P.O. Box 460, The Commons
NOTES TO FINANCIAL STATEMENTS
DECEMBER 31, 2013 AND 2012
NOTE A: DESCRIPTION OF PLAN
The following description of the Tompkins
Financial Corporation Investment and Stock Ownership Plan (the “Plan”) provides only general information. Participants
should refer to the Plan agreement for a more complete description of the Plan’s provisions.
General
The Plan is a defined contribution plan covering
eligible employees who have met certain age and service requirements. The Plan is administered by the Executive, Compensation/Personnel
Committee appointed by Tompkins Financial Corporation’s Board of Directors, and is subject to the provisions of the Employee
Retirement Income Security Act of 1974 (ERISA). All investments of the Plan are participant directed.
Eligibility
All employees are eligible to begin voluntary
contributions and receive matching contributions on the first day of the month coinciding with attaining the age of twenty-one.
Employees are eligible for discretionary contributions on the first day of the month coinciding with completing one year of credited
service and attaining the age of twenty-one. Leased employees, employees covered under a collective bargaining agreement and “On Call”
employees are not eligible to participate.
Vesting
Participants are immediately vested in all
contributions and earnings thereon. Effective January 1, 2014, the vesting provision of the plan was amended to provide for vesting
on the non-elective and matching contributions based on years of service. For employees hired on or after January 1, 2014, a participant
is 100 percent vested in the matching contributions after three years of service.
Contributions
Participants may contribute their entire eligible
compensation, as defined, subject to certain Internal Revenue Service limitations. The Plan sponsor matching contributions are
equal to 100% of the first 3% of elective deferral and 50% of the next 2% of elective deferral.
Additionally, the Plan sponsor may contribute
amounts annually at the discretion of the Board of Directors based on a percentage of the total compensation of all eligible participants
during any plan year. Participants are given the opportunity to elect to receive in cash that portion of their allocation, which
the Board shall designate as eligible for cash election for the Plan year, or they may elect to allocate all or part to their
plan account maintained on their behalf in the Plan. The Board approved a 4% and 3% contribution for 2013 and 2012, respectively.
Participant notes receivable
Participant notes receivable are measured
and valued at their unpaid principal balance plus any accrued but unpaid interest. Loans may be made to participants for a maximum
of $50,000, but no more than 50% of the participant’s vested account balance. The loans are secured by the balance of the
participant’s account and bear interest at the bank prime rate plus 1% at the time of the loan. Principal and interest is
paid through payroll deductions over a term of one to five years, except loans used to purchase a participant’s principal
residence which may exceed five years.
TOMPKINS FINANCIAL CORPORATION
INVESTMENT AND STOCK OWNERSHIP PLAN
NOTES TO FINANCIAL STATEMENTS, Cont’d
DECEMBER 31, 2013 AND 2012
NOTE A: DESCRIPTION OF PLAN
, Cont’d
Diversification and transfers
Under the Tompkins Financial Corporation Employee
Stock Ownership Plan document, participants meeting certain age and service requirements may elect to diversify the eligible portion
of the Company stock held in their account. The funds elected to be diversified are transferred to the Plan and invested into
funds as chosen by the participant. During 2013 and 2012, participants transferred $188,278 and $227,713, respectively.
Participants’ accounts
Each participant’s account is credited
with the participant’s elective deferral, an allocation of the Company’s matching and discretionary contributions
and allocation of plan earnings. Allocations of company contributions are based upon the participant’s compensation and
the allocations of plan earnings are based upon participant account balances. The benefit to which a participant is entitled is
the benefit that can be provided from the participant’s account.
Payment of benefits
Upon termination of service, the participant’s
account is either maintained in the Plan, transferred to an individual retirement account in the participant’s name, directly
rolled over into a qualified retirement plan or paid to the participant in a lump sum.
NOTE B: SUMMARY OF SIGNIFICANT ACCOUNTING
POLICIES
Basis of accounting
The financial statements of the Plan are prepared
under the accrual method of accounting.
Investment valuation and income recognition
The Plan’s investments are stated at
fair value. Purchases and sales of investments are recorded on a trade-date basis. Interest income is accrued when earned. Dividends
are recorded on the ex-dividend date.
Following is a description of the valuation
methodologies used for assets measured at fair value. There have been no changes in the methodologies used at December 31, 2013
and 2012.
