§ 529A vs. § ABLE Act529 Statute Beneficiary Limit(1) per beneficiaryNone Annual Contribution Limit$14,000 per beneficiary None Maximum Account Balance State limit for Section 529 accountsMD $350,000 Income LimitationsSocial Security Income eligibility limitNone Beneficiary Change Siblings and step-siblings Blood or Marriage CertificationYES. Signed by a doctorNO Distribution FrequencyFrequentLess Frequent Recapture (Back to the state) Medicaid recapture requirementNO ReportingABLE Reporting requirementMSRB Reporting of AccountYESNO Monthly ReportMonthly electronic reportNO

§ 529A vs. § 529 (cont.) 2 ABLE Act529 Statute Yearly EligibilityYESNO Home State RequirementYES or contracting state. NO ExpensesQualified DisabilityQualified Tuition Tax Penalty on Non-Qualified Expenses 10% Exceptions: Death Contribution growth is returned to the account before the federal tax filing deadline. 10% Exception: Death Disability preventing beneficiary from attending college Verification of Qualified Expenses TBDTaxpayer

Qualified Expenses 3 Dictated by IRS Publication 970 Generally: Tuition Books and Supplies (as required by the university) Room and Board (student must be enrolled at least half-time) Expenses of a special-needs beneficiary necessary for enrollment at an eligible institution Education Housing Assistive technology and personal support services Transportation Employment training and support Health Prevention and wellness Financial management and administrative services Legal fees Expenses for oversight and monitoring Funeral and burial expenses Other expenses approved by the Treasury Secretary 529 PlansABLE Accounts

ABLE ACT(cont.) Considerations for locating ABLE with CSPM: Board Currently 10 people/ ABLE would add 10 more How would the Board address the diverse issues governing both plans? Staffing and funding CSPM is funded by the program fees generated from the Plans Start up costs for ABLE? Who would fund them? Who would take on the administrative costs to add additional staff ? Contractual Obligations T. Rowe Price Program manager – would they be willing to amend their contract? Future RFP in 2016 What role should Community Development Financial Institutions play? Verification of Disability Who will do it? Who will take on the administrative burden? Medical Information Privacy Issue Increase administrative costs 4