employee who is not a Key Employee at any time during the Plan Year or any of the preceding four (4) Plan Years and the Beneficiaries of such Employee. 1.34 "Plan" means the Stewart Title Guaranty Company Salary Deferral Plan herein set forth and all subsequent amendments hereto. 1.35 "Plan Year" begins on January 1 and ends on December 31. 1.36 "Qualified Nonelective Contributions" means any Employer Contribution or Employer Matching Contribution (other than a Deferral Contribution) that satisfies the same vesting and distribution provisions applicable to Deferral Contributions as provided in Article VII of the Plan and is designated by the Administrative Committee as such. 1.37 "Qualifying Employer Security" means a security issued by a Signatory Company or by an Affiliated Company of any such -19- 27 Signatory Company which is Employer Stock or a Marketable Obligation. 1.38 "Retired Member" means a person who was at one time a Member and who has retired in accordance with the provisions of this Plan. 1.39 "Signatory Company" or "Signatory Companies" means the Corporation, any of the Corporation's Affiliated Companies (and any other business organization) which adopts this Plan. 1.40 "Total Permanent Disability" means a mental or physical disability which, in the opinion of a physician selected by the Administrative Committee, will prevent a Member from earning a reasonable livelihood and which: (a) Was neither contracted, suffered or incurred while such Member was engaged in, nor resulted from his having engaged in, a felonious criminal enterprise; (b) Did not result from an intentionally self inflicted injury; (c) Did not result from an injury incurred while a member of the Armed Forces of the United States after the Effective Date of this Plan and for which such Member receives a military pension; and (d) Did not result (directly or indirectly) from the Member's engaging in substance abuse as determined by the Administrative Committee under standards set forth in the substance abuse policy adopted by the Signatory Company which employs the Member. 1.41 "Transferred" as used with respect to an Employee and "Transfer of an Employee" means the termination of employment of an Employee by one Signatory Company and the contemporaneous commencement of the employment of such Employee by another Signatory Company. -20- 28 1.42 "Trust" means the trust estate created herein or by the separate agreement of the Corporation and the Trustee. 1.43 "Trust Fund" means the cash, bonds, stocks and other properties held by the Trustee pursuant to the Trust created under the Plan. 1.44 "Trustee" or "Trustees" means the Ameritrust Texas, N.A. until April 1, 1991 and then it means First Interstate Bank of Texas, N.A. (and its successors) and any individual(s), corporation(s) or institution(s) appointed by the Corporation as successor Trustee(s). 1.45 "Year of Service" means a period of twelve (12) consecutive months during which an Employee has not less than one thousand (1,000) Hours of Service with a Signatory Company or is on an Authorized Leave of Absence. For purposes of determining eligibility under Article II, an Employee's initial twelve (12) months of service with the Signatory Company, beginning with the day he first performs an Hour of Service, shall be the computation period used initially to determine whether he has a Year of Service. However, if an Employee does not have at least one thousand (1,000) Hours of Service during his initial twelve (12) months of service, the one thousand (1,000) Hours of Service requirement shall be measured with respect to the Plan Year which includes the first anniversary of his employment commencement date and, where necessary, subsequent Plan Years. The computation of Years of Service before a Break-in-Service includes Years of Service required for eligibility plus all vesting computation periods based on one thousand (1,000) Hours of Service during a -21- 29 Plan Year. For all other purposes the computation of such period shall be made with reference to the Plan Year. Years of Service for eligibility and vesting purposes shall also include Hours of Service with an Affiliated Company or predecessor Employer to the extent designated by the Administrative Committee or as otherwise required by law. ARTICLE II. Employees Entitled to Participate 2.1 Eligibility to Participate. Every Employee shall become a Member of the Plan on the Entry Date coincident with or next following the completion of one (1) Year of Service with a Signatory Company and the filing of a written application for membership with the Administrative Committee in which he authorizes payroll deductions, agrees to conform to the requirements of the Plan and furnishes to the Administrative Committee such information as is necessary to enable it to fulfill its duties and responsibilities under the terms and provisions of the Plan. If an Eligible Employee does not elect to participate in the Plan, he may become a Member on a subsequent Entry Date by submitting the required written application to the Administrative Committee prior to that Entry Date. A Member's election to make Deferral Contributions under this Plan shall in no way be made a direct or indirect condition of any other benefit provided by the Employer to such Member under this or any other plan or arrangement. The preceding sentence shall not apply to any Employer Matching Contribution made by reason of such election. -22- 30 2.2 Participation Status. In the event that any Member shall fail, in any Plan Year of his employment after the Effective Date, to accumulate one thousand (1,000) Hours of Service but does not incur a one (1) year Break-in-Service, his Account shall be placed on inactive status. In such case, such Plan Year shall not be considered as a Year of Service for the purpose of determining the Member's vested interest in accordance with Article VII, 7.1 hereof and the Member shall not share in any Employer Contributions or Employer Matching Contributions for any such Plan Year, but he shall continue to receive income allocations and valuation adjustments in accordance with Article IV, Sections 4.5 and 4.6 and shall continue to have the right to elect to make Deferral Contributions in accordance with Article III, Section 3.1 until his employment terminates as described in the following paragraph. In the event such Member accumulates one thousand (1,000) Hours of Service in a subsequent Plan Year, his Account shall revert to active status with full rights and benefits under this Plan restored. In the event a Member terminates employment for any reason, such Member shall (to the extent previously eligible): (a) share in any Employer Matching Contributions and Employer Contributions through the date of his termination of employment, (b) continue to receive income allocations and valuation adjustments on the amount in his Account pursuant to Article IV, Sections 4.5 and 4.6 after his termination of employment until the complete distribution of his Account pursuant to Article IX, and (c) continue to have the right to elect to make Deferral Contributions in accordance with Article III, Section 3.1 until the date of his termination of employment. -23- 31 2.3 Participation and Service Upon Reemployment. Participation in the Plan shall cease upon termination of employment with the Signatory Company. Termination of employment may result from retirement, death, disability, voluntary or involuntary termination of employment, unauthorized absence, or by failure to return to active employment with the Signatory Company by the date on which an Authorized Leave of Absence expires. Upon the reemployment of any person after the Effective Date who had previously been employed by the Signatory Company on or after the Effective Date, the following rules shall apply in determining his participation in the Plan: (a) If the reemployed Employee was not a Member of the Plan during his prior period of employment, he must meet the service requirements of Section 2.1 for participation in the Plan as if he were a new Employee; provided, however, that if such Employee failed to incur a Break-in-Service prior to his reemployment commencement date, the eligibility computation period for such reemployed Employee shall be the initial period beginning with the Employee's employment commencement date and not the date of his reemployment; (b) If the reemployed Employee had previously satisfied the requirements of Section 2.1 and had been a Member of the Plan prior to his termination of employment, he shall become an Eligible Employee on his reemployment commencement date; (c) If the reemployed Employee had been a Member of the Plan prior to his termination but suffered a one-year Break-in-Service prior to his resumption of employment, he shall not be eligible to reparticipate in the Plan until he has completed a Year of Service after his return. For purposes of this section, an Employee's employment commencement date shall be the date he first performs an Hour of Service for the Signatory Company and his reemployment commencement date shall be -24- 32 the date he first performs an Hour of Service upon reemployment with the Signatory Company. 2.4 Full Participation. A Member who completes a Year of Service shall participate fully in the Plan for such Plan Year. Employment for the full Plan Year shall not be required in order for a Member to be eligible to participate fully in the Plan for such Plan Year for purposes of sharing in Employer Matching Contributions and Employer Contributions. The number of Hours of Service completed by a Member during a particular Plan Year shall be the sole determinant as to whether a Member shall be credited with a Year of Service and thereby be entitled to participate fully in the Plan for such Plan Year. There shall be no condition to participation in a Plan Year other than meeting the eligibility requirements of Section 2.1 and attaining an Entry Date. Any Member who fails to complete a Year of Service during the Plan Year in which he dies, retires, is determined to be suffering from a Total Permanent Disability or otherwise terminates his employment with a Signatory Company shall not be eligible to fully participate in the Plan for such Plan Year. However, his Account shall continue to be credited with income allocations and valuation adjustments pursuant to Article IV, Sections 4.5 and 4.6 until his Account is distributed to him. Conversely, if the Member completes a Year of Service during a Plan Year in which such a terminating event occurs, he shall be eligible to fully participate in the Plan for such Plan Year. As long as a terminated Member's Account remains in the Plan such -25- 33 Member's Account shall be credited with income allocations and valuation adjustments. A Member who ia not eligible to "fully participate" in the Plan within the meaning of this Section 2.4, shall nonetheless have the right to elect to make Deferral Contributions in accordance with Article III, Section 3.1. 2.5 Transferred Employee. An Employee's status as either an Employee, Eligible Employee or a Member shall not be deemed to be interrupted or severed by the fact that he is transferred from the employ of one Signatory Company to that of any other Signatory Company or performs services for more than one Signatory Company. 2.6 Certification. Eligibility shall be determined and certified to the Trustee by the Administrative Committee, based upon information furnished by the Signatory Company, not later than thirty (30) days after each Entry Date. 2.7 Notice to Employees. The Administrative Committee shall notify each Employee of his eligibility to participate within thirty (30) days before the Entry Date on which he will become an Eligible Employee under Section 2.1 hereof, and each such notice shall be accompanied by an enrollment form and a description of the Plan written in a manner reasonably calculated to be understood by the Employee. The Administrative Committee shall notify each Member whose Account is placed on inactive status, or restored to active status pursuant to Section 2.2 hereof, within a reasonable time after such action has been taken. -26- 34 ARTICLE III. Contributions 3.1 Deferral Contributions. For each Plan Year beginning with the first Plan Year with respect to which this Plan is adopted by a Signatory Company, each Member employed by such Signatory Company may elect to have allocated to his Account as a Deferral Contribution any percentage (or whole dollar amount if authorized by the Administrative Committee in its sole discretion), not to exceed eighteen percent (18%) of his Considered Compensation for the Plan Year; provided, however, that the Administrative Committee in its discretion may limit the percentage (or dollar amount) deferred by any Member who is a Highly Compensated Eligible Employee. The Deferral Contribution shall be paid through payroll deductions of the applicable percentage (or dollar amount) by the Signatory Company, and the compensation otherwise paid to the Member shall be reduced to the extent of such Deferral Contribution. The Member may change his Deferral Contribution percentage (or dollar amount) by filing the required form with the Administrative Committee before the beginning of a payroll period. The new Deferral Contribution shall become effective as of the payroll period which begins after the day the Administrative Committee receives and processes the form. The Member shall have the right to suspend his Deferral Contribution at any time by giving a written notification to the Administrative Committee. Such suspension shall become effective for the payroll period next following the payroll period during -27- 35 which such notification is received by the Administrative Committee. If the Member suspends his Deferral Contribution, he shall forfeit his right to elect to make additional Deferral Contributions until the next Entry Date. As of this next or any subsequent Entry Date, the Member may resume Deferral Contributions to his Account by filing the required form prior to an Entry Date, to take effect for the next payroll period following such Entry Date. Elections to make Deferral Contributions, increase or decrease Deferral Contributions, suspend Deferral Contributions or resume Deferral Contributions shall be in writing, signed by the Member, on such form or forms as the Administrative Committee shall provide. Upon termination of employment, the amount attributable to the Deferral Contribution allocated to the Member's Account shall be distributed pursuant to Article VII of this Plan. Each Member's Deferral Contribution for a Plan Year under this Plan shall be limited to $7,000 (as adjusted for the cost of living, or such other amount provided in Section 402(g)(5) of the Code). If a Member's total personal deferral contributions exceed $7,000 (as adjusted for the cost of living, or such other amount provided in Section 402(g)(5) of the Code) in any Plan Year, the provisions of Article III, Section 3.7 hereof shall become applicable. The term "total personal deferral contributions" means the sum of all Deferral Contributions and any other "elective deferrals" by an Eligible Employee under any other cash or deferred arrangements or (qualified plan type) elective deferral vehicle of -28- 36 the Employer or any other employer, subject to any offset rules provided under the Code or regulations. No Deferral Contribution may be taken into account for purposes of determining whether any other contributions under this Plan or any other plan meet the requirements of Section 401(a) or Section 410(b) of the Code, or for purposes of satisfying the ("top heavy") minimum allocation rules of Article X, Section 10.6 of this Plan. The preceding sentence shall not apply for purposes of determining whether a plan meets the percentage portion or average benefit requirement of Section 410(b)(2)(A)(ii) of the Code. 3.2 Employer Matching Contributions and Employer Contributions. For each Plan Year beginning with the first Plan Year with respect to which this Plan is adopted by a Signatory Company, such Signatory Company shall, subject to the limitations contained in Section 3.3 hereof, contribute to the Trust, an Employer Matching Contribution equal to a percentage of each Member's Deferral Contribution for such Plan Year, such Employer Matching Contribution to be determined by the Board of Directors of the Corporation, acting in its sole discretion. The amount of the Employer Matching Contribution for each Plan Year shall be established by a resolution adopted by such Board of Directors. The Corporation's Board of Directors shall have the right to make a larger or additional Employer Matching Contribution on behalf of Members who are not Highly Compensated Members for the purpose of assuring the Plan's compliance with the Actual Deferral Percentage Test of Section 3.3 of this Article and the Actual Contribution Test of Section 3.8 of this Article, and such additional Employer -29- 37 Matching Contribution for non-Highly Compensated Members shall be immediately and fully nonforfeitable and shall not be subject to any vesting schedule in Article VII, Section 7.1. For each Plan Year beginning with the first Plan Year with respect to which this Plan is adopted by a Signatory Company, such Signatory Company may, subject to the limitations contained in Section 3.3 of this Article, contribute to the Trust an Employer Contribution equal to a percentage of an Eligible Employee's Considered Compensation, such sum to be determined by the Corporation's Board of Directors, acting in its sole discretion. Such Employer Contribution for any Plan Year will be allocated to an Eligible Employee pursuant to Article IV, regardless of whether the Eligible Employee makes Deferral Contributions for all or any part of such Plan Year. The amount of the Employer Matching Contribution and Employer Contribution for each Plan Year shall be established by a resolution adopted by the Corporation's Board of Directors. Such resolution will be communicated to the Signatory Companies by the Corporation and to the Members by their respective Signatory Companies. For the initial Plan Year, ending December 31, 1986, and for each year thereafter, unless otherwise established or determined by the Board of Directors the Employer Matching Contribution shall be equal to fifty percent (50%) of each Member's Deferral Contribution up to a maximum Deferral Contribution of four percent (4%) of each such Member's Considered Compensation. For purposes of this Section 3.2, in computing the Employer Matching -30- 38 Contribution, a Member's Considered Compensation shall only be taken into account up to fifty thousand dollars ($50,000) 3.3 Actual Deferral Percentage Test. If for the Plan the Actual Deferral Percentage for the group of Highly Compensated Eligible Employees (based upon Eligible Employee participation elections) would be more than the greater of: (a) the Actual Deferral Percentage of all other Eligible Employees multiplied by 1.25; or (b) the lesser of (i) two percentage (2%) points plus the Actual Deferral Percentage of all other Eligible Employees, or (ii) the Actual Deferral Percentage of all other Eligible Employees multiplied by two (2), such Excess Contribution shall be corrected in the manner set forth below. The calculation described in the preceding sentence is referred to herein as the "Actual Deferral Percentage Test." The Administrative Committee may, in its discretion, select either of the following methods of correction or any combination thereof in any Plan Year: (1) The Excess Contributions (and income allocable thereto) may, if such Excess Contributions are designated by the Administrative Committee as distributions of Excess Contributions (and income), be distributed to the appropriate Highly Compensated Eligible Employees after the close of such Plan Year and within 12 months of the close of such Plan Year. The income allocable to Excess Contributions includes both income for the Plan Year for which the Excess Contributions were made and income for the period between the end of the Plan Year and the date of distribution, and will be calculated pursuant to Prop. Reg. Section 1.401(k)-l(f)(4). If feasible, the Administrative Committee shall in its sole discretion determine and distribute the amount of Excess Contributions within two and one-half (2 1/2) months after the end of the Plan Year. The Administrative Committee may distribute Excess Contributions without regard to any notice or consent otherwise required under the Plan or Section 411(a)(11) and Section 417 of the Code limiting distributions. The amount of Excess Contributions for a Highly Compensated Eligible Employee for a Plan Year is to be determined by -31- 39 the following leveling method, under which the actual deferral ratio of the Highly Compensated Eligible Employee with the highest actual deferral ratio is reduced to the extent required to satisfy the Actual Deferral Percentage Test set forth above or cause such Highly Compensated Eligible Employee's actual deferral ratio to equal the ratio of the Highly Compensated Eligible Employee with the next highest actual deferral ratio. This process must be repeated until the Actual Deferral Percentage Test is satisfied for such Plan Year. Except to the extent otherwise provided in regulations, both refunded Excess Deferrals and retained Excess Deferrals under Section 3.7 of this Article are taken into account in determining a Member's Actual Deferral Percentage for purposes of the above calculation. (2) The Excess Contributions may be recharacterized as after-tax employee contributions in accordance with the provisions of Treas. Reg. Section 1.401(k)- l(f)(3). Recharacterized Excess Contributions remain subject to the nonforfeitability requirements and distribution limitations that apply to Deferral Contributions. Excess Contributions will not be recharacterized with respect to a Highly Compensated Eligible Employee to the extent that the recharacterized amounts, in combination with employee contributions actually made by such Highly Compensated Eligible Employee, exceed the maximum amount of employee contributions (determined prior to the application of Code Section 401(m)(2)(A)) that such Highly Compensated Eligible Employee is permitted to make under the Plan in the absence of recharacterization. In no event shall the sum of the Deferral Contributions (including recharacterized Excess Contributions), and the Signatory Company's Employer Matching Contribution, and the Signatory Company's Employer Contribution exceed an amount equal to fifteen percent (15%) of the total Considered Compensation otherwise paid or accrued during such Plan Year of such Signatory Company plus the maximum amount deductible under the "carry-over" provisions of the Code relating to Employer Matching Contributions and Employer Contributions in previous years of less than the maximum amount permissible. In addition, in no event shall the aggregate of such Deferral Contribution, Employer Matching Contribution, Employer -32- 40 Contribution and the Signatory Company's contributions to all other qualified pension, profit sharing or stock bonus plans for such Plan Year exceed the amount deductible from the Signatory Company's income for such Plan Year under Section 404(a)(7) of the Code. In the event the aggregate of the Signatory Company's contributions under all plans would exceed such maximum deductible amount, the Employer Matching Contribution and Employer Contribution to the Plans shall be reduced by the amount necessary to reduce the Signatory Company's aggregate contribution under all such plans to the maximum amount deductible under said section of the Code. Deferral Contributions will be taken into account under the Actual Deferral Percentage Test for a Plan Year only if such Deferral Contributions are allocated to the Eligible Employee as of a date within such Plan Year. For this purpose, a Deferral Contribution is considered allocated as of a date within a Plan Year if the allocation is not contingent on participation or performance of services after such date and the Deferral Contribution is actually paid to the Trust no later than twelve (12) months after the Plan Year to which the contribution relates. In the case of a Highly Compensated Eligible Employee whose Actual Deferral Percentage is determined under the family aggregation rules of Code Section 414(q)(6), the determination of the amount of Excess Contributions shall be made as follows: (3) If the Highly Compensated Eligible Employee's Actual Deferral Percentage is determined under Article I, Section 1.4(1)(ii), then the Actual Deferral Percentage is reduced in accordance with the leveling method described in Treas. Reg. Section 1.401(k)-l(f)(2) and the Excess Contributions for the family unit are allocated among the Family Members in proportion to the elective contribu- -33- 41 tions of each Family Member that have been combined to determine the Actual Deferral Percentage. (4) If the Highly Compensated Eligible Employee's Actual Deferral Percentage is determined under Article I, Section 1.4(1)(i), then the Actual Deferral Percentage is reduced in accordance with the leveling method described in Treas. Reg. Section 1-401(k)-l(f)(2) but not below the Actual Deferral Percentage of Family Members who are Non-Highly Compensated Eligible Employees without regard to family aggregation. Excess Contributions are determined by taking into account the contributions of the eligible Family Members who are Highly Compensated Eligible Employees without regard to family aggregation, and are allocated among such Family Members in proportion to each such Family Member's elective contributions. If further reduction of the Actual Deferral Percentage is required, Excess Contributions resulting from this reduction are determined by taking into account the contributions of all eligible Family Members and are allocated among such Family Members in proportion to the elective contributions of each Family Member. Paragraphs (3) and (4) above shall be administered in accordance with Prop. Reg. Section 1.401(k)-1(f)(5)(iii). Excess Contributions will be corrected in accordance with this Section 3.3 in a timely fashion to avoid disqualification of the Plan or other sanction imposed under the Code (including the imposition of tax under Code Section 4979). 3.4 Time of Payment. The Employer Matching Contribution and Employer Contribution of each Signatory Company for each Plan Year shall be paid to the Trustee in one or more installments as the Signatory Company (subject to the consent of the Corporation) may from time to time determine; provided, however, that all such installments shall be paid no later than the time prescribed by law for filing such Signatory Company's federal income tax return for such taxable year (including extensions thereof) and, if earlier with respect to the Employer Matching Contribution, no later than -34- 42 12 months after the close of the Plan Year (or other period prescribed by final regulations). 3.5 Administrative Committee to Prescribe Rules Governing Deferral Contributions. Deferral Contributions may be made only in accordance with such uniform rules and regulations as may be prescribed from time to time by the Administrative Committee. Such uniform rules and regulations of the Administrative Committee may, among other things and subject to the provisions set forth in the Plan, restrict Deferral Contributions to those made through authorized payroll deductions, require payroll deductions to be authorized on a specified periodic basis and suspend, for a specified period, the right to Deferral Contributions on the part of a Member who has discontinued his Deferral Contributions. 3.6 Prohibition Against Reversion. In no event, except as expressly provided in Article XX and Article V, Section 5.6 hereof, shall the principal or income of the Trust herein created be paid to or revert to the Signatory Company, or be used for any purpose other than for the exclusive benefit of the Members or their Beneficiaries. 3.7 Excess Deferral Contributions. The amount by which an Eligible Employee's Deferral Contribution (including for this purpose any other total personal deferral contributions within the meaning of Section 3.1 above) in any Plan Year exceeds the limitation in effect under Section 402(g)(1) of the Code and referred to in Section 3.1 above for such Plan Year shall be known as the Eligible Employee's Excess Deferral for such Plan Year. An Eligible Employee's Excess Deferral for any Plan Year shall not be -35- 43 considered as reducing such Eligible Employee's compensation under Article III, Section 3.1 to the extent of such Excess Deferral. An Eligible Employee's Excess Deferral is not required to be refunded to such Eligible Employee. However, notwithstanding any other provision of law or of this Plan limiting distributions, the Administrative Committee in its sole discretion may refund any Eligible Employee's Excess Deferral (plus any allocable income) to such Eligible Employee in accordance with the provisions set forth below. If a Member has made an Excess Deferral for his taxable year, the Member must notify the Administrative Committee in writing no later than the March 15th following the end of such taxable year, on the form prescribed by the Administrative Committee for this purpose, of the amount the Member requests to be distributed. The distribution to the Member shall be made after such taxable year but no later than the first April 15 following the close of such taxable year. Alternatively, the Administrative Committee may also provide for a distribution of the Excess Deferral during ,such taxable year, provided the following conditions are satisfied: (a) The Member designates the distribution as an Excess Deferral; (b) The distribution of the Excess Deferral is made after the date in which the Plan received the Excess Deferral; and (c) The Administrative Committee designates the distribution as a distribution of an Excess Deferral. The amount of Excess Deferral to be distributed to a Member for the Member's taxable year shall be reduced by any Excess Contribution previously distributed or recharacterized as an after-tax employee -36- 44 contribution under Section 3.3 of the Plan for the Plan Year beginning with or within such taxable year. 3.8 Actual Contribution Percentage Test. If for the Plan Year the Actual Contribution~Percentage for the group of Highly Compensated Eligible Employees would be more than the greater of: (a) the Actual Contribution Percentage for all other Eligible Employees multiplied by 1.25; or (b) the lesser of (i) the Actual Contribution Percentage for all other Eligible Employees plus two percentage (2%) points, or (ii) the Actual Contribution Percentage for all other Eligible Employees multiplied by two (2), such Excess Aggregate Contributions, shall be corrected in the manner set forth below. The calculation described in the preceding sentence is referred to herein as the "Actual Contribution Percentage Test." The Excess Aggregate Contributions (and income allocable thereto) shall be distributed to (or, if forfeitable, in the discretion of the Administrative Committee uniformly applied, forfeited by) Highly Compensated Eligible Employees after the close of the Plan Year in which such Excess Aggregate Contributions arose and within 12 months after the close of the following Plan Year. If feasible, the Administrative Committee shall in its sole discretion determine and distribute the amount of Excess Aggregate Contributions within two and one-half (2 1/2) months after the end of the Plan Year. In the event of the complete termination of the Plan during such Plan Year, the distributions described in the preceding sentence shall be made after termination of the Plan and within the 12 months following such termination. The amount of Excess Aggregate Contributions for a Highly Compensated Eligible Employee for a Plan Year is to be determined -37- 45 by the following contribution leveling method, under which the actual contribution ratio of the Highly Compensated Eligible Employee with the highest actual contribution ratio is reduced to the extent required to satisfy the Actual Contribution Percentage Test set forth above or to cause such Highly Compensated Eligible Employee's actual contribution ratio to equal the ratio of the Highly Compensated Eligible Employee with the next highest actual contribution ratio. This process must be repeated until the Actual Contribution Percentage Test is satisfied for such Plan Year. In determining the amount of Excess Aggregate Contributions under the leveling method set forth above, actual contribution ratios must be rounded to the nearest one-hundredth percent of the Eligible Employee's Considered Compensation. In no case shall the amount of Excess Aggregate Contributions with respect to any Highly Compensated Eligible Employee exceed the amount of the after-tax employee contributions and Employer Matching Contributions on behalf of such Highly Compensated Eligible Employee for such Plan Year. Excess Aggregate Contributions for a Plan Year shall be distributed or forfeited in accordance with the provisions Ret forth above and shall not remain unallocated or allocated to a suspense account for allocation to one or more Employees in any future year. The determination of the amount of Excess Aggregate Contributions witH respect to a Plan Year shall be made after the determination and correction of Excess Deferrals under Article III, Section 3.7, and the determination and correction of Excess Contributions under Article III, Section 3.3, respectively, have been made. -38- 46 In the case of a Highly Compensated Eligible Employee whose Actual Contribution Percentage is determined under the family aggregation rules of Code Section 414(q), the determination of the amount of Excess Aggregate Contributions shall be made as follows: (1) If the, Highly Compensated Eligible Employee's Actual Contribution Percentage is determined by combining the contributions and compensation of all Family Members, then the Actual Contribution Percentage is reduced in accordance with the leveling method described in Prop. Reg. Section l-401(m)-l(e)(2) and the Excess Aggregate Contributions for the family unit are allocated among the Family Members in proportion to the contributions of each Family Member that have been combined to determine the Actual Contribution Percentage. (2) If the Highly Compensated Eligible Employee's Actual Contribution Percentage is determined by combining the contributions of only those Family Members who are Highly Compensated Eligible Employees without regard to family aggregation, then the Actual Contribution Percentage is reduced in accordance with the leveling method described in Prop. Reg. Section 1.401(m)- l(e)(2) but not below the Actual Contribution Percentage of Family Members who are Non-Highly Compensated Eligible Employees without regard to family aggregation. Excess Aggregate Contributions are determined by taking into account the contributions of the eligible Family Members who are Highly Compensated Eligible Employees without regard to family aggregation and are allocated among such Family Members in proportion to each such Family Member's employee contributions and Employer Matching Contributions. If further reduction of the Actual Contribution Percentage is required, Excess Aggregate Contributions resulting from this reduction are determined by taking into account the contributions of all eligible Family Members and are allocated among such Family Members in proportion to the employee contributions and Employer Matching Contributions of each Family Member. Paragraphs (1) and (2) above shall be administered in accordance with Prop. Reg. Section l.401(m)-l(e)(4)(iii). -39- 47 ARTICLE IV. Allocation to Accounts 4.1 Certification by the Signatory Company. As soon as practicable after the end of the first Plan Year and the end of each succeeding Plan Year thereafter, the Signatory Company shall certify to the Administrative Committee the amount of its Employer Matching Contribution and Employer Contribution (if any) for the Plan Year then ended and the names of the Members entitled to share therein, the amount of Considered Compensation paid to each Member for such Plan Year and the amount of Considered Compensation paid to all Members for such Plan Year. Such certification shall be conclusive evidence of such facts. 