APPENDICES 
APPENDICES 

A) BY-LAWS 

B) INVESTMENT GUIDELINES 

C) 2002 MEMORANDUM OF UNDERSTANDING 

D) 2014 MEMORANDUM OF UNDERSTANDING

E) 2018 MEMORANDUM OF UNDERSTANDING

F) CONFLICTS OF INTEREST POLICY STATEMENT

G) CONFIDENTIALITY POLICY STATEMENT

H) PROXY VOTING POLICY

I) AUDIT COMMITTEE CHARTER

J) ADMINISTRATIVE COMMITTEE CHARTER

K) CHIEF INVESTMENT OFFICER AND CHIEF FINANCIAL AND OPERATING 

OFFICER CERTIFICATION LETTERS 

L) RAILROAD RETIREMENT BOARD CERTIFICATION LETTER TO TREASURY 

AND TREASURY FEDERAL REGISTER NOTICE ON 2022 TAX RATE 

M) NOTICE TO THE RAILROAD RETIREMENT BOARD AND ACCEPTANCE OF 

NEW TRUSTEES 

N) BIOGRAPHICAL INFORMATION ON TRUSTEES AND STAFF 
 

 

 APPENDIX A
As Amended on August 17, 2017 

BYLAWS 

of 

THE NATIONAL RAILROAD RETIREMENT 

INVESTMENT TRUST 

A Trust Established Pursuant to 

The Railroad Retirement and Survivors' Improvement Act of 2001 

ARTICLE I 

Purposes 

 The National Railroad Retirement Investment Trust (hereinafter, the “Trust”) is 

organized exclusively for the purposes set forth in Section 105 of The Railroad 

Retirement and Survivors' Improvement Act of 2001 (the "Act"): to manage and invest 

the assets of the Trust. Section 105(a) of the Act provides for the establishment of a 

Board of Trustees (the “Board”) to operate the Trust and authorizes the Board to make 

rules to govern its operations, employ professional staff, and contract with outside 

advisors to provide legal, accounting, investment advisory or other services necessary for 

the proper administration of the Trust. Subject to the provisions of the Act, applicable 

laws of the District of Columbia and these Bylaws, the Trust may conduct any or all 

lawful affairs necessary to manage and invest its assets.
ARTICLE II 

Trustees 

Section 1. Powers. Subject to the provisions of the Act, applicable laws 

of the District of Columbia and these Bylaws, the activities and affairs of the Trust shall 

be conducted and all powers shall be exercised by or under the direction of the Board. 

The Board may delegate the management of specific activities of the Trust to any 

person(s) or committees, provided that the activities and affairs of the Trust shall be 

managed and all powers shall be exercised under the direction of the Board. Without 

prejudice to the aforementioned general powers, but subject to the same limitations, it is 

hereby expressly declared that the Board shall have the following powers in addition to 

the other powers enumerated in these Bylaws: 

(a) To select and remove the officers, agents, independent contractors, 

employees and advisors of the Trust (including, but not limited to, legal counsel, 

independent advisers, investment managers, custodial institutions and public accountants, 

as prescribed by the Act), prescribe powers and duties for them and, where appropriate, 

fix their compensation. 

(b) To conduct the affairs and activities of the Trust and to make such 

rules and regulations as the Board may deem appropriate for the proper administration of 

the Trust. 

(c) To borrow money and incur indebtedness for the purposes of the 

Trust, and to cause to be executed and delivered therefor, in the Trust's name, promissory 

notes, bonds, debentures, deeds of trust, mortgages, pledges or other evidences of debt 

and securities therefor. 
3 

(d) to acquire, by lease or by purchase, interests in real property in 

furtherance of the purposes of the Trust and to execute and deliver such agreements, 

indemnifications, undertakings, and other writings as may be required in connection 

therewith. 

Section 2. Number of Trustees, Selection and Term of Office. Seven 

(7) Trustees shall be selected, qualified and appointed to staggered terms, in accordance 

with the provisions of Section 105(a) of the Act. The six (6) Trustees who are selected 

by rail labor and management shall have the power to select the Independent Trustee. 

Terms of office shall commence on February 1 of each year. 

Section 3. Vacancies. Subject to the provisions of the Act, applicable 

laws of the District of Columbia and these Bylaws, any Trustee may resign, effective 

upon giving sixty days' written notice to the Board, or on such shorter notice as may be 

agreed between the Board and the resigning Trustee. Pursuant to Section 105(a) of the 

Act, a vacancy in the Board shall not affect the power of the Board and shall be filled in 

the same manner as the selection of the Trustee whose departure caused the vacancy. 

Each Trustee so selected shall hold office until the expiration of the term of the replaced 

Trustee and until a successor has been appointed. 

A vacancy or vacancies in the Board shall be deemed to exist in case of 

the death, resignation, or removal of any Trustee. The Board may declare vacant the 

office of a Trustee who has been declared of unsound mind by a final order of court, or 

convicted of a felony, or been found by a final order or judgment of any court to have 

breached any fiduciary duty arising under the Act or under any other applicable law 

governing the Trust. 
4 

Section 4. Compensation. The six (6) Trustees who are selected by rail 

labor and management shall have the power to fix the Independent Trustee’s 

compensation for services to the Trust. None of the six (6) Trustees who are selected by 

rail labor and management shall receive compensation from the Trust; provided, 

however, that any such Trustee who is not employed by either rail labor or management 

shall be entitled to receive reasonable compensation to be determined by the other 

Trustees. All Trustees shall be entitled to receive reimbursement for reasonable costs 

incurred in connection with their attendance at Board meetings and performance of other 

services to the Trust.

Section 5. Place of Meetings. Meetings of the Board shall be held at any 

place, within or without the District of Columbia, which has been designated from time to 

time by the Board. In the absence of such designation, meetings shall be held at the 

principal office of the Trust. 

Section 6. Public Access to Board Meetings. The Board shall have the 

authority to determine the extent to which individuals other than Trustees may attend 

meetings or otherwise participate in the deliberations of the Board; provided, however, 

that no such individual employed by rail labor or management shall be entitled to receive 

reimbursement for such activities.

Section 7. Annual Meetings. The Board shall hold an annual meeting for 

the purpose of organization and the transaction of business. Annual meetings of the 

Board shall be held without call or notice on March 1 at 10:00 a.m. local time or on 

such other date as the Board may specify. 
5 

Section 8. Regular Meetings. Regular meetings of the Board shall be 

held at least quarterly without call or notice on such dates as may be fixed by the Board. 

Section 9. Special Meetings. Special meetings of the Board for any 

purpose or purposes may be called at any time by the Chair of the Board or any three 

Trustees upon at least seven (7) business days’ notice to each Trustee or on such shorter 

notice as all Trustees may agree. 

Section 10. Quorum. Pursuant to Section 105(a) of the Act, five (5) 

Trustees constitute a quorum of the Board for the transaction of business. Investment 

guidelines must be adopted by a unanimous vote of the entire Board. Unless otherwise 

specified in the Act or these Bylaws, all other decisions of the Board shall be decided by 

a majority vote of the quorum present. Subject to the foregoing, every act or decision 

taken or made by a majority of the Trustees present at a meeting duly held at which a 

quorum is present shall be regarded as an act of the Board.

Section 11. Participation in Meetings Via Telephone or Video 

Conference. Trustees and others entitled to participate in Board meetings may 

participate in meetings of the Board via telephone or video conference.

Section 12. Adjournment. A majority of the Trustees present, whether 

or not a quorum is present, may adjourn any Board meeting to another time and place. 

Trustees who are absent from the adjourned meeting shall be given notice of the time and 

place at which such meeting will resume. 

Section 13. Action Without a Meeting. Any action required or 

permitted to be taken by the Board may be taken without a meeting if all Trustees consent 

in writing (including by facsimile) to such action. Such written consent shall have the 
6 

same effect as a vote of the Board and shall be filed with the minutes of the proceedings 

of the Board.

Section 14. Rights of Inspection. Every Trustee shall have the right at 

any reasonable time to inspect and copy all books, records, and documents of every kind 

and to inspect the physical properties of the Trust. 

Section 15. Committees. The Board may appoint one or more 

committees, including, but not limited to, (i) an Administrative Committee and (ii) an 

Audit Committee, each consisting of two or more Trustees. Except as otherwise provided 

in these Bylaws or in the Act, the Board may delegate to such committees any of the 

authority of the Board, provided that no such Committee shall have the authority to: 

(a) Amend or repeal these Bylaws or any other organizational 

documents of the Trust or the Board; 

(b) Fill vacancies on the Board or in any committee; 

(c) Appoint other committees of the Board or the members thereof; 

(d) Approve any self-dealing (or “conflict of interest”) transaction; 

(e) Adopt an agreement of merger or consolidation; or 

(f) Sell, lease or exchange Trust property and assets.

The Board may appoint, in the same manner, alternate members of any 

committee who may replace any absent member at any meeting of the committee. The 

Board shall have the power to prescribe the manner in which proceedings of any such 

committee shall be conducted. In the absence of any such prescription, such committee 

shall have the power to prescribe the manner in which its proceedings shall be conducted. 
7 

Minutes shall be kept of each meeting of each committee, and such minutes shall be 

included as an appendix to the minutes of the next meeting of the Board 

ARTICLE III 

Officers 

Section 1. Officers. The officers of the Trust shall be a Chair, and such 

other officers as may be appointed by the Board. The Chair shall preside at all meetings 

of the Board and exercise and perform such other powers and duties as may be from time 

to time assigned by the Board. If the Chair cannot be present at a particular meeting, the 

Chair shall appoint another Trustee to preside at such meeting. 

Section 2. Selection, Removal and Resignation. The officers of the 

Trust shall be appointed by, and shall serve at the pleasure of, the Board, and shall hold 

their respective offices until their resignation, removal, or other disqualification from 

service, or until their respective successors shall be appointed. 

Any officer may be removed, either with or without cause, by the Board at 

any time. Any officer may resign at any time by giving written notice to the Board, and 

any such resignation shall take effect at the date of the receipt of such notice or at any 

later time specified therein. 

Section 3. Vacancies. A vacancy in any office because of death, 

resignation, removal or any other cause shall be filled in the manner prescribed in these 

Bylaws for regular appointment to such office. Such vacancies shall be filled as they 

occur. 

