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Beneficiary Designations for Life Insurance: Estate Planning for Southern California Edison Employees

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Healthcare Provider Update: Healthcare Provider for Southern California Edison: Southern California Edison (SCE) primarily utilizes Blue Shield of California as its healthcare provider for employees. This partnership enables the company to offer a variety of health insurance options to its workforce, including comprehensive coverage options tailored to meet the diverse needs of its employees. Potential Healthcare Cost Increases in 2026: As the healthcare landscape shifts, Southern California Edison employees may see a significant impact on healthcare costs in 2026. With projected record increases in insurance premiums-some states reporting hikes exceeding 60%-combined with the potential expiration of enhanced federal subsidies, many employees could face out-of-pocket premium spikes exceeding 75%. Factors contributing to this trend include rising medical costs and aggressive rate hikes from major insurers, which underline the importance of strategic planning for healthcare expenses as retirement approaches. Adapting to these changes is essential for maintaining financial stability and ensuring access to necessary healthcare services. Click here to learn more

What Is a Beneficiary?

The receiver of Death Proceeds

As an employee and retiree from Southern California Edison, it's important to know about designating a beneficiary. A beneficiary is an individual or entity you name (designate) to receive the proceeds of a life insurance policy on your life.

Irrevocable Versus Revocable

A beneficiary can be irrevocable or revocable. You cannot change an irrevocable beneficiary. An irrevocable beneficiary has a vested property interest in the life insurance death benefit (effective immediately upon being named as a beneficiary). This interest cannot be taken away or decreased without his or her consent. A revocable beneficiary is someone whose interest is contingent; that is, it can be decreased or terminated at any time.

Primary Versus Secondary Versus Final

Southern California Edison employees can name as many beneficiaries as they want, subject to limitations set by the policy. Most policies allow you to choose more than one beneficiary at each level and the proceeds would thereby be split equally between all beneficiaries surviving at a particular level upon the insured's death. 

The beneficiary to whom the proceeds go first is called the primary beneficiary. If the primary beneficiary predeceases the insured, the secondary beneficiary becomes entitled to the proceeds upon the insured's death. A 'final' beneficiary can be named as well. Final beneficiaries will receive the proceeds only if they outlive the designated primary and secondary beneficiaries. Usually, charities or more remote relatives such as aunts, uncles, nieces, and nephews are named at this level.

In addition to the primary beneficiary, Southern California Edison employees should consider naming both secondary and final beneficiaries in case you outlive the primary beneficiary, you and your primary beneficiary die simultaneously, or the primary beneficiary is unable to collect the proceeds. In such cases, if you have not named secondary or final beneficiaries, the proceeds of the policy will pass to your estate and may therefore be subject to estate taxes. Naming secondary and final beneficiaries gives some extra protection against such eventualities.

Technical Note:  If you and your primary beneficiary die simultaneously (and there are no other named beneficiaries), the proceeds are distributed under the Uniform Simultaneous Death Act (USDA). That is, you are presumed to have survived the beneficiary and the proceeds go to your estate.

Technical Note:  A beneficiary who kills you by accident, in self-defense, or through gross negligence or manslaughter will be unable to collect the proceeds of insurance on your life. Every state bars intentional killers from profiting from their act.

Why Is Designating the Proper Beneficiary Important?

Estate Planning Goals of Life Insurance

In estate planning, life insurance is purchased for two primary reasons: 1) to provide cash to the insured's family members for daily living expenses, and 2) to provide cash for death taxes and estate expenses. In order to ensure that your beneficiaries receive the maximum benefit from life insurance policies on your life, you must properly structure ownership of your policies to avoid income and estate taxes that might deplete the funds. Proper designation of your beneficiaries is also important.

Caution:  Southern California Edison employees should note that to avoid taxes, you must arrange proper  ownership  of policies on your life.

Subject to Federal Estate Taxes and/or Certain Limitations

Naming or changing the beneficiaries of your life insurance policies may have federal estate tax consequences. Additionally, naming or changing a beneficiary may be subject to some limitations. Therefore, Southern California Edison employees need to understand all the ins and outs of naming/changing a beneficiary.

Who Should You Name As Your Beneficiary In Order to Avoid Federal Estate Taxes?

Not Your Estate or Your Personal Representative (Executor)

Life insurance proceeds will not be includable in your gross estate for federal estate tax purposes unless: (1) the proceeds are payable to or for the benefit of your estate, (2) you possessed 'incidents of ownership' in the policy at the time of your death or at any time during the three years prior to your death, or (3) you transferred ownership of a policy within three years of your death.