4.2 Separate Account Maintained for Each Member. The Administrative Committee shall create and maintain adequate records to disclose the interest in the Trust Fund of each Member, Retired Member and Beneficiary. Such records shall be in the form of individual Accounts, and credits and charges shall be made to such Accounts in the manner herein described. The maintenance of individual Accounts is only for accounting purposes and a segregation of the assets of the Trust Fund to each Account shall not be required. 4.3 Allocation of Deferral Contribution to Members' Accounts. At the end of each payroll period under procedures adopted by the Administrative Committee, the Signatory Company shall transfer the Deferral Contributions to the Trustee and shall certify to the Administrative Committee the names of the Eligible Employees, the names of the Members, and the Deferral Contribution amount for each -40- 48 Member. The Administrative Committee shall allocate the Deferral Contribution made on behalf of a Member directly to such Member's Account. 4.4 Allocation of Employer Matching Contributions. Employer Contributions to Members' Accounts. The Administrative Committee shall determine the Deferral Contribution amount for each Member of the Plan. The Administrative Committee shall then, under procedures adopted by it, allocate an amount from the Signatory Company's Employer Matching Contribution (if any) to the Member's Account which is equal to the matching percentage, as determined by the Corporation's Board of Directors under Article III, Section 3.2 hereof, of the Member's Deferral Contribution for the Plan Year. The Administrative Committee shall allocate the Signatory Company's Employer Contribution (if any) for each Plan Year among the Members employed by the Signatory Company in the proportion that the Considered Compensation of each Member employed by the Signatory Company bears to the total Considered Compensation of all Members employed by the Signatory Company. If a Member has been transferred or performs services for more than one (1) Signatory Company during the Plan Year, such Member shall be entitled to have allocated to his Account a portion of the Employer Matching Contribution and Employer Contribution made by each Signatory Company by whom such Member was employed during such Plan Year and the amount allocated to the Member's Account shall be computed with respect to each Signatory Company in the manner hereinabove provided based (in the case of Employer Matching Contributions) upon the Deferral Contribution made on his behalf by -41- 49 each Signatory Company during the Plan Year and (in the case of Employer Contributions) upon the Considered Compensation earned by the Member from each Signatory Company during the Plan Year. A Member shall not receive a lesser allocation to his Account by reason of having been transferred or having performed services for more than one (1) Signatory Company during the Plan Year than such Member would have received had his Deferral Contribution or Considered Compensation for the Plan Year been paid by one Signatory Company. If an adjustment of the allocation to such Member's Account is necessary in order to achieve this result, it shall be made by the Signatory Company with whom such Member was employed for the greatest portion of the Plan Year. 4.5 Allocation of Trust Fund Income. As of the end of each calendar quarter, the Administrative Committee shall determine the amount of income earned by each class of investment since the preceding Entry Date. The Administrative Committee shall allocate such income among the Members in the proportion that the amount in each Member's Account invested in each class of investment at the end of each such calendar quarter since the preceding Entry Date bears to the aggregate amount of all Members' Accounts invested in such class of investments at the end of such calendar quarter since the preceding Entry Date. However, in the event that a Member receives a distribution from his Account during any such calendar quarter, the allocation of income to such Member's Account for such calendar quarter shall be based upon his reduced Account balance at the end of such calendar quarter and the amount invested in each class of -42- 50 investment as of the end of such calendar quarter. If a Member received the total balance in his Account during a calendar quarter, he shall not be entitled to an income allocation for such calendar quarter. 4.6 Valuation of Trust Fund. As of the end of each calendar quarter, the Trustee shall revalue the Trust Fund at its then fair market value. The Administrative Committee shall then allocate any appreciation or depreciation in the Trust Fund among the Members' Accounts in the proportion that the amount in each Member's Account invested in such class of investments at such Entry Date bears to the aggregate amount of all Members' Accounts at the end of such calendar quarter after the allocation of income under Section 4.5. Beginning with the second calendar quarter, the Trustee shall allocate any appreciation in the Trust Fund among the Members in the proportion that the amount in each Member's Account at the beginning of the calendar quarter bears to the aggregate of all Members' Accounts at the beginning of such calendar quarter. However, in the event that a Member receives a distribution from his Account during a calendar quarter preceding an Entry Date, the valuation adjustment allocated to such Member's Account for such calendar quarter shall be based upon his reduced Account balance at the end of such calendar quarter. If a Member receives the total balance in his Account during a calendar quarter, he shall not be entitled to a valuation adjustment for such calendar quarter. However, the Administrative Committee shall have the authority to change the number of times the Trust Fund is revalued -43- 51 during the Plan Year, provided that such authority is exercised in a nondiscriminatory manner. 4.7 Special Allocation Upon Termination, Partial Termination, or Complete Discontinuance of Employer Matching Contributions or Employer Contributions. Notwithstanding any other provision of this instrument to the contrary, if: (a) the Plan is terminated pursuant to Article XVI, Section 16.3 hereof; or (b) the Plan is terminated with respect to a group of Members resulting in a partial termination of the Plan, all previously unallocated funds shall be allocated to the Accounts of the Members at the time of such termination, partial termination or Employer Contributions under the Plan using the allocation methods prescribed by Sections 4.3 through 4.5 hereof as appropriate depending on the nature and source of such unallocated funds. 4.8 Entry of Adjustments to Each Member's Account. The Administrative Committee shall credit to each Member's Account such Member's portion of the adjustments and allocations required by Sections 4.3 through 4.5 of this Plan, so that all such adjustments and allocations become effective and shall be entered into each Member's Account as of the end of the Plan Year to which they are attributable unless required more frequently by the Administrative Committee pursuant to Sections 4.4 and 4.5. 4.9 Accounts for Transferred Members. In the case of a Member who has transferred or performs services for more than one Signatory Company during a Plan Year, the Administrative Committee -44- 52 shall maintain on its books such Member's Account and open or reopen an Account for such Member with respect to each Signatory Company to which the Member has transferred. In this fashion, the Administrative Committee may maintain several different Accounts with respect to each Transferred Member. However, the foregoing provisions of this Section 4.9 are for administrative convenience only. For all other purposes under this Plan, all Accounts of each Transferred Member shall be regarded as one Account, which shall be attributable to the Signatory Company by whom such Transferred Member is then employed. 4.10 Rights in Trust Assets. No such allocations, adjustments, credits or transfers shall ever vest in any Member any right, title or interest in the Trust Fund except at the times and upon the terms or conditions below set forth. Such Trust Fund shall, as to all Accounts of Members, be a commingled fund, and all securities purchased or otherwise acquired by the Trustee under the Plan shall be issued in the name of the Trustee for the Stewart Title Guaranty Company Salary Deferral Savings Plan, or in such other name or names as the Trustee shall designate. 4.11 Application of Forfeitures. The Administrative Committee shall, within thirty (30) days after the end of each Plan Year, determine the Members from the Signatory Company who have forfeited all or part of their respective interests in their Accounts pursuant to the provisions of Article VII, Sections 7.5(a) and 7.6 hereof, during such Plan Year and shall certify such information to the Trustee. The total amount of all Forfeitures shall then be used to reduce such Signatory Company's future Employer Matching -45- 53 Contributions and Employer Contributions under Article III, Section 3.2 of the Plan. ARTICLE V. Limitations on Annual Additions 5.1 Limitation Under this Plan. Notwithstanding any provisions herein to the contrary, the Annual Addition to the Accounts of any Member under all defined contribution plans of his Employer (as that term is defined in Section 5.4 hereof) for any Plan Year cannot exceed the lesser of: (a) Thirty thousand dollars ($30,000) or such greater amount as may be determined pursuant to Section 415(c)(1)(A) of the Code, as adjusted under Section 415(d) of the Code; or (b) Twenty-five percent (25%) of the Member's compensation from his Employer for such Plan Year, as determined under Section 415(c)(3) of the Code and the regulations thereunder. 5.2 Limitation in Event of Member's Participation in Defined Benefit Plan and Defined Contribution Plan. In any case in which an Employee is a participant in both a defined benefit plan and this Plan, the sum of the defined benefit plan fraction and the defined contribution plan fraction for any year may not exceed 1.0 except as may be permitted by Section 2004(a)(3) or otherwise under the Act. The defined benefit plan fraction for any year is a fraction (a) the numerator of which is the projected annual benefit of the Member under the plan (determined as of the close of the Plan Year); and (b) the denominator of which is the lesser of: (i) the product of 1.25, multiplied by the dollar limitation in effect for such Plan Year under Section 415(b)(1)(A) of the Code, or (ii) the product of 1.4, multiplied by the amount which may be -46- 54 taken into account under Section 415(b)(1)(B) of the Code with respect to such Member for such Plan Year. The defined contribution plan fraction for any year is a fraction (a) the numerator of which is the sum of the Annual Additions to the Member's Account as of the close of the Plan Year; and (b) the denominator of which is the sum of the lesser of the following amounts determined for such Plan Year and for each prior Year of Service: (i) the product of 1.25, multiplied by the dollar limitation in effect for such Plan Year as may be determined pursuant to Section 415(c)(1)(A) of the Code, or (ii) the product of 1.4, multiplied by the amount which may be taken into account under Section 415(c)(1)(B) of the Code for such Plan Year. The Administrative Committee shall reduce the numerator of the defined contribution plan fraction in order that their sum shall not exceed 1.0 for any Plan Year in accordance with Section 5.3 hereof. However, 1.0 shall be substituted for 1.25 for any Top Heavy Plan Year unless an extra minimum Employer Matching Contribution equal to one percent (1%) of the Considered Compensation of all Members who are Non-Key Employees is allocated among such members pursuant to Article IV, Section 4.4. Notwithstanding the foregoing, 1.0 shall be substituted for 1.25 for any Plan Year in which the Plan is a Super Top Heavy Plan. 5.3 Disposition of Excessive Annual Additions. If as a result of a reasonable error in estimating a Member's Considered Compensation, the Annual Additions under the terms of the Plan for a particular Member would cause the limitations of Section 415 of the Code which are applicable to that Member for that Plan Year to -47- 55 be exceeded, the excess amounts shall not be deemed Annual Additions to such Member's Account in that Plan Year, but shall be treated as follows: The excess amounts attributable to Employer Matching Contributions or Employer Contributions in the Member's Account must be allocated and reallocated to the Accounts of the other Members in the Plan, pursuant to the provisions of Article IV, Section 4.4. However, if the allocation or reallocation of the excess amounts further causes the limitations of Section 415 of the Code to be exceeded with respect to each Plan Member for that Plan Year, then these amounts must be held unallocated in a suspense account. If a suspense account is in existence at any time during a particular Plan Year (other than the Plan Year described in the preceding sentence), all amounts in the suspense account must first be allocated and reallocated to Members' Accounts (subject to the limitations of Section 415 of the Code) before any Employer Matching Contributions or Employer Contributions may be made to the Plan for that Plan Year. 5.4 Combining of Plans. For purposes of applying the limitations contained in this article, all defined contribution plans, terminated or not, of an Employer shall be treated as one defined contribution plan and all defined benefit plans, terminated or not, of an Employer shall be treated as one defined benefit plan. For purposes of this article, Employer shall mean all trades or businesses, whether or not incorporated, which are either under common control as determined under Sections 414(b) or 414(c) of the Code or are an affiliated service group as determined under Section 414(m) of the Code. For the purpose of applying the limitations set forth above, as imposed by Section 415 of the Code, a Member's compensation or annual benefit payable by the Signatory Company or any Affiliated Company of the Signatory Company shall be treated as being from a single employer. For purposes of the limitations of this section and of applying Sections 414(b) and -48- 56 414(c) of the Code as they relate to Sections 415 and 1563(a)(1) of the Code, the phrase "more than fifty percent (50%)" shall be substituted for the phrase "at least eighty percent (80%)". 5.5 Transition Fraction. At the election of the Administrative Committee, in applying the provisions of Section 5.3 with respect to the defined contribution fraction for any Plan Year ending after December 31, 1982, the amount taken into account for the denominator for each Member for all Plan Years ending before January 1, 1983 shall be an amount equal to the product of (a) the amount of the denominator determined under Section 5.3 (as in effect for the Plan Year ending in 1982) for Plan Years ending in 1982, multiplied by (b) the "transition fraction". For purposes of the preceding paragraph, the term "transition fraction" shall mean a fraction (a) the numerator of which is the lesser of (1) $51,875 or (2) 1.4 multiplied by twenty-five percent (25%) of the Member's compensation for the Plan Year ending in 1981, and (b) the denominator of which is the lesser of (1) $41,500 or (2) twenty-five percent (25%) of the Member's compensation for the Plan Year ending in 1981. Notwithstanding the foregoing, for any Plan Year in which the Plan is a Top Heavy Plan, $41,500 shall be substituted for $51,875 in determining the transition fraction." 5.6 Right of Reversion. Notwithstanding Article III, Section 3.6, in the event of termination of the Plan as provided in Article XVI, Section 16.3 any amounts held in the suspense account shall revert to the Signatory Company. -49- 57 ARTICLE VI. Retirement and Designation of Beneficiary 6.1 Normal Retirement Date. "Normal Retirement Age" means the date on which an Employee attains age sixty-five (65). Each Employee shall retire from employment on the date he reaches his Normal Retirement Age, such date to be his Normal Retirement Date; provided, however, that an Employee may continue employment thereafter subject to the condition that, in the event the Signatory Company has nineteen (19) or fewer employees, such Employee must obtain the approval of the Board of Directors of the Signatory Company to continue employment after his Normal Retirement Date. Each Employee who is employed by the Signatory Company on the date it adopts the Plan shall be deemed for the purposes of this Section 6.1 to have secured the approval of the Board of Directors of the Signatory Company and shall continue to be so deemed until such approval is affirmatively withdrawn. This Section 6.1 shall be applied in a uniform, nondiscriminatory manner to all Employees, present and future. 6.2 Designation of Beneficiary. Each Member and each Retired Member shall have the unrestricted right at any time, and from time to time, to designate and to rescind or change any designation of a primary and contingent Beneficiary or Beneficiaries to receive benefits in the event of his death, except as hereinafter provided. The designation by a Member who was married at the time of his death of a Beneficiary other than the Member's spouse shall only be permitted with such spouse's written consent. Such consent must designate a specific beneficiary, must acknowledge the effect of -50- 58 the Member's designation and must be witnessed either by a member of the Administrative Committee or by a Notary Public. Otherwise the death benefits of the Member shall be paid to the Member's spouse, except as hereinafter provided. A Member's designation of a Beneficiary other than such Member's spouse, which is consented to by such Member's spouse as provided above, may not be changed without subsequent spousal consent (unless the spouse's consent to the original Beneficiary designation expressly permits designations by the Member without further spousal consent). Any such designation, change or rescission of designation shall be made in writing by filling out and furnishing to the Administrative Committee the appropriate form prescribed by it. A contingent Beneficiary or Beneficiaries shall be entitled to receive any unpaid death benefits only if no primary Beneficiary is alive or legally entitled to receive it on the date of payment of the benefit. Any estate, assignee or appointee of either a primary or a contingent Beneficiary shall have no interest in or right to receive any death benefit payment not actually made before the death of such Beneficiary. The last such designation received by the Administrative Committee shall be controlling over any testamentary or other disposition; provided, however, that no designation, rescission or change thereof shall be effective unless received by the Administrative Committee prior to the death of the Member. Upon the divorce of a Member or a retired Member, any designation of his divorced spouse as a primary Beneficiary or as a contingent Beneficiary hereunder shall automatically terminate and become ineffective, and such divorced spouse shall have no -51- 59 interest in or right to receive any death benefit hereunder unless such Member shall file with the Administrative Committee, after the date of such divorce decree, a new designation of Beneficiary naming his divorced spouse as a Beneficiary hereunder. If there is no designated Beneficiary alive at the time of any payment of the death benefit, then the death benefit or balance thereof shall be paid to the surviving spouse of the deceased Member or, if there is no surviving spouse, to the estate of the deceased Member. The Signatory Company employing a Member shall not be named as his Beneficiary. If the Administrative Committee shall be in doubt as to the right of any Beneficiary designated by a deceased Member to receive any unpaid death benefit, the Administrative Committee may direct the Trustee to pay the amount in question to the estate of such Member, in which event the Trustee, the Signatory Company, the Administrative Committee and any other person in any manner connected with the Plan shall have no further liability in respect to the payment so paid. ARTICLE VII. Vesting of Members' Interests 7.1 Vesting. The interest of each Member who began participating in the Plan prior to January 1, 1989 in the amount credited to his Account attributable to Employer Matching Contributions and Employer Contributions shall be immediately one hundred percent (100%) vested and shall not be forfeitable for any reason. The interest of each Member who commenced participation on or after January 1, 1989, in the amount credited to his Account attributable to Employer Matching Contributions and Employer -52- 60 Contributions shall vest as hereinafter specified and, once vested, shall not be forfeitable for any reason. Each Member shall immediately and at all times have a one hundred percent (100%) vested interest in the amount credited to his Account attributable to Deferral Contributions. 7.2 Death. On the death of a Member (or a Retired Member prior to the complete distribution of such Retired Member's Account) his death benefit shall be one hundred percent (100%) of the amount credited to his Account at the end of the calendar quarter in which he dies. Payment of such death benefit to the Member's designated Beneficiary or Beneficiaries shall commence no later than ninety (90) days after the end of the calendar quarter in which the Member dies. However, in the event that the payment of his death benefit under this Section would violate Article IX, 9.4, then such benefit shall commence no later than sixty (60) days after the end of the Plan Year in which the Member dies. Notwithstanding any other provision of this Plan, in the case of a Member who is married at the time of his death, the death benefit under this Section (reduced by any security interest held by the Plan by reason of a loan outstanding to such Member) shall be payable in full to such Member's spouse, or in the event there is no surviving spouse or such surviving spouse has consented in the manner provided in Article VI, Section 6.2, to a designated Beneficiary. 7.3 Retirement. Upon attaining his Normal Retirement Date as provided in Article VI, Section 6.1 and upon reaching his Normal Retirement Age, a Member shall have a nonforfeitable right to his -53- 61 Account balance. Such retirement benefit shall be paid to the Member in the form of benefit determined by the Administrative Committee pursuant to Article IX, Section 9.3. The payment of his retirement benefit shall commence no later than ninety (90) days after the end of the calendar quarter in which he retires after attaining his Normal Retirement Date unless the Member requests otherwise in writing. However, in the event that the payment of his retirement benefit under this Section would violate Article IX, Section 9.4, then payment of such benefit shall commence no later than sixty (60) days after the end of the Plan Year in which such Member retires. 7.4 Disability. In the event the Administrative Committee determines that a Member is suffering from a Total Permanent Disability, his disability benefit shall be one hundred percent (100%) of the amount credited to his Account at the end of the calendar quarter following such determination. Such disability benefit shall be paid to the Member in the form of benefit determined by the Administrative Committee pursuant to Article IX, Section 9.3. Payments shall commence no later than ninety (90) days after the end of the calendar quarter in which the Member is determined to be totally, permanently disabled unless the Member requests otherwise in writing. However, in the event that the payment of his disability benefit under this section would violate Article IX, Section 9.4, then such benefit shall commence no later than sixty (60) days after the end of the Plan Year in which the Member is determined to be totally, permanently disabled. -54- 62 If a Member who had previously been determined to be totally, permanently disabled returns to the employment of the Signatory Company prior to receiving the entire balance in his Account, a separate ledger account shall be created for such Member and the remaining portion of his Account shall be transferred to such new Account, which shall share in income allocations and valuation adjustments pursuant to Article IV, Sections 4.5 and 4.6 until the amount is distributed in full upon his subsequent death, retirement, determination of Total Permanent Disability or severance of employment. A new Account shall be established for the returning Member as if he were a new Member, and said Account shall vest pursuant to Section 7.5 starting at the point on the vesting schedule the Member had achieved prior to the determination of his Total Permanent Disability. 7.5 Termination of Employment. In no event shall the vested interest of a Member who began participating in the Plan prior to January 1, 1989 in the amount credited to his Account attributable to Employer Matching Contributions and Employer Contributions be less than his nonforfeitable vested amount as determined under Section 7.1. (a) Vesting Schedule. A Member whose employment is terminated for any reason other than death, retirement under Section 7.3 above or Total Permanent Disability shall be entitled to a severance benefit no later than one hundred twenty (120) days after the end of the Plan Year in which he terminates employment equal to the vested interest attributable to Deferral Contributions, Employer Matching Contributions and Employer Contributions in such Member's Account at the end of the Plan Year. However, in the event that the payment of his severance benefit under this section would violate Article IX, Section 9.4, then such benefit shall commence no later than sixty (60) days after the latest date determined under that section. For the purpose of this -55- 63 Section 7.5(a), a Member's "vested interest" shall be determined using the following schedules and shall be an amount equal to the percentage of the balance of such Member's Account attributable to Employer Matching Contributions and Employer Contributions for the number of Years of Service as of the end of the Plan Year. As provided in Section 7.1, a Member's vested interest in his Account attributable to Deferral Contributions shall at all times be one hundred percent (100%). In the event that the vesting schedule contained in this Section 7.5(a) is amended, the vested percentage of a Member who began participating in the Plan on or after January 1, 1989 shall not be less than his nonforfeitable vested percentage as computed under this Section 7.5(a). If such a Member has at least three (3) Years of Service, he shall have the right during the election period to elect to have the nonforfeitable percentage of his benefit derived from Employer Matching Contributions and Employer Contributions computed under this Section 7.5(a) without regard to such amendment. Notwithstanding the preceding sentence, no election need be provided for any Member whose nonforfeitable percentage under the Plan, as amended, at any time cannot be less than such percentage determined without regard to such amendment. The election period shall begin on the date the amendment is adopted and shall end no earlier than the latest of (a) sixty (60) days after the date the amendment is adopted, (b) sixty (60) days after the date the amendment becomes effective, or (c) sixty (60) days after the Member is issued written notice of the Plan amendment by the Employer, Signatory Company or Administrative Committee. A Member shall be considered to have completed three (3) Years of Service for purposes of this paragraph if such Member has completed three (3) Years of Service as defined in Article I, Section 1.44, whether or not consecutive, without regard to the exceptions of Code Section 411(a)(4) prior to the expiration of the election period. For any Employee who does not have an Hour of Service in any Plan Year beginning after December 31, 1988, "five (5) Years of Service" shall be substituted for "three (3) Years of Service" in applying this paragraph.
Percentage of Participating Employee's Years of Service Account that Becomes Vested ---------------- --------------------------- Less than four years . . . . . . . . . . . . 0% Four years or more . . . . . . . . . . . . . 100%