Tompkins Financial Corporation common stock
Tompkins Financial Corporation common stock
is valued at the market value as listed on the American Stock Exchange for publicly traded securities.
Mutual funds
Mutual funds are valued at quoted market prices.
Pooled market value separate accounts
The funds are organized as pooled separate
accounts of Prudential Retirement Insurance and Annuity Company (PRIAC), an ultimate wholly-owned subsidiary of Prudential Financial,
Inc., as investment vehicles for qualified retirement plans.
TOMPKINS FINANCIAL CORPORATION
INVESTMENT AND STOCK OWNERSHIP PLAN
NOTES TO FINANCIAL STATEMENTS, Cont’d
DECEMBER 31, 2013 AND 2012
NOTE B: SUMMARY OF SIGNIFICANT ACCOUNTING
POLICIES
, Cont’d
The value of each fund and of each unit of
participation is determined at the close of each day in which PRIAC and the New York Stock Exchange are open for business or as
determined by PRIAC (“Valuation Date”). Units of participation in each Fund are issued and redeemed only on a Valuation
Date, at the value so determined.
Guaranteed income fund (GIF)
Under the group annuity insurance contract
that supports this product, participants may ordinarily direct permitted withdrawal or transfers of all or a portion of their
account balance at Contract Value within reasonable timeframes. Contract Value represents deposits made to the contract, plus
earnings at guaranteed crediting rates, less withdrawals and fees. The GIF is a benefit responsive annuity contract. This product
is not a traditional guaranteed insurance contract and therefore there are not any known cash flows that could be discounted.
As a result, the fair value shown is equal to Contract Value.
The average yield earned by the Plan and its
participants was 2.25% and 2.60% for the years ended December 31, 2013 and 2012, respectively. Generally there are not any
events that could limit the ability of the Plan to transact at Contract Value paid within 90 days or in rare circumstances, Contract
Value paid over time. There are not any events that allow the issuer to terminate the contract and which require the Plan sponsor
to settle at an amount different than Contract Value paid either within 90 days or over time.
The preceding methods described may produce
a fair value calculation that may not be indicative of net realizable value or reflective of future fair values. Furthermore,
while the Plan believes its valuation methods are appropriate and consistent with other market participants, the use of different
methodologies or assumptions to determine the fair value of certain financial instruments could result in a different fair value
measurement at the reporting date.
Administrative expenses
The Plan sponsor has elected to pay certain
administrative expenses of the Plan.
Use of estimates in the preparation of
financial statements
The preparation of financial statements in
conformity with accounting principles generally accepted in the United States of America requires the Plan’s management
to make estimates and assumptions that affect the reported amounts of assets and liabilities and changes therein, and disclosure
of contingent assets and liabilities. Actual results could differ from those estimates and assumptions.
Payment of benefits
Benefits are recorded when paid.
Subsequent events
The Plan has evaluated subsequent events and
determined no subsequent events have occurred requiring adjustments to the financial statements or disclosures.
TOMPKINS FINANCIAL CORPORATION
INVESTMENT AND STOCK OWNERSHIP PLAN
NOTES TO FINANCIAL STATEMENTS, Cont’d
DECEMBER 31, 2013 AND 2012
NOTE C: FAIR VALUE MEASUREMENTS
Accounting principles generally accepted in
the United States of America provides a framework for measuring fair value. That framework provides a fair value hierarchy that
prioritizes the inputs to valuation techniques used to measure fair value. The hierarchy gives the highest priority to unadjusted
quoted prices in active markets for identical assets or liabilities (Level 1 measurements) and the lowest priority to unobservable
inputs (Level 3 measurements). The three levels of the fair value hierarchy are described as follows:
Level
1
|
-
|
Inputs
to the valuation methodology are unadjusted quoted prices for identical assets or liabilities in active markets that the Plan
has the ability to access.
|
|
|
|
Level
2
|
-
|
Inputs
to the valuation methodology include:
|
|
-
|
Quoted
prices for similar assets or liabilities in active markets;
|
|
-
|
Quoted
prices for identical or similar assets or liabilities in inactive markets;
|
|
-
|
Inputs
other than quoted prices that are observable for the asset or liability;
|
|
-
|
Inputs
that are derived principally from or corroborated by observable market data by correlation or other means.
|
|
If
the asset or liability has a specified (contractual) term, the Level 2 input must be observable for substantially the full
term of the asset or liability.
|
Level
3
|
-
|
Inputs
to the valuation methodology are unobservable and significant to the fair value measurement.
|
The asset’s or liability’s fair
value measurement level within the fair value hierarchy is based on the lowest level of any input that is significant to the fair
value measurement. Valuation techniques used, as outlined in Note B, need to maximize the use of observable inputs and minimize
the use of unobservable inputs.
