Contract analysis

1. Purpose of This Letter This letter is provided annually to guide you through the procedures for funding the annual premium payment on the second-to-die universal life insurance policy held by the ILIT. As you will recall, the ILIT was established on March 15, 2023, pursuant to the Caldwell Family Insurance Trust Agreement of even date (the "Trust Agreement"), with Northgate Trust Company of Delaware serving as the

2. Annual Premium Amount and Payment Timing The annual premium due on the Policy is $187,500. The premium due date for each policy year should be confirmed with Beacon Life Assurance Company through your insurance broker, Glenmore Insurance Brokerage LLC (Nathan C. Freed, Senior Vice President, Private Client Division), or through Northgate Trust Company of Delaware (Philip A. Rossiter, Senior Vice President, Trust A

3. Gift Tax Treatment of Premium Contributions 3.1 Overview. Each annual premium payment that you make to the ILIT constitutes a gift for federal gift tax purposes. Because the ILIT is an irrevocable trust of which you are neither a trustee nor a beneficiary, and because you retain no incidents of ownership in the Policy, your contribution of funds to the ILIT for the purpose of paying the premium is treated as a com

4. Crummey Withdrawal Notice Procedures 4.1 Requirement. Under established IRS guidance and the seminal decision in Crummey v. Commissioner, 397 F.2d 82 (9th Cir. 1968), in order for contributions to the ILIT to qualify for the annual gift tax exclusion under IRC § 2503(b), each Crummey beneficiary must receive timely written notice of his or her right to withdraw a portion of the contribution. The notice requirement

5. Three-Year Lookback Rule — IRC § 2035 An important consideration in the administration of the ILIT is the three-year lookback rule under IRC § 2035. Under this provision, if an insured transfers a life insurance policy — or any incidents of ownership in a life insurance policy — to an irrevocable trust within three years of the insured's death, the full death benefit of the policy may be included in the insured's

6. Annual Checklist — Summary of Steps For your convenience, the following is a numbered checklist summarizing the steps you should take each year in connection with the annual premium funding cycle. We recommend that you (and Ms. Linden at Havensbrook Wealth Advisors) refer to this checklist approximately 60 days before the anticipated premium due date to ensure that all steps are completed in a timely manner.

1. Confirm premium amount and due date. Contact Northgate Trust Company of Delaware (Philip A. Rossiter, Senior Vice President, Trust Administration, 1201 North Market Street, Suite 1600, Wilmington, DE 19801) or Glenmore Insurance Brokerage LLC (Nathan C. Freed, Senior Vice President, Private Client Division, 44 Wall Street, Suite 1200, New York, NY 10005) to confirm the annual premium amount ($187,500, subject to a

2. Transfer funds to Northgate. Wire $187,500 to the Caldwell Family Insurance Trust account at Northgate Trust Company of Delaware at least 45 days before the premium due date. Include the reference: "Policy No. BLA-2023-77419 — Annual Premium." Verify wire instructions with Mr. Rossiter before initiating the transfer.

3. Notify Northgate and Calderwood & Harkness LLP. Upon completing the wire transfer, confirm the transfer with Philip A. Rossiter at Northgate and with Victoria Chambers or Monica Reyes at Calderwood & Harkness LLP.

4. Crummey notices issued. Confirm with Northgate that Crummey withdrawal notices have been sent to each of the three beneficiaries — Thomas R. Caldwell, Katherine C. Hartfield, and Olivia G. Caldwell — within 3 to 5 business days of Northgate's receipt of the contribution. Request copies of the notices and proof of mailing for your records. 5. 30-day withdrawal period lapses. No action is required on your part durin

6. Premium paid by Northgate. Confirm with Northgate that the premium payment has been remitted to Beacon Life Assurance Company before the premium due date. Request written confirmation from Northgate of the date and amount of the payment.

7. Policy confirmation. Request an annual policy statement from Beacon Life Assurance Company (through Glenmore Insurance Brokerage LLC, Nathan C. Freed) confirming that the Policy is in force, the current cash surrender value, and the death benefit of $15,000,000. Review the statement for any discrepancies and forward a copy to Calderwood & Harkness LLP and Havensbrook Wealth Advisors LLC.

8. Gift tax return coordination. Provide the following documentation to Strathmore Corporation & Greaves LLP (Martin J. Prescott, CPA) for inclusion on your annual Form 709: • the amount contributed to the ILIT; • copies of all Crummey withdrawal notices issued by Northgate; • annual exclusion and lifetime exemption calculations (as set forth in this letter, updated for the applicable year); and • any other documenta

9. File records. Retain all correspondence, wire transfer confirmations, Crummey withdrawal notices, proof of mailing, policy statements, and Form 709 copies in your dedicated ILIT file. Provide copies to Havensbrook Wealth Advisors LLC (Diana R. Linden) for inclusion in your comprehensive financial records.

7. Coordination with Advisors The proper administration of the ILIT requires ongoing coordination among several professional advisors. This letter should be shared with each of the following individuals for coordination purposes: Strathmore Corporation & Greaves LLP — Martin J. Prescott, CPA, Senior Partner, Private Client Group, 600 Third Avenue, 28th Floor, New York, NY 10016. Mr. Prescott is responsible for the pr

8. Important Reminders and Caveats We wish to emphasize the following important reminders and caveats in connection with the annual premium funding process: (a) Annual Review of This Letter. This letter is designed as a template for annual use and should be reviewed each year to reflect any changes in applicable law, exemption amounts, annual exclusion amounts, premium amounts, or family circumstances. Examples of ci

1. ILIT — Form Crummey Withdrawal Notice (template)

2. Wire transfer instructions for Northgate Trust Company of Delaware (Caldwell Family Insurance Trust account)

3. Beacon Life Assurance Company premium billing schedule (Policy No. BLA-2023-77419) Field | Detail Bank | [To be provided by Northgate Trust Company of Delaware] Account Name | Caldwell Family Insurance Trust Trustee Contact | Philip A. Rossiter, Senior Vice President, Trust Administration Trustee Address | 1201 North Market Street, Suite 1600, Wilmington, DE 19801 Reference/Memo | Policy No. BLA-2023-77419 — Annua