-56- 64 The amount credited to such Member's Account which is not vested when he terminates employment shall be disposed of as provided in Section 7.6 hereof. (b) Years of Service Computation. For purposes of determining the Member's vested interest in the assets in his Account, all Years of Service with the Signatory Company, or any Affiliated Company, or any Predecessor Employer as of the date of severance shall be taken into account except the following with respect to Breaks-in-Service: (i) If a Member does not have a vested interest in his Account at the time he incurs a Break-in-Service, Years of Service completed by such Member prior to such Break shall not be taken into account if at such time the number of consecutive one-year Breaks-in-Service included in his most recent Break-in-Service equals or exceeds the aggregate number of his Years of Service (whether or not consecutive) completed before such Break, or five (5), if greater. In computing the aggregate number of Years of Service prior to such Break, Years of Service which could have been disregarded under this subsection by reason of a prior Break-in-Service may be disregarded. Pre-Break and post-Break Years of Service will not be aggregated until the Member has completed one (1) Year of Service after his return to employment; (ii) If a Member has five consecutive years of Breaks-in-Service for Plan Years, then any service after such Break will not increase the Member's vested interest in his Account before such Break; and (iii) If a Member has a vested interest in his Account and his separation from employment and his subsequent reemployment do not incur five consecutive years of Breaks-in-Service, his Account will continue to vest, starting at the point in the vesting schedule where he left employment. 7.6 Disposition of Unvested Amounts. Upon termination of employment, the amount in the Member's Account shall be maintained until the end of the Plan Year in which the Member terminates employment. As of the end of such Plan Year, the unvested amount -57- 65 shall be forfeited and used to reduce future Employer Matching Contributions and Employer Contributions as provided in Article IV, Section 4.11 of the Plan. 7.7 Circumstances Rendering Vesting Schedule Inapplicable. Notwithstanding any other provisions of this instrument to the contrary, if: (a) the Plan is terminated pursuant to Article XVI, Section 16.3 hereof; or (b) the Plan is terminated with respect to a group of Members resulting in a partial termination of the Plan; or (c) there occurs a complete discontinuance of Employer Contributions under the Plan, the vesting schedule contained in Section 7.5(a) hereof shall be inapplicable and each Member affected by such termination, partial termination or complete discontinuance of Employer Contributions shall thereupon have a full one hundred percent (100%) vested interest in the amount standing to his credit in his Account at such time and in any amounts thereafter credited or allocated to his Account; provided, however, that if the Signatory Company shall thereafter resume making Employer Contributions hereunder, all amounts credited or allocated to a Members Account with respect to the Plan Year for which such Employer Contributions are resumed and the Plan Years for which they are continued, shall vest only in accordance with the vesting schedule contained in Section 7.5(a) hereof. For purposes of this section, a complete discontinuance of Employer Contributions under the Plan is contrasted with a suspension of Employer Contributions under the Plan which is merely a temporary cessation of Employer Contributions by the Signatory -58- 66 Company. During any such period of termination, partial termination or complete discontinuance of Employer Contributions under the Plan, all other provisions of this Plan shall nevertheless continue in full force and effect other than provisions for Employer Contributions and allocations thereof to Members' Accounts. The Signatory Company shall notify the District Director of the Internal Revenue Service in the event it has completely discontinued to make Employer Contributions to the Plan or in the event of termination or partial termination of the Plan. ARTICLE VIII. Claims for Plan Benefits 8.1 Application for Benefits. Each Member or designated Beneficiary claiming benefits under this Plan must make written application therefor within fifteen (15) days preceding or following (whichever is applicable) the actual retirement, termination of employment, death prior to retirement, determination of Total Permanent Disability, or the happening of any other occurrence believed by the claimant to entitle him to benefits hereunder. The date the claim shall be considered as filed shall be the date a properly completed application is received by the Administrative Committee. Each such application (a) shall be in writing on a form to be provided by the Administrative Committee, (b) shall be signed by the claimant or his personal representative, (c) shall be made to the Administrative Committee, and (d) shall be filed in such a manner and with such persons as the Administrative Committee may specify. The Administrative Committee may require that there be furnished to it in connection with such application all relevant -59- 67 information. Failure to timely file such application or to supply all relevant information shall not result in the forfeiting of any rights claimed but shall excuse postponement of the orderly processing of such claim and the time of commencing payment thereof. 8.2 Processing of Claim. Upon receipt by the Administrative Committee of a properly completed application for benefits form, it shall be the duty and responsibility of the Administrative Committee to verify the facts and claims made therein with the appropriate Signatory Company and to determine whether the claim is valid. In arriving at a decision, the Administrative Committee may require additional relevant information from the claimant. In any event, within ninety (90) days of receipt of the application, the Administrative Committee shall determine whether, when and in what amount distributions are to be paid from the Plan to the claimant. If the Administrative Committee fails to act on the claim within said ninety (90) day period, the claimant may proceed to the review stage described in Section 8.4 hereof as if the claim had been denied. 8.3 Notification to Claimant of Decision. If distributions are to be made, the Administrative Committee shall immediately notify the claimant and the Trustee of the amount and method of payment. It shall then be the responsibility of the Trustee to arrange the distribution. If the claim is denied, in whole or in part, the Administrative Committee shall send written notice of the denial to the claimant. A notice that a claim has been denied -60- 68 shall set forth, in a manner calculated to be understood by the claimant: (a) The specific reason or reasons for the denial; (b) Specific reference to the pertinent Plan provisions on which the denial was based; (c) A description of any additional material or information necessary for the claimant to perfect the claim and an explanation of why such material is necessary; and (d) An explanation of the Plan's claim review procedure. 8.4 Review Procedure. A claimant shall be entitled to a full and fair review of a denial of claim for benefits. To avail himself of this right, the claimant, or his duly authorized representative, must timely file an application for review with the Administrative Committee. Such application must be in writing and must be filed within sixty (60) days of receipt of the notice of denial of benefits. If the claimant desires a personal appearance or hearing before the Administrative Committee to present his case, he shall so state in his application for review. An appeal shall be considered as filed on the date it is received by the Administrative Committee. Subsequent to the filing of an appeal and prior to the rendering of a decision thereon, the claimant, or his duly authorized representative, may review pertinent documents and may submit issues and comments in writing. If a hearing is held, the claimant may be represented thereat by legal counsel or other duly authorized representative. 8.5 Decision on Review. The Administrative Committee shall render a decision no later than sixty (60) days after its receipt -61- 69 of a request for review unless special circumstances, such as the need to hold a hearing, require an extension of time for processing, in which case a decision shall be rendered as soon as possible, but not later than one hundred twenty (120) days after receipt of a request for review. The decision for review shall be in writing and shall include the specific reasons for the decision, written in a manner calculated to be understood by the claimant, with specific reference to the pertinent Plan provisions on which the decision is based. The review decision by the Administrative Committee shall be considered final. 8.6 Disputed Benefits. If any dispute shall arise between a Member, or other person claiming under a Member, and the Administrative Committee after the review of the claim for benefits, or if any dispute shall develop as to the person to whom the payment of any benefit under the Plan shall be made, the Trustee may withhold payment of all or any part of the benefits payable hereunder to the Member, or other person claiming under the Member, until such dispute has been resolved by a court of competent jurisdiction or settled by the parties involved. ARTICLE IX. Distributions from Trust Funds 9.1 Occasions for Distributions. Distributions from the Trust shall be made to Members or Beneficiaries only upon the occurrence of one of the following events: (1) the Member's death, retirement at Normal Retirement Age, or Total Permanent Disability as provided in Article VII, Sections 7.2, 7.3 and 7.4 hereof, respectively; -62- 70 (2) termination of employment as provided in Article VII, Section 7.5 hereof; (3) termination of the Plan and Trust as provided in Article XVI; (4) the sale or other disposition by a Signatory Company to an unrelated corporation which does not maintain the Plan, of substantially all of the Signatory Company's assets (but only with respect to Members who continue employment with the acquiring corporation); or (5) the sale or other disposition by a Signatory Company of its interest in a subsidiary to an unrelated entity which does not maintain the Plan (but only with respect to Members who continue employment with the subsidiary). A distribution pursuant to paragraphs (4) or (5) above shall be made in a method provided under Article VII, Section 7.5. All distribution events set forth above are subject to the conditions and specifications set forth hereafter in this Article IX. 9.2 Consent to Distribution: Special Rules Upon Reemployment. (a) In those instances where a Member severs his employment with the Signatory Company for any reason other than death or retirement and, as a result thereof, would otherwise be entitled to a distribution of his vested interest in the Employer Contributions in his Account, no such distribution shall, under any circumstances, be authorized by the Administrative Committee nor effected by the Trustee prior to the death or retirement of such Member unless (i) the gross amount to be distributed is $3,500 or less, or (ii) the gross amount is in excess of $3,500 and the Member consents to the distribution and executes a distribution form supplied by the Administrative Committee signifying such consent. A certified copy of such distribution form shall be transmitted to the Trustee for its records along with written directions as to the amount, time and manner of distribution. (b) In the event that a Member does not consent to a distribution as required under this Section 9.2, a separate ledger account shall be created for such Member upon his incurring a forfeiture under Article VII, Section 7.6. The vested portion of his Account, as determined under Article VII, Section 7.1, shall be -63- 71 transferred to the separate ledger account. Such separate ledger account shall share in income and valuation adjustments pursuant to Article IV, Sections 4.4 and 4.5 until the amount is distributed in full upon the Member's subsequent death, retirement or Total Permanent Disability. Any Member who does not consent to a distribution under this Section 9.2 and is reemployed within five (5) years from the date his employment is severed shall be entitled to have the forfeited portion of his Account restored to him in full, unadjusted by any gains or losses occurring subsequent to the valuation date preceding his termination. Such restoration shall be paid from Employer Contributions, Forfeitures and income or gain to the Plan for the Plan Year of such restoration, as determined by the Administrative Committee. (c) If an Employee returns to the employment of a Signatory Company after incurring a forfeiture under Article VII, Section 7.6 and again becomes a Member under the Plan, a new Account shall be established for him as if he were a new Member. The new Account shall be maintained independently of the separate ledger account. Such account shall share in Employer Contributions, Forfeitures, income and valuation adjustments pursuant to Article IV and shall vest as determined under Article VII, Section 7.1. Upon subsequent termination of employment, the vested portion of the Account shall be distributed upon the Member's entitlement to a distribution under Article VII hereof or, if the Member again does not give the necessary consent to a distribution, such vested amount shall be added to the separate ledger account. (d) If any such reemployed Employee is reemployed before incurring five (5) consecutive years of Break-in-Service, and such Employee had received prior to his reemployment an entire distribution of the vested portion of his Account which was less than fully vested, the forfeited portion of his Account shall be reinstated only if he repays the full amount distributed to him before the end of the earlier of the following periods: (i) five (5) consecutive Years of Break-in-Service, or (ii) the period ending on the fifth (5th) anniversary of the Member's reemployment. If such Employee repays such full amount distributed to him, the undistributed portion of his Account must be restored in full, unadjusted by any gains or losses occurring subsequent to the valuation date preceding his termination. Such restoration shall be paid from Employer Contributions, Forfeitures and income or gain to the Plan for the Plan Year of such restoration, as determined by the Administrative Committee. This provision shall be interpreted in a -64- 72 manner consistent with the transitional rules of Section 303(a)(2) of the Retirement Equity Act as to service prior to Plan Years beginning before January 1, 1985. 9.3 Manner of Distributions. The Administrative Committee shall direct the Trustee, in writing, when to distribute the amounts referred to in Article VII, Sections 7.2, 7.3, 7.4 and 7.5, in accordance with the Member's election, under one of the following methods: (a) A lump sum payment in cash or in kind or both; except that this form of payment shall not apply in cases under Article VII, Sections 7.3 and 7.5 (pertaining to termination from employment for reasons other than death or Total Permanent Disability or continuation in employment beyond Normal Retirement Age) where the entire Account balance exceeds fifty thousand dollars ($50,000.00); or (b) Distributions in the manner provided below, after having segregated the aggregate amount thereof in a special account; provided, that the monies in such special account will earn the going rate of interest paid by local banks on savings accounts placed in insured depositories at interest, or, at the option of the Member or Beneficiary (or Beneficiaries), be credited with their portion of the gains or losses of the Trust pursuant to Article IV, Sections 4.5 and 4.6; provided further that the interest or other income earned on such special account shall be paid at the end of each Plan Year. Distribution of his entire Plan benefit in substantially equal annual, quarterly or monthly installments, over any time period not exceeding his life expectancy (or the life expectancies of such Member and his designated Beneficiary); provided that the value of any such installment in cases under Article VII, Sections 7.3 and 7.5 (pertaining to termination from employment for reasons other than death or Total Permanent Disability or continuation in employment beyond Normal Retirement Age) shall (except as otherwise provided in the Plan) not exceed fifty thousand dollars ($50,000.00) on an annual basis; provided further, that the present value of the benefits to be distributed to the Member shall exceed fifty percent (50%) of the prevent value of the total benefit to be distributed to the Member and his designated Beneficiary. -65- 73 In the event of the Member's death, the benefit shall be paid according to the method either set forth on the beneficiary designation on file with the Administrative Committee or elected by the Beneficiary or Beneficiaries. 9.4 Time of Distributions. Distributions required by Section 9.3 hereof shall commence as soon as administratively feasible. Unless the Member executes an election form consented to by the Administrative Committee which states how and when benefits are to commence, payment of benefits to the Member shall in no event begin later than the sixtieth (60th) day after the latest of the close of the Plan Year in which: (a) the Member attains age 65, (b) the Member has his tenth (lOth) anniversary of the year in which he commenced participation in the Plan, and (c) the Member's employment with a Signatory Company terminates. 9.5 Mandatory Distributions. Notwithstanding any other provision in the Plan to the contrary, benefits shall be distributed to the Member or his Beneficiary no later than set forth in this section. (a) Mandatory Age Distribution. A Member's benefits shall be distributed to him no later than the April 1st of the calendar year following the calendar year in which the Member attains age 70 1/2, but the balance of his benefits must be distributed over the life of such Member (or lives of such Member and his designated Beneficiary) or over a time period not exceeding the Member's life expectancy (or the life expectancies of the Member and his designated Beneficiary). (b) Mandatory Death Distribution. If the distribution of the Member's benefits had commenced pursuant to Section 9.5(a) and the Member dies before his entire benefit is distributed to him, the remaining portion of -66- 74 his benefit will be distributed at least as rapidly as under the method of distribution being used pursuant to Section 9.5(a) as of the date of such Member's death. If a Member dies prior to the commencement of his benefit distribution pursuant to Section 9.5(a), the entire benefit of such Member will be distributed within five (5) years after the death of such Member. However, such five (5) year rule shall be disregarded for any portion of the Member's benefit which is payable to (or for the benefit of) a designated Beneficiary, such portion to be distributed (in Accordance with regulations issued by the Secretary) over the life of such designated Beneficiary (or over a period not exceeding beyond the life expectancy of such Beneficiary), and such distributions commence not later than one (1) year after the date of the Member's death or such later date as the Secretary may prescribe by regulations. In such a situation, the benefit portion distributed to such Beneficiary shall be treated as distributed on the date on which such distribution begins. In the event that the designated Beneficiary is the deceased Member's surviving spouse, the date on which the benefit distribution is required to commence shall be no earlier than the date on which the Member would have attained age 70 1/2. If the surviving spouse dies before the distributions to such spouse commence, this subsection shall be applied as if the surviving spouse were the Member. For purposes of this subsection, any amount paid to a child shall be treated as if it had been paid to the surviving spouse if such amount shall become payable to the surviving spouse upon such child reaching majority (or other designated event permitted under Treasury regulations). (c) Prior Irrevocable Election. If the Member made an irrevocable election prior to December 31, 1983 to defer the distribution of benefits beyond the dates set forth in Section 9.5(a) and (b), such election shall govern the distribution 80 long as said election was pursuant to the terms of the Plan at the time of the election. (d) Recalculation of Life Expectancies. For purposes of this Section, the life expectancy of a Member and a Member's spouse may, in the discretion of the Administrative Committee, be redetermined but no more frequently than annually and in accordance with such rules as may be prescribed by Treasury regulations. Notwithstanding any other provision of this Plan, the Plan shall in all respects comply with the provisions of Prop. Reg. -67- 75 Section 1.401(a)(9)-1 and the minimum incidental death benefit limits of Prop. Reg. Section 1.401(a)(9)-2, which are specifically incorporated herein by reference. 9.6 Distribution to Minors or Persons under Disability. Should any distribution hereunder become payable to a minor or to a person who, in the opinion of the Administrative Committee, is incapable of taking care of his affairs, the Administrative Committee may direct the Trustee to make such distribution in any one or combination of the following ways: (1) directly to such minor or person; (2) to the legal guardian of the person or estate of such minor or person; or (3) to a person or financial institution serving as Custodian for such Beneficiary under the Uniform Gifts to Minors Act of any state. Any distribution so made shall constitute full and complete discharge of any liability under the Plan with respect to the amount so distributed. 9.7 Community Property Interests - Interest of Spouse of Member in the Event of Divorce. In the event of a divorce between a Member and his spouse and in the event that the Divorce Decree entered by the Court having jurisdiction in the matter gives such divorced spouse a portion of the Member's vested interest in his Account, the Trustee shall, pursuant to the direction of the Administrative Committee, segregate such amount in a separate account for the benefit of such spouse. Such account shall thereafter be held and administered as a part of the Trust Fund (but such account shall only share in income allocations and valuation adjustments of the Trust Fund) until such time as the Member or his Beneficiary becomes entitled to a distribution -68- 76 hereunder. In the event the spouse is also awarded a portion of the future Deferral Contributions, and/or future Employer Matching Contributions and/or future Employer Contributions which normally would be allocated to the Members Account, the Administrative Committee, after it receives a certified copy of such Divorce Decree, shall instruct the Trustee to allocate such portion to the spouse's account. At the time the Member or his Beneficiary becomes entitled to a distribution hereunder, the amounts held by the Trustee for the spouse shall be distributed to such spouse in a lump sum. If such spouse should die prior to the time of distribution to such spouse hereunder, such amounts then held by the Trustee shall be paid over to the estate of such spouse within six (6) months after notification to the Trustee of the death of such spouse. All rights and benefits, including elections, provided to a Member in this Plan shall be subject to the rights afforded to any "alternate payee" under a "qualified domestic relations order" as those terms are defined in Section 414(p) of the Code. ARTICLE X. Top Heavy Provisions 10.1 Determination of Top Heavy Plan Status. The Plan shall be considered a Top Heavy Plan for any Plan Year in which, as of the Determination Date, the sum of the Aggregate Accounts of Key Employees under this Plan and any plan of an Aggregation Group exceeds sixty percent (60%) of the Aggregate Accounts of all Members under this Plan and any plan of an Aggregation Group. If a Member, who was a Key Employee for any prior Plan Year, is a Non- -69- 77 Key Employee for any Plan Year, such Member's Aggregate Account balance shall not be taken into account for purposes of determining whether the Plan is a Top Heavy Plan (or whether any Aggregation Group which includes the Plan is a Top Heavy Group). In addition, the Account balance of any Member who has not within the past five (5) years performed any services for the Signatory Company shall not be taken into account for purposes of determining whether the Plan is a Top Heavy Plan (or whether any Aggregation Group which includes the Plan is a Top Heavy Group). 10.2 Determination of Super Top Heavy Plan Status. The Plan shall be considered a Super Top Heavy Plan for any Plan Year in which, as of the Determination Date, the sum of the Aggregate Accounts of Key Employees under this Plan and any plan of an Aggregation Group exceeds ninety percent (90%) of the Aggregate Accounts of all Members under this Plan and any plan of an Aggregation Group. For purposes of determining if the Plan is a Super Top Heavy Plan, a Member's inclusion in the Key Employee grouping shall be determined in the manner set forth in Section 10.1. 10.3 Aggregate Accounts. A Member's Aggregate Account as of the Determination Date shall be the sum of: (a) his Account balance as of the most recent valuation date occurring within a twelve (12) month period ending on the Determination Date; (b) an adjustment for any contributions due as of the Determination Date. Such adjustment shall be the amount of any contributions actually made after the valuation date but before the Determination Date, except for the first Plan Year when such adjustment shall also reflect the amount of any contributions made after the Determination Date that are allocated as of a date in that first Plan Year; -70- 78 (c) any Plan distributions made within the Plan Year that includes the Determination Date or within the four (4) preceding Plan Years. However, in the case of distributions made after the valuation date and prior to the Determination Date, such distributions are not included as distributions for top heavy purposes to the extent that such distributions are already included in the Member's Aggregate Account balance as of the valuation date. Notwithstanding anything herein to the contrary, all distributions, including distributions made prior to January 1, 1984, will be counted, and distributions under a terminated plan which if it had not been terminated would have been required to be included in an Aggregation Group will be counted; and (d) any Employee contributions, whether voluntary or mandatory. However, amounts attributable to tax deductible qualified Employee contributions shall not be considered to be a part of the Members Aggregate Account balance. 10.4 Aggregation Group. An Aggregation Group for purposes of this article is either a Required Aggregation Group or a Permissive Aggregation Group as hereinafter determined. In determining Aggregation Groups, "Employer" means an employer as defined in Section 416 of the Code and the regulations issued thereunder. (a) Required Aggregation Group. In determining a Required Aggregation Group hereunder, each plan of the Employer in which a Key Employee is a participant, and each other plan of the Employer which enables any plan in which a Key Employee participates to meet the require-ments of Code Sections 401(a)(4) or 410, will be required to be aggregated. Such group shall be known as a Required Aggregation Group. In the case of a Required Aggregation Group, each plan in the group will be considered a Top Heavy Plan if the Required Aggregation Group is a Top Heavy Group. No plan in the Required Aggregation Group will be considered a Top Heavy Plan if the Required Aggregation Group is not a Top Heavy Group. (b) Permissive Aggregation Group. The Employer may also include any other plan not required to be included in the Required Aggregation Group, provided the resulting group, taken as a whole, would continue to satisfy the provisions of Code Sections 401(a)(4) or 410. Such group shall be known as a Permissive Aggregation Group. In the case of a Permissive Aggregation Group, only a plan that is part of the Required Aggregation Group will be -71- 79 considered a Top Heavy Plan if the Permissive Aggregation Group is a Top Heavy Group. No plan in the Permissive Aggregation Group will be considered a Top Heavy Plan if the Permissive Aggregation Group is not a Top Heavy Group. (c) Aggregation of Multiple Plans. When more than one plan is aggregated, the Aggregate Accounts (including distributions for Key Employees and all Employees) are determined separately for each plan as of each plan's Determination Date. The plans are then aggregated by adding the results of each plan as of the Determination Dates for such plans that fall within the same calendar year. 10.5 Top Heavy Plan Requirements. For any Plan Year in which the Plan is considered to be a Top Heavy Plan, the Plan shall: (a) limit the Considered Compensation maximum dollar amount pursuant to Article I, Section 1.13; (b) require minimum allocations to Non-Key Employees pursuant to Section 10.6; and (c) replace the vesting schedule in Article VII, Section 7.5(a) of this Plan with the following:
Percentage of Participating Employee's Years of Service Account that Becomes Vested ---------------- --------------------------- Less than two years . . . . . . . . . 0% Two years . . . . . . . . . . . . . . 20% Three years . . . . . . . . . . . . . 40% Four years. . . . . . . . . . . . . . 60% Five years. . . . . . . . . . . . . . 80% Six years or more . . . . . . . . . . 100%