The following disclosures are required by
FASB ASC 820-10-55 and FASB ASU 2009-12, “Investments in Certain Entities That Calculate Net Asset Value Per Share”:
The fair values of these funds have been calculated
using the net asset value per share of the underlying investments. There are no unfunded commitments for the pooled market value
separate accounts as of December 31, 2013 and 2012. There is no waiting period or other restrictions on redemptions from pooled
market value separate accounts. The following are descriptions of the pooled market value separate accounts:
Large Cap Growth – MFS
This fund invests primarily in U.S. Stocks.
The fund seeks to provide long-term growth of capital and to outperform the Russell 1000 Growth Index over the long-term.
TOMPKINS FINANCIAL CORPORATION
INVESTMENT AND STOCK OWNERSHIP PLAN
NOTES TO FINANCIAL STATEMENTS, Cont’d
DECEMBER 31, 2013 AND 2012
NOTE C: FAIR VALUE MEASUREMENTS,
Cont’d
Core Plus Bond - Pimco Fund
This fund invests primarily in U.S. Bonds.
The fund seeks to exceed the return of the Barclay’s Capital U.S. Aggregate Bond Index, consistent with preservation of
capital by investing in a diversified portfolio of fixed income securities.
Mid Cap Value – Systematic Fund
This fund invests primarily in U.S. Stocks.
The fund seeks to provide capital appreciation and to outperform the Russell Midcap Value Index over the long-term. The securities
of mid-capitalization companies involve greater risks than those associated with larger, more established companies and may be
subject to more abrupt or erratic price movements.
Mid Cap Growth - Frontier Fund
This fund invests primarily in U.S. Stocks.
The fund seeks to provide capital appreciation and to outperform the Russell Midcap Growth Index over the long-term. The securities
of mid-capitalization companies involve greater risks than those associated with larger, more established companies and may be
subject to more abrupt or erratic price movements.
Dryden S&P 500 Index Fund
This fund invests primarily in U.S. Stocks.
The fund is constructed to reflect the composition of the S&P 500 Index. It seeks to provide long-term growth of capital and
income.
Large Cap Blend – MFS Fund
This fund invests primarily in U.S. Stocks.
The fund seeks to provide long-term growth of capital by investing in equity securities and equity securities convertible into
common stocks traded on the U.S. exchanges and issued by large, established companies. The fund invests in both value and growth
securities.
The preceding methods as described above may
produce a fair value calculation that may not be indicative of net realizable value or reflective of future fair values. Furthermore,
while the Plan believes its valuation methods are appropriate and consistent with other market participants, the use of different
methodologies or assumptions to determine the fair value of certain financial instruments could result in a different fair value
measurement at the reporting date.