Therefore, in order to avoid inclusion of the proceeds in your estate, thereby subjecting them to estate tax, you should not name your estate or your executor as a beneficiary. If you own the policy on your death (or within three years of your death), the proceeds will be includable in your estate whether you name your estate as your beneficiary or not.

The primary reason for not naming your estate or your executor as your beneficiary is that doing so subjects the proceeds to probate expenses and claims of creditors, whereas, if someone other than your estate or your executor were named, the proceeds would pass to that person free of such expenses and claims. It is a good idea for Southern California Edison employees to make sure that policies on their life that are owned by others do not name their estate or their executor as the beneficiary since this would cause inclusion of the proceeds in their estate when this would otherwise not be true.

Tip:  Some state laws provide that proceeds payable to an estate or executor are treated as if they are paid to the ultimate beneficiaries of your estate (your heirs). The IRS honors state law in these cases. The effect of the IRS honoring such state laws is that the proceeds may not be taxable in the decedent's estate if the decedent did not own the policy prior to his or her death or within three years of his or her death or if the proceeds are directed by the decedent's will to a charitable beneficiary or the decedent's spouse.

Not to a Beneficiary to Satisfy a Debt

Naming a beneficiary to receive life insurance proceeds in payment of a debt will be considered by the IRS to be for the benefit of your estate, and the proceeds will be includable in your gross estate for estate tax purposes.

Not to a Beneficiary to Pay Death Taxes or Other Estate Debts or Expenses

Naming a beneficiary to receive proceeds under an agreement that requires him or her to pay death taxes or other estate debts or expenses will be considered by the IRS to be for the benefit of your estate, and the proceeds will be includable in your gross estate for estate tax purposes.

Not to a Beneficiary to Pay Alimony or Support

Naming a beneficiary to receive life insurance proceeds to pay alimony or support will be considered by the IRS to be for the benefit of your estate and these proceeds will also be includable in your gross estate for estate tax purposes. If the decedent/insured owns the policy on his or her death (or within three years of his or her death), ownership will cause the inclusion of the proceeds in the decedent/insured's estate regardless of who the ultimate beneficiaries are.

Who Should You Name As Your Beneficiary to Avoid Limitations?

No One, If You Are Incompetent

If you are incompetent (whether or not you are legally declared to be so), you cannot name or change a beneficiary. The test for incompetency to name or change a beneficiary is similar to the test for incompetency to execute a will; that is, do you have the capacity to understand your actions?

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Tip:  There is a presumption that you are competent. If a party claims that you are incompetent, that party must prove it.

Not Your Employer, If You Have Coverage Under a Group Life Policy

Southern California Edison employees should note that some states do not allow you to name your employer as the beneficiary if your coverage is under a group life policy provided by that employer.

Not A Minor, Unless a Guardian Has Been Appointed (or a Trust Is Used)

Generally, insurers will not make settlements directly to minors. Southern California Edison employees should carefully consider whether to name a minor as a beneficiary unless they also appoint a guardian or use a trust.

Only As Allowed Under a Divorce Decree or Settlement Agreement

Your right to change a beneficiary may be limited by a divorce decree or settlement agreement. In some states, divorce automatically terminates a spouse's interest in insurance on the other spouse's life. In other states, divorce allows a policyowner to change the beneficiary upon divorce, even if the beneficiary is otherwise irrevocable.

Only a Specified Class, If You (The Insured) Are a Minor

In some states, if you (the insured) are a minor, you can name only a certain class of persons as beneficiaries. That class generally includes your spouse, parents, grandparents, and brothers and sisters.

Tip:  Once a minor insured has reached the age of majority, he or she can change the beneficiary of a policy on his or her life.

Someone With an 'Insurable Interest'

Some states require that where you are not the owner of the policy, the beneficiary of the policy should have an 'insurable interest' in your life. The purpose of this rule is to prevent gambling. An insurable interest is a financial interest that would be adversely affected if you died. Blood and legal relatives are presumed to have an insurable interest. 

Anyone, As Long As You Have an Existing Irrevocable Beneficiary's Consent

If you want to change the beneficiary, but have already named an irrevocable beneficiary, you need that irrevocable beneficiary's written consent to do so.

Tip:  An irrevocable beneficiary's property right ends at his or her death.