10.6 Allocations to Non-Key Employees. For any Plan Year in which the Plan is determined to be a Top Heavy Plan, the following allocation provisions shall be operational and shall supplement Article IV, Section 4.4. -72- 80 (a) Minimum Allocations Required for Top Heavy Plan Years. Notwithstanding the foregoing, for any Top Heavy Plan Year, the sum of the Employer Contributions, Employer Matching Contributions and Deferral Contributions allocated to the Member's account of each Non-Key Employee shall be equal to at least three percent (3%) of such Non-Key Employee's Considered Compensation. However, should the sum of the Employer's contributions allocated to the Member's Account of each Key Employee for such Top Heavy Plan Year be less than three percent (3%) of each Key Employee's Considered Compensation, the sum of the Employer Contributions allocated to the Member's Account of each Non-Key Employee shall be equal to the largest percentage allocated to the Member's Account of any Key Employee. For allocation purposes, where contributions to Key Employees are less than three percent (3%) of Considered Compensation amounts contributed by Key Employees to a salary deferral plan must be included as part of such Key Employee's Considered Compensation for purposes of determining contributions made on behalf of Key Employees. (b) Extra Minimum Allocation Permitted for Top Heavy Plans other than Super Top Heavy Plans. If a Key Employee is a Member in both a defined contribution plan and a defined benefit pension plan that are both part of a Top Heavy Group (but neither of such plans is a Super Top Heavy Plan), the defined contribution and the defined benefit fractions set forth in Article V, Section 5.2 shall remain unchanged, provided the Member's Account of each Non-Key Employee who is a Member receives an extra allocation (in addition to the minimum allocation set forth above) equal to not less than one percent (1%) of such Non-Key Employee's Considered Compensation. (c) Computation of the Minimum Contribution. For purposes of the minimum allocations set forth above, the percentage allocated to the Member's Account of any Key Employee shall be equal to the ratio of the sum of the Employer Contribution, Employer Matching Contribution and Deferral Contribution allocated on behalf of such Key Employee divided by the Considered Compensation for such Key Employee. (d) Eligibility for the Minimum Contribution. For any Plan Year in which the Plan is a Top Heavy Plan, the minimum allocations set forth above shall be allocated to the Accounts of all Non-Key Employees who are Members and who are employed by the Employer on the last day of the Plan Year, including Non-Key Employees who are Members but have failed to complete a Year of Service regardless of compensation. -73- 81 (e) Alternative Methods of Complying with the Minimum Benefit Requirement. Notwithstanding anything herein to the contrary, in any Plan Year in which a Non-Key Employee is a Member in both this Plan and a defined benefit pension plan, and both such plans are Top Heavy Plans, the Employer shall not be required to provide a Non-Key Employee with both the full separate minimum defined benefit plan benefit and the full separate defined contribution plan allocations. Therefore, for Non-Key Employees who are participating in a defined benefit plan maintained by the Employer and the minimum benefits under Section 416(c)(2) of the Code are accruing to a Non-Key Employee under such Plan, the minimum allocations provided for above shall not be applicable, and no minimum contribution shall be made to the Plan on behalf of the Non-Key Employee. Alternatively, the Employer may satisfy the minimum benefit requirement of Section 416(c)(1)(E) of the Code for the Non-Key Employee by providing any combination of benefits and/or contributions that satisfy the safe harbor rules contained in Treasury Regulation Section 1.416-1(M-12). (f) Accounting. The Administrative Committee may establish a second Account for each Member to which allocations are credited for Plan Years in which the Plan is a Top Heavy Plan or a Super Top Heavy Plan. Such separate Accounts shall be credited with income allocations and earning adjustments pursuant to Article IV, Section 4.5 and 4.6. Contributions to each Member's top heavy Account shall be invested pursuant to such Member's instruction regarding the investment of his Deferral Contributions, Employer Matching Contributions (if any), Employer Contributions (if any) and his non-top heavy Account. ARTICLE XI. Other Qualified Plans 11.1 Transfers from Other Qualified Plans. The Administrative Committee may give its consent to the transfer of assets to this Plan and Trust from any other corporate qualified plan meeting the requirements of Section 401(a) of the Code, except that no such transfer shall be permitted if such assets are subject to the joint and survivor annuity requirements of Section 401(a)(11) of the Code. -74- 82 11.2 Transfers to Other Qualified Plans. The Administrative Committee may, upon written request of a Member otherwise entitled to receive a distribution of benefits under Article IX, direct the Trustee to transfer the vested amount of such Member's Account hereunder to another qualified plan meeting the requirements of Section 401(a) of the Code which is maintained by the Signatory Company or a successor employer of the Member and which makes provision for receiving such transferred assets. The assets so transferred shall be accompanied by written instructions from the Administrative Committee identifying this Plan, the other plan, the name of the Member, his one hundred percent (100%) vested interest, the actual Employer Contributions and Employer Contributions of the Signatory Company and the current value of the assets attributable thereto. Prior to the transfer of any assets, the Trustee must be satisfied that the holding of such assets is permitted in the transferee trust. Upon receipt of such written instructions, the Trustee shall effect the transfer of the Member's Account. Such transferred assets shall be credited to such Member's Account in the transferee plan and trust as a fully vested portion thereof. ARTICLE XII. Administrative Committee 12.1 Appointment, Resignation and Removal. The Board of Directors of the Corporation shall appoint an Administrative Committee of one or more persons, the members of which shall serve until resignation, death or removal. Any member of the Administrative Committee may resign at any time by mailing or delivering written notice of such resignation to the Board of -75- 83 Directors of the Corporation thirty (30) days before the effective date of such resignation. Such notice may be waived by written consent of the Corporation. Any member of the Administrative Committee may be removed by the Board of Directors of the Corporation with or without cause. Vacancies in the Administrative Committee arising by resignation, death, removal or otherwise shall be filled by such persons as may be appointed by the Board of Directors of the Corporation. Each member of the Administrative Committee shall, before entering upon the performance of his duties, qualify by signing a consent to serve as a member of the Administrative Committee under and pursuant to this Plan and by filing such consent with the Corporation. 12.2 Rights, Powers and Authority. The Administrative Committee shall have general supervision of the administration of the Plan and Trust according to the terms and provisions of this Amendment and Restatement and shall have all powers necessary to accomplish such purposes, including, but not limited to, the right, power, discretion and authority: (a) To make rules and regulations for the administration of the Plan and Trust which are not inconsistent with the terms and provisions hereof; provided, that such rules and regulations are evidenced in writing and copies thereof are delivered to the Trustee and to each Signatory Company; (b) To construe in its sole and absolute discretion in a manner that is not arbitrary or capricious all terms, provisions, conditions and limitations of the Plan and Trust; and its construction thereof, made in good faith and without discrimination in favor of or against any Member, shall be final and conclusive on all parties at interest; (c) To correct any defect or supply any omission or reconcile any inconsistency which may appear in the Plan -76- 84 and Trust, in such manner and to such extent as it shall deem expedient to carry the Plan and Trust into effect for the greatest benefit of all parties in interest, and its judgment of such expediency shall be final and conclusive on all parties at interest; (d) To select, employ and compensate from time to time such consultants, actuaries, accountants, attorneys and other agents and employees as the Administrative Committee may deem necessary or advisable for the proper and efficient administration of the Plan or Trust; and any agent or employee so selected by the Administrative Committee may be a person or firm then, theretofore, or thereafter serving any Signatory Company in any capacity; (e) To determine in its sole and absolute discretion in a manner that is not arbitrary or capricious all questions relating to the eligibility of Employees to become Members, and to determine the Years of Service and the amount of Considered Compensation upon which the benefits of each Member shall be calculated; (f) To determine all questions in its sole and absolute discretion in a manner that is not arbitrary or capricious relating to the administration of the Plan and Trust; including, but not limited to, differences of opinion which may arise between a Signatory Company, the Trustee, a Member or any of them; and, whenever it is deemed advisable, to determine such questions in order to promote the uniform and nondiscriminatory administration of the Plan and Trust for the benefit of all parties at interest; and (g) To direct and instruct the Trustee in all matters relating to the payment of Plan benefits. 12.3 Administration. Whenever, in the administration of the Plan, any action is taken by the Administrative Committee, such action shall be uniform in nature as applied to all persons similarly situated and no such action shall be taken which will discriminate in favor of Members who are officers, shareholders, partners or highly compensated. The Administrative Committee shall keep records containing all relevant data pertaining to individual Members and their rights under the Plan and is charged with the duty of seeing that Member receives the benefits to which he is -77- 85 entitled. Any Employee may consult with the Administrative Committee on any matter or matters relating to the Plan. The Administrative Committee shall supply each Member with a designation of beneficiary form which may be completed and signed by the Member pursuant to Article VI, Section 6.2 and filed with the Administrative Committee, and with any other forms it shall require in connection with the administration of the Plan. 12.4 Annual Audit of Plan. Unless otherwise relieved of the responsibility to file audited financial statements with the Department of Labor, if the Plan has one hundred (100) or more Members, it shall be the duty and responsibility of the Administrative Committee to engage, on behalf of all Members, an independent Certified Public Accountant who shall conduct an annual examination of any financial statements of the Plan and Trust and of other books and records of the Plan and Trust as the Certified Public Accountant may deem necessary to enable him to form and provide a written opinion as to whether the financial statements and related schedules required to be filed with the Department of Labor or furnished to each Member are presented fairly and in conformity with generally accepted accounting principles applied on a basis consistent with that of the preceding Plan Year. Such examination shall be conducted in accordance with generally accepted auditing standards and shall involve such tests of the books and records of the Plan and Trust as the Certified Public Accountant considers necessary. However, if the statements required to be submitted as part of the reports to the Department of Labor are prepared by a bank or similar institution or insurance -78- 86 carrier regulated and supervised and subject to periodic examination by a state or federal agency and if such statements are certified by the preparer as accurate and if such statements are, in fact, made a part of the annual report to the Department of Labor, then the examination required by the foregoing provisions of this section shall be optional with the Administrative Committee. 12.5 Chairman and Secretary. The Administrative Committee shall select a Chairman from among its members who shall preside at all meetings of the Administrative Committee and who shall be authorized to execute all documents in the name of the Administrative Committee. In addition, it shall select a Secretary who may or may not be a member of the Administrative Committee and who shall keep the minutes of the Administrative Committee's proceedings and all records, documents and data pertaining to the Administrative Committee's supervision of the administration of the Plan and Trust. 12.6 Quorum and Voting Majority. A majority of the members of the Administrative Committee shall constitute a quorum for the transaction of business, and the vote of a majority of the members present and voting at any meeting shall decide any question brought before such meeting. The Administrative Committee may decide any question by the vote, taken without a meeting, of a majority of its members. 12.7 Limitation on Voting. A member of the Administrative Committee who is also a Member hereunder shall not vote or act upon any matter relating solely to himself. -79- 87 12.8 Delegation of Rights. Powers and Duties. The Chairman or the Secretary of the Administrative Committee may execute any certificate or other written evidence of the action of the Administrative Committee. The Administrative Committee may delegate any of its rights, powers, and duties to any one or more of its member, including the power to execute any document on behalf of the Administrative Committee, in which event the Administrative Committee shall notify the Trustee, in writing, of such action and the name or names of its members so designated. The Trustee thereafter shall accept and may rely upon any document executed by such member or members as representing action by the Administrative Committee until the Administrative Committee shall file with the Trustee a written revocation of such designation. 12.9 Liability. Except to the extent that such liability is created by Section 405 of the Act, no member of the Administrative Committee shall be liable for any act or omission of any other member of the Administrative Committee, nor for any act or omission on his own part, except for his own gross negligence or willful misconduct, nor for the exercise of any power or discretion in the performance of any duty assumed by him hereunder. 12.10 Compensation and Expense. The members of the Administrative Committee shall serve without compensation for their services, but all expenses of the Administrative Committee, including premiums for bonds for each member thereof as required by Section 12.11 hereof, shall be paid by each Signatory Company in the proportion that the total amount in the Accounts of -80- 88 the Members of such Signatory Company bears to the total amount in the Accounts of the Members of all Signatory Companies; provided, however, that at the election of all of the Signatory Companies, such expenses (except the premiums for the required bonds under Section 12.11) may be paid from the Trust Fund. 12.11 Bonds. Each and every member of the Administrative Committee shall be required to give bond for the faithful performance of his duties, the amount of which shall be fixed at the beginning of each Plan Year. The amount of each bond shall be determined annually by the Board of Directors of the Corporation but shall not be less than ten percent (10%) of the amount of funds handled. Unless otherwise required by the Secretary of Labor, however, no bond shall be less than one thousand dollars ($1,000) nor more than five hundred thousand dollars ($500,000). For purposes of fixing the amount of the bond, the amount of funds handled shall be determined by the funds handled by the Administrative Committee during the preceding Plan Year, or, if the Plan had no preceding Plan Year, the amount of funds to be handled during the current Plan Year by the Administrative Committee. The bond shall provide protection to the Plan against loss by reason of acts of fraud or dishonesty on the part of the members of the Administrative Committee, directly or through connivance with others. 12.12 Indemnity. The Signatory Companies shall indemnify and save the members of the Administrative Committee, and each of them, harmless from any and all claims, losses, damages, expenses (including counsel fees approved by the Administrative Committee) and liabilities (including any amounts paid in settlement with the -81- 89 Administrative Committee's approval) or other effects and consequences arising from any act, omission or conduct in their official capacity, except when the same is judicially determined to be due to the gross negligence or willful misconduct of such member. Any amounts paid or owing under this Section 12.12 shall be considered as an expense of the Administrative Committee to be paid by the respective Signatory Companies as provided in Section 12.10 hereof. It is expressly provided, however, that any excise tax assessed against any member or members of the Administrative Committee pursuant to the provisions of Section 4975 of the Code shall not, for the purposes of this Plan and Trust, be considered an expense of the Administrative Committee to be paid by the Signatory Companies as hereinabove provided. 12.13 Reporting and Disclosure. The Administrative Committee shall file or cause to be filed with the appropriate office of the Internal Revenue Service and the Department of Labor all reports, returns, notices and other information required under the Act or Code, including, but not limited to, the plan description, summary plan description, annual reports and amendments thereto, requests for determination letters, annual reports and registration statements required by Section 6057(a) of the Code, returns and reports required by Section 6047(c) of the Code, and shall provide the Members and their Beneficiaries with such information as may be required by the Act or Code. Nothing contained in this Plan shall give any Member or Beneficiary the right to examine any data or records reflecting the compensation paid to any other Member or Beneficiary. -82- 90 12.14 Statement to Members. Within one hundred twenty (120) days after the end of each Entry Date, the Administrative Committee shall transmit to each Member or Beneficiary a written statement showing, as of such calendar quarter: (a) The balance in his Account as of the last day of the preceding calendar quarter; (b) The amount of Deferral Contributions, and Employer Matching Contributions (if any) and Employer Contributions (if any) allocated to his Account for such calendar quarter; (c) The adjustment of his Account to reflect his share of the income, valuation adjustments and expenses of the Trust for such calendar quarter; (d) The new balance in his Account; and (e) Such other information as may be required under the Code and regulations thereunder. 12.15 Signatory Company to Supply Information. To enable the Administrative Committee to perform its functions, the Signatory Company shall supply full and timely information to the Administrative Committee on all matters relating to the compensation of all Members, their Hours of Service, their Years of Service, their retirement, death, disability, or termination of employment and such other pertinent facts as the Administrative Committee may require; and the Administrative Committee shall advise the Trustee of such of the foregoing facts as may be pertinent to the Trustee's duties under the Plan. The Administrative Committee may rely upon such information as is supplied by the Signatory Company and shall have no duty or responsibility to verify such information. -83- 91 ARTICLE XIII. Trustee 13.1 Acceptance and Holding of Funds. The Trustee shall retain, manage, administer and hold the Trust Fund in accordance with the terms of this Plan. The Trustee shall receive any securities or other property that are tendered to the Trustee and that the Trustee deems acceptable. The Trustee shall have no duty to compel any Employer Matching Contribution or Employer Contribution to the Trust Fund by a Signatory Company. 13.2 Responsibility for Actions. The Trustee shall not be responsible for any acts or omissions of the Administrative Committee and may assume that the Administrative Committee is discharging its duties under this Plan until and unless it is notified to the contrary, in writing, by any person known to be a Member of the Plan or by a Signatory Company. If the Trustee receives such notice, the Trustee may exercise its own discretion and may apply to a court of competent jurisdiction for guidance with respect to the disposition of the Trust Fund or any other matter. Any powers granted to the Trustee that are to be exercised according to the direction of the Administrative Committee shall be exercised by the Trustee exactly as directed by the Administrative Committee in a written instrument signed by the person or persons authorized to sign for the Administrative Committee and delivered to the Trustee. The Trustee shall have absolutely no liability for any loss or breach of trust of any kind which may result from any action or failure of action due to its compliance with written direction from the Administrative Committee (whether or not such action is to be -84- 92 taken solely at the direction of the Administrative Committee) or for a failure on the part of the Administrative Committee to give a written direction properly or within a required period of time. The Trustee may accept as true all paper, certificates, statements and representations of fact that are presented to it without investigation or verification if the Trustee believes; them to be genuine, to have been signed by the Administrative Committee and to be the act of the Administrative Committee, and may rely solely on the written advice of the Administrative Committee on any question of fact. If at any time the Administrative Committee shall fail to give directions or instructions to the Trustee or to express its consent and approval to proposed action within a reasonable time after consent and approval is requested by the Trustee, the Trustee, although being under no obligation to do so, may act (and shall be protected in so acting) without such directions, instructions, consent or approval and may exercise its own discretion and judgment as seems appropriate and advisable under the circumstances in order to effectuate the purposes of this Plan. 13.3 Resolutions of Board of Directors. The Trustee shall be fully protected in relying upon a resolution of the Board of Directors of the Corporation, duly certified by the Corporation's secretary or assistant secretary, as to the membership of the Administrative Committee until a subsequent resolution is filed with the Trustee by the Board of Directors. 13.4 Judicial Protection. The Trustee may seek judicial protection for any action or proceeding it deems necessary to settle the accounts of the Trustee; a judicial determination or a -85- 93 declaratory judgment as to a question of construction of the Plan or Trust; or judicial instruction as; to action under this Plan or Trust. The Trustee need join only the Administrative Committee and the Signatory Company as parties defendant although the Trustee may join other parties. The district court of Harris County, Texas, shall have jurisdiction and venue in all such matters. 13.5 Dealings with Third Parties. No person dealing with the Trustee shall be required to verify the application by the Trustee for Trust purposes of any money paid or other property delivered to the Trustee. All persons dealing with the Trustee shall be entitled to rely upon the representations of the Trustee as to its authority and are released from any duty of inquiry with respect thereto. Any action of the Trustee hereunder shall be conclusively evidenced for all purposes of this Agreement by a certificate duly signed by the Trustee, and such certificate shall be conclusive evidence of the facts recited therein and shall fully protect all persons relying upon the truth thereof. Any person dealing with the Trustee in good faith shall not be required to inquire whether the Administrative Committee has instructed the Trustee or whether the Trustee is otherwise authorized to take or omit any action. Any such person shall be fully protected in acting upon any notice, resolution, instruction, direction, order, certificate, opinion, letter, telegram or other document believed by such person to be genuine, to have been signed by the Trustee and to be the act of the Trustee. 13.6 Annual Accounting by Trustee. Within forty-five (45) days after the end of each Plan Year, the Trustee shall render to -86- 94 the Administrative Committee and to each Signatory Company a written accounting of its administration of the Trust Fund showing all receipts and disbursements during the preceding Plan Year and the market value of the assets of the Trust Fund as of the end of such Plan Year. The written approval of any accounting by the Administrative Committee as to all matters and transactions stated or shown therein relating to the Trust shall be final and binding upon the Administrative Committee, each Signatory Company and upon all persons who shall then be or shall thereafter become interested in such Trust and the Trustee shall be released and discharged as to all items, matters and things set forth in such accounting as if such accounting had been settled by decree of a court of competent jurisdiction. The failure of the Administrative Committee to notify the Trustee of its disapproval of such accounting within ninety (90) days after receipt of any such accounting shall be equivalent to written approval. The Trustee shall have, nevertheless, the right to have its accounts settled by judicial proceeding. The records of the Trustee as to the Trust Fund may be inspected by the Administrative Committee or Signatory Company during normal business hours of the Trustee. 13.7 Preparation of Statement to Members. The Trustee shall provide any assistance and information requested by the Administrative Committee in conjunction with the preparation of the statements to Members in accordance with Section 12.14. 13.8 Resignation of Trustee. The Trustee may resign at any time by giving thirty (30) days' written notice to the Corporation. Such notice may be waived by written consent of the Corporation. -87- 95 Upon such resignation, the Trustee shall within a reasonable time render to the Administrative Committee and to each Signatory Company a written account of its administration of the Trust for the period following that which was covered by the last annual accounting, through the effective date of resignation. 13.9 Removal of Trustee. The Corporation may remove any Trustee at any time by giving thirty (30) days' written notice. Such notice may be waived by written consent of the Trustee being removed. In the event of removal, the Trustee shall be under the same duty to settle its accounts as provided in Section 13.6 above. 13.10 Appointment of Successor Trustee. The resignation or removal of a Trustee shall not terminate the Trust. In the event of a vacancy in the position of Trustee at any time, the Corporation shall designate and appoint a successor Trustee. Any successor Trustee, upon executing an acknowledged acceptance of the trusteeship and upon settlement of the accounts and discharge of the retiring Trustee, shall be vested, without further act on the part of anyone, with all the estates, titles, rights, powers, duties and discretions granted to the retiring Trustee. The retiring Trustee shall execute and deliver such assignments or other instruments as may be deemed advisable by the successor Trustee. 13.11 Trustee's Compensation and Expenses. The Trustee may receive such reasonable compensation as may be agreed upon from time to time; provided, however, that no person serving as Trustee who receives full-time compensation from a Signatory Company or group of Signatory Companies shall receive compensation from the -88- 96 Trust Fund except for reimbursement of expenses properly and actually paid. All brokerage costs, transfer taxes and expenses incurred in connection with the investment and reinvestment of the Trust Fund, all income taxes or other taxes of any kind whatsoever which may be levied or assessed under existing or future laws upon or with respect to the Trust Fund, and any interest which may be payable on money borrowed by the Trustee for the purposes of the Trust, shall be paid from the Trust Fund, and, until paid, shall constitute a charge upon the Trust Fund. All other administrative expenses incurred by the Trustee in the performance of its duties, including fees for legal, appraisal and accounting services rendered to the Trustee, such compensation to the Trustee as may be agreed upon in writing from time to time between the Corporation and the Trustee, all premiums for bonds required under Section 13.12 hereof and all other proper charges and disbursements of the Trustee, shall be paid by each Signatory Company in the proportion that the total amount in the Accounts Of the Members of such Signatory Company bears to the total amount in the Accounts of the Members of all Signatory Companies; provided, however, that at the election of all of the Signatory Companies, such expenses (except premiums for required bonds under Section 13.12 hereof) may be paid from the Trust Fund. It is expressly provided, however, that any excise tax assessed against any Trustee pursuant to the provisions of Section 4975 of the Code shall not, for the purposes of this Plan and Trust, be considered an expense of the Trust to be paid by the Signatory Companies as hereinabove provided. -89- 97 13.12 Bonds. Unless otherwise specifically exempted by federal statute or regulations promulgated thereunder, each and every Trustee shall be required to give bond for the faithful performance of its duties, the amount of which shall be fixed at the beginning of each Plan Year. The amount of each bond shall be determined annually by the Board of Directors of the Corporation but shall not be less than ten percent (10%) of the amount of funds handled. Unless otherwise required by the Secretary of Labor, however, no bond shall be less than one thousand dollars ($1,000) nor more than five hundred thousand dollars ($500,000). For purposes of fixing the amount of the bond, the amount of funds handled by the Trustee shall be determined by the funds handled by the Trustee during the preceding Plan Year, or, if the Plan had no preceding Plan Year, the amount of funds to be handled during the current Plan Year by the Trustee. The bond shall provide protection to the Plan against loss by reason of acts of fraud or dishonesty on the part of the Trustee, directly or through connivance with others. However, this Section 13.12 shall not apply as to any Trustee who is also a member of the Administrative Committee and has given bond as required by Article XI, Section 12.11 hereof. 13.13 Indemnity. The Signatory Companies shall indemnify and save the Trustee harmless from any and all claims, losses, damages, expenses (including counsel fees approved by the Trustee) and liabilities (including any amounts paid in settlement with the Trustee's approval) or other effects and consequences arising from any act, omission or conduct in its official capacity, except when the same is judicially determined to be due to the gross negligence -90- 98 or willful misconduct of the Trustee. Any amounts paid or owing under this Section 13.13 shall be considered as an expense of the Trustee to be paid by the respective Signatory Companies as provided in Section 13.11 hereof. It is expressly provided, however, that any excise tax assessed against the Trustee pursuant to the provisions of Section 4975 of the Code shall not, for the purposes of this Plan and Trust, be considered an expense of the Trustee to be paid by the Signatory Companies as hereinabove provided. 13.14 Appointment of Investment Manager. The Corporation, upon notice to the Trustee, may appoint an investment manager or managers over any portion or portions of the Trust Fund. Such investment manager shall be a fiduciary who is (a) registered as an investment adviser under the Investment Advisers Act of 1940, (b) a bank, as defined in that act, or (c) an insurance company qualified to perform these types of services under the laws of more than one state. Such investment manager shall acknowledge in writing its appointment as a fiduciary under this Plan. The investment manager shall, except to the extent limited in its written agreement with the Corporation, have all the powers and duties over the portion of the Trust Fund designated as under its control, as the powers and duties of a Trustee under this Plan including those set forth in Article XIV of this Plan. In accordance with Section 405(d)(1) of the Act, the Trustee shall not be liable for any acts or omissions of the investment manager or be under an obligation to invest or otherwise manage any assets of the -91- 99 Plan, which are subject to the management of such investment manager. ARTICLE XIV. Investment Powers of Trustee 14.1 Standards: Prudent Man Rule. The Trustee shall, in discharging its duties, act solely in the interest of the Members and Beneficiaries of the Plan. It must act exclusively for the purpose of providing benefits to Members and Beneficiaries and for defraying the reasonable expenses of the Plan. The Trustee shall carry out its duties with the same care, skill, prudence and diligence that a prudent man acting in a like capacity would use under conditions prevailing at that time. 14.2 Powers of Trustee. The Trustee shall have the following authority, rights, privileges and powers in addition to the authority, rights, privileges and powers elsewhere vested in the Trustee and those now or hereafter conferred by law, subject to any limitations stated in this Plan: (a) To hold, manage, control, collect, use (including the power to hold any property unproductive of income) and dispose of the Trust Fund in accordance with the terms of this instrument as if it were the fee simple owner of such Trust Fund; and (b) To keep any or all securities or other property in the name of some other person, partnership or corporation with a power of attorney for transfer attached, or in its name without disclosing its fiduciary capacity; and (c) To invest and reinvest the Trust Assets, as instructed pursuant to Section 14.4; and (d) To vote, either in person or by proxy, with or without power of substitution, any stocks, bonds or other securities held by it; to exercise any options appurtenant to any stocks, bonds or other securities for the conversion thereof into other stocks, bonds or securities; to exercise -92- 100 any rights to subscribe for additional stocks, bonds or other securities and to make any and all necessary payments thereof; and (e) To collect the principal and income of the Trust as the same may become due and payable and to give binding receipt therefor; and (f) To institute, join in, maintain, defend, compromise, submit to arbitration or settle any litigation, claim, obligation or controversy in favor of or against the Trust Fund, all in the name of the Trustee and without the joinder of any Member; and (g) From time to time transfer to a common or pooled trust fund maintained by any corporate Trustee hereunder or any affiliate of such trustee, all or such part of the Trust Fund as the Trustee may deem advisable and such part or all of the Trust Fund so transferred shall be subject to all the terms and provisions of the common or pooled trust fund which contemplate the commingling for investment purposes of such trust assets with trust assets of other employees' profit sharing and pension plans established by other public institutions and organizations. The Trustee may, from time to time, withdraw from such common or pooled trust fund all or such part of the Trust Fund as the Trustee may deem advisable; and (h) To partition any property or interest held as part of the Trust Fund and to pay or receive such money or property necessary or advisable to equalize differences; to make any distribution from the Trust Fund in cash or in kind, or both (including an undivided interest in any property) or in any other manner (including composing shares differently) and to value any property belonging to the Trust Fund, which valuation at all times shall be binding upon the Signatory Company and all Members; and (i) To loan or borrow money in any manner (including joint and several obligations) with or with out security, upon such terms as the Trustee may deem advisable regardless of the duration of the Trust created by this instrument and to mortgage (including the making of purchase money mortgages), pledge or in any other manner encumber all or any part of the Trust Fund as the Trustee may deem advisable. However, this Section shall not apply to purchases of Qualifying Employer Securities or Employer Stock; and (j) To select, employ and compensate such lawyers, brokers, banks, investment counsel or other agents or employees and to delegate to them such of the duties, rights and powers of the Trustee (including the power to vote shares -93- 101 of stock) as the Trustee deems advisable in administering the Trust Fund; and (k) To appoint any person or corporation in any state of the United States to act as ancillary Trustee with respect to any portion of the Trust Fund. Any ancillary Trustee shall have such rights, powers, duties and discretions as are delegated to it by the Trustee but shall exercise the same, subject to such limitations or further directions of the Trustee as shall be specified in the instrument evidencing its appointment. Any ancillary Trustee shall be account able solely to the Trustee and shall be entitled to reasonable compensation; and (l) To exercise all the rights, powers, options and privileges now or hereafter granted to trustees under the Texas Trust Code, except such as conflict with the terms of this instrument. So far as possible, no subsequent legislation or regulation shall limit the rights, powers or privileges granted in this Plan or in the Texas Trust Code, as it now exists. The Trustee shall have, hold, manage, control, use, invest and reinvest, disburse and dispose of the Trust Fund as if the Trustee were the owner thereof in fee simple instead of in trust, subject only to such limitations as are contained herein or such of the laws of the State of Texas as cannot be waived. The instrument shall always be construed in favor of the validity of any act or omission of the Trustee; and (m) To make a loan or loans to Members under such terms and conditions as provided in Article XV hereof; and (n) To deposit the assets of the Trust with itself or its successors as a bank and/or its bank holding affiliate. Notwithstanding any other provision of the Plan, the Trustee may cause all or any part of the monies or other assets of the Trust, without limitation as to amounts, to be commingled with the monies and assets of similar trusts created by others by causing such monies and assets to be invested as a part of any one or more of the trust funds created by the Trustee, and monies or other assets of this Trust 80 added to any of such trust funds at any time shall be subject to all of the provisions of the governing instruments of any said trust funds. 