NATIONAL LIFE GROUP PENSION PLAN FOR EMPLOYEES

Benefits under the plan are primarily determined with reference to a participant's pay (e.g. final-average-pay formula).

A cash balance formula in a defined benefit plan that expresses the accrued benefit in terms more common to a defined contribution plan such as a hypothetical account balance or single sum amount (includes personal account plan pension equity plan life cycle plan and cash account plan).

Plan sponsor(s) is (are) a member(s) of a controlled group (Code sections 414(b) (c) or (m)).