Anyone, As Long as You Have Your Spouse's Consent If You Use Community Funds to Pay Premiums

If you live in a community property state, any assets acquired during the marriage are considered community property (i.e., each spouses owns an undivided one half interest in the property). A spouse's interest in community property cannot be disposed of by the other spouse. If you make premium payments from community funds, the insurance so purchased is also considered community property; you must, therefore, have your spouse's written consent when naming a beneficiary to such policies.

Should You Name Your Spouse As Beneficiary?

We'd like our Southern California Edison clients to consider that naming your spouse as a beneficiary may not be a good idea. If a spouse is named as the beneficiary, the unlimited marital deduction applies, and the proceeds will pass free of estate taxes regardless of who owns the policy. However, the proceeds will be included in the surviving spouse's gross estate (unless, of course, they have been spent before the surviving spouse's death).

By naming your spouse as the beneficiary, you will only postpone estate taxes, not avoid them entirely. Additionally, if you and your spouse die simultaneously and your spouse is named as the beneficiary of a policy on your life, the USDA provides that the beneficiary (your spouse) will be presumed to have predeceased the insured (you). Since your spouse will be deemed to have predeceased you, the unlimited marital deduction will be inapplicable, and the proceeds may be subject to tax in your estate.

How Do You Name or Change (I.E., Designate) a Beneficiary?

Complete a Beneficiary Designation form

When you buy life insurance, the insurer will provide you with a beneficiary designation form. Generally, the form need only be completed (i.e., the names of the beneficiaries filled in), signed, and dated by you.

Specifically Identify All Beneficiaries and the Distribution They Are to Receive

Southern California Edison employees should be specific when naming the beneficiaries. Make sure the designation clearly identifies to whom the proceeds are to be paid (and in what order if you are naming secondary and/or final beneficiaries). If you want the proceeds to be distributed to your children (including legitimate, illegitimate, and adopted children, and children from a previous marriage), specify the name of each child to be sure the ones you want to name as beneficiaries are included and the ones you don't want to name as beneficiaries are excluded. You may want to include a clause such as 'and any afterborn children' to provide for any children not yet born.

The phrase  to my lawful children  may disqualify illegitimate children in certain states. If you want to ensure that the proceeds go to your wife at your death, do not say 'to my wife, Anne Boleyn.' Rather, say 'to my present wife,' since one day Anne Boleyn may no longer be your wife.

Caution:  Southern California Edison employees should note that t erms such as heirs, issue, per stripes, and per capita have legal definitions. Be sure you understand what the terms mean before you use them. These Southern California Edison employees should consult a lawyer if they are not sure.

Specifically Revoke Previous Designations

When changing a beneficiary, it is advisable to specifically revoke any previous designations by simply writing this on the change of beneficiary form.

Review Beneficiary Designations Every Two or Three Years or Upon a Change of Circumstances

You may want to review your beneficiary designations every two or three years to ensure they comport with your current circumstances and wishes. Additionally, Southern California Edison employees should be sure to check and update their beneficiary designations upon the occurrence of certain life events, such as marriage, divorce, remarriage, and the birth of children.

Can You Change a Life Insurance Beneficiary In Your Will?

No. A beneficiary designation made in your will does NOT override the beneficiary designation made on the insurer's form. For any Southern California Edison employees who want to change their beneficiary, you must execute a change of beneficiary form provided by your insurer. Do not rely on your will to do so.

How does SoCalGas determine its pension contribution levels for 2024, and what factors influence the funding strategies to maintain financial stability? In preparing for the Test Year (TY) 2024, SoCalGas employs a detailed actuarial process to ascertain the necessary pension contributions. The actuarial valuation includes an assessment of the company's Projected Benefit Obligation (PBO) under Generally Accepted Accounting Principles (GAAP). These calculations incorporate variables such as current employee demographics, expected retirement ages, and market conditions. Additionally, SoCalGas must navigate external economic factors, including interest rates and economic forecasts, which can impact the funded status of its pension plans and the associated financial obligations.

SoCalGas determines its pension contribution levels using a detailed actuarial process that evaluates the Projected Benefit Obligation (PBO) under Generally Accepted Accounting Principles (GAAP). The contribution is influenced by variables such as employee demographics, retirement age expectations, market conditions, and external economic factors like interest rates and economic forecasts. SoCalGas maintains financial stability by adjusting funding strategies based on market returns and required amortization periods​(Southern_California_Gas…).