14.3 Prohibited Transactions. Except as elsewhere permitted in the Act: (a) The Trustee shall not cause the Plan to engage in a transaction if it knows, or should know, that such transaction constitutes a direct or indirect: -94- 102 (1) Sale, exchange or leasing of any property between the Plan and a party in interest; (2) Lending of money or other extension of credit between the Plan and a party in interest, except for exempt and authorized transactions; (3) Furnishing of goods, services or facilities between the Plan and a party in interest; (4) Transfer to, or use by or for the benefit of, a party in interest of any assets of the Plan; or (5) Acquisition on behalf of the Plan of any Employer Security or Employer Real Property in violation of Section 407(a) of said Act. (b) The Trustee who has authority or discretion to control or manage the assets of a Plan shall not permit the Plan to hold any Employer Security or Employer Real Property if it knows, or should know, that holding such security or real property violates Section 407(a) of said Act. (c) The Trustee shall not: (1) Deal with the assets of the Plan in its own interest or for its own account; (2) In his individual capacity or any other capacity act in any transaction involving the Plan on behalf of a party (or represent a party) whose interests are adverse to the interests of the Plan or the interests of its Members or Beneficiaries; or (3) Receive any consideration for its own personal account from any party dealing with the Plan in connection with a transaction involving the assets of the Plan. (d) A transfer of real or personal property by a party in interest to the Plan shall be treated as a sale or exchange if the property is subject to a mortgage or similar lien which the Plan assumes or if it is subject to a mortgage or similar lien which a party in interest placed on the property within the ten-year period ending on the date of the transfer. -95- 103 (e) Except as otherwise permitted in the Act: (1) The Plan shall not acquire or hold: (A) Any Employer Security which is not a Qualifying Employer Security, or (B) Any Employer Real Property or Qualifying Employer Real Property. (f) For purposes of determining the time at which a Plan acquires Employer Real Property for purposes of this section, such property shall be deemed to be acquired by the Plan on the date on which the Plan acquires the property or on the date on which the lease to the Signatory Company (or Affiliated Company) is entered into, whichever is later. (g) The Trustee shall not acquire any collectibles. For purposes for this subsection, "collectibles" means any work of art, any rug or antique, any metal or gem, any stamp or coin, any alcoholic beverage, or any other tangible personal property specified by the Secretary of Labor or Secretary of the Treasury. 14.4 Investment of Contributions. Each Member shall have the right to elect, in writing on a form provided by the Administrative Committee, to have the Deferral Contributions, Employer Matching Contributions and Employer Contributions which are allocated to his Account invested in such classes of investments as are selected by the Administrative Committee and offered for Members' investment on a uniform, nondiscriminatory basis including the following investments: Fund A - Fixed Income. Invested predominantly in fixed income investments, including but not limited to bonds, preferred stocks, debentures, insurance contracts, and notes secured by real estate mortgages. Fund B - Equity. Invested predominantly in equity investments, including but not limited to common stocks, preferred stocks and convertible debt securities. -96- 104 Fund C - Time Deposit/Money Market Account. Invested predominantly in time deposits and money market funds, including savings accounts and certificates of a financial organization (including such accounts with the Trustee or its affiliates which bear a reasonable rate of interest), United States Treasury Bills, bankers acceptances, commercial paper and notes (including variable amount notes maintained by the Trustee). Fund D - General Balanced Portfolio. Invested as a general balanced portfolio in all forms of investments, including (without limitation) equities or fixed income securities, time deposits or money market funds, in any combination and in any amount, all in the sole discretion of the Trustee. The Administrative Committee shall then instruct the Trustee to invest the Deferral Contributions and Employer Matching Contributions in the manner and proportions instructed by the Member. The Member may elect any combination of investments in these Funds in increments of twenty-five percent (25%). A Member may elect to change the investment of his present Account and/or the investment of future contributions to be made on his behalf. In the event that the Member wants to change his investment election, he must notify the Administrative Committee of such change in writing. Investment election changes must be in increments of twenty-five percent (25%) and shall be effective on the Entry Date coincident with or next following fifteen (15) days after the election change is received by the Administrative Committee. ARTICLE XV. Loans to Members 15.1 No Plan Loans. Loans to Members are not authorized under this Plan. -97- 105 ARTICLE XVI. Amendment and Termination 16.1 Amendment - General. The Corporation shall have the sole right to amend this Plan. In the event of any such amendment, each other Signatory Company shall be deemed to have consented to the amendment unless it notifies the Corporation, in writing, that it refuses to ratify the amendment. In the event that a Signatory Company refuses to ratify to any such amendment, such refusal to ratify shall constitute a withdrawal from this Plan by such Signatory Company. Upon the delivery by the Corporation to the Trustee of a certified copy of the resolution authorizing an amendment to this Plan, this Plan shall be deemed to have been so amended and all Members and other persons claiming any interest hereunder shall be bound thereby; provided, that no amendment: (a) Shall have the effect of vesting in any Signatory Company any interest in any property held subject to the terms of the Trust; or (b) Shall cause or permit any property held subject to the terms of the Trust to be diverted to purposes other than the exclusive benefit of the present or future Members and Beneficiaries; or (c) Shall substantially increase the duties or liabilities of the Trustee without its written consent; or (d) Shall (except as permitted by law) reduce benefits of a Member. For purposes of this paragraph, a plan amendment which has the effect of (1) eliminating or reducing an early retirement benefit or a retirement-type subsidy, or (2) eliminating an optional form of benefit, with respect to benefits attributable to service before the amendment, shall be treated as reducing benefits. In the case -98- 106 of a retirement-type subsidy, the preceding sentence shall apply only with respect to a Member who satisfies (either before or after the amendment) the preamendment conditions for the subsidy. In general, a retirement-type subsidy is a subsidy that continues after retirement, but does not include a qualified disability benefit, a medical benefit, a social security supplement, a death benefit (including life insurance), or a plant shutdown benefit (that does not continue after retirement age). Furthermore, no amendment to the plan shall have the effect of decreasing a Member's vested Account balance determined without regard to such amendment as of the later of the date such amendment is adopted, or becomes effective. 16.2 Amendments Necessary to Comply with Intentions of Signatory Companies. It is the intention of each Signatory Company that its Employer Matching Contributions and Employer Contributions to this Plan be deductible under the applicable provisions of the Code, that such Employer Matching Contributions and Employer Contributions not be subject to withholding under the Code or the Federal Insurance Contributions Act; and that such Employer Matching Contributions and Employer Contributions not be subject to the Fair Labor Standards Act of 1938, as amended, as part of the "regular rate". The Corporation shall make such amendments to this Plan as may be necessary to carry out these intentions. All amendments to this Plan which may be required for the purpose of realizing the intentions above stated may be made retroactively. 16.3 Termination with Respect to Signatory Company Without Establishment of a Successor Plan. A termination of this Plan by -99- 107 any Signatory Company, as provided below in this Section 16.3, without establishment of a successor plan, shall constitute a termination only with respect to such Signatory Company and such termination shall not constitute a termination of this Plan with respect to any other Signatory Company. This Plan shall terminate as to a Signatory Company upon the happening of any of the following events: (a) The approval of the Administrative Committee of a written request by such Signatory Company to terminate the Plan, effective as of the last day of the Plan Year in which such consent is issued; (b) Adjudication of the Signatory Company as a "debtor" under the Bankruptcy Act of 1978 or general assignment by the Signatory Company to or for the benefit of creditors or dissolution of the Signatory Company; and/or (c) Twenty-one (21) years following the death of the last surviving original Member living at the time this Plan was adopted by the Signatory Company; provided, however, that this Section 16.3(c) shall be effective only in the event that the Rule Against Perpetuities is applicable to the Trust established under this Plan. Upon termination of this Plan by any Signatory Company without establishment of a successor plan, the Administrative Committee and the Trust will continue until the Plan benefit of each Member has been distributed. Plan benefits shall be computed and, if necessary, the Trust Fund shall be partially or totally converted to a liquid posture to permit an efficient and equitable distribution. The Signatory Company will give written notice to the District Director of the Internal Revenue Service of the fact that the Signatory Company has terminated or partially terminated the Plan. -100- 108 Upon termination of the Plan, a Member who is partially vested in amounts in his Account attributable to Employer Matching Contributions and Employer Contributions as of such Plan termination shall immediately be fully vested in accordance with the provisions of Article VII, Section 7.7 of the Plan. Distribution on account of termination of the Plan shall be made in accordance with the distribution alternatives set forth in Article IX, Section 9.3 of the Plan. 16.4 Continuation of Plan and Trust by Successor. This Trust shall not be considered terminated upon the dissolution or liquidation of a Signatory Company in the event that a successor to the Signatory Company, by operation of law or by the acquisition of its business interests, shall elect to continue this Plan and Trust as provided in Article XVI hereof. ARTICLE XVII. Continuance of Plan by Successor 17.1 Adoption of Plan by Successor. In the event of the consolidation or merger of any Signatory Company or the sale by any Signatory Company of its assets, the resulting successor person or persons corporation may continue the Plan by direction from such person, (if not a corporation); or (if a corporation) by adopting the same by resolution of its Board of Directors and by executing a proper supplemental Trust Agreement with the Trustee. If, within ninety (90) days from the effective date of such consolidation, merger or sale of assets, such successor neither adopts this Plan as provided herein nor adopts a successor plan for the benefit of the employees of the Signatory Company, then the Plan automatically -101- 109 shall be terminated and the Trust Fund shall be distributed exclusively to the Members or their Beneficiaries in the manner provided in Article XVI, Section 16.3. ARTICLE XVIII. Merger of Plan or Transfer of Plan Assets 18.1 Transfer, Consolidation or Merger with Another Plan. In the event of (1) a merger or consolidation of the Plan with any other plan or (2) a transfer of assets and liabilities of the Plan to any other plan, each Member of the Plan will (if the Plan then terminated) be entitled to receive a benefit immediately after such merger, consolidation or transfer which is equal to or greater than the benefit he would have been entitled to receive immediately before such merger, consolidation or transfer (if the Plan had then been terminated). ARTICLE XIX. Adoption of Plan by a Signatory Company 19.1 Method of Adoption. Any Affiliated Company (or other business organization) except those with a payroll system which is incompatible with the Corporation's or otherwise, in the determination of the Administrative Committee, incapable of making the computations and accountings necessary to administer the Plan may, with the approval of the Corporation, adopt this Plan for all or any classification of its Employees, as permitted by Section 401(a) of the Code. The Plan should be adopted by the Affiliated Company in a manner which indicates the following: -102- 110 (a) The particular classification or classifications of its Employees which are to be eligible for membership in the Plan; and (b) Its agreement to be bound as a Signatory Company by all the terms, provisions, conditions and limitations of this Plan with respect to its Employees eligible for membership in this Plan; and (c) Any other information required by the Administrative Committee or the Trustee with reference to Employees or Members. This Plan may be adopted by compliance with the foregoing conditions on or before the end of any Plan Year. 19.2 Withdrawal from the Plan. Subject to the consent of the Corporation, any Signatory Company may at any time withdraw from or discontinue its participation in this Plan either by failure to consent to an amendment as provided in Article XVI, Section 16.1 or by giving written notice of such withdrawal to the Trustee and may cause to be segregated from the Trust Fund that part of the assets held in the Trust Fund for the Accounts of the Members employed by such Signatory Company at the date of such discontinuance. A withdrawal, whether or not voluntary, from this Plan by a Signatory Company shall not of itself constitute a termination of the Plan with respect to such Signatory Company. A Signatory Company which withdraws, voluntarily or involuntarily, from this Plan shall, as soon as may be practicable, adopt a comparable employee benefit -103- 111 plan and trust which shall qualify under Section 401(a) of the Code. The withdrawing Signatory Company shall then file with the Trustee a written instrument evidencing its discontinuance in this Plan and shall likewise file with the Trustee a certification by the Administrative Committee authorizing the segregation from the Trust Fund of the assets attributable to the Members employed by such Signatory Company. In the event of segregation as hereinabove provided, the Trustee shall deliver to the successor Trustee such part of the Trust Fund as may be determined by the Administrative Committee to constitute the appropriate share of the Trust Fund then held with respect to the Members employed by such Signatory Company. Such former Signatory Company will thereafter exercise with respect to such Plan and Trust all of the rights and powers which may be reserved to such Signatory Company under the terms of the written instruments providing for such segregation as aforesaid. Such segregating Signatory Company shall likewise file with the successor Trustee such other written instruments as may be necessary in order to make effective the continuance as a separate trust (as though such Signatory Company were the sole creator thereof) of the assets so segregated in accordance with the provisions of this Plan or in accordance with such other plan as may be mutually agreed upon between such Signatory Company and a successor Trustee. ARTICLE XX. Recovery of Employer Contributions 20.1 Initial Approval By Internal Revenue Service. Notwithstanding any other provision of this Plan and Trust Agreement, -104- 112 it is specifically understood that this Plan and Trust Agreement is adopted and executed by the Signatory Company upon the condition precedent that the Plan and Trust shall be approved and qualified by the Internal Revenue Service as meeting the requirements of the Code and the regulations and rulings issued thereunder with respect to salary deferral plans and trusts so that the Signatory Company will be permitted to deduct for federal income tax purposes the amount of the Deferral Contributions, Employer Contributions (if any) and its Employer Matching Contributions (if any) to the Trust under the Plan, that such Deferral Contributions, Employer Contributions (if any) and Employer Matching Contributions (if any) will not be taxable to the Members as income when made and that the Trust will be exempt from federal income tax. In the event the Internal Revenue Service shall rule that the Plan and Trust are not so approved and qualified, all Deferral Contributions, Employer Contributions (if any) and all Employer Matching Contributions (if any) made to the Trust under the Plan by a Signatory Company prior to the initial determination by the Internal Revenue Service as to the qualification of the Plan and Trust shall revert and be repaid by the Trustee to the Signatory Company. No Member, Eligible Employee, Employee or other person shall have any right to the Employer Matching Contributions (if any) or Employer Contributions (if any). However, Deferral Contributions allocated to each Member's Account shall be paid to such Member. If the Corporation shall determine, however, in consultation with the Commissioner's representatives, that such failure of qualification may be cured by steps that the Corporation deems will be in the interest of it and -105- 113 its Employees, the Corporation may elect to amend the Plan and/or Trust in order to achieve such qualification rather than cause the reversion of Deferral Contributions, Employer Contributions (if any) and Employer Matching Contributions (if any) as herein provided. 20.2 Conditioned on Deductibility. All employer contributions of any kind to this Plan are expressly made conditioned on being allowed as a deduction to the Signatory Company for federal income tax purposes. ARTICLE XXI. Miscellaneous 21.1 Plan is a Voluntary Undertaking by the Signatory Company. The adoption and maintenance of this Plan and Trust are strictly voluntary undertakings on the part of the Signatory Company and shall not be deemed to be a contract between the Signatory Company and any Employee. Nothing contained herein shall be deemed to give any Employee the right to be retained in the employment of the Signatory Company, to interfere with the rights of the Signatory Company to discharge any Employee at any time or to interfere with an Employee's right to terminate his employment at any time. 21.2 Benefit Provided Solely by the Trust Fund. All benefits payable under this Plan shall be paid or provided for solely from the Trust and the Signatory Company assumes no liability or responsibility therefor. 21.3 Nonalienation. No benefit payable or to become payable under the Plan will, except as otherwise specifically provided by law, be subject in any manner to anticipation, alienation, sale, -106- 114 transfer, assignment, pledge, encumbrance or charge, and any attempt so to anticipate, alienate, sell, transfer, assign, pledge, encumber or charge the same by a Member or Beneficiary prior to distribution as herein provided shall be absolutely and wholly void, whether such conveyance, transfer, assignment, mortgage, pledge or encumbrance be intended to take place or become effective before or after the expiration of the period herein fixed for the continuance of the said Trust estate; nor will any benefit be in any manner liable for or subject to the debts, contracts, liabilities, engagements or torts of the person entitled thereto. The Trustee shall never under any circumstances be required to recognize any conveyance, transfer, assignment, mortgage or pledge by a Member or Beneficiary hereunder of any part of the Trust estate or any interest therein and shall never be required to pay any money or thing of value thereon or therefor, to any creditor of a Member or Beneficiary or upon any debt created by a Member or Beneficiary for any cause whatsoever. For purposes of this Section 21.3, a loan made to a Member or Beneficiary pursuant to Article XV hereof shall not be treated as an assignment or alienation if such loan is secured by the Member's vested interest in the amount standing as a credit to his Account and is exempt from the tax imposed by Section 4975 (relating to tax on prohibited transactions) of the Code, as amended by the Act. This provision shall not apply to a "qualified domestic relations order" defined in Section 414(p) of the Code, and those other domestic relations orders permitted to be so treated by the Administrative Committee under the provisions of the Retirement Equity Act of 1984. The -107- 115 Administrative Committee shall establish a written procedure to determine the qualified status of domestic relations orders and to administer distributions under such qualified orders. Further, to the extent provided under a "qualified domestic relations order," a former spouse of a Participant shall be treated as the spouse of a surviving spouse for all purposes under the Plan. 21.4 Applicable Law. The provisions of this Plan shall be construed, administered and enforced according to the Code, as amended, the Act, and, to the extent applicable, the laws of the State of Texas. All contributions to and distributions from the Trust shall be deemed to take place in the State of Texas. The Trustee or Signatory Company may at any time initiate any legal action or proceeding for the settlement of the accounts of the Trustee, for the determination of any questions (including questions of construction which may arise) or for instruction, and the only necessary parties to such action or proceeding shall be the Trustee and the Signatory Company, except that any other person or persons may be included as parties defendant at the elections of the Trustee and the Signatory Company. 21.5 Construction. Unless the context clearly indicates to the contrary, the masculine gender shall include the feminine and neuter, and the singular shall include the plural. The words "hereof," "herein, n hereunder" and other similar compounds of the word "here" shall mean and refer to the entire Plan and not to any particular provision or section. 21.6 Reference to Code or Act Sections. Reference to the provisions of any particular Section of the Code or Act shall be -108- 116 deemed reference to any Section of the Code or Act which may hereafter contain the same or similar provisions. 21.7 Binding Agreement. This Plan shall be binding upon the adopting Signatory Companies, the Trustee and their respective successors and assigns, and upon the Members, their Beneficiaries and their respective heirs and legal representatives. 21.8 No Joint Venture Implied. The adoption of this Plan by any Signatory Company shall not create a joint venture or partnership relationship between it and any other party hereto, nor shall such action ever be construed as having that effect. Any rights, duties, liabilities or obligations assumed hereunder by each participating Signatory Company or imposed upon it as a result of the terms and provisions of this Plan, shall relate to and affect such Signatory Company alone. 21.9 Copies of Plan Available. Copies of this Plan and any and all amendments thereto shall be made available for inspection at all reasonable times at the principal office of the Signatory Company to all Employees, and any Employee may obtain a copy of them upon request and the payment of a reasonable reproduction fee. 21.10 Titles and Headings. The titles to and headings of paragraphs in this Plan are for convenience and reference only and, in the event of any conflict, the text of this Plan and Trust, rather than such titles or headings, shall control. 21.11 Counterparts. This Plan and all amendments thereto may be executed in any number of counterparts, each of which shall be deemed an original, and said counterparts shall constitute but one -109- 117 and the same instrument which may be sufficiently evidenced by any one counterpart. 21.12 Severability. If any provision of this Plan and Trust shall be held illegal or invalid for any reason, said illegality or invalidity shall not affect the remaining provisions hereof, but each provision shall be fully severable and the Plan and Trust shall be construed and enforced as if said illegal or invalid provision had never been inserted herein. 21.13 Agent for Service of Legal Process. The President of the Corporation is hereby designated as agent of the Plan for the service of legal process. Such designated agent may be changed from time to time by action of the Board of Directors of the Corporation in writing, and such changes shall become effective upon of the U.S. Secretary of Labor. 21.14 Withholding: Reports. Except for loans within the limits specified in Section 15.1 for which Federal income tax withholding is not required, the Administrative Committee shall withhold Federal income tax from all distributions from the Trust Fund to any Payee (or, alternatively direct the Trustee to do so, providing the Trustee with such information as may be required under Treasury Regulations), unless such Payee elects not to have -110- 118 withholding apply to a distribution. For purposes of this Section 21.14, Payee means the Member or other individual or entity entitled to a distribution under this Plan. The manner and amount of withholding will be determined pursuant to Section 3405 of the Code and the regulations thereunder. The Payee shall be timely provided with the following: notice of the Payee's right to elect not to have withholding apply to any distribution; notice of the method of making such election; a statement that the election remains effective until revoked; notice of the Payee's right to revoke such election at any time; and a statement to advise the Payee that penalties may be incurred under the estimated tax payment rules if the payments of the estimated tax are not adequate or if sufficient tax is not withheld from the distribution. Procedures with respect to such notice requirements and the Payee's election shall be determined pursuant to Section 3405 of the Code and the regulations thereunder. The Administrative Committee shall maintain records, and make returns and reports with respect to distributions and withholding thereof, if any, as required under Section 6047(e) of the Code and the regulations thereunder. In addition the Administrative Committee shall make any reports required under Sections 402(f) and 6652(j) pertaining to explanations to recipients of lump sum distributions from the Plan. 21.15 Single Plan. The Plan shall be administered, accounted for and otherwise treated as a single plan with respect to all the Signatory Companies that adopt this Plan. -111- 119 IN WITNESS WHEREOF, the Corporation and the Trustee have caused this Agreement to be executed in multiple counterpart copies on this 11th day of May, 1992, effective as set forth above. STEWART TITLE GUARANTY COMPANY By: /s/ Malcom S. Morris President TRUSTEE: FIRST INTERSTATE BANK OF TEXAS, N.A. By: /s/ John Kelley Title: Vice President -112- 120 THE STATE OF TEXAS } } COUNTY OF HARRIS } BEFORE ME, the undersigned authority, on this day personally appeared Malcolm S. Morris, known to me to be the person whose name is subscribed to the foregoing instrument, as President of STEWART TITLE GUARANTY COMPANY, and acknowledged to me that he executed the same for the purposes and consideration therein expressed, in the capacity therein stated and as the act and deed of said Corporation. GIVEN UNDER MY HAND AND SEAL OF OFFICE, this the 11th day of May, 1992. /s/ Kevin L. Carter NOTARY PUBLIC IN AND FOR THE STATE OF T E X A S THE STATE OF TEXAS } } COUNTY OF HARRIS } BEFORE ME, the undersigned authority, on this day personally appeared John Kelley, known to me to be the person whose name is subscribed to the foregoing instrument, as Vice President of FIRST INTERSTATE BANK OF TEXAS, N.A., and acknowledged to me that he executed the same for the purposes and consideration therein expressed, in the capacity therein stated and as the act and deed of said banking institution. GIVEN UNDER MY HAND AND SEAL OF OFFICE, this the 7th day of May, 1992. /s/ Renella T. Hill NOTARY PUBLIC IN AND FOR THE STATE OF T E X A S -113-