TOMPKINS FINANCIAL CORPORATION
INVESTMENT AND STOCK OWNERSHIP PLAN
NOTES TO FINANCIAL STATEMENTS, Cont’d
DECEMBER 31, 2013 AND 2012
NOTE C: FAIR VALUE MEASUREMENTS
, Cont’d
The following table sets forth by Level, within
the fair value hierarchy, the Plan’s assets at fair value as of December 31, 2013 and 2012:
|
|
Level 1
|
|
|
Level 2
|
|
|
Level 3
|
|
|
Total
|
|
December 31, 2013
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Tompkins Financial Corporation common stock
|
|
$
|
10,551,163
|
|
|
$
|
—
|
|
|
$
|
—
|
|
|
$
|
10,551,163
|
|
Mutual funds:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Mid cap growth fund
|
|
|
982,202
|
|
|
|
—
|
|
|
|
—
|
|
|
|
982,202
|
|
Foreign large blend fund
|
|
|
13,701,512
|
|
|
|
—
|
|
|
|
—
|
|
|
|
13,701,512
|
|
Large cap value fund
|
|
|
8,515,022
|
|
|
|
—
|
|
|
|
—
|
|
|
|
8,515,022
|
|
Pooled market value separate accounts:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
U.S. bond
|
|
|
—
|
|
|
|
12,178,641
|
|
|
|
—
|
|
|
|
12,178,641
|
|
Large cap growth stock
|
|
|
—
|
|
|
|
9,361,809
|
|
|
|
—
|
|
|
|
9,361,809
|
|
Mid cap value stock
|
|
|
—
|
|
|
|
5,188,822
|
|
|
|
—
|
|
|
|
5,188,822
|
|
Mid cap growth stock
|
|
|
—
|
|
|
|
6,332,624
|
|
|
|
—
|
|
|
|
6,332,624
|
|
Index fund stock
|
|
|
—
|
|
|
|
2,185,254
|
|
|
|
—
|
|
|
|
2,185,254
|
|
Large cap blend stock
|
|
|
—
|
|
|
|
1,971,602
|
|
|
|
—
|
|
|
|
1,971,602
|
|
Guaranteed Income Fund
|
|
|
—
|
|
|
|
—
|
|
|
|
13,413,435
|
|
|
|
13,413,435
|
|
Total assets at fair value
|
|
$
|
33,749,899
|
|
|
$
|
37,218,752
|
|
|
$
|
13,413,435
|
|
|
$
|
84,382,086
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
December 31, 2012
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Tompkins Financial Corporation common stock
|
|
$
|
7,736,285
|
|
|
$
|
—
|
|
|
$
|
—
|
|
|
$
|
7,736,285
|
|
Mutual funds:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Small blend fund
|
|
|
660,321
|
|
|
|
—
|
|
|
|
—
|
|
|
|
660,321
|
|
Foreign large blend fund
|
|
|
10,787,301
|
|
|
|
—
|
|
|
|
—
|
|
|
|
10,787,301
|
|
Large cap value fund
|
|
|
6,544,892
|
|
|
|
—
|
|
|
|
—
|
|
|
|
6,544,892
|
|
Pooled market value separate accounts:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
U.S. bond
|
|
|
—
|
|
|
|
10,809,430
|
|
|
|
—
|
|
|
|
10,809,430
|
|
Large cap growth stock
|
|
|
—
|
|
|
|
7,414,079
|
|
|
|
—
|
|
|
|
7,414,079
|
|
Mid cap value stock
|
|
|
—
|
|
|
|
3,860,073
|
|
|
|
—
|
|
|
|
3,860,073
|
|
Mid cap growth stock
|
|
|
—
|
|
|
|
4,841,836
|
|
|
|
—
|
|
|
|
4,841,836
|
|
Index fund stock
|
|
|
—
|
|
|
|
1,359,280
|
|
|
|
—
|
|
|
|
1,359,280
|
|
Large cap blend stock
|
|
|
—
|
|
|
|
1,413,445
|
|
|
|
—
|
|
|
|
1,413,445
|
|
Guaranteed Income Fund
|
|
|
—
|
|
|
|
—
|
|
|
|
11,919,560
|
|
|
|
11,919,560
|
|
Total assets at fair value
|
|
$
|
25,728,799
|
|
|
$
|
29,698,143
|
|
|
$
|
11,919,560
|
|
|
$
|
67,346,502
|
|
TOMPKINS FINANCIAL CORPORATION
INVESTMENT AND STOCK OWNERSHIP PLAN
NOTES TO FINANCIAL STATEMENTS, Cont’d
DECEMBER 31, 2013 AND 2012
NOTE C: FAIR VALUE MEASUREMENTS
, Cont’d
The following is a reconciliation of the beginning
and ending balances for assets measured at fair value, on a recurring basis using significant unobservable inputs (Level 3) for
the years ended December 31, 2013 and 2012:
|
|
December 31,
|
|
|
|
2013
|
|
|
2012
|
|
|
|
|
|
|
|
|
Guaranteed income fund:
|
|
|
|
|
|
|
|
|
Balance at beginning of year
|
|
$
|
11,919,560
|
|
|
$
|
7,203,756
|
|
Purchases
|