ARTICLE IV 

Other Provisions
8 

Section 1. Principal Office. The principal office of the Trust shall be 

fixed and located at 2001 K Street, N.W., Washington, D.C., or such other address as the 

Board shall determine. The Board is granted full power and authority to change said 

principal office from one location to another. The Board may make such changes 

pursuant to this Section 1 without amending the Bylaws, provided that any such changes 

are documented in a Board resolution duly noted in the minutes of the meetings where 

such decisions are made.

Section 2. Books and Records. The Trust’s books and records, together 

with all of the documents and papers pertaining to the business of the Trust, shall be kept 

and maintained at the principal office of the Trust. The fiscal year of the Trust shall end 

on September 30, unless otherwise provided for by the Board, and the books and records 

of the Trust shall be kept on a fiscal year basis and shall reflect all the transactions of the 

Trust and be appropriate and adequate for the Trust’s business. 

Section 3. Representation of Ownership Interests. The Board or any 

duly authorized delegate of the Board may vote, represent, and exercise on behalf of the 

Trust all rights incident to any and all shares of any corporation, or other interest in any 

entity, held in the name of the Trust. The authority herein granted may be exercised 

either by any such officer in person or by proxy or power of attorney.

Section 4. Banking. The Chair, or any duly authorized delegate of the 

Board, may: (i) make deposits into operating accounts held in the Trust's name and 

endorse checks, drafts, or other instruments for such deposits; and (ii) sign or countersign 

checks, drafts, or other orders for the payment of money issued in the name of the Trust 

against any funds deposited into any such accounts. 
ARTICLE V 

Indemnification 

The Trust shall indemnify, in the manner and to the fullest extent 

permitted by law (including, without limitation, the Act), any person (or the estate of any 

person) who was or is a party to, or is threatened to be made a party to, any threatened, 

pending or completed action, suit or proceeding, whether or not by or in the right of the 

Trust, and whether civil, criminal, administrative, investigative or otherwise, by reason of 

the fact that such person is or was a Trustee or an employee of either a rail carrier or a rail 

union who performed services for the Trust at the direction of one or more Trustees. To 

the fullest extent permitted by law, the indemnification provided herein shall include 

expenses (including attorneys' fees), judgments, fines and amounts paid in settlement; 

and, in the manner provided by law, any such attorneys' fees and expenses may be paid 

by the Trust in advance of the final disposition of such action, suit or proceeding upon 

receipt, in each case, of an undertaking by or on behalf of the Trustee to repay such 

amounts, together with interest thereon, if it is ultimately determined that such Trustee is 

not entitled to indemnification with respect thereto. 

ARTICLE VI 

Amendment, Construction and Definitions 

Section 1. Amendments. These Bylaws may be amended or repealed by 

a majority vote of a quorum of Trustees present at a duly held meeting or by a consent in 

writing of all Trustees. 

Section 2. Construction and Definitions. Unless the context otherwise 

requires, the general provisions, rules of construction and definitions contained in the Act 
10 

and in any applicable laws of the District of Columbia not inconsistent with the Act shall 

govern the construction of these Bylaws. 
 

 

 APPENDIX B

 
INVESTMENT GUIDELINES

The National Railroad Retirement Investment Trust (the “Trust” or “NRRIT”) was 

established, effective February 1, 2002, pursuant to Section 15(j) of the Railroad Retirement Act 

of 1974, as amended by Public Law 107-90, the Railroad Retirement and Survivors’ 

Improvement Act of 2001 (the “Act”). The Act was amended subsequently by Public Law 108-

203, the Social Security Protection Act of 2004, to make certain technical corrections to the 2001 

legislation creating the Trust. The Trust’s sole purpose is to invest the assets of the railroad 

retirement system for the Railroad Retirement Board. Domiciled in Washington, D.C., the Trust 

is a tax-exempt entity (pursuant to Section 501(c)(28) of the Internal Revenue Code) and is not 

an agency or instrumentality of the United States federal government. 

The Trust is governed by a Board of seven Trustees (the "Board of Trustees") -- three 

selected by railroad carriers, three selected by railroad labor unions, and an independent Trustee 

selected by the other six Trustees. The Act sets forth fiduciary standards for the Trustees and 

directs them to discharge their duties solely in the interest of the Railroad Retirement Board (an 

agency of the United States federal government) and, through it, the participants and 

beneficiaries of the programs funded under the Railroad Retirement Act. 

The Board of Trustees has adopted the following Mission Statement to guide the work of 

the Board and its investment staff:

The mission of the National Railroad Retirement Investment Trust is to help 

secure the retirement benefits of all participants of the railroad retirement system. 

Through the diligent oversight and prudent investment of railroad retirement 

assets, and an adherence to the highest ethical and professional standards within 

the industry, NRRIT’s trustees and investment professionals contribute to the 

financial security of rail workers, retirees, and their families, and the strength of 

the American rail industry.

The Trust is authorized by the Act to diversify the investment of the assets of the railroad 

retirement system through the use of multiple asset classes as is customary for defined benefit 

plans of other U.S. industries. Section 15(j) of the Act directs the Board of Trustees to adopt 

Investment Guidelines which must be approved by a unanimous vote of the Trustees. The Act 

authorizes the Board of Trustees to invest the assets of the Trust in a manner consistent with such 

Investment Guidelines. The Trustees are required by the Act to diversify the Trust’s 

investments “so as to minimize the risk of large losses and to avoid disproportionate influence 

over a particular industry or firm, unless under the circumstances it is clearly prudent not to do 

so.” In accordance with these statutory directives, the Board of Trustees has adopted these 

Investment Guidelines.

National Railroad Retirement Investment Trust
2

I. Investment Objectives 

The Trust’s primary investment objectives are to establish a portfolio that will achieve a 

long-term rate-of-return on assets sufficient to enhance the financial strength of the railroad 

retirement system and to do so in a diversified manner that minimizes the risk of large losses. 

Achievement of these objectives will facilitate the payment of benefits under the Act by the 

Railroad Retirement Board and the United States Treasury. To further these objectives, the Trust 

has established the asset allocation policy set forth in these Investment Guidelines and will seek 

to obtain returns that are in the aggregate greater than the returns of the strategic policy 

benchmark set forth below. In addition, the Trust shall take such other steps as may be 

appropriate to effectively manage investment risk and volatility. 

II. A. Asset Allocation Policy and Strategic Policy Benchmark

In 2002, the Trustees retained an independent investment advisory firm to conduct a 

comprehensive asset allocation study for the purpose of analyzing asset allocation strategies for 

the Trust. The study analyzed the long-term expected return, risk, and return correlation of 

various asset classes, as well as the expected return and risk of various portfolios of these asset 

classes. In 2004, 2006, 2008, 2011, 2014, 2017 and 2020, the Trust took steps to review and 

update its asset allocation with new analysis performed by the Trust's investment staff with the 

use of analytic resources provided by independent investment advisory firms. As a result of 

these reviews, the Board of Trustees periodically has refined the Trust’s asset allocation policy 

and strategic policy benchmark. 
3

The Trust’s overall asset allocation (target allocation and policy range) and strategic 

policy benchmark to govern the investment of assets managed by the Trust are set forth below. 

Asset Class

Policy

Benchmark

Target

Allocation %

Policy

Range %

 US Equity Russell 3000 Total Return 31 26-36

 Non-US Equity MSCI ACWI Ex-US IMI-$Net 24 19-29

 Private Equity 2/3 Russell 3000 TR + 1/3 MSCI 

ACWI ex-US IMI-$Net + 200 bps

12 7-17

Global Equity 67% 60-74%

 US Fixed Income Bloomberg Barclays US Universal 10 6-14

 Global Fixed Income Bloomberg Barclays Global 

Aggregate Index 2 0-4

 Private Debt CS Leveraged Loan Index + 150 bps 2 0-4

Global Fixed Income 14% 10-18%

 Real Estate

NCREIF Fund Index – Open End 

Equity (NFI-OE) 9 5-15

(combined)

NRRIT Custom REIT1 1

Global Real Assets 10% 5-15%

 Absolute Return NRRIT Custom Absolute Return2 4 2-6

 Opportunistic NRRIT Public Markets Composite 3 1-5

 Cash BofA ML 91 Day T-bill 2 0-4

Other 9% 6-12%

TOTAL FUND 100%

1

NRRIT’s Custom REIT benchmark is 1/3 “FTSE NAREIT Equity REIT index” and 2/3 “FTSE EPRA/NAREIT Developed Index – Net Return to 

US Investors.”

2

NRRIT’s Custom Absolute Return benchmark is 40% BB US Universal Index, 30% BB Global Aggregate Index, and 30% MSCI ACWI IMI NR 

Index.

The Trust maintains an Investment Plan developed by the investment staff and approved 

by the Board of Trustees, which is updated periodically.1 The Investment Plan sets forth the 

strategy to implement the asset allocation policy for each asset class and its provisions must be 

consistent with the requirements of these Investment Guidelines. As set forth in the Investment 

Plan, certain asset classes may include proposed allocations to “specialist managers” who have 

investment strategies with attributes similar to Absolute Return asset class investments (e.g., use 

1 The most recent update of the Investment Plan was approved on November 18, 2020.
4

of leverage, ability to take significant short positions, illiquidity, and/or the presence of 

significant incentive fees). The aggregate assets held by managers with these attributes shall be 

subject to an overall limitation calculated as follows: 

The sum of the:

(i) assets held in the Absolute Return asset class; and

(ii) assets held by specialist managers in other asset classes with absolute return-type 

attributes, other than managers in the Private Equity and Real Estate asset classes; 

shall not exceed 15% of the overall assets in the Trust portfolio. 

This limitation shall be a “new investment” limitation calculated by the Board at the time of a 

proposed investment covered by this limitation, and shall not require remedial action with 

respect to existing investments previously made consistent with the limitation.

The asset allocation policy contains certain asset classes that are relatively illiquid in 

nature and may not otherwise be suitable for interim investment in index-type investment 

vehicles to obtain the market exposure contemplated by the asset allocation policy. As a result, 

investments in these asset classes are funded over an extended period of time. To accurately 

reflect the interim investment of funds earmarked for these more complex asset classes, the Trust 

maintains an internal version of its target allocation and policy ranges to properly track the 

interim retention of such funds within other asset classes at any given point in time. The interim 

version of the target allocation and policy ranges is updated at the start of each fiscal year. 

Rebalancing decisions made pursuant to subsection B of this section II are to be made with 

reference to these interim target allocations and policy ranges.