EX-4.4 4 SIXTH AMENDMENT 1 EXHIBIT 4.4 SIXTH AMENDMENT OF THE STEWART TITLE GUARANTY COMPANY SALARY DEFERRAL PLAN AND TRUST THIS SIXTH AMENDMENT of the STEWART TITLE GUARANTY COMPANY SALARY DEFERRAL PLAN AND TRUST (hereinafter sometimes called the "Plan" or "Trust") is made this the 18th day of September, 1991, to be effective as set forth below, by and between STEWART TITLE GUARANTY COMPANY (hereinafter sometimes called "Corporation") of Houston, Texas, and FIRST INTERSTATE BANK OF TEXAS, N.A. (hereinafter sometimes called "Trustee"), a national banking association of Houston, Texas. W I T N E S S E T H: WHEREAS, on December 31, 1986, the Corporation previously adopted the Plan and Trust for the sole and exclusive benefit of its employees and their beneficiaries, effective January 1, 1986; and WHEREAS, the Plan was previously amended on May 18, 1986, effective January 1, 1987; subsequently amended on February 26, 1988 effective January 1, 1986; amended on April 5, 1989 effective January 1, 1989; amended on May 30, 1989 effective May 31, 1989; and amended and restated on April 26, 1991 effective January 1, 1989; and WHEREAS, the Corporation, through the action of its Board of Directors, wishes to amend the Plan and Trust effective the date set forth below. -1- 2 NOW, THEREFORE, pursuant to the provisions of Article XVI, Section 16.1 of the Plan, the Plan is hereby amended as follows: 1. Effective January 1, 1989, Article I, Section 1.45 of the Plan shall be amended by adding to the end thereof the following: Years of Service for eligibility and vesting purposes shall also include Hours of Service performed by the Member while employed as an employee of the following companies: (a) Commonwealth Title Services of Indiana, Inc. (b) Landata, Inc. of Illinois; (c) Coldwell Banker of Fairfax, Virginia. 2. Effective October 1, 1991, Article XV of the Plan shall be amended by deleting it in its entirety and substituting therefor the following: ARTICLE XV. Loans to Members 15.1 Application and Limitation. Upon the written application of any Member (including any Member who (a) has terminated employment, (b) has not received a distribution of the entire balance in such Member's account, and (c) is a "party-in-interest" (as defined in Section 3(14) of the Act)) the Administrative Committee, in accordance with its uniform, nondiscriminatory policy, may make a loan to such Member under this Plan. The Trustee shall have no power or responsibility to administer or make interpretations under this Article XV and shall be directed by the Administrative Committee in any action it takes under this Article. If the Member is married at the time of the application, written spousal consent regarding the amount of the loan and the possible reduction of the Member's Account balance as a result of default shall be obtained within the 90-day period ending on the date the loan is made, and such consent shall meet requirements comparable to those set forth in Section 417(a)(2) of the Code. The preceding sentence shall not apply if the Administrative Committee does not have actual knowledge of such marriage or the Member reasonably demonstrates that the whereabouts of his spouse is unknown. -2- 3 The amount of a loan to any Member shall not exceed the lesser of: (a) $50,000, reduced by the excess (if any) of (i) the highest outstanding balance of loans from the Plan during the one-year period ending on the day before the date on which a loan is made, over (ii) the outstanding balance of loans from the Plan on the date on which a loan is made, or (b) one-half (1/2) of the vested amount in the Member's Account. 15.2 Purposes of Loans. Loans shall be made under the provisions of this Article XV for any legal purpose except for the purposes of purchasing securities. The authority herein granted to the Administrative Committee to approve such loans from the Trust Fund is for the purpose of above and shall not be used as a means of distributing benefits before they otherwise become due. The Administrative Committee shall review and process Members' applications for loans on a case-by-case basis in accordance with its uniform, nondiscriminatory policy. 15.3 Terms. All loans to Plan Members granted under this provision shall be treated as a segregated individual earmarked investment of each such borrowing Member's Account (as provided in Section 15.6 below) and shall be evidenced by the Member's promissory note payable to the order of the Trustee. the Administrative Committee shall have the right to make any reasonable interpretations to implement the rate of interest charged and shall have the right to modify such interpretations upon proper notice with respect to all future loans. Such loans shall bear interest at the rate determined by the Administrative Committee at the time the loan is made commensurate with the interest rate charged by persons in the business of lending money for loans that could be made under similar circumstances on either a local geographical basis or if the Administrative Committee determines it appropriate on a uniform national basis. The terms of any loan shall be prescribed by the Administrative Committee in accordance with the provisions of this Article and with notice to the Member. The specified maturity date, including extensions, -3- 4 renewals, renegotiations, or revisions, shall not be later than the earlier of (a) except for a "party- in-interest," the date of the Member's termination of employment or (b) either five (5) years measured from the date the loan is made by the Trustee, or, in the event of a home loan, as described in Section 15.4, ten (10) years measured from the date such home loan is made. Any loan granted under the terms of this Article XV shall be repaid on an installment basis, with substantially level amortization of principal and interest, not less often than quarterly. Loan repayments shall be made through payroll deduction, which shall be irrevocably authorized by the borrowing member in writing on a form prescribed by the Administrative Committee for this purpose. Payroll deduction shall be the exclusive means of repayment except for a Member with an outstanding loan balance who terminates employment and no longer receives compensation payments from a Signatory Company. Such a terminated Member shall continue to make payments in the form of personal checks or money orders. The borrowing Member's Account shall serve as security for the loan and a provision for this shall be provided in the promissory note made by the Member. Every loan applicant shall receive, at the time the loan is made, a clear statement of the charges involved in each loan transaction. this statement shall include the dollar amount and annual interest rate of the finance charge. To the extent applicable, these disclosures shall comply with the requirements of the federal Truth-in-Lending laws. Expenses incurred by the Plan in processing a Member's loan shall be charged against the borrowing Member. The Administrative Committee, in its discretion, shall promulgate a written loan procedures program to carry out the provisions of this Article and applicable tax and labor regulations. 15.4 Home Loans. A home loan is any loan used to acquire any dwelling unit (including, but not limited to, a house, apartment, condominium, or mobile home not used on a transient basis) which within a reasonable time is to be used (determined at the time the loan is made) as the principal residence of the Member. 15.5 Recourse: Prohibition Against Distributions While Loan Outstanding. There shall not be any payment out of the Trust Fund (except to the extent the Plan allows for hardship withdrawals) to any Member, Beneficiary, or other individual or entity under this Plan unless and until all unpaid loans to such Member, and interest thereon, shall have been first satisfied in full. In the event a note is not paid as and when due, the Administrative Committee (or Trustee) may, in addition and without resort to such other remedies as it -4- 5 may have under the law, give written notice to the Member sent to his last known address. If the note is not paid after a reasonable time as prescribed by the Administrative Committee in accordance with its uniform procedures, the amount standing to the credit of the member's Account in the Trust will be offset by the amount of the unpaid balance of the loan, together with the interest thereon. The Administrative Committee shall then send a written notice to the Member at his last known address which confirms the amount the Member must include in his income as a deemed distribution from the Plan. The Administrative Committee shall also be responsible for any informational reporting, withholding or other tax notice requirements incident to such deemed distribution. At the time an event requiring a distribution from the Trust Fund occurs, such as death, disability, retirement or termination of employment, such amount which had offset against the Member's Account, will now be applied to actually reduce the Member's interest in such Account. If an event normally requiring a distribution, as described above, occurs before any loan is repaid in full, the unpaid balance thereof, together with the interest thereon, shall become due and payable and the Trustee shall first satisfy the indebtedness from the amount in the member's Account before making any payments to the Member, or to such other individual or entity as determined under this Plan. 15.6 Treatment of Loan Proceeds. The Administrative Committee shall determine in accordance with its prescribed procedures the amount and extent of the investment funds in which the Member's Account is held at the time of the loan from which the loan shall be charged and debited. the borrowing Member shall be furnished a copy of these procedures. All Member loans under this Article XV shall be treated as segregated earmarked investments of such borrowing Member's Account. Each Member's Account shall be credited with repayments of interest made by such Member and received by the Trust. Each repayment of principal and interest shall be credited to the underlying investment funds in the same proportion as the Member's most recent designation of investments of his current Deferral Contributions except to the extent that the procedures prescribed by the Administrative Committee otherwise provide. 15.7 Effect on Right to Participate in Plan. Unless a Member leaves the employ of a Signatory Company or withdraws from the Plan temporarily or permanently, the existence of a loan from the Plan shall not affect such Member's good standing and right to continue to participate in the Plan. -5- 6 15.8 Minimum Loan Amounts and Other Limitations. Notwithstanding any other provision of this Plan, no Member shall be eligible for a loan under the provisions of this Article XV unless the amount such loan, considered separately without regard to or adding back to any other outstanding loans of the Member from the Plan, exceeds the minimum limit uniformly prescribed by the Administrative Committee. Under current Department of Labor regulations the limit may not be greater than $1,000.00. The Administrative Committee may also prescribe other procedures and limitations with respect to the number of loans that a Member may make from the Plan each year or have outstanding at any one time and the time, method and frequency during each year when such loan or loans shall be made and charged against such Member's Account. 3. In all other respects, the Plan shall be and remain as previously amended. IN WITNESS WHEREOF, this Sixth Amendment to the Stewart Title Guaranty Company Salary Deferral Plan and Trust has been entered into and is effective on the date set forth above. CORPORATION: STEWART TITLE GUARANTY COMPANY By: ________________________________ Malcolm Morris, President TRUSTEE: FIRST INTERSTATE BANK OF TEXAS, N.A. By: ________________________________ John J. Kelley, Vice President and Trust Officer -6- 7 THE STATE OF TEXAS } } COUNTY OF HARRIS } BEFORE ME, the undersigned authority, on this day personally appeared Malcolm Morris, known to me to be the person whose name is subscribed to the foregoing instrument as President of Stewart Title Guaranty Company, and acknowledged to me that he executed the same for the purposes and consideration therein expressed, in the capacity therein stated and as the act and deed of said corporation. GIVEN UNDER MY HAND AND SEAL OF OFFICE, this the _______ day of September, 1991. ____________________________________ NOTARY PUBLIC, STATE OF TEXAS THE STATE OF TEXAS } } COUNTY OF HARRIS } BEFORE ME, the undersigned authority, on this day personally appeared John J. Kelley, known to me to be the person whose name is subscribed to the foregoing instrument as Vice President and Trust Officer of First Interstate Bank of Texas, N.A., and acknowledged to me that he executed the same for the purposes and consideration therein expressed, in the capacity therein stated and as the act and deed of said national banking association. GIVEN UNDER MY HAND AND SEAL OF OFFICE, this the _______ day of September, 1991. ____________________________________ NOTARY PUBLIC, STATE OF TEXAS -7- EX-4.5 5 SEVENTH AMENDMENT 1 EXHIBIT 4.5 SEVENTH AMENDMENT OF THE STEWART TITLE GUARANTY COMPANY SALARY DEFERRAL PLAN AND TRUST THIS SEVENTH AMENDMENT of the STEWART TITLE GUARANTY COMPANY SALARY DEFERRAL PLAN AND TRUST (hereinafter sometimes called the "Plan" or "Trust") is made this the _____ day of _____________, 1992, to be effective as set forth below, by and between STEWART TITLE GUARANTY COMPANY (hereinafter sometimes called "Corporation") of Houston, Texas, and FIRST INTERSTATE BANK OF TEXAS, N.A. (hereinafter sometimes called "Trustee"), a national banking association of Houston, Texas. W I T N E S S E T H: WHEREAS, on December 31, 1986, the Corporation previously adopted the Plan and Trust for the sole and exclusive benefit of its employees and their beneficiaries, effective January 1, 1986; and WHEREAS, the Plan was previously amended on May 18, 1986, effective January 1, 1987; subsequently amended on February 26, 1988 effective January 1, 1986; amended on April 5, 1989 effective January 1, 1989; amended on May 30, 1989 effective May 31, 1989; amended and restated on April 26, 1991 effective January 1, 1989; and amended on September 18, 1992; and 2 WHEREAS, the Corporation, through the action of its Board of Directors, wishes to amend the Plan and Trust effective the date set forth below. NOW, THEREFORE, pursuant to the provisions of Article XVI, Section 16.1 of the Plan, the Plan is hereby amended as follows: 1. Effective July 1, 1992, Article III, Section 3.2 shall be amended by deleting the last paragraph thereof in its entirety and substituting therefor the following: The amount of the Employer Matching Contribution and Employer Contribution for each Plan Year shall be established by a resolution adopted by the Corporation's Board of Directors. Such resolution will be communicated to the Signatory Companies by the Corporation and to the Members by their respective Signatory Companies. Effective July 1, 1992, and for each Plan Year beginning thereafter, unless otherwise established or determined by the Board of Directors, the Employer Matching Contribution shall be equal to fifty percent (50%) of each Member's Deferral Contribution up to a maximum Deferral Contribution of six percent (6%) of each such Member's Considered Compensation. The Employer Matching Contribution in any Plan Year, unless otherwise established or determined by the Board of Directors, shall not exceed One Thousand Dollars ($1,000.00). 2. Effective January 1, 1992, Article XII, Section 12.6 shall be amended by adding to the end thereof the following: The Members of the Administrative Committee may participate in and hold a meeting of such committee by means of conference telephone or similar communications equipment by means of which all persons participating in the meeting can hear each other, and participation in a meeting pursuant to this provision shall constitute presence in person at such meeting. 3. In all other respects, the Plan shall continue as previously amended. -2- 3 IN WITNESS WHEREOF, this Seventh Amendment to the Stewart Title Guaranty Company Salary Deferral Plan and Trust has been entered into and is effective on the date set forth above. CORPORATION: STEWART TITLE GUARANTY COMPANY By: ________________________________ Malcolm Morris, President TRUSTEE: FIRST INTERSTATE BANK OF TEXAS, N.A. By: ________________________________ John J. Kelley, Vice President and Trust Officer -3- 4 THE STATE OF TEXAS } } COUNTY OF HARRIS } BEFORE ME, the undersigned authority, on this day personally appeared Malcolm Morris, known to me to be the person whose name is subscribed to the foregoing instrument as President of Stewart Title Guaranty Company, and acknowledged to me that he executed the same for the purposes and consideration therein expressed, in the capacity therein stated and as the act and deed of said corporation. GIVEN UNDER MY HAND AND SEAL OF OFFICE, this the _______ day of ______________, 1992. ____________________________________ NOTARY PUBLIC, STATE OF TEXAS THE STATE OF TEXAS } } COUNTY OF HARRIS } BEFORE ME, the undersigned authority, on this day personally appeared John J. Kelley, known to me to be the person whose name is subscribed to the foregoing instrument as Vice President and Trust Officer of First Interstate Bank of Texas, N.A., and acknowledged to me that he executed the same for the purposes and consideration therein expressed, in the capacity therein stated and as the act and deed of said national banking association. GIVEN UNDER MY HAND AND SEAL OF OFFICE, this the _______ day of ____________________, 1992. ____________________________________ NOTARY PUBLIC, STATE OF TEXAS -4- EX-4.6 6 EIGHTH AMENDMENT 1 EXHIBIT 4.6 EIGHTH AMENDMENT OF THE STEWART TITLE GUARANTY COMPANY SALARY DEFERRAL PLAN AND TRUST THIS EIGHTH AMENDMENT of the STEWART TITLE GUARANTY COMPANY SALARY DEFERRAL PLAN AND TRUST (hereinafter sometimes called the "Plan" or "Trust") is made this the _____ day of _____________, 1992, to be effective as of the 1st day of January, 1992, by and between STEWART TITLE GUARANTY COMPANY (hereinafter sometimes called "Corporation") of Houston, Texas, and FIRST INTERSTATE BANK OF TEXAS, N.A. (hereinafter sometimes called "Trustee"), a national banking association of Houston, Texas. W I T N E S S E T H: WHEREAS, on December 31, 1986, the Corporation previously adopted the Plan and Trust for the sole and exclusive benefit of its employees and their beneficiaries, effective January 1, 1986; and WHEREAS, the Plan was previously amended on May 18, 1986, effective January 1, 1987; subsequently amended on February 26, 1988, effective January 1, 1986; amended on April 5, 1989, effective January 1, 1989; amended on May 30, 1989, effective May 31, 1989; amended and restated on April 26, 1991, effective January 1, 1989; and amended on September 18, 1992; and amended on _______________, 1992; 2 WHEREAS, the Corporation, through the action of its Board of Directors, wishes to amend the Plan and Trust effective the date set forth below. NOW, THEREFORE, pursuant to the provisions of Article XVI, Section 16.1 of the Plan, the Plan is hereby amended as follows: Article IX, Section 9.7 of the Plan is amended by deleting the present Section 9.7 in its entirety and substituting therefor the following new Section 9.7: 9.7 Community Property Interests - Interest of Spouse of Member in the Event of Divorce. In the event of a divorce between a Member and his spouse and in the event that the Divorce Decree entered by the Court having jurisdiction in the matter gives such divorced spouse a portion of the Member's vested interest in his Account, the Trustee shall, pursuant to the direction of the Administrative Committee, segregate such amount in a separate account for the benefit of such spouse. Such account shall thereafter be held and administered as a part of the Trust Fund (but such account shall only share in income allocations and valuation adjustments of the Trust Fund). In the event the spouse is also awarded a portion of the future Deferral Contributions, and/or future Employer Matching Contributions and/or future Employer Contributions which normally would be allocated to the Member's Account, the Administrative Committee, after it receives a certified copy of such Divorce Decree, shall instruct the Trustee to allocate such portion to the spouse's account. Within the period of time specified therein after entry of the final Qualified Domestic Relations Order which complies with Section 414(p) of the -2- 3 Code (even if earlier than the "earliest retirement age" as defined in Section 414(p)(4)(B) of the Code) or, if no period of time is specified therein, at the time the Member or his Beneficiary becomes entitled to a distribution hereunder, the amounts held by the Trustee for the spouse shall be distributed to such spouse in a lump sum unless otherwise elected by such spouse. If such spouse should die prior to the time of distribution to such spouse hereunder, such amounts then held by the Trustee shall be paid over to the designated Beneficiary of such spouse or, if none has been designated, to the estate of such spouse within six (6) months after notification to the Trustee of the death of such spouse. All rights and benefits, including elections, provided to a Member in this Plan shall be subject to the rights afforded to any "alternate payee" under a "qualified domestic relations order" as those terms are defined in Section 414(p) of the Code. In all other respects, the Plan shall remain as previously amended. IN WITNESS WHEREOF, this Eighth Amendment to the Stewart Title Guaranty Company Salary Deferral Plan and Trust has been entered into and is effective on the date set forth above. CORPORATION: STEWART TITLE GUARANTY COMPANY By: ________________________________ Malcolm Morris, President -3- 4 TRUSTEE: FIRST INTERSTATE BANK OF TEXAS, N.A. By: ________________________________ John J. Kelley, Vice President and Trust Officer THE STATE OF TEXAS } } COUNTY OF HARRIS } BEFORE ME, the undersigned authority, on this day personally appeared Malcolm Morris, known to me to be the person whose name is subscribed to the foregoing instrument as President of Stewart Title Guaranty Company, and acknowledged to me that he executed the same for the purposes and consideration therein expressed, in the capacity therein stated and as the act and deed of said Corporation. GIVEN UNDER MY HAND AND SEAL OF OFFICE, this the _______ day of ______________, 1992. ____________________________________ NOTARY PUBLIC, STATE OF TEXAS THE STATE OF TEXAS } } COUNTY OF HARRIS } BEFORE ME, the undersigned authority, on this day personally appeared John J. Kelley, known to me to be the person whose name is subscribed to the foregoing instrument as Vice President and Trust Officer of First Interstate Bank of Texas, N.A., and acknowledged to me that he executed the same for the purposes and consideration therein expressed, in the capacity therein stated and as the act and deed of said national banking association. GIVEN UNDER MY HAND AND SEAL OF OFFICE, this the _______ day of ____________________, 1992. ____________________________________ NOTARY PUBLIC, STATE OF TEXAS -4- EX-4.7 7 NINTH AMENDMENT 1 EXHIBIT 4.7 NINTH AMENDMENT OF THE STEWART TITLE GUARANTY COMPANY SALARY DEFERRAL PLAN AND TRUST THIS NINTH AMENDMENT of the STEWART TITLE GUARANTY COMPANY SALARY DEFERRAL PLAN AND TRUST (hereinafter sometimes called the "Plan" or "Trust") is made this the _____ day of _____________, 1993, to be effective as set forth below, by and between STEWART TITLE GUARANTY COMPANY (hereinafter sometimes called "Corporation") of Houston, Texas, and FIRST INTERSTATE BANK OF TEXAS, N.A. (hereinafter sometimes called "Trustee"), a national banking association of Houston, Texas. W I T N E S S E T H: WHEREAS, on December 31, 1986, the Corporation previously adopted the Plan and Trust for the sole and exclusive benefit of its employees and their beneficiaries, effective January 1, 1986; and WHEREAS, the Plan was previously amended on May 18, 1986, effective January 1, 1987; subsequently amended on February 26, 1988 effective January 1, 1986; amended on April 5, 1989 effective January 1, 1989; amended on May 30, 1989 effective May 31, 1989; amended and restated on April 26, 1991 effective January 1, 1989; and amended on September 18, 1991; and amended on April 24, 1992; and 2 WHEREAS, the Corporation, through the action of its Board of Directors, wishes to amend the Plan and Trust effective the date set forth below. NOW, THEREFORE, pursuant to the provisions of Article XVI, Section 16.1 of the Plan, the Plan is hereby amended as follows: 1. Article VII, Section 7.5(a) shall be amended by deleting the first paragraph in its entirety and substituting the following: (a) Vesting Schedule. A Member whose employment is terminated for any reason other than death or retirement under Section 7.3 above or Total Permanent Disability shall be entitled to a severance benefit no later than ninety (90) days after the end of the calendar quarter in which he terminates employment equal to the vested interest attributable to Deferral Contributions, Employer Matching Contributions and Employer Contributions in such Member's Account at the end of such calendar quarter. However, in the event that the payment of his severance benefit under this section would violate Article IX, Section 9.4, then such benefit shall commence no later than sixty (60) days after the latest date determined under that section. For the purpose of this Section 7.5(a), a Member's "vested interest" shall be determined using the following schedules and shall be an amount equal to the percentage of the balance of such Member's Account attributable to Employer Matching Contributions and Employer Contributions for the number of Years of Service as of the end of the Plan Year. As provided in Section 7.1, a Member's "vested interest" in his Account attributable to Deferral Contributions shall at all times be one hundred percent (100%). 2. Article IX, Section 9.3(a) shall be amended by deleting it in its entirety and substituting the following: (a) A lump sum payment in cash or in kind or both; except that this form of payment shall not apply in cases under Article VII, Section 7.3 and 7.5 (pertaining to termination from employment for reasons other than death or Total Permanent Disability or continuation in employment beyond Normal Retirement Age) where the entire Account balance exceeds one hundred thousand dollars ($100,000.00). 3. Article IX, Section 9.3(b) shall be amended by deleting it in its entirety and substituting the following: -2- 3 (b) Distributions in the manner provided below, after having segregated the aggregate amount thereof in a special account; provided, that the monies in such special account will earn the going rate of interest paid by local banks on savings accounts placed in insured depositories at interest, or, at the option of the Member or Beneficiary (or Beneficiaries), be credited with their portion of the gains or losses of the Trust pursuant to Article IV, Sections 4.5 and 4.6; provided further that the interest or other income earned on such special account shall be paid at the end of each Plan Year. Distribution of his entire Plan benefit in substantially equal annual, quarterly or monthly installments, over any time period not exceeding his life expectancy (or the life expectancies of such Member and his designated Beneficiary); provided that the value of any such installment in cases under Article VII, Sections 7.3 and 7.5 (pertaining to termination from employment for reasons other than death or Total Permanent Disability or continuation in employment beyond Normal Retirement Age) shall (except as otherwise provided in the Plan) not exceed one hundred thousand dollars ($100,000.00) on an annual basis; provided further, that the present value of the benefits to be distributed to the Member shall exceed fifty percent (50%) of the present value of the total benefit to be distributed to the Member and his designated Beneficiary. 4. Article IX is amended by inserting immediately following the present Section 9.7, the following new Section 9.8 which is intended to incorporate into the Plan the Model Amendment from Revenue Procedure 93-12: 9.8 Incorporation of Revenue Procedure 93-12 Model Amendment. This Section 9.8 applies to distributions made on or after January 1, 1993. Notwithstanding any provision of the Plan to the contrary that would otherwise limit a distributee's election under this Section 9.8, a distributee may elect at the time and in the manner prescribed by the Administrative Committee, to have any portion of an eligible rollover distribution paid directly to an eligible retirement plan specified by the distributee in a direct rollover. a) Eligible rollover distribution: For purposes of this Section 9.8, an eligible rollover distribution -3- 4 is any distribution of all or any portion of the balance to the credit of the distributee, except that an eligible rollover distribution does not include: any distribution that is one of a series of substantially equal periodic payments (not less frequently than annually) made for the life (or life expectancy) of the distributee or the joint lives (or joint life expectancies) of the distributee and the distributee's designated beneficiary, or for a specified period of ten years or more; any distribution to the extent such distribution is required under Section 401(a)(9) of the Code; and the portion of any distribution that is not includible in gross income (determined without regard to the exclusion for net unrealized appreciation with respect to employer securities). b) Eligible retirement plan: For purposes of this Section 9.8, an eligible retirement plan is an individual retirement account described in Section 408(a) of the Code, an individual retirement annuity described in Section 408(b) of the Code, an annuity plan described in Section 403(a) of the Code, or a qualified trust described in Section 401(a) of the Code, that accepts the distributee's eligible rollover distribution. However, in the case of an eligible rollover distribution to the surviving spouse, an eligible retirement plan is an individual retirement account or individual retirement annuity. c) Distributee: For purposes of this Section 9.8, a distributee includes an employee or former employee. In addition, the employee's or former employee's surviving spouse and the employee's or former employee's spouse or former spouse who is the alternate payee under a qualified domestic relations order, as defined in Section 414(p) of the Code, are distributees with regard to the interest of the spouse or former spouse. d) Direct rollover: For purposes of this Section 9.8, a direct rollover is a payment by the Plan to the eligible retirement plan specified by the distributee. 5. Article XI, Section 11.1 shall be amended by deleting the present Section 11.1 in its entirety and substituting therefore a new Section 11.1 which shall read as follows: -4- 5 11.1 Transfers from Other Qualified Plans. With the consent of the Administrative Committee, assets compatible with the investment objectives of this Plan may be transferred to this Plan and Trust from any other qualified plan meeting the requirements of Section 401(a) of the Code which is maintained by a Signatory Company or by a predecessor employer of the Member for the benefit of the Member if he is one hundred percent (100%) vested in such assets, or from an Individual Retirement Account ("IRA") to the extent that the assets from such IRA had been previously rolled over from another qualified plan and that such rollover into the Plan is permitted under the Code. However, in the event the Member rolls over assets from his IRA to the Plan, he shall first certify to the Administrative Committee the amount he rolled over into the IRA and both the name and classification of the previous qualified plan. Assets may not be transferred directly or indirectly from any other qualified plan meeting the requirements of Section 401(a) of the Code which is not exempt from the joint and survivor annuity requirements of Section 401(a)(11) of the Code; provided, however, that if by mistake or otherwise any such benefits are transferred to the Plan on behalf of a Member from (a) a defined benefit plan, (b) a defined contribution plan subject to Section 412 of the Code, or (c) a defined contribution plan which is subject to Sections 401(a)(11) and 417 of the Code with respect to that Member, such benefits shall be subject to the requirements of Reg. Section 1.401(a)-20, Q & A-5(a) and (b), including the separate accounting requirement for such benefits. The assets so transferred shall be accompanied by written instructions from the Administrative -5- 6 Committee to the Trustee identifying the other plan, the Member's IRA (if applicable), this Plan, the name of the Member, his one hundred percent (100%) vested interest therein, the actual contributions of the Member and the Signatory Company or predecessor employer, as the case may be, and the current value of the assets attributable thereto. Such transferred assets shall be credited to such Member's Account as a fully vested portion thereof. 