What specific changes to SoCalGas's pension plan are being proposed for the upcoming fiscal year, and how will these changes impact existing employees and retirees? The proposals for the TY 2024 incorporate adjustments to the existing pension funding mechanisms, including the continuation of the two-way balancing account to account for fluctuations in pension costs. This measure is designed to stabilize funding while meeting both the service cost and the annual minimum contributions required under regulatory standards. Existing employees and retirees may see changes in their benefits as adjustments are made to align with these funding strategies, which may include modifications to expected payouts or contributions required from retirees depending on their service years and retirement age.

For the 2024 Test Year, SoCalGas is proposing to adjust its pension funding policy by shortening the amortization period for the PBO shortfall from fourteen to seven years. This change aims to fully fund the pension plan more quickly, improving long-term financial health while reducing intergenerational ratepayer burden. Existing employees and retirees may experience greater financial stability in the pension plan due to these proactive funding strategies​(Southern_California_Gas…).

In what ways does SoCalGas's health care cost escalation projections for postretirement benefits compare with national trends, and what strategies are in place to manage these costs? The health care cost escalations required for the Postretirement Health and Welfare Benefits Other than Pension (PBOP) at SoCalGas have been developed in alignment with industry trends, which show consistent increases in health care expenses across the nation. Strategies implemented by SoCalGas involve negotiation with health care providers for favorable rates, introduction of health reimbursement accounts (HRAs), and ongoing assessments of utilization rates among retirees to identify potential savings. These measures aim to contain costs while ensuring that retirees maintain access to necessary healthcare services without a significant financial burden.

SoCalGas's healthcare cost projections for its Postretirement Benefits Other than Pensions (PBOP) align with national trends of increasing healthcare expenses. To manage these costs, SoCalGas employs strategies like negotiating favorable rates with providers, utilizing health reimbursement accounts (HRAs), and regularly assessing healthcare utilization. These efforts aim to control healthcare costs while ensuring that retirees receive necessary care​(Southern_California_Gas…).

What resources are available to SoCalGas employees to help them understand their benefits and the changes that may occur in 2024? SoCalGas provides various resources to employees to clarify their benefits and upcoming changes, including dedicated HR representatives, comprehensive guides on benefits options, web-based portals, and informational seminars. Employees can access personalized accounts to view their specific benefits, contributions, and projections. Additionally, the company offers regular training sessions covering changes in benefits and how to navigate the retirement process effectively, empowering employees to make informed decisions regarding their retirement planning.

SoCalGas provides employees with various resources, including HR representatives, benefit guides, and web-based portals to help them understand their benefits. Employees also have access to personalized retirement accounts and training sessions that cover benefit changes and retirement planning, helping them make informed decisions regarding their future​(Southern_California_Gas…).

How does the PBOP plan impact SoCalGas’s overall compensation strategy for attracting talent? The PBOP plan is a critical component of SoCalGas’s total compensation strategy, designed to attract and retain high-caliber talent in an increasingly competitive market. SoCalGas recognizes that comprehensive postretirement benefits enhance their appeal as an employer. The direct correlation between competitive benefits packages, including the PBOP plan's provisions for health care coverage and financial support during retirement, plays a significant role in talent acquisition and retention by providing peace of mind for employees about their long-term financial security.

SoCalGas's PBOP plan plays a crucial role in its overall compensation strategy by offering competitive postretirement health benefits that enhance the attractiveness of the company's total compensation package. This helps SoCalGas attract and retain a high-performing workforce, as comprehensive retirement and healthcare benefits are important factors for employees when choosing an employer​(Southern_California_Gas…).

What are the anticipated trends in the pension and postretirement cost estimates for SoCalGas from 2024 through 2031, and what implications do these trends hold for financial planning? Anticipated trends in pension and postretirement cost estimates are projected to indicate gradual increases in these costs due to changing demographics, increasing life expectancies, and inflation impacting healthcare costs. Financial planning at SoCalGas thus necessitates a proactive approach to ensure adequate funding mechanisms are in place. This involves forecasting contributions that will remain in line with the projected obligations while also navigating regulatory requirements to avoid potential funding shortfalls or impacts on corporate finances.

SoCalGas anticipates gradual increases in pension and postretirement costs from 2024 to 2031 due to changing demographics, increased life expectancies, and rising healthcare costs. This trend implies that SoCalGas will need to implement robust financial planning strategies, including forecasting contributions and aligning funding mechanisms with regulatory requirements to avoid potential shortfalls​(Southern_California_Gas…).