B. Asset Allocation Rebalancing Rules

1. Mandatory Rebalancing Requirements

a. If, at the end of any calendar quarter, the proportion of Trust assets invested in 

any asset class, other than private equity, private real estate, or absolute return, (as 

calculated by the Trust's custodian bank) is above the upper or below the lower 

limits of the policy range for such asset class, as prescribed above, the Trust is 

required by its Board of Trustees to rebalance assets by transferring assets to or 

from such asset class from or to one or more other asset classes ("Mandatory 

Rebalancing"). Mandatory Rebalancing shall be implemented by the trust's 

investment staff. Mandatory Rebalancing will be required if either the upper or 

lower limits for the policy range of a particular asset class (e.g., US Equity) or the 

upper or lower limits for the policy range of a global class (e.g., Global Equity) 

have been exceeded. 

b. When a Mandatory Rebalancing of an asset class is required, the Trust's 

investment staff shall rebalance the asset class to a point that is within 50% of the 

midpoint of the target allocation within the policy range (e.g., where the target 
5

allocation is 26% and the policy range is 21% - 31%, the rebalance must reset the 

asset class to a point between 23.5% and 28.5%).

c. In implementing and transferring assets from or to an existing investment as 

part of a Mandatory Rebalancing, the Trust's investment staff shall not increase 

the position in any particular investment by more than 100% or reduce a position 

by more than 50% (e.g., if the value of a particular investment at the time of the 

Mandatory Rebalancing is 80, it cannot be increased to more than 160, or reduced 

below 40 as a result of the rebalancing).

d. Mandatory Rebalancing will be initiated promptly in the first month following 

receipt of a quarterly notice from the Trust's custodian bank that one or more asset 

classes are above the upper or below the lower policy range limits prescribed 

above. Rebalancing must be completed promptly and in a cost effective manner.

e. If the Trust's investment staff concludes that a Mandatory Rebalancing is not 

deemed advisable, consent of the Board of Trustees will be required to supersede 

the requirements of this subsection B.1.

2. Non-mandatory Rebalancing Authority 

a. The Trust's investment staff shall regularly monitor the positioning of each 

asset class within its policy range and make such recommendations to the 

Trustees as are appropriate with respect to the advisability of rebalancing asset 

classes that are nearing, but have not exceeded, the high or low points of their 

policy ranges. 

b. In addition, the Trust may initiate a rebalancing (each such rebalancing, a "Nonmandatory Rebalancing") in situations where with respect to any asset class other 

than private equity, private real estate or absolute return, such a rebalancing: 

(i) moves the asset class closer to the approved policy target for an asset class 

(or subcategory of an asset class where subcategories are set forth in the Trust's 

Investment Plan); (ii) involves the transfer of less than one percent (1%) of Trustmanaged assets; and (iii) transfers assets only to mandates of investment 

managers that have been previously approved by the Trustees. Any Non-mandatory 

Rebalancing shall be initiated and implemented by the Trust's investment staff.

c. In transferring assets from or to an existing investment as part of a Nonmandatory Rebalancing, the Trust's investment staff shall not increase the position 

in any particular investment by more than 100% or reduce a position by more than 

50% (e.g., if the value of a particular investment at the time of the rebalancing is 

80, it cannot be increased to more than 160, or reduced below 40 as a result of the 

rebalancing).

d. Where a Non-mandatory Rebalancing is undertaken, the Trust's investment 

staff shall report the specifics of such rebalancing to the Trustees promptly after 

such rebalancing has been completed. After a Non-mandatory Rebalancing has 

been completed, no subsequent Non-mandatory Rebalancing can be 
6

undertaken that would have the effect, when combined with the immediately 

preceding Non-mandatory Rebalancing, of transferring more than one percent 

(1%) of Trust assets, or increasing the position in any particular investment by 

more than 100% or reducing a position by more than 50%, unless the subsequent 

Non-mandatory Rebalancing occurs at least two days after the notification to the 

Trustees of the prior Non-mandatory Rebalancing.

e. In evaluating how best to liquidate assets to fund periodic transfers to the 

United States Treasury required by Section 15(k) of the Act for the payment of 

benefits, the Trust shall take into consideration the asset classes that are at the 

high end of their respective policy ranges, relative cash positions of the Trust's 

investment managers, and other relevant factors.

III. Selection of Investment Managers

Pursuant to Section 15(j) of the Act, the Board of Trustees shall retain independent 

investment managers to invest the assets of the Trust consistent with these Investment 

Guidelines. A separate agreement between the Trust and each individual investment manager 

will document the specific responsibilities, limitations, and compensation arrangements of each 

investment manager. Each investment manager will have full discretion, within the parameters 

of that manager's Investment Management Agreement with the Trust, to (i) select securities and 

properties for investment, (ii) determine the timing of and execute transactions, and (iii) act in 

accordance with the Trust’s Proxy Voting Policy Statement.

IV. Other Investment Requirements and Limitations

A. No more than 10% of the Trust’s assets may be invested by any individual investment 

manager (including any of its affiliates). This limitation shall not apply to assets 

invested by an investment manager retained to invest assets in index accounts.

B. Trust assets shall not be invested either directly, or through private equity investment 

entities, in securities of publicly traded corporations whose primary business is the 

operation of North American railroads. This limitation shall not apply to securities 

that are purchased as part of a market index account or market exchange traded fund, 

pooled or commingled fund, or separate account, where an investment manager 

selects the underlying securities of the portfolio and the Trust is not in a position to 

control investment or securities selection.

C. In making investments on behalf of the Trust, an investment manager is authorized to 

utilize leverage (including by the use of derivative instruments to the extent permitted 

by paragraph D below) in the manager’s investment strategy only to the extent 

delineated by the Trust in the investment manager’s Investment Management 
7

Agreement with the Trust; provided, however, that the use of such leverage shall not 

directly or indirectly expose the Trust to a risk of financial loss that exceeds the dollar 

amount of the Trust’s investment with the investment manager in question.

D. Subject to the limitations of the immediately preceding paragraph C, and only to the 

extent delineated by the Trust in an Investment Management Agreement with an 

investment manager, derivative instruments may be used by an investment manager 

as a means of hedging and risk control, for arbitrage, to create market exposures, or 

to manage country and asset allocation exposures. In these situations, an investment 

manager may use derivatives when they are the most effective means of achieving the 

investment objective. 

1. Where appropriate, an investment manager may use derivative instruments for the 

following reasons: 

a. Hedging and risk control. To the extent that a portfolio is exposed to clearly 

defined risks and there are derivative instruments that can be used to reduce 

those risks, an investment manager may use such derivative instruments for 

the purpose of hedging such risks, including cross-hedging of currency 

exposures.

b. Arbitrage. An investment manager may use derivative instruments to 

facilitate the simultaneous purchase and sale of securities for the purpose of 

taking advantage of a pricing disparity. 

c. Creation of market exposures. An investment manager may use derivative 

instruments to replicate the risk/return profile of an asset or asset class 

provided that the Investment Management Agreement for such investment 

manager allows for such exposures to be created with the underlying assets 

themselves. 

d. Management of country and asset allocation exposure. An investment 

manager whose portfolio mandate permits tactically changing the exposure of 

the portfolio to different countries and/or asset classes may use derivative 

instruments for this purpose.

2. Derivative instruments may not be used in the following ways:

a. Derivative instruments may not be used to invest in asset classes, securities, 

currencies, indices, or any other financial vehicle unless such exposures 

would be allowed by a portfolio’s investment guidelines if created with nonderivative instruments. 

b. Derivative instruments may not be used to magnify overall portfolio 

exposure to an asset, asset class, interest rate, or any other financial vehicle 
8

beyond that which would be allowed by a portfolio’s investment guidelines if 

created with non-derivative instruments. 

c. Derivative instruments may not be used to increase the portfolio risk above 

that which could be experienced by using permitted physical securities. 

d. An investment manager may not use borrowed funds to finance the use of 

any derivative instrument. 

E. In order to diversify the Trust’s counterparty credit risk, and to limit the Trust’s credit 

exposure to any one counterparty, the Trust’s investment managers shall establish 

limits for each of their trading counterparties based upon both the credit rating of the 

counterparty and the relative level of risk associated with each existing and proposed 

transaction. These limits shall satisfy such standards as may be established by the 

Trust from time-to-time.

F. All investments shall be made in accordance with the Trust’s Conflict of Interest 

Policy.

V. Voting of Proxies

All proxies shall be voted solely in the interest of plan participants and beneficiaries as 

outlined in the Trust's Proxy Voting Policy Statement.

VI. Periodic Review and Amendment

The Board of Trustees shall review these Investment Guidelines on a regular basis. Any 

material changes approved by the Board of Trustees will be communicated to the Trust's 

investment managers.

 

 APPENDIX C

 


















 

 APPENDIX D 




 

 APPENDIX E



 

 APPENDIX F
CONFLICTS OF INTEREST 

Policy Statement of the 

National Railroad Retirement Investment Trust

Statement of policy 

The policy of the National Railroad Retirement Investment Trust (the "Trust") with respect to 

conflicts of interest requires that the Trustees and all employees (hereinafter "NRRIT personnel") 

avoid any conflict or appearance of conflict between their personal interests and the interest of 

the Trust in dealing with all entities or individuals doing or seeking to do business with the Trust. 

Underlying these standards is the fundamental proposition that all NRRIT personnel must 

discharge their duties solely in the interest of the Railroad Retirement Board and through it, the 

participants and beneficiaries of the programs funded under the Railroad Retirement Act of 1974, 

as amended. 

Personal finances 

NRRIT personnel shall not, without the consent of the Board of Trustees, hold or acquire a 

financial interest in any enterprise which to the knowledge of the individual has any business 

relationship with the Trust, or is seeking to establish such business relationship. A financial 

interest shall not include securities in a publicly traded company held directly or indirectly, 

provided that such interest is less than one percent (1%) of the outstanding shares of such 

company or debt of such company. 

NRRIT employees are prohibited from investing in securities offered in private placements and 

participating in any initial public offerings (IPOs) of equity securities. 

All employees are required to complete a financial disclosure form on an annual basis. This 

form requires the disclosure of personal investment holdings in any company with which the 

Trust conducts, or is likely to conduct business. The Chief Compliance Officer shall prepare and 

maintain a “watchlist” of securities that are subject to this annual disclosure requirement. 

Disclosure must be made for any watchlist securities owned by the employee, spouse and any 

dependent children that, in aggregate, fall into the following ranges: ($10,000 - $50,000; 

$50,000 - $100,000; Over $100,000). 