6. Article XIV, Section 14.4 shall be amended by deleting the present Section 14.4 in its entirety and substituting therefore a new Section 14.4 which shall read as follows: 14.4 Investment of Contributions. Each Member shall have the right to elect, in writing on a form provided by the Administrative Committee, to have the Deferral Contributions, Employer Matching Contributions and Employer Contributions which are allocated to his Account invested in such classes of investments as are selected by the Administrative Committee and offered for Members' investment on a uniform, nondiscriminatory basis including the following investments: Fund A - Fixed Income. Invested predominantly in fixed income investments, including but not limited to bonds, preferred stocks, debentures, insurance contracts, and notes secured by real estate mortgages. Fund B - Equity. Invested predominantly in equity investments, including but not limited to common stocks, preferred stocks and convertible debt securities. Fund C - Time Deposit/Money Market Account. Invested predominantly in time deposits and money market funds, including savings accounts and certificates of a financial organization (including such accounts with the Trustee or its affiliates which bear a reasonable rate of interest), United States Treasury Bills, bankers -6- 7 acceptances, commercial paper and notes (including variable amount notes maintained by the Trustee). Fund D - General Balanced Portfolio. Invested as a general balanced portfolio in all forms of investments, including (without limitation) equities or fixed income securities, time deposits or money market funds, in any combination and in any amount, all in the sole discretion of the Trustee. The Administrative Committee shall then instruct the Trustee to invest the Deferral Contributions and Employer Matching Contributions in the manner and proportions instructed by the Member. The Member may elect any combination of investments in these Funds in increments of ten percent (10%). As of any point in time, a Member may elect to change the investment of his present account and/or the investment of future contributions to be made on his behalf. In the event that the Member wants to change his investment election, he must notify the Administrative Committee of such change in writing. Investment election changes must be in increments of ten percent (10%) and shall be effective on the Entry Date coincident with or next following fifteen (15) days after the election change is received by the Administrative Committee. 7. The Plan is amended by inserting immediately following the present Article XXI, the following new Article XXII: ARTICLE XXII Merger of Stewart Title Services Savings Plan Effective January 1, 1994, (the "Plan Merger Date") the Stewart Title Services Savings Plan (the "Transferor Plan") maintained by Stewart Title Services Corporation, -7- 8 Landmark Holdings Corporation and Stewart Title Services Corporation of Colorado Springs has been merged into this Plan. On the Plan Merger Date, the participants in the Transferor Plan, commenced participation as Members of this Plan, subject to the eligibility and participation provisions of this Plan. Vesting Service (as defined) under the Transferor Plan shall be counted as Years of Service under this Plan. Each transferring participant's account balance in the Transferor Plan as of January 1, 1994 shall be transferred to this Plan and shall become such participant's initial account balance in this Plan as of January 1, 1994, ("Initial Account Balance"). Such a Member's Account in this Plan shall thereafter be credited with all such Member's Deferral Contributions, Employer Contributions and Employer Matching Contributions under this Plan plus earnings, gains and losses on the entire Account balance$ and such Melber's vest%d - ntepA@I'GBDBAD8B"Dce (as defined) under the Transferor Plan as of the Plan Merger Date shall have a vested percentage under Section 7.5 of this Plan of not less than 20 percent. The assets in each such Member"s Account from the Transferor Plan shall be maintained and merged together with all assets deriving from the commencement of such Member"s participation in the Plan. With respect to each such Member, the Member's entire account balance shall be maintained, administered and distributed in accordance with the provisions of this Plan, -8- 9 except when a distribution is due to be made to such a Member under Article VII and Article IX of this Plan, the Member shall be offered all the distribution options under Article VI of the Transferor Plan with respect to such Member"s Initial Account Balance, to the extent each such distribution option is protected and required under Section 1.411(d)-4 of the Regulations. Under this Article XXII, this Plan shall not be treated as a "transferee plan" within the meaning of Section 1.401(a)-20 Q & A-5(a) of the Regulations and the Initial Account Balance shall not be accounted for in the manner provided in Section 1.401(a)-20 Q & A-5(b) of the Regulations. 8. The amendments made in Sections 1, 2, 3, 5 and 6 above shall become effective on July 1, 1993. The amendment made in Section 7 above shall become effective on January 1, 1994. The amendment made in Section 4 above shall become effective for all distributions from the Plan on or after January 1, 1993. 9. The Plan, as amended hereby, shall continue to remain in effect. IN WITNESS WHEREOF, this Ninth Amendment to the Stewart Title Guaranty Company Salary Deferral Plan and Trust has been entered into and is effective on the date set forth above. CORPORATION: STEWART TITLE GUARANTY COMPANY By: ________________________________ Malcolm Morris, President TRUSTEE: -9- 10 FIRST INTERSTATE BANK OF TEXAS, N.A. By: ________________________________ John J. Kelley, Vice President and Trust Officer THE STATE OF TEXAS } } COUNTY OF HARRIS } BEFORE ME, the undersigned authority, on this day personally appeared Malcolm Morris, known to me to be the person whose name is subscribed to the foregoing instrument as President of Stewart Title Guaranty Company, and acknowledged to me that he executed the same for the purposes and consideration therein expressed, in the capacity therein stated and as the act and deed of said corporation. GIVEN UNDER MY HAND AND SEAL OF OFFICE, this the _______ day of ______________, 1993. ____________________________________ NOTARY PUBLIC, STATE OF TEXAS THE STATE OF TEXAS } } COUNTY OF HARRIS } BEFORE ME, the undersigned authority, on this day personally appeared John J. Kelley, known to me to be the person whose name is subscribed to the foregoing instrument as Vice President and Trust Officer of First Interstate Bank of Texas, N.A., and acknowledged to me that he executed the same for the purposes and consideration therein expressed, in the capacity therein stated and as the act and deed of said national banking association. GIVEN UNDER MY HAND AND SEAL OF OFFICE, this the _______ day of ____________________, 1993. ____________________________________ NOTARY PUBLIC, STATE OF TEXAS -10- EX-4.8 8 TENTH AMENDMENT 1 EXHIBIT 4.8 TENTH AMENDMENT OF THE STEWART TITLE GUARANTY COMPANY SALARY DEFERRAL PLAN AND TRUST THIS TENTH AMENDMENT of the STEWART TITLE GUARANTY COMPANY SALARY DEFERRAL PLAN AND TRUST (hereinafter sometimes called the "Plan" or "Trust") is made this the 8th day of August, 1994, to be effective as set forth below, by and between STEWART TITLE GUARANTY COMPANY (hereinafter sometimes called "Corporation") of Houston, Texas, and FIRST INTERSTATE BANK OF TEXAS, N.A. (hereinafter sometimes called "Trustee"), a national banking association of Houston, Texas. W I T N E S S E T H: WHEREAS, on December 31, 1986, the Corporation previously adopted the Plan and Trust for the sole and exclusive benefit of its employees and their beneficiaries, effective January 1, 1986; and WHEREAS, the Plan was previously amended on May 18, 1986, effective January 1, 1987; subsequently amended on February 26, 1988 effective January 1, 1986; amended on April 5, 1989 effective January 1, 1989; amended on May 30, 1989 effective May 31, 1989; amended and restated on April 26, 1991 effective January 1, 1989; and amended on September 18, 1991; and amended on April 24, 1992; and amended on May 27, 1992; and amended on May 20, 1993; and WHEREAS, the Corporation, through the action of its Board of Directors, wishes to amend the Plan and Trust effective the date set forth below. 2 NOW, THEREFORE, pursuant to the provisions of Article XVI, Section 16.1 of the Plan, the Plan is hereby amended as follows: Article I, Section 1.3 of the Plan is amended by deleting the present Section 1.3 in its entirety and substituting therefor the following new Section 1.3: 1.3 "Actual Contribution Percentage" means, with respect to a specified group of Eligible Employees, the average of the ratios (expressed as a percentage, rounded to the nearest one-hundredth percent) calculated separately for each Eligible Employee in such group of: (a) the sum of the following contributions paid under the Plan on behalf of each such Eligible Employee for such Plan Year (i) Employer Matching Contributions or any other matching contributions that are not Qualified Nonelective Contributions; (ii) any after-tax employee contributions (including any Excess Contributions that are recharacterized pursuant to the provisions of Article III, Section 3.3(2) of the Plan); (iii) Qualified Nonelective Contributions specifically designated for this purPose; and (iv) Deferral Contributions specifically designated for this purpose; to (b) the Eligible Employee's Considered Compensation for such Plan Year. For purposes of subsection (a)(i) above, "matching contribution shall mean (I) any Employer contribution made to the Plan on behalf of an Eligible Employee on account of an after-tax employee contribution made by such employee, (II) any Employer contribution made to the Plan on behalf of an Eligible Employee on account of -2- 3 such Employee's Deferral Contribution, and (III) any forfeitures allocated on the basis of after-tax employee contributions, Deferral Contributions or matching contributions. With respect to any Highly Compensated Eligible Employee who is eligible to participate in two or more plans of the Corporation or an Affiliated Company to which matching contributions, employee contributions or both are made, all such contributions on behalf of such Highly Compensated Eligible Employee must be aggregated for purposes of determining such Employee's Actual Contribution Percentage. For the purpose of determining the Actual Contribution Percentage of a Highly Compensated Employee who is either a 5% owner or one of the ten (10) Highly Compensated Employees paid the greatest amount of compensation (as defined under Code Section 415) during the Plan Year, and is thereby subject to the family aggregation rules of Code Section 414(q)(6), the Actual Contribution Percentage for the family group (which is treated as one Highly Compensated Employee) is the Actual Contribution Percentage determined by combining the contributions and compensation of all eligible Family Members. Except to the extent taken into account in the preceding sentence, the contributions and compensation of all Family Members are disregarded in determining the Actual Contribution Percentages for the groups of Highly Compensated Employees and Non-Highly Compensated Employees. Article I, Section 1.13 of the Plan is amended by deleting the present Section 1.13 in its entirety and substituting therefor the following new Section 1.13: -3- 4 1.13 "Considered Compensation" means, as to each Eligible Employee, all compensation otherwise paid or accrued to him after he has become eligible for the Plan by the Signatory Company during the Plan Year, including regular salary, hourly base pay, overtime pay, contractual bonuses, bonuses derived by formula, commissions, discretionary bonuses and Deferral Contributions, but excluding any Employer Contributions or any Employer Matching Contributions under this Plan and other contingent compensation. For Plan Years beginning on or after January 1, 1990 (or a later date permitted by Treasury regulations) for purposes of calculating the Actual Deferral Percentage and Actual Contribution Percentage, Considered Compensation shall be taken into account for the entire Plan Year of each Eligible Employee without regard to whether that Employee was eligible to participate in the Plan for the entire Plan Year. For purposes of Article V of the Plan, Considered Compensation shall not include the following: (a) Employer contributions to a plan of deferred compensation which are not included in the Employee's gross income for the taxable year in which contributed or employer contributions under a simplified employee pension plan to the extent such contributions are deductible by the Eligible Employee, or any distributions from a plan of deferred compensation; (b) Amounts realized from the exercise of a nonqualified stock option, or when restricted stock (or property) held by the Employee either becomes freely transferable or is no longer subject to a substantial risk of forfeiture; (c) Amounts realized from the sale, exchange or other disposition of stock acquired under a qualified stock option; and (d) Other amounts which received special tax benefits, or contributions made by the Employer (whether or not under a salary reduction agreement) towards the purchase of an annuity described in Section 403(b) of the -4- 5 Code (whether or not the amounts are actually excludable from the gross income of the Employee). Considered Compensation shall be limited to two hundred thousand dollars ($200,000) or such greater amount as may be determined pursuant to Section 416(d) or Section 401(a)(17) of the Code. In determining an Employee's Considered Compensation the rules of Section 414(q)(6) of the Code shall apply, except that the term "family" as used therein shall include only the Employee's spouse and any of the Employee's lineal descendants who have not attained age nineteen (19) on or before the last day of the Plan Year. For this purpose in applying the $200,000 limit above, a Highly Compensated Employee and members of his family will be treated as a single employee with one compensation and the $200,000 limit will be allocated among the members of the family unit in proportion to each such family member's compensation (except for the purpose of determining compensation below the Plan's integration level, if applicable). For other purposes in the Plan, the term "family member" unless otherwise indicated means with respect to the affected Member, such Member's spouse, such Member's lineal descendants and ascendants and the spouses of such lineal descendants and ascendants, as described in Section 414(q)(6)(B) of the Code. In addition to other applicable limitations set forth in the Plan, and notwithstanding any other provision of the Plan to the contrary, for Plan Years beginning on or after January 1, 1994, the annual compensation of each employee taken into account under the Plan shall not exceed the OBRA '93 annual compensation limit. The OBRA '93 annual compensation limit is $150,000, as adjusted by the -5- 6 Commissioner for increases in the cost of living in accordance with Section 401(a)(17)(B) of the Internal Revenue Code. The cost-of-living adjustment in effect for a calendar year applies to any period, not exceeding 12 months, over which compensation is determined (determination period) beginning in such calendar year. If a determination period consists of fewer than 12 months, the OBRA '93 annual compensation limit will be multiplied by a fraction, the numerator of which is the number of months in the determination period, and the denominator of which is 12. For Plan Years beginning on or after January 1, 1994, any reference in this Plan to the limitations under Section 401(a)(17) of the Code shall mean the OBRA '93 annual compensation limit set forth in this provision. If compensation for any prior determination period is taken into account in determining an employee's benefits accruing in the current Plan Year, the compensation for that prior determination period is subject to the OBRA '93 annual compensation limit in effect for that prior determination period. For this purpose, for determination periods beginning before the first day of the first Plan Year beginning on or after January 1, 1994, the OBRA '93 annual compensation limit is $150,000. Article II, Section 2.3 of the Plan is amended by deleting the present Section 2.3 in its entirety and substituting therefor the following new Section 2.3: 2.3 Participation and Service Upon Reemployment. Partici-pation in the Plan shall cease upon termination of employment with the Signatory Company. Termination of employment may result from -6- 7 retirement, death, disability, voluntary or involuntary termination of employment, unauthorized absence, or by failure to return to active employment with the Signatory Company by the date on which an Authorized Leave of Absence expires. Upon the reemployment of any person after the Effective Date who had previously been employed by the Signatory Company on or after the Effective Date, the following rules shall apply in determining his participation in the Plan: (a) If the reemployed Employee was not a Member of the Plan during his prior period of employment, he must meet the service requirements of Section 2.1 for participation in the Plan as if he were a new Employee; provided, however, that if such Employee failed to incur a Break-in-Service prior to his reemployment commencement date, the eligibility computation period for such reemployed Employee shall be the initial period beginning with the Employee's employment commencement date and not the date of his reemployment; (b) If the reemployed Employee had previously satisfied the requirements of Section 2.1 and had been a Member of the Plan prior to his termination of employment, he shall become an Eligible Employee on his reemployment commencement date; (c) If the reemployed Employee had been a Member of the Plan prior to his termination but suffered a one-year Break-in-Service prior to his resumption of employment, he shall not be eligible to reparticipate in the Plan until he has completed a Year of Service after his return, and his reparticipation shall be effective as of his reemployment commencement date. For purposes of this section, an Employee's employment commencement date shall be the date he first performs an Hour of Service for the Signatory Company and his reemployment commencement date shall be the date he first performs an Hour of Service upon reemployment with the Signatory Company. In the case of a Member who does not have any nonforfeitable right under the Plan to the portion of his Account attributable to -7- 8 employer contributions, and who has multiple consecutive one-year Breaks-in-Service, the number of Years of Service earned before the Break-in-Service will be totalled. If the number of consecutive one-year Breaks-in-Service equals or exceeds the greater of: (i) five (5), or (ii) the aggregate number of pre-Break Years of Service, all pre-Break Years of Service may be excluded in determining such Member's eligibility or reeligibility for the Plan. Article III, Section 3.3 of the Plan is amended by deleting the present Section 3.3 in its entirety and substituting therefor the following new Section 3.3: 3.3 Actual Deferral Percentage Test. If for the Plan Year the Actual Deferral Percentage for the group of Highly Compensated Eligible Employees (based upon Eligible Employee participation elections) would be more than the greater of: (a) the Actual Deferral Percentage of all other Eligible Employees multiplied by 1.25; or (b) the lesser of (i) two percentage (2%) points plus the Actual Deferral Percentage of all other Eligible Employees, or (ii) the Actual Deferral Percentage of all other Eligible Employees multiplied by two (2), such Excess Contribution shall be corrected in the manner set forth below. The calculation described in the preceding sentence is referred to herein as the "Actual Deferral Percentage Test." The Administrative Committee may, in its discretion, select either of the following methods of correction or any combination thereof in any Plan Year: (1) The Excess Contributions (and income allocable thereto) may, if such Excess Contributions are designated by the Administrative Committee as distributions of Excess Contributions (and income), be distributed to the appropriate Highly Compensated Eligible Employees after -8- 9 the close of such Plan Year and within 12 months of the close of such Plan Year. The income allocable to Excess Contributions includes both income for the Plan Year for which the Excess Contributions were made and income for the period between the end of the Plan Year and the date of distribution, and will be calculated pursuant to Treas. Reg. Section 1.401(k)-1(f)(4). If feasible, the Administrative Committee shall in its sole discretion determine and distribute the amount of Excess Contributions within two and one-half (2 1/2) months after the end of the Plan Year. The Administrative Committee may distribute Excess Contributions without regard to any notice or consent otherwise required under the Plan or Section 411(a)(11) and Section 417 of the Code limiting distributions. The amount of Excess Contributions for a Highly Compensated Eligible Employee for a Plan Year is to be determined by the following leveling method, under which the actual deferral ratio of the Highly Compensated Eligible Employee with the highest actual deferral ratio is reduced to the extent required to satisfy the Actual Deferral Percentage Test set forth above or cause such Highly Compensated Eligible Employee's actual deferral ratio to equal the ratio of the Highly Compensated Eligible Employee with the next highest actual deferral ratio. This process must be repeated until the Actual Deferral Percentage Test is satisfied for such Plan Year. Except to the extent otherwise provided in regulations, both refunded Excess Deferrals and retained Excess Deferrals under Section 3.7 of this Article are taken into account in determining a Member's Actual Deferral percentage for purposes of the above calculation. (2) The Excess Contributions may be recharacterized as after-tax employee contributions in accordance with the provisions of Treas. Reg. Section 1.401(k)-1(f)(3). Recharacterized Excess Contributions remain subject to the nonforfeitability requirements and distribution limitations that apply to Deferral Contributions. Excess Contributions will not be recharacterized with respect to a Highly Compensated Eligible Employee to the extent that the recharacterized amounts, in combination with employee contributions actually made by such Highly Compensated Eligible Employee, exceed the maximum amount of employee contributions (determined prior to the application of Code Section 401(m)(2)(A)) that such Highly Compensated Eligible Employee is permitted to make under the Plan in the absence of recharacterization; provided recharacterization as provided in the foregoing paragraph (2) will not be applied or utilized unless the Plan is first amended on a timely basis (so to be in effect on the first day of the Plan Year for which recharacterization is to be applied) to -9- 10 provide for after tax employee contributions and satisfy the other conditions set forth in Treas. Reg. Section 1.401(k)-1(f)(3)(iii). In no event shall the sum of the Deferral Contributions (including recharacterized Excess Contributions), and the Signatory Company's Employer Matching Contribution, and the Signatory Company's Employer Contribution exceed an amount equal to fifteen percent (15%) of the total Considered Compensation otherwise paid or accrued during such Plan Year of such Signatory Company plus the maximum amount deductible under the "carry-over" provisions of the Code relating to Employer Matching Contributions and Employer Contributions in previous years of less than the maximum amount permissible. In addition, in no event shall the aggregate of such Deferral Contribution, Employer Matching Contribution, Employer Contribution and the Signatory Company's contributions to all other qualified pension, profit sharing or stock bonus plans for such Plan Year exceed the amount deductible from the Signatory Company's income for such Plan Year under Section 404(a)(7) of the Code. In the event the aggregate of the Signatory Company's contributions under all plans would exceed such maximum deductible amount, the Employer Matching Contribution and Employer Contribution to the Plans shall be reduced by the amount necessary to reduce the Signatory Company's aggregate contribution under all such plans to the maximum amount deductible under said section of the Code. Deferral Contributions will be taken into account under the Actual Deferral Percentage Test for a Plan Year only if such Deferral Contributions are allocated to the Eligible Employee as of a date within such Plan Year. For this purpose, a Deferral Contribution is considered allocated as of a date within a Plan -10- 11 Year if the allocation is not contingent on participation or performance of services after such date and the Deferral Contribution is actually paid to the Trust no later than twelve (12) months after the Plan Year to which the contribution relates. In the case of a Highly Compensated Eligible Employee whose Actual Deferral Percentage is determined under the family aggregation rules of Code Section 414(q)(6), the determination of the amount of Excess Contributions shall be made as follows: (3) If the Highly Compensated Eligible Employee's Actual Deferral Percentage is determined under Article I, Section 1.4(1)(ii), then the Actual Deferral Percentage is reduced in accordance with the leveling method described in Treas. Reg. Section 1.401(k)-1(f)(2) and the Excess Contributions for the family unit are allocated among the Family Members in proportion to the elective contributions of each Family Member that have been combined to determine the Actual Deferral Percentage. (4) If the Highly Compensated Eligible Employee's Actual Deferral Percentage is determined under Article I, Section 1.4(1)(i), then the Actual Deferral Percentage is reduced in accordance with the leveling method described in Treas. Reg. Section 1.401(k)-1(f)(2) but not below the Actual Deferral Percentage of Family Members who are Non-Highly Compensated Eligible Employees without regard to family aggregation. Excess Contributions are determined by taking into account the contributions of the eligible Family Members who are Highly Compensated Eligible Employees without regard to family aggregation, and are allocated among such Family Members in proportion to each such Family Member's elective contributions. If further reduction of the Actual Deferral Percentage is required, Excess Contributions resulting from this reduction are determined by taking into account the contributions of all eligible Family Members and are allocated among such Family Members in proportion to the elective contributions of each Family Member. Paragraphs (3) and (4) above shall be administered in accordance with Treas. Reg. Section 1.401(k)-1(f)(5)(ii). Excess Contributions will be corrected in accordance with this Section 3.3 in a timely fashion to avoid disqualification of the Plan or other sanction -11- 12 imposed under the Code (including the imposition of tax under Code Section 4979). Article III, Section 3.8 of the Plan is amended by deleting the present Section 3.8 in its entirety and substituting therefor the following new Section 3.8: 3.8 Actual Contribution Percentage Test. If for the Plan Year the Actual Contribution Percentage for the group of Highly Compensated Eligible Employees would be more than the greater of: (a) the Actual Contribution Percentage for all other Eligible Employees multiplied by 1.25; or (b) the lesser of (i) the Actual Contribution Percentage for all other Eligible Employees plus two percentage (2%) points, or (ii) the Actual Contribution Percentage for all other Eligible Employees multiplied by two (2), such Excess Aggregate Contributions, shall be corrected in the manner set forth below. The calculation described in the preceding sentence is referred to herein as the "Actual Contribution Percentage Test." For this purpose, an eligible employee is any employee who is directly or indirectly eligible to receive an allocation of matching contributions or to make employee contributions and includes: an employee who would be a plan participant but for the failure to make required contributions; an employee whose right to make employee contributions or to receive matching contributions has been suspended because of an election (other than certain one-time elections) not to participate; and an employee who cannot make an employee contribution or receive a matching contribution because section 415(c)(1) or section 415(e) prevents the employee from receiving additional annual additions. In the case of an -12- 13 eligible employee who makes no employee contributions and who receives no matching contributions, the contribution ratio that is to be included in determining the ACP is zero. For a plan year, contributions will be taken into account as follows: An employee contribution is to be taken into account if it is paid to the trust during the plan year or paid to an agent of the plan and transmitted to the trust within a reasonable period after the end of the plan year. An excess contribution to a cash or deferred arrangement that is recharacterized (but only if such recharacterization is properly provided for under Section 3.3(2) above) is to be taken into account in the plan year in which the contribution would have been received in cash by the employee had the employee not elected to defer the amounts. A matching contribution taken into account for a plan year only if it is (1) made on account of the employee's elective or employee contributions for the plan year, (2) allocated to the employee's account as of a date within that year, and (3) paid to the trust by the end of the 12th month following the close of that year. Qualified matching contributions which are used to meet the requirements of section 401(k)(3)(A) are not to be taken into account for purposes of the ACP test of section 401(m). For purposes of determining whether a plan satisfies the actual contribution percentage test of section 401(m), all employee and matching contributions that are made under two or more plans that are aggregated for purposes of section 401(a)(4) and 410(b) (other than section 410(b)(2)(A)(ii)) are to be treated as made under a single plan and that if two or more plans are permissively aggregated for purposes of section 401(m), -13- 14 the aggregated plans must also satisfy section 401(a)(4) and 410(b) as though they were a single plan. The Excess Aggregate Contributions(and income allocable thereto) shall be distributed to (or, if forfeitable, in the discretion of the Administrative Committee uniformly applied, forfeited by) Highly Compensated Eligible Employees after the close of the Plan Year in which such Excess Aggregate Contributions arose and within 12 months after the close of the following Plan Year. If feasible, the Administrative Committee shall in its sole discretion determine and distribute the amount of Excess Aggregate Contributions within two and one-half (2 1/2) months after the end of the Plan Year. In the event of the complete termination of the Plan during such Plan Year, the distributions described in the preceding sentence shall be made after termination of the Plan and within the 12 months following such termination. The amount of Excess Aggregate Contributions for a Highly Compensated Eligible Employee for a Plan Year is to be determined by the following contribution leveling method, under which the actual contribution ratio of the Highly Compensated Eligible Employee with the highest actual contribution ratio is reduced to the extent required to satisfy the Actual Contribution Percentage Test set forth above or to cause such Highly Compensated Eligible Employee's actual contribution ratio to equal the ratio of the Highly Compensated Eligible Employee with the next highest actual contribution ratio. This process must be repeated until the Actual Contribution Percentage Test is satisfied for such Plan Year. In determining the amount of Excess Aggregate Contributions under the leveling method set forth above, actual contribution -14- 15 ratios must be rounded to the nearest one-hundredth percent of the Eligible Employee's Considered Compensation. In no case shall the amount of Excess Aggregate Contributions with respect to any Highly Compensated Eligible Employee exceed the amount of the after-tax employee contributions and Employer Matching