|
|
3,740,751
|
|
|
|
5,238,995
|
|
Sales
|
|
|
(2,527,928
|
)
|
|
|
(754,212
|
)
|
Interest
|
|
|
281,052
|
|
|
|
231,021
|
|
Balance at end of year
|
|
$
|
13,413,435
|
|
|
$
|
11,919,560
|
|
TOMPKINS FINANCIAL CORPORATION
INVESTMENT AND STOCK OWNERSHIP PLAN
NOTES TO FINANCIAL STATEMENTS, Cont’d
DECEMBER 31, 2013 AND 2012
NOTE D: INVESTMENTS
The following presents the fair value of investments
and the net appreciation in fair value. Investments that represent 5% or more of the Plan’s net assets available for benefits
are separately identified:
|
|
December 31,
|
|
|
|
2013
|
|
|
2012
|
|
|
|
Fair value at
|
|
|
Fair value at
|
|
|
|
end of year
|
|
|
end of year
|
|
|
|
|
|
|
|
|
Tompkins Financial Corporation common stock
|
|
$
|
10,551,163
|
|
|
$
|
7,736,285
|
|
Mutual funds:
|
|
|
|
|
|
|
|
|
American – Europacific Growth R4
|
|
|
13,701,512
|
|
|
|
10,787,301
|
|
Eaton Vance Large Cap Value A
|
|
|
8,515,022
|
|
|
|
6,544,892
|
|
Other
|
|
|
982,202
|
|
|
|
660,321
|
|
|
|
|
23,198,736
|
|
|
|
17,992,514
|
|
Pooled market value separate accounts:
|
|
|
|
|
|
|
|
|
Large Cap Growth – MFS
|
|
|
9,361,809
|
|
|
|
7,414,079
|
|
Core Plus Bond – Pimco
|
|
|
12,178,641
|
|
|
|
10,809,430
|
|
Mid Cap Value – Systematic
|
|
|
5,188,822
|
|
|
|
3,860,073
|
|
Mid Cap Growth – Frontier
|
|
|
6,332,624
|
|
|
|
4,841,836
|
|
Other
|
|
|
4,156,856
|
|
|
|
2,772,725
|
|
|
|
|
37,218,752
|
|
|
|
29,698,143
|
|
Group Annuity Contract:
|
|
|
|
|
|
|
|
|
Guaranteed Income Fund
|
|
|
13,413,435
|
|
|
|
11,919,560
|
|
|
|
$
|
84,382,086
|
|
|
$
|
67,346,502
|
|
The investments appreciated in fair value as follows:
|
|
Year ended December 31,
|
|
|
|
2013
|
|
|
2012
|
|
|
|
|
|
|
|
|
Tompkins Financial Corporation common stock
|
|
$
|
2,395,009
|
|
|
$
|
173,438
|
|
Mutual funds
|
|
|
3,815,292
|
|
|
|
2,047,974
|
|
Pooled market value separate accounts
|
|
|
6,416,534
|
|
|
|
2,123,408
|
|
|
|
$
|
12,671,835
|
|
|
$
|
4,344,820
|
|
TOMPKINS FINANCIAL CORPORATION
INVESTMENT AND STOCK OWNERSHIP PLAN
NOTES TO FINANCIAL STATEMENTS, Cont’d
DECEMBER 31, 2013 AND 2012
NOTE E: TAX STATUS
The Internal Revenue Service has determined
and informed the Plan sponsor by a letter dated March 31, 2008, that the prototype plan under which the Plan was adopted is designed
in accordance with the applicable sections of the Internal Revenue Code (IRC). The Plan has been amended since receiving the determination
letter. However, the Plan administrator and the Plan’s legal counsel believe that the Plan is designed and is currently
being operated in compliance with the applicable requirements of IRC.
Accounting principles generally accepted in
the United States of America require plan management to evaluate tax positions taken by the plan and recognize a tax liability
(or asset) if the Plan has taken an uncertain position that more likely than not would not be sustained upon examination by the
Internal Revenue Service. The Plan Administrator has analyzed the tax positions taken by the Plan, and has concluded that as of
December 31, 2013, there are no uncertain positions taken or expected to be taken that would require recognition of a liability
(or asset) or disclosure in the financial statements. The Plan is subject to routine audits by tax jurisdictions; however, there
are currently no audits for any tax periods in progress. The Plan Administrator believes it is no longer subject to income tax
examinations for years prior to December 31, 2010.