Staff must also disclose all individual securities owned by the employee, spouse and dependent 

children whose market value exceeds $100,000, regardless of whether or not such securities are 

on the watchlist. The following security types are excluded from this disclosure requirement: 

Certificates of Deposit, Municipal Bonds, Treasury Bonds, Mutual Funds (including Money 

Market Funds) and Exchange Traded Funds. 

Prior to any investment recommendation, any investment staff who materially participated in the 

recommendation must disclose any investment holdings in the recommended manager, and, for 

private markets, any opportunity to invest in the recommended fund / strategy granted by the 

investment manager or general partner. 

Outside activities 

NRRIT personnel shall not hold any position with any other enterprise, the existence of which 

would conflict or might reasonably be supposed to conflict with the individual’s performance of 

his or her duties or responsibilities to the Trust without full and complete disclosure thereof to 

the Board of Trustees. 
2

NRRIT personnel shall not negotiate employment with any person or entity that is doing 

business or seeking to do business with the Trust without full and complete disclosure thereof to 

the Board of Trustees. 

Inside Information and Material Non-public Information 

NRRIT personnel shall maintain the confidentiality of all information related to deliberations and 

decisions, including but not limited to investment decisions, of the Trust and shall not use such 

information for personal profit or allow it to be used for personal profit of others. 

NRRIT personnel shall not trade on material non-public information. Material information 

generally is defined as information that a reasonable investor would likely consider important in 

making their investment decisions, or information that is reasonably certain to have a substantial 

effect on the price of a company’s securities, regardless of whether the information is related 

directly to the company’s business. Information is considered to be non-public until it has been 

effectively communicated to the marketplace. 

Gifts & Gratuities 

NRRIT personnel, or members of their families, shall not accept gifts from any person, firm or 

corporation doing business or seeking to do business with the Trust, of such a nature or in such a 

circumstance that a reasonable person could infer that the acceptance of such gifts might unduly 

influence the individual in the performance of his or her duties. In deciding whether to accept 

any gift from such person, firm or corporation, NRRIT personnel, or members of their families 

should exercise proper judgment and shall not accept any gifts in excess of $100 in estimated 

fair market value per year from any given investment manager / vendor. This $100 limit does not 

apply to gifts of de minimis value, such as promotional / branded items distributed at meetings or 

conferences. Also excluded from this limitation are gifts such as chocolates or fruit baskets that 

are typically received around the holidays and are shared with all NRRIT personnel. 

NRRIT personnel, or members of their families, may accept business-related entertainment (e.g., 

food or beverages, invitations to attend a sporting event or participate in a sporting activity) 

where such entertainment is (a) reasonable in scope, (b) associated with a bona fide business 

meeting or conference, and (c) provided to others as a normal part of doing business in the 

industry or profession. Moreover, consistent with policies established by the SEC and FINRA 

for investment managers, business-related entertainment may be accepted by NRRIT personnel 

or members of their families only when a representative of the host accompanies such 

individuals to the event. If no representative of the host is present at the event, such services are 

regarded as gifts and subject to the gift policies above. Any business-related entertainment with 

an estimated fair market value in excess of $200 requires written pre-approval from the Chief 

Compliance Officer. In addition, business-related entertainment in excess of five events per 

calendar year from any one investment manager or vendor relationship is prohibited, regardless 

of the estimated fair market value of such entertainment. 

Excluded from the $200 pre-approval threshold are items of value offered to NRRIT staff 

members that are also offered to others in a group as a normal and customary part of doing 

business. Examples of such items include: meals or event tickets offered to a group as part of a 

conference or annual meeting, hotel rooms for LP advisory board members, and car service 

to/from the airport. 
3

Notwithstanding the terms of the preceding two paragraphs, NRRIT personnel, or members of 

their families, shall not accept money or any other thing of value in connection with any 

investment made by or for the Trust, nor shall any such person have any pecuniary interest in 

such investment. 

Disclosure 

Whenever a NRRIT personnel becomes aware of a conflict of interest, or has any question as to 

any activity, interest, or relationship which could be construed as a conflict of interest, such 

individual shall promptly report the circumstances to the Board of Trustees. 

All NRRIT personnel shall annually sign a statement affirming that such person has: 

a. received a copy of this conflict of interest policy, 

b. read and understands this policy, and 

c. agreed to comply with its terms. 

 

 

As approved and adopted in amended form by the Board of Trustees on February 24, 2017. This 

Policy Statement was originally approved and adopted by the Board on July 19, 2002. 
 

 APPENDIX G
CONFIDENTIALITY

Policy Statement of the 

National Railroad Retirement Investment Trust

Statement of general policy 

The Board of Trustees (the “Board”) of the National Railroad Retirement Investment Trust (the 

“Trust”) recognizes the sensitivity of all deliberations related to investment decision making, 

particularly in a Trust of this size and unique statutory structure. As such, the Board has 

adopted a policy that requires that the Trustees, Trust Advisors, and all Trust employees 

(hereinafter "NRRIT personnel"), as well as any investment advisor, manager, or custodian 

retained by the Trust, maintain the confidentiality of all information related to investment 

deliberations and decisions and other operations of the Trust. 

The Trustees also recognize their statutory obligation to discharge their duties solely in the 

interest of the Railroad Retirement Board and through it, the participants and beneficiaries of the 

programs funded under the Railroad Retirement Act of 1974. As such, the Trust shall respond to 

any inquiry of the Railroad Retirement Board with respect to investment activities of the Trust, 

but shall do so in a manner so as to maintain the confidentiality of such information, under such 

terms and conditions as may be developed by Trust counsel and the General Counsel of the 

Railroad Retirement Board. Any request for confidential information from any other agency or 

instrumentality of the Federal Government shall be considered by the Trustees on a case-by-case 

basis and in consultation with the Railroad Retirement Board. 

Confidential information 

All information relating to Trust business, including Trustee investment and business 

deliberations, internal staff deliberations, Board and Committee meeting book materials and 

meeting minutes, Trust investment plans, manuals and memoranda, internal investment analyses, 

meeting summaries or notes, and all other similar work papers should be treated as confidential 

by NRRIT personnel, unless (1) release of such information is required to carry out a direction 

from the Board, (2) is otherwise authorized by the Board or the Chief Investment Officer, or (3) 

is included in summary or aggregate form in annual reports that are required pursuant to the Act, 

or any other applicable Federal law. 

Continuing Obligation to Preserve Confidentiality 

All confidential information of the Trust is the sole and exclusive property of the Trust, and the 

obligation to preserve such confidentiality shall continue for former NRRIT personnel after their 

professional affiliation with the Trust ends. 

Annual Affirmation 

All NRRIT personnel annually shall sign a statement affirming that such person has: 
2

a. received a copy of this confidentiality policy, 

b. read and understands this policy, and 

c. agreed to comply with its terms. 

 

Approved by the Board of Trustees on January 27, 2005. 
 

 APPENDIX H
NATIONAL RAILROAD RETIREMENT INVESTMENT TRUST 

PROXY VOTING POLICY STATEMENT 

I. PURPOSE 

 The purpose of the National Railroad Retirement Investment Trust’s (“NRRIT” or the 

“Trust”) Proxy Voting Policy Statement is to provide investment managers and the Railroad 

Retirement Board (the “RRB”) with written documentation of the requirements for the voting of 

proxies for assets held in NRRIT’s accounts. 

 Section 15(j)(5)(A) of the Railroad Retirement Act of 1974 (the “Act”), as amended by 

NRRIT’s enabling legislation, the Railroad Retirement and Survivors’ Improvement Act of 

2001, sets forth the fiduciary duties of NRRIT’s Board of Trustees. Specifically, the Trustees are 

required to discharge their duties with respect to Trust assets, including the voting of proxies, 

“solely in the interest” of the RRB, and through it, the participants and beneficiaries of the 

programs funded through the Trust. Although the Trust is not subject to ERISA, the general 

prudence standard set forth in the Act is based upon the general fiduciary standards imposed by 

ERISA. 

II. RESPONSIBILITIES OF INVESTMENT MANAGERS 

 Independent investment managers retained by the Trust pursuant to Section 15(j)(4)(B) of 

the Act will be fiduciaries of the Trust, and as such they will be required to exercise the same 

duties of loyalty and care in managing Trust assets. Where the Trust delegates management 

authority with respect to specified Trust assets to an investment manager, such investment 

manager will have exclusive authority to vote all proxies related to the Trust securities under its 

control unless such authority is expressly limited in the investment manager’s contract with the 

Trust. Prudent investment management includes the voting of proxies consistent with the 

investment manager’s own proxy voting guidelines and solely in the interest of the participants 

and beneficiaries of the Railroad Retirement system. 

 Each investment manager retained by the Trust will agree to fulfill the following 

responsibilities: 

A. Each investment manager will be obligated to vote all proxies on securities held by 

such manager in the Trust’s portfolios.

B. Each investment manager will be expected to carefully examine all proxy issues. The

decision with respect to the proxy vote must be made on a case by case basis, 

prudently and solely in the interest of the participants and beneficiaries of the 

Railroad Retirement System. 

C. Each investment manager must adopt and implement written policies and procedures 

that are reasonably designed to ensure that proxies with respect to Trust assets will be 

voted in the best interest of the participants and beneficiaries of the Railroad 

Retirement System. The manager must provide to the Trust: (i) a copy of its proxy 
2 

voting guidelines, and (ii) a summary of its procedures for recording proxy votes and 

reporting them to the Trust. 

D. Decisions with respect to proxy voting may be delegated by the investment manager 

to an independent third party advisory firm, provided however that such advisory firm 

must exercise its judgment in a manner that it is consistent with this Proxy Voting 

Policy Statement and with the proxy voting policy of the investment manager. 

E. Each investment manager must accurately record its proxy votes for each Trust 

security held and the basis for such votes. The votes may be tallied by general 

category. These records must be made available to the Trust upon its request. 

F. Each investment manager must provide to the Trust on a quarterly basis: 

1) Written certification that all proxies with respect to Trust securities have been 

voted solely in the interest of the participants and beneficiaries of the Railroad 

Retirement system; 

2) Written certification that neither the officers of the investment management firm 

nor their personnel have been unduly influenced by outside sources regarding the 

voting of any proxy; 

3) In cases where a conflict of interest has been identified, written certification that 

adequate measures were taken to ensure that such conflict did not affect any 

proxy vote and documentation explaining the nature of such conflict; and 

4) Adequate documentation to report all proxy votes with respect to Trust securities 

cast by the investment manager and, for all non-routine matters, the basis for such 

votes. 