Contributions on behalf of such Highly Compensated Eligible Employee for such Plan Year. Excess Aggregate Contributions for a Plan Year shall be distributed or forfeited in accordance with the provisions set forth above and shall not remain unallocated or allocated to a suspense account for allocation to one or more employees in any future year. The determination of the amount of Excess Aggregate Contributions with respect to a Plan Year shall be made after the determination and correction of Excess Deferrals under Article III, Section 3.7, and the determination and correction of Excess Contributions under Article III, Section 3.3, respectively, have been made. The distribution (or forfeiture, if applicable) of excess aggregate contributions will include the income allocable thereto. The income allocable to the excess aggregate contributions includes income for the plan year for which the excess aggregate contributions were made and may include income for the period between the end of the plan year and the date of distribution (or forfeiture). The manner in which income allocable to excess aggregate contributions is to be calculated shall be made in accordance with Treas. Reg. Section 1.401(m)-1(e)(3)(ii). In the case of a Highly Compensated Eligible Employee whose Actual Contribution Percentage is determined under the family -15- 16 aggregation rules of Code Section 414(q), the determination of the amount of Excess Aggregate Contributions shall be made as follows: (1) If the Highly Compensated Eligible Employee's Actual Contribution Percentage is determined by combining the contributions and compensation of all Family Members, then the Actual Contribution Percentage is reduced in accordance with the leveling method described in Treas. Reg. Section 1.401(m)-1(e)(2) and the Excess Aggregate Contributions for the family unit are allocated among the Family Members in proportion to the contributions of each Family Member that have been combined to determine the Actual Contribution Percentage. (2) If the Highly Compensated Eligible Employee's Actual Contribution Percentage is determined by combining the contributions of only those Family Members who are Highly Compensated Eligible Employees without regard to family aggregation, then the Actual Contribution Percentage is reduced in accordance with the leveling method described in Treas. Reg. Section 1.401(m)-1(e)(2) but not below the Actual Contribution Percentage of Family Members who are Non-Highly Compensated Eligible Employees without regard to family aggregation. Excess Aggregate Contributions are determined by taking into account the contributions of the eligible Family Members who are Highly Compensated Eligible Employees without regard to family aggregation and are allocated among such Family Members in proportion to each such Family Member's employee contributions and Employer Matching Contributions. If further reduction of the Actual Contribution Percentage is required, Excess Aggregate Contributions resulting from this reduction are determined by taking into account the contributions of all eligible Family Members and are allocated among such Family Members in proportion to the employee contributions and Employer Matching Contributions of each Family Member. Paragraphs (1) and (2) above shall be administered in accordance with Treas. Reg. Section 1.401(m)-1(e)(2)(iii). Restriction on Multiple Use of Alternative Limit. In addition to the limits prescribed by this Section 3.3 and Section 3.8 of this Article III, in the event the limits in those sections have been both satisfied under the 1.25 or (a) portion limit or otherwise in a manner that would violate Section 401(m)(9)(A) of the Code, the provisions of Section 1.401(m)-2 of the Treasury -16- 17 Regulations shall be applied and complied with in order to satisfy this requirement. This may result in corrective distributions to certain Highly Compensated Eligible Employees. Any corrections or other adjustments made to satisfy this requirement shall be determined by the Committee in accordance with the Treasury Regulations. The corrective distribution shall be first made by reducing the Actual Deferral Percentage and with respect to all Highly Compensated Eligible Employees. Article IV, Section 4.3 of the Plan is amended by deleting the present Section 4.3 in its entirety and substituting therefor the following new Section 4.3: 4.3 Allocation of Deferral Contribution to Members' Accounts. At the end of each payroll period under procedures adopted by the Administrative Committee, the Signatory Company shall transfer the Deferral Contributions to the Trustee and shall certify to the Administrative Committee the names of the Eligible Employees, the names of the Members, and the Deferral Contribution amount for each Member. The Administrative Committee shall allocate the Deferral Contribution made on behalf of a Member directly to such Member's Account and such Deferral Contribution shall be held in a separate account under such Member's Account. This separate account shall not contain any other contributions. Article V is amended by inserting immediately after the present Section 5.3(b), the following new Section 5.3(c): (c) Notwithstanding the provisions of paragraphs (a) and (b) above, to the extent that Annual Additions in excess of the permissible limit of Code Section 415 result from a reasonable error in determining total elective deferrals as defined in Treas. Reg. Section 1.415-6(b)(6), then such excess Annual Additions may be corrected by distributing elective deferrals to the -17- 18 Member to the extent necessary to eliminate the amount in excess of the Code Section 415 limitation. The amount distributed is includible in the Member's income for the taxable year in which it is distributed, and is characterized for tax and reporting purposes as a corrective distribution rather than a distribution of benefits. This paragraph (c) shall be administered in accordance with the provisions of Treas. Reg. Section 1.415-6(b)(6)(iv) and Revenue Procedure 92-93, 1992-2 C.B. 505. The Plan, as amended hereby, shall continue to remain in effect. IN WITNESS WHEREOF, this Tenth Amendment to the Stewart Title Guaranty Company Salary Deferral Plan and Trust has been entered into and is effective on the date set forth above. CORPORATION: STEWART TITLE GUARANTY COMPANY By: ______________________________ Malcolm Morris, President TRUSTEE: FIRST INTERSTATE BANK OF TEXAS, N.A. By: _________________________________ John J. Kelley, Vice President and Trust Officer -18- 19 THE STATE OF TEXAS } } COUNTY OF HARRIS } BEFORE ME, the undersigned authority, personally appeared Malcolm Morris, known to me to be the person whose name is subscribed to the foregoing instrument as President of Stewart Title Guaranty Company, and acknowledged to me that he executed the same for the purposes and consideration therein expressed, in the capacity therein stated and as the act and deed of said Corporation. GIVEN UNDER MY HAND AND SEAL OF OFFICE, this the _____ day of August, 1994. _____________________________________ NOTARY PUBLIC, STATE OF TEXAS THE STATE OF TEXAS } } COUNTY OF HARRIS } BEFORE ME, the undersigned authority, personally appeared John J. Kelley, known to me to be the person whose name is subscribed to the foregoing instrument as Vice President and Trust Officer of First Interstate Bank of Texas, N.A., and acknowledged to me that he executed the same for the purposes and consideration therein expressed, in the capacity therein stated and as the act and deed of said national banking association. GIVEN UNDER MY HAND AND SEAL OF OFFICE, this the _____ day of August, 1994. _____________________________________ NOTARY PUBLIC, STATE OF TEXAS -19- EX-4.9 9 ELEVENTH AMENDMENT 1 EXHIBIT 4.9 ELEVENTH AMENDMENT TO THE STEWART TITLE GUARANTY COMPANY SALARY DEFERRAL PLAN AND TRUST THIS ELEVENTH AMENDMENT of the Stewart Title Guaranty Company Salary Deferral Plan and Trust (hereinafter sometimes called the "Plan" and/or "Trust") is made this ________ day of ______________, 1994, to be effective as stated herein, by and between Stewart Title Guaranty Company (hereinafter sometimes called "Corporation"), of Houston, Texas and First Interstate Bank of Texas, N.A. (hereinafter sometimes called "Trustee"), a national banking association of Houston, Texas: W I T N E S S E T H: WHEREAS, on December 31, 1986, the Corporation previously adopted the Plan and Trust for the sole and exclusive benefit of its Employees and their Beneficiaries, effective January 1, 1986; and WHEREAS, the Plan was previously amended May 18, 1986, effective January 1, 1987; and amended February 26, 1988, effective January 1, 1986; and amended April 5, 1989, effective January 1, 1989; and amended May 30, 1989, effective May 31, 1989; and amended and restated May 11, 1992, effective January 1, 1989; and amended September 18, 1991; and amended April 24, 1992; and amended May 27, 1992, and amended May 20, 1993; and amended August 8, 1994; and WHEREAS, the Corporation through the action of its Board of Directors, wishes to amend the Plan effective the date set forth above so it may continue to qualify under Sections 401(a) and 2 501(a) of the Internal Revenue Code of 1986, as amended, and the Employment Retirement Income Security Act of 1974, as amended. NOW THEREFORE, pursuant to the provisions of Article XVI, Section 16.1, the Plan is hereby amended as follows: Article IX, Section 9.8 of the Plan is amended effective January 1, 1993 by inserting at the end of present Section 9.8 the following paragraph: If a distribution is one to which Sections 401(a)(11) and 417 of the Code do not apply, such distribution may commence less than thirty (30) days after the notice required under Treasury Regulation Section 1.411(a)-11(c) is given, provided that: (1) the Administrative Committee clearly informs the Member that the Member has a right to a period of at least thirty (30) days after receiving the notice to consider the decision of whether or not to elect a distribution (and, if applicable, a particular distribution option), and (2) the Member, after receiving the notice, affirmatively elects a distribution. IN WITNESS WHEREOF, the Corporation and the Trustee have caused this Eleventh Amendment to be executed on this ____ day of ______________, 1994, to be effective as of the dates stated above. STEWART TITLE GUARANTY COMPANY BY: _______________________________ Malcolm Morris, President TRUSTEE: FIRST INTERSTATE BANK OF TEXAS, N.A. ____________________________________ John J. Kelley, Vice President and Trust Officer 3 THE STATE OF TEXAS } } COUNTY OF HARRIS } BEFORE ME, the undersigned authority, on this day personally appeared Malcolm Morris, known to me to be the person whose name is subscribed to the foregoing instrument as President of Stewart Title Guaranty Company, and acknowledged to me that he executed the same for the purposes and consideration therein expressed and in the capacity therein stated, as the act and deed of said Corporation. GIVEN UNDER MY HAND AND SEAL OF OFFICE on this the _____ day of ________________, 1994. _______________________________ NOTARY PUBLIC IN AND FOR THE STATE OF T E X A S My Commission Expires:________ THE STATE OF TEXAS } } COUNTY OF HARRIS } BEFORE ME, the undersigned authority, on this day personally appeared John J. Kelley, Vice President and Trust Officer of First Interstate Bank of Texas, N.A., known to me to be the person whose name is subscribed to the foregoing instrument as Trustee, and acknowledged to me that he executed the same for the purposes and consideration therein expressed and in the capacity therein stated. GIVEN UNDER MY HAND AND SEAL OF OFFICE on this the _____ day of _______________, 1994. _______________________________ NOTARY PUBLIC IN AND FOR THE STATE OF TEXAS My Commission Expires:_________ -3- EX-4.10 10 TWELFTH AMENDMENT 1 EXHIBIT 4.10 TWELFTH AMENDMENT TO THE STEWART TITLE GUARANTY COMPANY SALARY DEFERRAL PLAN AND TRUST THIS TWELFTH AMENDMENT of the Stewart Title Guaranty Company Salary Deferral Plan and Trust (the "Plan" and/or "Trust") is made this ________ day of ______________, 1995, by and between Stewart Title Guaranty Company (the "Corporation"), of Houston, Texas and First Interstate Bank of Texas, N.A. (the "Trustee"), a national banking association of Houston, Texas: W I T N E S S E T H: WHEREAS, on December 31, 1985, the Corporation previously adopted the Plan and Trust for the sole and exclusive benefit of its Employees and their Beneficiaries, effective January 1, 1986; and WHEREAS, the Plan was previously amended May 18, 1986, effective January 1, 1987; and amended February 26, 1988, effective January 1, 1986; and amended April 5, 1989, effective January 1, 1989; and amended May 30, 1989, effective May 31, 1989; and amended and restated May 11, 1992, effective January 1, 1989; and amended September 18, 1991; and amended April 24, 1992; and amended May 27, 1992, and amended May 20, 1993; and amended August 8, 1994; and amended December 12, 1994, effective January 1, 1993; and WHEREAS, the Corporation wishes to amend the Plan and Trust effective beginning on or after October 1, 1995; 2 NOW THEREFORE, pursuant to the provisions of Article XVI, Section 16.1, the Plan and Trust is hereby amended as follows: 1. Article XIV, Section 14.2 shall be amended by deleting paragraph (d) thereunder in its entirety, and substituting therefor the following: (d) (In its sole and complete discretion): to vote, either in person or by proxy, with or without power of substitution, any stocks (including Employer Stock), bonds or other securities held by it; to respond to any tender or exchange offer and any matters related thereto with respect to any stock including Employer Stock; to exercise any options appurtenant to any stocks, bonds or other securities for the conversion thereof into other stocks, bonds or securities; to exercise any rights to subscribe for additional stocks, bonds or other securities and to make any and all necessary payments thereof; and 2. Article XIV, Section 14.2 shall be amended by adding to the end thereof a new paragraph (o) to read as follows: ; and (o) To invest in whole or in part, the assets of the Trust in Employer Stock or other Qualifying Employer Securities which satisfy the definition in Section 407(d)(5) of the Act, including the common stock, $1.00 par value, of Stewart Information Services Corporation, an Affiliated Company hereunder (the "SISCO Stock"); provided that the purchase or other acquisition of the SISCO Stock be made by the Trustee on the open market, in private transactions or by matching corresponding orders within the Trust, and not be made by issuance of such stock by SISCO or the sale of such stock as treasury stock by SISCO without the written legal opinion of the -2- 3 Corporation's counsel in or regarding compliance with applicable securities laws; provided further that the acquisition of SISCO Stock by the Trustee for the Trust is subject to the limitations provided in Section 14.4 below; (This Plan is intended to qualify as an "eligible individual account plan" as defined in Section 407(d)(3) of the Act.) 3. Article XIV, shall be amended by deleting in its entirety Section 14.4 (as modified by the Ninth Amendment to the Plan) thereunder and substituting therefor the following: 14.4 Investment of Contributions. Each Member shall have the right to elect, in writing on a form provided by the Administrative Committee, to have the Deferral Contributions, Employer Matching Con-tributions, Employer Contributions (if any) and any rollover contributions accepted into the Plan pursuant to Article XI, Section 11.1, which are allocated to his Account invested in such classes of investments as are selected from time to time by the Administrative Com-mittee and offered for investment by the Members on a uniform, nondiscriminatory basis. It is contemplated that the Administrative Committee will select and administer a variety of investment funds to make available to the Members in a manner generally intended (except as provided below) to satisfy the participant control provisions of Section 404(c) of the Act and the regulations thereunder. At the present time it is contemplated that the Administrative Committee will make the following types of investment funds available: Fixed Income Fund. Invested predominantly in fixed income invest- ments, including but not limited to bonds, preferred stocks, debentures, insurance contracts, and notes secured by real estate mortgages. -3- 4 Equity Fund. Invested predominantly in equity investments, including but not limited to common stocks, preferred stocks and convertible debt securities. Money Market Fund. Invested pre-dominantly in time deposits and money market funds, including savings accounts and certificates of a financial organ-ization (including such accounts with the Trustee or its affiliates which bear a reasonable rate of interest), United States Treasury Bills, bankers accep-tances, commercial paper and notes (including variable amount notes maintained by the Trustee). Balanced Fund. Invested as a general balanced portfolio in all forms of investments, including (without limitation) equities or fixed income securities, time deposits or money market funds, in any combination and in any amount, all in the sole discretion of the Trustee. International Securities Fund. Invested in the equity and fixed income securities of foreign companies and the securities of foreign governments. Company Stock Fund. Invested in SISCO Stock. The Administrative Committee shall have the authority to change from time to time the investment funds and types of investment funds made available hereunder and to oversee and monitor the management of these funds by the Trustee and any Investment Managers, except that with respect to the Company Stock Fund, the Administrative Committee shall be subject to the direction of the Corporation. With respect to the Company Stock Fund, the Plan and Trust shall be administered and managed in a manner to comply with the applicable regu-lations, releases, rulings and exemptions of the Securities and Exchange Commission, including to the extent applicable those under Rule 144 and Rule 16(b)(3). -4- 5 The Administrative Committee shall instruct the Trustee to invest the Deferral Contributions, Employer Matching Contributions, Employer Contributions (if any) and any rollover contributions accepted into the Plan pursuant to Article XI, Section 11.1, in the manner and proportions instructed by the Member. The Member may elect any combination of investments in his existing Account and the future contributions to be made to his Account in the funds made available under the Plan in increments of 10 percent, except that the maximum amount a Member may have invested in the Company Stock Fund under this Plan, is 20 percent of his total Account balance. Not- withstanding the limitation in the preceding sentence, the 20 percent limitation on a Member's investment in the Company Stock Fund shall not cause a divestment or liquidation of any amount of the Member's Account in the Company Stock Fund even if such amount exceeds 20 percent of his total Account balance by virtue of the greater appreciation (or lesser depreciation) in value of the Company Stock Fund as compared to the total appreciation (or depreciation) in value of the other funds in such Member's Account. Each Member shall be allowed to designate without limit that up to the maximum 20 percent of such Member's cur-rent and future Deferral Contributions and Employer Matching Contributions made to the Trust at any time or after any payroll period, may be invested in the Company Stock Fund, without regard to whether or not the pro-portion of his Account balance held in the Company Stock Fund as compared to the total Account balance exceeds the 20 percent limit. It is contemplated that at the present time, that the administration of the Company Stock Fund shall not be conducted by the Administrative Committee in a manner intended to comply with the participant control pro-visions of Section 404(c) of the Act and the regulations thereunder. The Administrative Committee shall have sole authority to deter-mine whether the administration of any or all of the investment funds shall be conducted in a manner intended to comply with the partic- -5- 6 ipant control provisions of Section 404(c) of the Act and the regulations thereunder. It is also recognized that since the SISCO Stock is not actively traded on the open market each and every business day, that the execution of any trade by the Trustee in the SISCO Stock pursuant to a direction of the Member may become subject to a delay or lag of several or more days until a corresponding order is received from another investor in order to complete the trade. The Trustee shall have the authority in its discretion to match within the Trust any corresponding buy and sell orders for the SISCO Stock currently made by Members, before filling such orders outside the Trust in the open market or otherwise. For purposes of all trades, orders and buy and sell directions of the SISCO Stock, the Trustee shall have a reasonably sufficient period of time, as the Trustee may determine in its discretion, to complete such trade or other settlement, whether by matching within the Trust or by going outside the Trust such as on the open market. As of any point in time, a Member may elect to change the investment of his present account and/or the investment of future contributions to be made on his behalf. In the event that the Member wants to change his investment election, he must notify the Administrative Committee of such change in writing. Investment election changes must be in increments of 10 percent and shall be effective on the Entry Date coincident with or next following 15 days after the election change is received by the Administrative Committee. The Administrative Committee shall have complete authority to prescribe the forms and procedures for the making of elections and directions by the Members under this Section 14.4 and to prescribe any new forms and procedures including any of the percentage limits on any of the investment funds made available under this Plan. Therefore, the Administrative Committee shall have authority to change the procedures and limits specified above in this Section 14.4. -6- 7 4. The Plan, as amended hereby, shall continue to remain in effect. IN WITNESS WHEREOF, the Corporation and the Trustee have caused this Twelfth Amendment to be executed. STEWART TITLE GUARANTY COMPANY _________________, 1995 BY: _______________________________ Malcolm Morris, President TRUSTEE: FIRST INTERSTATE BANK OF TEXAS, N.A. _________________, 1995 BY:_________________________________ John J. Kelley, Vice President and Trust Officer THE STATE OF TEXAS } } COUNTY OF HARRIS } BEFORE ME, the undersigned authority, on this day personally appeared Malcolm Morris, known to me to be the person whose name is subscribed to the foregoing instrument as President of Stewart Title Guaranty Company, and acknowledged to me that he executed the same for the purposes and consideration therein expressed and in the capacity therein stated, as the act and deed of said Corporation. GIVEN UNDER MY HAND AND SEAL OF OFFICE on this the _____ day of ________________, 1995. _______________________________ NOTARY PUBLIC IN AND FOR THE STATE OF T E X A S -7- 8 My Commission Expires:________ THE STATE OF TEXAS } } COUNTY OF HARRIS } BEFORE ME, the undersigned authority, on this day personally appeared John J. Kelley, Vice President and Trust Officer of First Interstate Bank of Texas, N.A., known to me to be the person whose name is subscribed to the foregoing instrument as Trustee, and acknowledged to me that he executed the same for the purposes and consideration therein expressed and in the capacity therein stated. GIVEN UNDER MY HAND AND SEAL OF OFFICE on this the _____ day of _______________, 1995. _______________________________ NOTARY PUBLIC IN AND FOR THE STATE OF TEXAS My Commission Expires:_________ -8- EX-5.1 11 OPINION OF CHAMBERLAIN HRDLICKA 1 EXHIBIT 5.1 [CHAMBERLAIN, HRDLICKA, WHITE, WILLIAMS & MARTIN LETTERHEAD] September 11, 1995 Stewart Information Services Corporation 1980 Post Oak Boulevard Houston, Texas 77056 Gentlemen: We have acted as your counsel in the preparation and filing of a Registration Statement on Form S-8 under the Securities Act of 1933, as amended, relating to the registration of (i) participa-tions in the Stewart Title Guaranty Company Salary Deferral Plan and Trust (the "Plan") and (ii) shares of Common Stock of Stewart Information Securities Corporation (the "Company"), both of which may be offered under and pursuant to the Plan. You have requested that we furnish you this legal opinion concerning certain matters about the Company, the Plan and the securities being registered. In connection with this opinion, we have examined originals, or copies certified or otherwise identified to our satisfaction, of such documents, corporate records, and other instruments and have made such other and further investigations as we have deemed necessary to enable us to express the opinions hereinafter set forth. Based upon the foregoing, we are of the opinion that: 1. The Company was duly and validly organized and is validly existing in good standing as a corporation under the laws of the State of Delaware. 2. The Plan constitutes a valid and legally binding agreement of Stewart Title Guaranty Company conferring valid, legal interests in the Plan in eligible employees participating therein to the extent and upon the terms and conditions described therein, and when issued pursuant to the terms and conditions of the Plan, such interests will be legally issued, fully paid and nonassessable. 2 Stewart Information Services Corporation September 11, 1995 Page 2 The foregoing opinion concerning the legality, validity, binding nature and enforceability of the Plan, is subject to the general principles of equity (regardless of whether such question is considered in a proceeding in equity or at law), and to applicable bankruptcy, insolvency, moratorium, fraudulent or preferential conveyance and other similar laws affecting the enforcement of creditors' rights. This opinion is solely for your benefit, and may not be relied on by any person other than you and your counsel. This opinion is rendered as of the date hereof and we undertake no, and hereby disclaim any, obligation to advise you of any changes in or new developments which might affect any matters or opinions set forth herein. We hereby consent to the filing of this opinion as an Exhibit to the Registration Statement on Form S-8. Very truly yours, CHAMBERLAIN, HRDLICKA, WHITE WILLIAMS & MARTIN /s/ Stephen M. Mason EX-23.1 12 CONSENTS OF INDEPENDENT ACCOUNTANTS 1 EXHIBIT 23.1 The Board of Directors Stewart Information Services Corporation We consent to the use of our report incorporated herein by reference and to the reference to our firm under the heading "Interests of Named Experts and Counsel" in the Registration Statement. /s/ KPMG Peat Marwick LLP Houston, Texas September 8, 1995 2 CONSENT OF INDEPENDENT ACCOUNTANTS We hereby consent to the incorporation by reference in this Registration Statement on Form S-8 of Stewart Information Services Corporation of our report dated January 20, 1995 on the consolidated financial statements of Stewart Title & Trust of Phoenix, Inc. appearing in the Annual Report on Form 10-K for the year ended December 31, 1994. We also consent to the reference to us under the heading "Interests of Named Experts and Counsel" appearing in such Registration Statement. /s/ Price Waterhouse LLP PRICE WATERHOUSE LLP Phoenix, Arizona September 7, 1995 3 The Board of Directors Stewart Information Services Corporation We consent to the reference to our firm under the caption "Interests of Named Experts and Counsel" in the Registration Statement (Form S-8) pertaining to the 1995 amendment of the Stewart Title Guaranty Company Salary Deferral Plan (401-K) and to the incorporation by reference therein of our reports dated January 19, 1993 with respect to the financial statements of Stewart Title of Central California, California, Fresno County, Modesto and Monterey County consolidated in Stewart Information Services Corporation's Annual Report (Form 10K) for the year ended December 31, 1994 filed with Securities and Exchange Commission. /s/ Perry-Smith & Co. PERRY-SMITH & Co. Certified Public Accountants Sacramento, California 4 The Board of Directors Stewart Information Services Corporation We consent to the reference to our firm under the caption "Interests of Names Experts and Counsel" in the Registration Statement (Form S-8) and related Prospectus pertaining to the 1995 amendment of the Stewart Title Guaranty Company Salary Deferral Plan (401-K) and to the incorporation by reference therein of our report dated January 20, 1995 with respect to the financial statements of Stewart Title (not presented separately therein) included in Stewart Information Services Corporation's Annual Report (Form 10-K) for the year ended December 31, 1994, filed with the Securities and Exchange Commission. /s/ ERNST & YOUNG ERNST & YOUNG Los Angeles, California September 8, 1995 5 The Board of Directors Stewart Information Services Corporation We consent to the use of our reports incorporated herein by reference and to the reference to our firm under the heading "Interests of Named Experts and Counsel" in the Registration Statement. /s/ Doshier, Pickens, & Francis, P.C. DOSHIER, PICKENS, & FRANCIS, P.C. Amarillo, Texas 6 The Board of Directors Stewart Information Services Corporation I consent to the use of my reports incorporated herein by reference and to the reference to me under the heading "Interests of Named Experts and Counsel" in the Registration Statement. /s/ Jim S. Walker JIM S. WALKER Beaumont, Texas 7 The Board of Directors Stewart Information Services Corporation We consent to the use of our reports incorporated herein by reference and to the reference to our firm under the heading "Interests of Named Experts and Counsel" in the Registration Statement. /s/ Denton Wolter & Company, P.C. DENTON WOLTER & COMPANY, P.C. Dallas, Texas 8 The Board of Directors Stewart Information Services Corporation We consent to the use of our reports incorporated herein by reference and to the reference to our firm under the heading "Interests of Named Experts and Counsel" in the Registration Statement. /s/ Fancher and Company FANCHER AND COMPANY Corpus Christi, Texas 9 The Board of Directors Stewart Information Services Corporation I consent to the use of my report incorporated herein by reference and to the reference to me under the heading "Interests of Named Experts and Counsel" in the Registration Statement. /s/ M. TIMOTHY O'ROARK M. TIMOTHY O'ROARK El Paso, Texas 10 The Board of Directors Stewart Information Services Corporation We consent to the reference to our firm under the caption "Interests of Named Experts and Counsel" in the Registration Statement (Form S-8) and related Prospectus pertaining to the 1995 amendment of the Stewart Title Guaranty Company Salary Deferral Plan (401-K) and to the incorporation by reference of our reports relating to the financial statements of Stewart Title (not presented separately therein) included in Stewart Information Services Corporation's Annual Report (Form 10-K) for the year ended December 31, 1994, filed with the Securities and Exchange Commission. /s/ GRANT BENNETT ACCOUNTANTS GRANT BENNETT ACCOUNTANTS A PROFESSIONAL CORPORATION Certified Public Accountants Sacramento, California 11 The Board of Directors Stewart Information Services Corporation We consent to the use of our reports incorporated herein by reference and to the reference to our firm under the heading "Interests of Named Experts and Counsel" in the Registration Statement. /s/ McGee, Haza & Co. McGEE, HAZA & CO. Dallas, Texas 12 The Board of Directors Stewart Information Services Corporation We consent to the use of our reports incorporated herein by reference and to the reference to our firm under the heading "Interests of Named Experts and Counsel" in the Registration Statement. /s/ Aaronson, White & Company AARONSON, WHITE & COMPANY Houston, Texas 13 The Board of Directors Stewart Information Services Corporation We consent to the use of our reports incorporated herein by reference and to the reference to our firm under the heading "Interests of Named Experts and Counsel" in the Registration Statement. /s/ Edgar, Kiker & Cross, LLP EDGAR, KIKER & CROSS, LLP Beaumont, Texas 14 The Board of Directors Stewart Information Services Corporation I consent to the use of my reports incorporated herein by reference and to the reference to me under the heading "Interests of Named Experts and Counsel" in the Registration Statement. /s/ Ginny Sanders May GINNY SANDERS MAY Lake Jackson, Texas