NOTE F: PLAN TERMINATION
Although it has not expressed any intent to
do so, the Plan sponsor has the right under the Plan to discontinue its contributions at any time and to terminate the Plan subject
to the provisions of ERISA. In the event of Plan termination, participants have a fully vested interest in their accounts and
their accounts will be paid to them as provided by the Plan document.
NOTE G: TRANSACTIONS WITH PARTIES-IN-INTEREST
The Plan invests in shares of the Guaranteed
Income Fund, mutual funds and pooled market value separate accounts managed by affiliates of Prudential Retirement. Prudential
Retirement acts as trustee for only those investments as defined by the Plan. Transactions in such investments qualify as party-in-interest
transactions which are exempt from the prohibited transactions rules.
The Plan invests in Tompkins Financial Corporation
common stock which represents approximately 12% and 11% of net assets available for benefits at December 31, 2013 and 2012, respectively.
NOTE H: RISKS AND UNCERTAINTIES
The Plan invests in various types of investment
securities. Investment securities are exposed to various risks, such as interest rate, market and credit risks. Due to the level
of risk associated with certain investment securities, it is at least reasonably possible that changes in the values of investment
securities will occur in the near term and that such changes could materially affect participants’ account balances and
the amounts reported in the accompanying statements of net assets available for benefits.
TOMPKINS FINANCIAL CORPORATION
INVESTMENT AND STOCK OWNERSHIP PLAN
NOTES TO FINANCIAL STATEMENTS, Cont’d
DECEMBER 31, 2013 AND 2012
NOTE I: TRANSFER FROM OTHER PLAN
In September 2012, net assets of $16,812,685
from the VIST Financial Corp. 401(k) Retirement Savings Plan were merged into the Plan. Additionally, employees of VIST Financial
Corp. were eligible to participant in the Plan.
NOTE J: RECONCILIATION OF THE FINANCIAL
STATEMENTS TO FORM 5500
The following is a reconciliation of net assets
available for plan benefits per the financial statements to Form 5500:
|
|
December 31,
|
|
|
|
2013
|
|
|
2012
|
|
Net assets available for benefits per the
financial statements
|
|
$
|
86,708,077
|
|
|
$
|
69,745,576
|
|
|
|
|
|
|
|
|
|
|
Less: employer contributions receivable
|
|
|
(486,394
|
)
|
|
|
(429,439
|
)
|
|
|
|
|
|
|
|
|
|
Net assets available for benefits per Form 5500
|
|
$
|
86,221,683
|
|
|
$
|
69,316,137
|
|
The following is a reconciliation of participant
contributions per the financial statements to Form 5500:
|
|
December 31,
|
|
|
|
2013
|
|
|
2012
|
|
|
|
|
|
|
|
|
Participant contributions per the financial statements
|
|
$
|
4,767,348
|
|
|
$
|
3,998,647
|
|
|
|
|
|
|
|
|
|
|
Add: prior year employer contributions receivable
|
|
|
429,439
|
|
|
|
408,206
|
|
|
|
|
|
|
|
|
|
|
Less: current year employer contributions receivable
|
|
|
(486,394
|
)
|
|
|
(429,439
|
)
|
|
|
|
|
|
|
|
|
|
Participant contributions per the Form 5500
|
|
$
|
4,710,393
|
|
|
$
|
3,977,414
|
|
As discussed in Note A, participants are given
the opportunity to elect to receive in cash that portion of their profit sharing allocation which the Board of Directors shall
designate as eligible for cash election for the Plan year or they may elect to allocate all or part to their plan account maintained
on their behalf in the Plan. These elective deferrals are not made by the participant until the year subsequent to the year in
which the profit sharing percentage is approved. Therefore, these elective deferrals are accrued as a receivable to the Plan in
the Plan year that the profit sharing amount is approved. However, these elective deferrals are considered in the relevant non-discrimination
testing in the year that they are received by the Plan.
TOMPKINS FINANCIAL CORPORATION
INVESTMENT AND STOCK OWNERSHIP PLAN
SUPPLEMENTAL SCHEDULE
TOMPKINS FINANCIAL CORPORATION
INVESTMENT AND STOCK OWNERSHIP PLAN
EIN: 15-0470650
PLAN #: 002
Note: Certain cost information in column (d) is not required
to be disclosed as investments are participant directed under an individual account plan.