III. COORDINATION WITH CUSTODIANS 

The investment manager will have the responsibility of ensuring that all proxies with 

respect to Trust securities are voted, and will coordinate as necessary with the custodians of the 

Trust's assets to see that this responsibility is carried out. 

Should the investment manager not receive proxy solicitation materials on a timely basis 

from the custodian, which could prevent normal handling of the materials and timely voting from 

taking place, the investment manager may designate the custodian as its agent to vote the proxy 

in question. Under these circumstances, the investment manager will not be relieved of its 

fiduciary responsibility for the voting of proxies; therefore, the investment manager must provide 

the custodian with specific voting instructions. 

IV. RESPONSIBILITIES OF THE TRUST 

Consistent with its fiduciary duties as they relate to the voting of proxies, the Trust assumes 

the following responsibilities: 
3 

A. As part of its due diligence review of prospective investment managers and its 

ongoing oversight of current managers, the Trust's investment staff will review each 

investment manager’s policies and procedures with respect to proxy voting to ensure 

that they are in compliance with this Proxy Voting Policy Statement. 

 

B. Upon receipt of the documentation submitted quarterly by the investment managers, 

the Trust's investment staff will review and report to the Board of Trustees regarding 

each investment manager's proxy voting record with respect to Trust securities. 

C. The Board of Trustees shall annually review the report of the Trust's investment staff 

with respect to proxy voting of Trust securities. 

D. The Trust reserves the right to modify or rescind the proxy voting authority delegated

to an investment manager at any time. 

V. DOCUMENTATION 

This Proxy Voting Policy Statement will be (i) attached to the Trust’s Investment 

Guidelines, and (ii) incorporated by reference into each investment management agreement 

entered into by the Trust. 

Revised and Approved by the Board on March 29, 2011 
 

 APPENDIX I 
 

National Railroad Retirement Investment Trust 

Audit Committee Charter 

It shall be the duty of the Audit Committee to: 

1. Retain an independent auditor pursuant to an engagement and fee letter approved by 

the Committee to perform the annual audit of the Trust, review the results of such 

audit and all other reports received from the auditor. In selecting an auditor the 

Committee shall take into consideration the auditing firm’s particular expertise with 

institutions that manage complex investment portfolios. 

2. Hold periodic meetings with the auditor to discuss any and all matters brought to 

the attention of the Committee by the auditor. Require that the auditor not 

undertake any non-audit consulting assignment for the Trust without the prior 

approval of the Audit Committee. 

3. Require that the auditor promptly disclose the results of any examination or 

inspection made by the Public Company Accounting Oversight Board, the 

Securities and Exchange Commission, and any other governmental or other 

regulatory body related to independence, audit quality, or any other significant 

matters. 

4. Review annual financial certification prepared by CIO and Chief Financial and 

Operating Officer affirming the completeness and accuracy of the Trust’s statement 

of financial position and the integrity of the Trust’s internal control structure and 

procedures for financial reporting. 

5. Review and provide a recommendation to the Board with respect to draft Annual 

Management Report prepared for transmittal to Congress as required by The 

Railroad Retirement Act of 1974 (the “Act”). 

6. Manage the Trust’s program of periodic performance reviews, including 

coordination and consultation with the Railroad Retirement Board with respect to 

such reviews. 

7. Oversee the Trust’s compliance program, including its conflicts-of-interest and 

confidentiality policies, to ensure that the Trustees, its employees and agents 

comply with duties and responsibilities specified in the Trust’s Compliance Manual, 

the Railroad Retirement Act, and fiduciary responsibilities arising under the Act or 

other applicable law. 

8. Establish and maintain a secure process for receiving, retaining and handling named 

or anonymous complaints or “whistleblower” submissions related to action of any 
2

Trustee, Trust employee or Trust agent that might constitute fraud or result in an 

inaccurate or incomplete recording of the Trust’s financial or accounting 

information. 

9. Oversee the Trust’s federal and District of Columbia tax filings including the 

annual filing of its Form 990 information return and any required Form 990T 

income tax return that might be applicable with respect to a fiscal year. 

10. Oversee the staff’s compliance with the Trust’s obligations under its 

Memorandum of Understanding (MOU) with the federal government entities that 

are parties to the MOU and assess the appropriateness of any proposed changes in 

those obligations that might arise from time-to-time. 

11. Undertake an annual self-assessment to ensure that the Committee is meeting the 

responsibilities set forth in this Resolution. This self-assessment shall include as an 

appendix a report prepared by the Chief Financial and Operating Officer on the 

operation of all material internal accounting and audit systems 

As revised and approved by the Board on February 24, 2017 
 

 APPENDIX J
National Railroad Retirement Investment Trust 

Administrative Committee Charter 

It shall be the duty of the Administrative Committee to: 

1. In General: Establish and oversee all matters related to the administrative functioning of 

NRRIT, including the development of its annual budget and policies to govern staff 

compensation, employee benefits, receipt of gifts, and travel reimbursement. 

2. Annual Budget: Review the annual budget prepared by the Chief Executive Officer/Chief 

Investment Officer (CEO/CIO) and the Senior Operating Officer (SOO) prior to its 

submission to the Board for review at the first Board meeting of each fiscal year. 

3. Base Compensation and Annual Bonus: Make recommendations to the Board regarding the 

criteria to be used annually to set base compensation and annual bonuses, taking into 

consideration the need to recruit and retain qualified investment professionals in a 

competitive environment, but also recognizing the unique public-private nature of NRRIT. 

4. Deferred Compensation Plan: Periodically review the Trust's deferred compensation plan for 

senior staff and make recommendations to the Board regarding prospective changes as may 

be appropriate, taking into consideration the need to recruit and retain qualified investment 

professionals in a competitive environment, but also recognizing the unique public-private 

nature of NRRIT. 

5. Employee Benefits: Make recommendations to the Board regarding the creation and 

operation of cost effective plans to provide such employee benefits as may be determined 

by the Committee to be necessary and appropriate, and using outside consultants to the 

extent necessary, review the adequacy and appropriateness of such plans on a periodic 

basis. These may include health insurance; life insurance; disability insurance; annual, 

medical or other types of paid or unpaid leave; severance; defined contribution plans; etc. 

6. Tax Filing: Oversee the preparation and filing of those sections of the Trust’s annual Form 

990 information return that relate to compensation matters. 

7. Compensation Comparability: Make recommendations to the Board regarding appropriate 

peer bench marks to assess NRRIT compensation practices for comparable positions of 

responsibility, employ outside consultants as necessary, and use independent survey data to 

review annually the compensation and benefit practices of peer pension and investment 

entities to assess the appropriateness of NRRIT compensation practices and peer 

benchmarks. 
2

8. Training, Advancement and Succession: Coordinate with the CEO/CIO with respect to the 

development of appropriate education and training opportunities for staff, and review staff 

advancement and succession planning periodically with the CEO/CIO. 

9. Trustee Expenses: Establish a policy to govern Trustee expense reimbursement and require 

the Committee Chair to review all reimbursement requests submitted pursuant to this 

policy. 

10. Gift and Travel Policies: Establish and monitor policies to govern staff receipt of gifts and 

travel reimbursements that are consistent with the NRRIT Conflict of Interest Policy 

Statement. 

11. Retention of Legal Counsel: Recommend to the Board for approval the retention of legal 

counsel as necessary to (i) advise the Board on all matters relating to the Board’s 

responsibilities, (ii) oversee investment matters approved by the Board, and (iii) provide 

counsel on such other matters as may be deemed necessary by the Board. 

12. Legal Compliance: Review processes recommended by counsel to ensure that all 

compensation and benefit programs (including any deferred compensation program 

structured to meet Internal Revenue Service rules) are structured to be compliant with 

federal and other applicable laws. 

13. Administrative Operations: Oversee NRRIT administrative operations and review annually 

a report prepared by the SOO on the operation and cost of systems to manage payroll, 

employee benefits, occupancy costs, insurance, information technology, and commercial 

banking services (other than those of the Trust custodian). 

14. Self Assessment: Undertake an annual self assessment to ensure that the Committee is 

meeting the responsibilities set forth in this Resolution. This self assessment shall include 

as an appendix the annual operations report prepared by the SOO referenced in the 

preceding paragraph. 

As approved by the Board on May 22, 2013 

4839-3009-4869, v. 3 
 

 APPENDIX K




 

 APPENDIX L
UNITED STATES OF AMERICA

RAILROAD RETIREMENT BOARD

844 NORTH RUSH STREET

CHICAGO, ILLINOIS 60611-1275

BOARD MEMBERS:

ERHARD R. CHORLÉ, CHAIRMAN

JOHN BRAGG, LABOR MEMBER

THOMAS JAYNE, MANAGEMENT MEMBER

October 22, 2021

The Honorable Janet L. Yellen

Secretary of the Treasury

Washington, D.C. 20220

Dear Madam Secretary:

In accordance with Section 23(b) of the Railroad Retirement Act of 1974, we certify the 

Account Benefits Ratio for fiscal year 2021 to be 5.09.

Chapter 22, Subchapter E, Section 3241 of the Internal Revenue Code of 1986, as added 

by Title II, Section 204, of the Railroad Retirement and Survivors’ Improvement Act of 

2001, requires that the Secretary of the Treasury determine the Average Account Benefits 

Ratio for the 10 most recent fiscal years, and publish a notice in the Federal Register, no 

later than December 1 of each calendar year, stating the rates of tax which are applicable 

for the following calendar year for rail employers, employee representatives, and 

employees. For your information, we estimate the 10-year Average Account Benefits 

Ratio, rounded to the next highest multiple of 0.1, to be 4.9.

Sincerely,
64992 Federal Register / Vol. 86, No. 221 / Friday, November 19, 2021 / Notices 

information on the safety performance 

of new vehicles to assist consumers 

with vehicle purchasing decisions and 

to encourage safety improvements. This 

proposed collection of information 

specifically seeks to evaluate design and 

consumer information improvements to 

the Government 5-Star Safety Ratings 

section of the Monroney label. NHTSA’s 

website is accessible and 508-compliant 

so that vehicle safety information is 

available and may benefit the 

purchasing decisions of everyone, 

including those with disabilities. 

(2) David DeVeau, DEVCO Design & 

Development: Consideration for a title 

and summary for the consumer research 

that is not restricted to the number of 

stars and is inclusive of the test results 

of conditions at speed. 

Response: The title of the proposed 

consumer research is based on the New 

Car Assessment Program’s (NCAP) 

current consumer program, the 

Government 5-Star Safety Ratings. 

NHTSA began using the 5-Star Safety 

Ratings system in 1993 to help 

consumers make informed safety 

choices when buying new or used 

vehicles. The proposed research seeks to 

evaluate a variety of label concepts to 

explore both graphical and text-based 

communications as potential 

modifications to the Government 5-Star 

Safety Ratings section of the Monroney 

label with the intent of finding the most 

effective way to display information 

related to vehicle safety. The research 

will also explore whether consumers 

prefer ratings using a 5-Star system (1– 

5 stars), a numerical value or numerical 

scale. If research findings determine that 

consumers prefer the presentation of 

ratings in an alternative way, NHTSA 

will explore further research which may 

have implications for changes to the 

title of the consumer program. 

(3) NTSB: Concerns about the 

proposed collection of information 

lacking specificity about crash 

avoidance and other technology to be 

included in the evaluated labels and 

consideration for performance ratings 

for vulnerable road user protection 

systems. 

Response: As NHTSA has done in the 

past, there are two separate tracks for 

NHTSA efforts to upgrade NCAP. One 

track is the development of NHTSA’s 

planned changes to NCAP—which is 

still ongoing, and the Agency intends to 

seek public comment on its proposal 

later in 2021. This track includes 

specific information about the crash 

avoidance and other technologies that 

NHTSA is considering including in 

NCAP such as performance thresholds, 

testing crash avoidance features, and 

developing a rating system that would 

compare all of those features. The other 

track is the rulemaking proceeding to 

update the safety ratings section on the 

Monroney label, which is the 

visualization of the safety performance 

information that would be available to 

consumers. NHTSA conducts 

comprehensive consumer research to 

inform its rulemakings to update the 

visualization of NCAP’s rating 

information that would be included on 

the Monroney label. This consumer 

research does not focus on the details of 

the underlying rating system or any 

substantive changes to NCAP. Instead, 

NHTSA plans to use this consumer 

research to determine how to best 

convey vehicle safety rating 

information, including crash avoidance 

technologies, to the public. This 60-day 

notice initiates the multi-phase 

consumer research that NHTSA intends 

to use to inform its future update to the 

Monroney label. NHTSA is mindful in 

its development of a new rating system 

and accompanying visualization of the 

rating system through the Monroney 

label of the flexibility necessary to allow 

the agency to regularly update NCAP 

while also minimizing the number of 

rulemaking actions needed each time 

the agency incorporates a new 

technology or program in NCAP. 

(4) Center for Auto Safety: Defining 

NCAP testing regimen before designing 

new safety labels. 

Response: Similar to the explanation 

provided to NTSB’s comment, there are 

two separate tracks for upgrading NCAP 

and upgrading the visualization of 

NCAP rating information on the 

Monroney label. Defining the NCAP 

testing regimen will be part of the first 

track, which will be detailed in 

upcoming requests for comments to 

upgrade NCAP. The consumer research 

efforts focus more on the consumer 

understanding of the safety information 

on the Monroney label and what 

NHTSA disseminates to the public. 

Also, due to the limited area on the 

Monroney label, the consumer research 

will help guide NHTSA on which 

visualization would best convey 

complex safety information to the 

public in a more consumer-friendly and 

flexible approach that is intended to 

minimize the number of rulemaking 

actions to update the Monroney label 

after future NCAP upgrades. 

Public Comments Invited: The results 

of this research will be used to inform 

labeling requirement proposals and 

communications for the New Car 

Assessment Program, also known as the 

Government 5-Star Safety Ratings 

Program. You are asked to comment on 

any aspects of this information 

collection, including (1) whether the 

proposed collection of information is 

necessary for the proper performance of 

the functions of the Department, 

including whether the information will 

have practical utility; (2) the accuracy of 

the Department’s estimate of the burden 

of the proposed information collection; 

(3) ways to enhance the quality, utility 

and clarity of the information to be 

collected; and (4) ways to minimize the 

burden of the collection of information 

on respondents, including the use of 

automated collection techniques or 

other forms of information technology. 

The agency will summarize and/or 

include your comments in the request 

for OMB’s clearance of this information 

collection. 

Authority: The Paperwork Reduction 

Act of 1995; 44 U.S.C. chapter 35, as 

amended; 49 CFR 1.49; and DOT Order 

1351.29. 

Issued on: November 16, 2021. 

Juliette Marie Vallese, 

Associate Administrator, Office of 

Communications and Consumer Information. 

[FR Doc. 2021–25241 Filed 11–18–21; 8:45 am] 

BILLING CODE 4910–59–P 

DEPARTMENT OF THE TREASURY 

Internal Revenue Service 

Publication of the Tier 2 Tax Rates 

AGENCY: Internal Revenue Service (IRS), 

Treasury. 

ACTION: Notice. 

SUMMARY: Publication of the tier 2 tax 

rates for calendar year 2022 as required 

by the Internal Revenue Code. Tier 2 

taxes on railroad employees, employers, 

and employee representatives are one 

source of funding for benefits under the 

Railroad Retirement Act. 

DATES: The tier 2 tax rates for calendar 

year 2022 apply to compensation paid 

in calendar year 2022. 

FOR FURTHER INFORMATION CONTACT: 

Kathleen Edmondson, 

CC:EEE:EOET:ET1, Internal Revenue 

Service, 1111 Constitution Avenue NW, 

Washington, DC 20224, Telephone 

Number (202) 317–6798 (not a toll-free 

number). 

Tier 2 Tax Rates: The tier 2 tax rate 

for 2022 under section 3201(b) on 

employees is 4.9 percent of 

compensation. The tier 2 tax rate for 

2022 under section 3221(b) on 

employers is 13.1 percent of 

compensation. The tier 2 tax rate for 

2022 under section 3211(b) on employee 

representatives is 13.1 percent of 

compensation. 


khammond on DSKJM1Z7X2PROD with NOTICES
Federal Register / Vol. 86, No. 221 / Friday, November 19, 2021 / Notices 64993 

Dated: November 9, 2021. 

Rachel D. Levy, 

Associate Chief Counsel (Employee Benefits, 

Exempt Organizations and Employment 

Taxes). 

[FR Doc. 2021–25296 Filed 11–18–21; 8:45 am] 

BILLING CODE 4830–01–P 

DEPARTMENT OF VETERANS 

AFFAIRS 

[OMB Control No. 2900–0618] 

Agency Information Collection 

Activity: Application by Insured 

Terminally Ill Person for Accelerated 

Benefit; Withdrawn 

AGENCY: Veterans Benefits 

Administration, Department of Veterans 

Affairs. 

ACTION: Notice; withdrawal. 

SUMMARY: On November 5, 2021 the 

Veterans Benefits Administration (VA), 

published a notice in the Federal 

Register announcing an opportunity for 

public comment on the proposed 

collection Application by Insured 

Terminally Ill Person for Accelerated 

Benefit Form SGLI 8284. This notice 

was published in error; therefore, this 

document corrects that error by 

withdrawing this FR notice, document 

number 2021–24223. 

DATES: As of November 15, 2021, the FR 

notice published at 86 FR 61400 on 

Friday, November 5, 2021, is 

withdrawn. 

FOR FURTHER INFORMATION CONTACT: 

Maribel Aponte, Office of Enterprise 

and Integration, Data Governance 

Analytics (008), 1717 H Street NW, 

Washington, DC 20006, (202) 266–4688 

or email maribel.aponte@va.gov. 

SUPPLEMENTARY INFORMATION: FR Doc. 

2021–24223, published on November 5, 

2021 (86 FR 61400), is withdrawn by 

this notice. 

By direction of the Secretary. 

Maribel Aponte, 

VA PRA Clearance Officer,Office of Enterprise 

and Integration/Data Governance 

Analytics,Department of Veterans Affairs. 

[FR Doc. 2021–25258 Filed 11–18–21; 8:45 am] 

BILLING CODE 8320–01–P 

DEPARTMENT OF VETERANS 

AFFAIRS 

[OMB Control No. 2900–0353] 

Agency Information Collection 

Activity: Certification of Lessons 

Completed 

AGENCY: Veterans Benefits 

Administration, Department of Veterans 

Affairs. 

ACTION: Notice. 

SUMMARY: Veterans Benefits 

Administration, Department of Veterans 

Affairs (VA), is announcing an 

opportunity for public comment on the 

proposed collection of certain 

information by the agency. Under the 

Paperwork Reduction Act (PRA) of 

1995, Federal agencies are required to 

publish notice in the Federal Register 

concerning each proposed collection of 

information, including each proposed 

revision of a currently approved 

collection, and allow 60 days for public 

comment in response to the notice. 

DATES: Written comments and 

recommendations on the proposed 

collection of information should be 

received on or before January 18, 2022. 

ADDRESSES: Submit written comments 

on the collection of information through 

Federal Docket Management System 

(FDMS) at www.Regulations.gov or to 

Nancy J. Kessinger, Veterans Benefits 

Administration (20M33), Department of 

Veterans Affairs, 810 Vermont Avenue 

NW, Washington, DC 20420 or email to 

nancy.kessinger@va.gov. Please refer to 

‘‘OMB Control No. 2900–0353’’ in any 

correspondence. During the comment 

period, comments may be viewed online 

through FDMS. 

FOR FURTHER INFORMATION CONTACT: 

Maribel Aponte, Office of Enterprise 

and Integration, Data Governance 

Analytics (008), 1717 H Street NW, 

Washington, DC 20006, (202) 266–4688 

or email maribel.aponte@va.gov. Please 

refer to ‘‘OMB Control No. 2900–0353’’ 

in any correspondence. 

SUPPLEMENTARY INFORMATION: Under the 

PRA of 1995, Federal agencies must 

obtain approval from the Office of 

Management and Budget (OMB) for each 

collection of information they conduct 

or sponsor. This request for comment is 

being made pursuant to Section 

3506(c)(2)(A) of the PRA. 

With respect to the following 

collection of information, VBA invites 

comments on: (1) Whether the proposed 

collection of information is necessary 

for the proper performance of VBA’s 

functions, including whether the 

information will have practical utility; 

(2) the accuracy of VBA’s estimate of the 

burden of the proposed collection of 

information; (3) ways to enhance the 

quality, utility, and clarity of the 

information to be collected; and (4) 

ways to minimize the burden of the 

collection of information on 

respondents, including through the use 

of automated collection techniques or 

the use of other forms of information 

technology. 

Authority: 38 U.S.C. 3032(d), 3034, 

3241, 3323, 3474, 3481, 3484, 3534(b), 

3680(b), 3684, 3686(a), and 10 U.S.C 

16131(e), and chapter 31 section 510., 

and 38 CFR 21.4203(e), 21.4206, 

21.5200(d) & (g), 21.7140(c)(3), 21.7159, 

21.7640(a)(4), 21.7659, and 21.9720. 

Title: Certification of Lessons 

Completed. 

OMB Control Number: 2900–0353. 

Type of Review: Revision of a 

currently approved collection. 

Abstract: VA uses information from 

the current collection to determine the 

number of lessons completed by the 

student and serviced by the 

correspondence school, and to 

determine the date of completion or 

termination of correspondence training. 

VA pays education benefits based on the 

information furnished on the form. 

Without this information, VA would be 

unable to determine the proper payment 

or the student’s training status. 

Affected Public: Individuals and 

Households. 

Estimated Annual Burden: 103 hours. 

Estimated Average Burden per 

Respondent: 10 minutes. 

Frequency of Response: Quarterly. 

Estimated Number of Respondents: 

616. 

By direction of the Secretary. 

Maribel Aponte, 

VA PRA Clearance Officer, Office of 

Enterprise and Integration/Data Governance 

Analytics, Department of Veterans Affairs. 

[FR Doc. 2021–25265 Filed 11–18–21; 8:45 am] 

BILLING CODE 8320–01–P 


khammond on DSKJM1Z7X2PROD with NOTICES
 

 APPENDIX M




 

 

 APPENDIX N

 
BOARD OF TRUSTEES

FEBRUARY 1, 2021 TO JANUARY 31, 2022 

BIOGRAPHICAL INFORMATION

CHAIR: George J. Francisco, Jr. currently serves as President Emeritus of the National 

Conference of Firemen & Oilers, SEIU (NCFO). Previously, he served as President of the 

NCFO, from January 1998 until his retirement on December 31, 2010. As NCFO President, 

he had extensive experience serving as a trustee of a number of union pensions, 401(k) 

and health and welfare funds, including the Affiliates’ Officers and Employees Pension 

and the Supplemental Retirement Savings (401(k)) plans of the 1.5 million-member SEIU, 

as well as the Firemen and Oilers National Pension and Welfare Plan. During his more 

than 35 years with NCFO, Mr. Francisco also served as the Conference Vice President, 

before becoming Conference Secretary-Treasurer in 1996. He also served as Vice 

President of Local 32BJ, SEIU, representing more than 120,000 members. Mr. Francisco 

holds a BS degree from the University of Dubuque. He has served on the Board since 

February 1, 2002. 

Mary S. Jones served as Vice President and Treasurer of Union Pacific Corporation until 

her retirement on December 1, 2017. In her position, Ms. Jones was responsible for 

corporate finance, investor relations, insurance, banking and cash management, and 

oversight of the company’s benefit plan investments. Ms. Jones joined Union Pacific 

Corporation in New York in 1980 as a Strategic Planning Associate. In 1982, she 

transferred to Union Pacific Resources in Denver, where she held various positions in 

financial management and analysis. She returned to Union Pacific Corporation in 1988, 

joining the controller’s department as Manager – Planning and Analysis, for trucking 

transportation. She became Assistant Vice President, Investor Relations in 1994, and 

was actively involved in the restructuring of the holding company. In 1998 she was 
2 

promoted to Vice President – Investor Relations, the position she held before her 

promotion to Vice President and Treasurer. She holds a Bachelor of Arts degree from 

Carleton College and a Master's degree in Business Administration from Columbia 

University. Ms. Jones has served on the Board since June 1, 2010.

Beth Miller is Treasurer of BNSF Railway Company, with more than 30 years of 

experience in rail industry financial management positions. Her current areas of 

responsibility include heading up BNSF’s treasury and risk management functions, 

including execution of capital market transactions, corporate liquidity management, 

equipment financing, developing cash management solutions and compliance, oversight 

of the company’s benefit plan investments, insurance procurement, insurance recoveries 

and compliance, and serving as President of two insurance companies. Prior to her 

current responsibilities she held various roles with increasing responsibility in the treasury 

and risk management areas, and had a leadership role in the inaugural SAP 

implementation at BNSF. Ms. Miller holds a BBA in Risk Management from the University 

of Wisconsin – Madison and a Master’s of Science in Corporate Finance from the University 

of Dallas. She has served on the Board since February 1, 2019. 

Joel Parker served as Special Assistant to the President and National Vice President of 

the Transportation Communications International Union (TCU)/IAM until his retirement 

at the end of 2016. He was elected to the Vice President position in 1991, and reelected 

in 1995, 1999, 2004, 2009, and 2014. The Transportation Communications International 

Union is one of the oldest, largest, and most diversified unions in the transportation 

industry, tracing its representation of railroad workers back to 1899. Today, the union 

represents 46,000 active railroad workers and 13,000 retirees that are covered by the 

railroad retirement program. In 2005, TCU merged with the International Association of 

Machinists, which has approximately 700,000 active and retired members. Mr. Parker, 

who has 40 years of experience within the railroad industry, had been active in union 

leadership for 36 years of this period. At the TCU, Mr. Parker had primary responsibility 

for collective bargaining, arbitration, and pension issues. In addition, Mr. Parker served 
3 

as Trustee for the TCU 401(k) Plan, and previously served as Trustee for the Los Angeles 

County MTA pension plan and the Los Angeles County TCU Health and Welfare Plan. Mr. 

Parker was one of the primary negotiators in the labor-management agreement signed 

in January 2000 that led to the passage of the Railroad Retirement and Survivors’ 

Improvement Act of 2001. He has served on the Board since February 1, 2002. 

William F. Quinn was the chairman and founder of American Beacon Advisors, a $56 

billion investment management firm responsible for managing the American Airlines 

pension funds as well as assets from external clients including the American Beacon 

mutual funds. Prior to his retirement from American Beacon on September 30, 2015, he 

had been with the firm and its predecessors, which was wholly owned by AMR Corporation 

until 2008, since 1974. Mr. Quinn was appointed by Mayor Rawlings to the Dallas Police 

& Fire Pension Board in September 2017 and was elected Chairman by the Board in 

October 2017. He was appointed to the Board of CSW Industrials, a publicly traded 

NASDAQ listed company, on October 1, 2015, and served until August 2021. In August 

2021, Mr. Quinn was elected to the Board of Texas Mutual Insurance, the predominant 

workers compensation insurer in the State of Texas. He also formerly served on the 

boards of directors of three other public companies, and has served on several investment 

committees for non-profit endowments and has been a leader within the corporate 

pension community serving on several industry groups. He is a graduate of Fordham 

University and became a certified public accountant while working at Arthur Young & Co. 

Mr. Quinn has served on the Board since February 1, 2011. 

Bill Slater currently serves as the Acting Head of Finance and Treasury at CSX, and 

previously oversaw CSX’s Investor Relations, Service Measures, and Pension functions. 

Before joining CSX, he served as a Vice President at Altamont Capital Partners where he 

oversaw a portfolio of operationally focused investments in the Healthcare, Consumer, 

and Industrial sectors. Prior to Altamont, he covered Large Cap Industrials at Janus 

Capital Group. Mr. Slater began his career as an investment banking analyst at Goldman 

Sachs and with Chicago-based private equity firm GTCR. He holds a bachelor’s degree 
4 

in economics from Vanderbilt University and earned an MBA from Harvard Business 

School. Mr. Slater has served on the Board since February 1, 2021. 

William C. Walpert is National Secretary-Treasurer Emeritus of the Brotherhood of 

Locomotive Engineers and Trainmen (BLET), a Division of the Rail Conference of the 

International Brotherhood of Teamsters. As the BLET’s National Secretary-Treasurer prior 

to January 1, 2015, he was in custody of all funds of the BLET and had supervision over 

the financial and record department personnel of the BLET. Since 2001, Mr. Walpert has 

served as a trustee for the BLET defined benefit retirement plan serving National Division 

employees; the Brotherhood of Locomotive Engineers’ (BLE) 401(k) retirement plan, a 

deferred compensation plan serving National Division and General Committee employees; 

and the BLE’s non-qualified deferred compensation plan serving National Division 

employees. Since 2004, he has served as Secretary of the BLET Disability and Welfare 

Benefit Trust Fund Administrative Trust. Previously, as General Secretary-Treasurer of 

the BLE, Mr. Walpert was in charge of the BLE Finance Committee that helped merge the 

BLE with the International Brotherhood of Teamsters. He first began working in the rail 

industry in 1973, and holds Bachelor’s and Master’s degrees from Missouri State 

University. Mr. Walpert has served on the Board since October 19, 2011. 
5 

NATIONAL RAILROAD RETIREMENT INVESTMENT TRUST

BIOGRAPHICAL INFORMATION

INVESTMENT STAFF AS OF SEPTEMBER 30, 2021 

Senior Staff 

William J. Carr, III was named Chief Executive Officer/Chief Investment Officer of 

the Trust on April 12, 2016. Mr. Carr joined the Trust as Director of US Equity on May 

3, 2010. Prior to joining the Trust, Mr. Carr was Senior Investment Analyst at the 

District of Columbia Retirement Board for more than eight years where he covered 

multiple asset classes and advised the Board on numerous issues, including asset 

allocation and manager selection. Previously, Mr. Carr was Vice President and Portfolio 

Manager for an emerging markets private equity fund manager for over five years. Mr. 

Carr served as a Peace Corps Volunteer in Poland as an economic advisor from 1994 to 

1996. Mr. Carr’s other prior work experience includes corporate attorney for Miller, 

Nash, Wiener, Hager, & Carlsen, and auditor for Touche Ross. Mr. Carr earned the CFA 

designation in 2001. Mr. Carr holds a BBA degree in accounting from Millsaps College 

and a JD degree from the University of Virginia School of Law. 

Neil E. Kotras was named Chief Financial Officer/Chief Operating Officer on October 2, 

2015. From April 25, 2006 to that date, Mr. Kotras served as the Trust’s Senior 

Accounting Officer. Effective August 17, 2016, Mr. Kotras also serves as Chief 

Compliance Officer of the Trust. Prior to joining the Trust, Mr. Kotras worked as 

Assistant Vice President as a member of the Investment Treasury group at T. Rowe 

Price Associates, where he was responsible for financial reporting and accounting policy 

for the firm’s mutual fund products. Also in this capacity, Mr. Kotras had oversight of 

the firm’s Financial Reporting group. Previously, he was a manager in the audit practice 

of PricewaterhouseCoopers LLP (PwC), where he was responsible for several large asset 

management engagements in the Baltimore/ Washington DC Metro area. Mr. Kotras 
6 

holds an undergraduate degree in accounting and economics from the Sellinger School 

of Business at Loyola University Maryland, and an MBA in finance from the Robert H. 

Smith School of Business at the University of Maryland. Mr. Kotras is a CFA 

charterholder and a CPA. 

Other Staff Members (in alphabetical order) 

Annita Biondo was named Director of Operations on July 1, 2015. She joined the 

Trust as a Financial Analyst on October 1, 2007. Prior to joining the Trust, she was a 

Tax Accountant at RSM McGladrey. Previously, Ms. Biondo worked at General Motors 

and other fortune 500 companies in finance and human resources. She received a BS 

degree from Indiana University of Pennsylvania and an MBA from Marymount 

University. 

Ross M. Breslin serves as the Senior Investment Analyst for Real Assets. Mr. Breslin 

joined the trust on January 1, 2017 as an Investment Analyst covering International 

Equities and in 2020 transitioned to Real Assets. Prior to joining the Trust, Mr. Breslin 

was an Assistant Vice President, Portfolio Manager Associate for U.S. Trust, Bank of 

America Private Wealth Management. He was responsible for providing integrated 

investment advice and portfolio management services to high net worth families and 

institutional clients. Mr. Breslin holds a BSBA with a concentration in finance from The 

Catholic University of America.

Rhett Butler serves as the Senior Investment Analyst for Fixed Income. Mr. Butler 

joined the Trust on March 3, 2014, as an Investment Analyst focused on Absolute 

Return and transitioned to the public markets team in 2016. Prior to joining the Trust, 

Mr. Butler worked at T. Rowe Price Associates, where he was responsible for providing 

investment research and analytical support on target-date and target-risk asset 

allocation portfolios. Mr. Butler earned a BA in economics from the University of 

Maryland, Baltimore County, and is a CFA and CAIA charterholder. 
7 

Collin Church serves as the Investment Analyst covering International Equities. Mr. 

Church joined the Trust on January 16, 2018 as an Investment Analyst focused on 

Absolute Return and Commodities and in 2019 transitioned to International Equities. 

Prior to joining the Trust, he was a Credit Risk Associate at KPMG within their 

Securitization division. Mr. Church earned a BA degree in Finance from James Madison 

University and is a CFA charterholder. 

Xiaolu “Claire” Cui joined the Trust on February 16, 2014. She currently serves as the 

Senior Investment Analyst for Private Equity. Prior to joining the Trust, Ms. Cui was a 

financial engineer at Fannie Mae responsible for implementing financial models used in 

the securitization of mortgage-backed securities. Previously, she was a Treasury Analyst 

at the Carlyle Group where she managed a billion dollar investment portfolio of shortterm securities and several multibillion-dollar credit facilities. Prior to that, she was an 

auditor with Ernst & Young where she performed financial statement audits of publicly 

and privately held companies in biotechnology, technology, and media industries. Ms. 

Cui holds a BS degree from the McIntire School of Commerce at the University of 

Virginia. She is a CFA charterholder and a CPA. 

Kyle Dellamura joined the Trust on May 7, 2019 as an Operations Analyst. Prior to 

joining the Trust, Mr. Dellamura worked at Morgan Stanley as an Operations Associate 

where he was responsible for trade processing and settlement as well as the monitoring 

of buy-in risk within Stock Loan Settlements. Mr. Dellamura earned a BA in International 

Business from Washington College.

Liz Fisher is the Senior Investment Director of Fixed Income. She was named as 

Director of Fixed Income in April 2014 and promoted to Senior Investment Director of 

Fixed Income in 2019. Ms. Fisher joined the Trust as Senior Investment Analyst – Real 

Assets on December 3, 2007 and transitioned to the public markets team in 2013. Prior 

to joining the Trust, Ms. Fisher was a Senior Investment Analyst with the State 
8 

Retirement and Pension System of Maryland for approximately two years, where she 

was responsible for oversight of the System’s fixed income and real estate managers. 

Previously, she worked for Legg Mason Wood Walker, Inc. for approximately 13 years, 

with the majority of her tenure as a credit analyst and strategist in the Fixed Income 

Capital Markets group. Ms. Fisher is a CFA charterholder and earned a BS degree in 

business at the University of Maryland. 

J. Lodge Gillespie Jr joined the Trust on September 1, 2014 and serves as Senior 

Investment Director – Real Assets. Prior to joining the Trust, Mr. Gillespie was a 

Managing Director of Private Investments at The Investment Fund for Foundations 

(TIFF), where he managed a $725 million portfolio of private real estate and natural 

resource investments on behalf of TIFF’s non-profit foundation and endowment 

members. Mr. Gillespie previously spent three years with Standard & Poor’s analyzing 

trends in the institutional investment marketplace. Mr. Gillespie received an AB degree 

from Colgate University and an MA degree from the University of Virginia. He is a CFA 

charterholder. 

Naya Gonzalez joined the Trust as the Office Manager on August 6, 2018. Prior to 

joining the Trust, Ms. Gonzalez worked as the Operations Manager for GriffinWorx, and 

has over ten years of business management experience in various fields. Ms. Gonzalez 

received a BBA in Finance and a BA in Accounting from the University of the District of 

Columbia, and is currently pursuing a Master’s degree in Business Administration from 

Howard University. 

Pauline Jones joined the Trust as a temporary Administrative Assistant on July 28, 

2014. In May of 2015, Pauline was brought on as a full-time employee to continue her 

duties as an Administrative Assistant in the Operations Department. Prior to joining the 

trust, Ms. Jones worked for six years with Loewinger & Brand Real Estate Law firm in 

Washington, DC as the receptionist/time entry billing clerk. She received a certificate 
9 

from Strive DC Inc. in Customer Service Training and a certificate in Fundamentals of 

Human Resources from Alison Advance Learning. 

Barry Kaplan is the Senior Investment Director of International Equity. From 2010 – 

2017, Mr. Kaplan was the Trust’s Director of Absolute Return Investments. On April 2, 

2007, Mr. Kaplan joined the Trust as a Senior Investment Analyst – Private 

Equity. Prior to joining the Trust, he worked for Nuveen Investments, where he was 

involved in the execution of closed-end fund product strategies. Additionally, Mr. 

Kaplan worked as an Associate for Duff & Phelps, performing business and asset 

valuations. Preceding this role, he completed the Financial Leadership Program at 

AT&T, working in various business units. He received an undergraduate degree from 

the University of Maryland and an MBA from the Kellogg School of Management at 

Northwestern University in 2005. Mr. Kaplan is a CFA charterholder.

Courtney C. Macdonald was named Director of US Equity on May 18, 2016. Ms. 

Macdonald joined the Trust as an Investment Analyst, focused on Private Markets, on 

March 16, 2010. Prior to joining the Trust, she was a Senior Associate in the 

Investment Consulting Group at Cambridge Associates, working with endowments and 

foundations on asset allocation and manager selection. Ms. Macdonald received a BA in 

economics from Johns Hopkins University in 2005 and is a CFA charterholder. 

Maire-Kate McGlynn joined the Trust on March 16, 2020 as an Investment Analyst 

covering US Equity. Prior to joining the Trust, Ms. McGlynn was a Senior Wealth 

Investment Associate at Wilmington Trust, N.A., collaborating with investment advisors 

to provide high net worth individuals and families customized investment advice and 

portfolio management. Additionally, she completed the Management Development 

Program at M&T Bank, the parent company of Wilmington Trust, N.A. Ms. McGlynn 

received a BA in Economics and Anthropology from the University of Notre Dame. She 

is a CFA Level III Candidate. She is a CFA charterholder. 
10 

Erik A. Murad is the Director of Absolute Return and Opportunistic. From 2017 – 

2020, Mr. Murad was the Director of Absolute Return and Commodities. Mr. Murad 

joined the Trust on July 1, 2012, as an Investment Analyst focused on public 

markets. Prior to joining the Trust, Mr. Murad completed his graduate degree at the 

University of Maryland. Previously, he worked as a Financial Analyst for Oberthur 

Technologies. Mr. Murad received a BA degree in economics from the University of 

Virginia in 2008 and an MBA degree from the University of Maryland’s Smith School of 

Business in 2012. Mr. Murad is a CFA charterholder. 

Michael A. Reeves joined the Trust on September 1, 2004 as Senior Investment 

Advisor of Private Equity. On October 1, 2006, Mr. Reeves was named Director of 

Private Markets, and on October 1, 2019, Mr. Reeves was named Senior Investment 

Director – Private Markets. Mr. Reeves joined the Trust from FleetBoston Financial 

Company where he was an Associate overseeing the bank’s private equity investments. 

Previously, he had worked with the State Street Corporation and other entities in the 

analysis and monitoring of private equity investments. Mr. Reeves earned a BS degree 

in finance from Western New England University and an MBA from the University of San 

Francisco. 

Emily C. Weiss is a Senior Financial Analyst. Ms. Weiss joined the Trust as a Financial 

Analyst on June 16, 2015. Prior to joining the Trust, Ms. Weiss worked as a Senior 

Associate at CohnReznick LLP, completing tax and financial statement engagements in 

the firm’s Private Company Services group. Ms. Weiss earned BSBA and MS degrees in 

accounting from American University and is a CPA. 

Justin R. Wood is a Senior Investment Analyst covering Absolute Return and 

Opportunistic. Mr. Wood joined the Trust on August 15, 2016, as an Investment Analyst 

focused on Global Fixed Income. He transitioned to focus on Absolute Return and 

Commodities, and then Absolute Return and Opportunistic, in 2019 and 2021, 

respectively. Prior to joining the Trust, Mr. Wood was an Investment Analyst for 
11 

Financial Services Advisory, an investment advisory firm in the Washington, DC-area, 

where he was a member of the firm’s portfolio management team. Prior to that, Mr. 

Wood worked for Cypress Capital (formerly known as Hays Advisory), an investment 

advisory firm in the Nashville, TN-area, where he supported the firm’s investment 

committee as a Research Analyst. Mr. Wood is a CFA charterholder and holds a BBA 

degree in finance from Belmont University in Nashville, TN, where he graduated summa 

cum laude.
NRRIT

National Railroad Retirement Investment Trust 

2001 K Street, N.W. 

Suite 1100 

Washington, DC 20006