How do SoCalGas's pension plans compare with those offered by other utility companies in California in terms of competitiveness and sustainability? When evaluating SoCalGas's pension plans compared to other California utility companies, it becomes evident that SoCalGas's offerings emphasize not only competitive benefits but also a sustainable framework for its pension obligations. This comparative analysis includes studying funding ratios, benefit structures, and employee satisfaction levels. SoCalGas aims to maintain a robust pension plan that not only meets current employee needs but is also sustainable in the long term, adapting to changing economic conditions and workforce requirements while remaining compliant with state regulations.

SoCalGas's pension plans are competitive with those of other utility companies in California, with a focus on both benefit structure and long-term sustainability. SoCalGas emphasizes maintaining a robust pension plan that is adaptable to changing market conditions, regulatory requirements, and workforce needs. This allows the company to remain an attractive employer while ensuring the sustainability of its pension commitments​(Southern_California_Gas…).

How can SoCalGas employees reach out for support regarding their pension and retirement benefits, and what types of inquiries can they make? Employees can contact SoCalGas’s Human Resources Benefits Department through dedicated communication channels such as the company’s HR support line, email, or scheduled one-on-one consultations. The HR team is trained to address a variety of inquiries related to pension benefits, eligibility requirements, plan options, and retirement planning strategies. Moreover, employees can request personalized benefits statements and assistance with understanding their entitlements and the implications of any regulatory changes affecting their plans.

SoCalGas employees can reach out to the company's HR Benefits Department through a dedicated support line, email, or consultations. They can inquire about pension benefits, eligibility, plan options, and retirement strategies. Employees may also request personalized benefits statements and clarification on regulatory changes that may affect their plans​(Southern_California_Gas…).

What role does market volatility and economic conditions play in shaping the funding strategy of SoCalGas's pension plans? Market volatility and economic conditions play a significant role in shaping SoCalGas's pension funding strategy, influencing both asset returns and liabilities. Fluctuations in interest rates, market performance of invested pension assets, and changes in demographic factors directly affect the PBO calculation, requiring SoCalGas to adjust its funding strategy responsively. This involved the use of sophisticated financial modeling and scenario analysis to ensure that the pension plans remain adequately funded and financially viable despite adverse economic conditions, thereby protecting the interests of current and future beneficiaries.

Market volatility and economic conditions significantly impact SoCalGas's pension funding strategy, affecting both asset returns and liabilities. Factors like interest rates, market performance of pension assets, and demographic shifts influence the PBO calculation, prompting SoCalGas to adjust its funding strategy to ensure adequate pension funding and long-term plan viability​(Southern_California_Gas…).

What steps have SoCalGas and SDG&E proposed to recover costs related to pension and PBOP to alleviate financial pressure on ratepayers? SoCalGas and SDG&E proposed implementing a two-way balancing account mechanism designed to smoothly recover the costs associated with their pension and PBOP plans. This initiative aims to ensure that any variances between projected and actual contributions are adjusted in a timely manner, thereby reducing the financial burden on ratepayers. By utilizing this approach, the Companies seek to maintain stable rates while ensuring that all pension obligations can be met without compromising operational integrity or service delivery to their customers. These questions reflect complex issues relevant to SoCalGas employees preparing for retirement and navigating the nuances of their benefits.

SoCalGas and SDG&E have proposed utilizing a two-way balancing account mechanism to recover pension and PBOP-related costs. This mechanism helps adjust for variances between projected and actual contributions, ensuring that costs are managed effectively and do not overly burden ratepayers. This approach aims to maintain stable rates while fulfilling pension obligations​(Southern_California_Gas…).

With the current political climate we are in it is important to keep up with current news and remain knowledgeable about your benefits.
Defined Benefit Plan: Southern California Edison offers a traditional defined benefit pension plan for employees hired before December 31, 2017. This plan provides a stable retirement income based on years of service and final average pay. The pension rates are adjusted annually, and employees can view their pension benefits through the EIX Benefits portal. Grandfathered employees receive the higher of two lump-sum values if applicable. Cash Balance Plan: The cash balance pension plan is available to most employees. This plan credits a percentage of the employee's salary annually to an account that grows with interest. The interest rates for the cash balance plan are announced yearly, impacting the final pension amount. Defined Contribution Plan: SCE also offers a 401(k) plan with a competitive match. Recent hires can receive up to a 10% match on their 401(k) contributions. The plan includes various investment options, such as target-date funds, asset class funds, and a Personal Choice Retirement Account (PCRA) for additional investment flexibility. Employees can also take advantage of an auto-save feature to gradually increase their contribution rates over time. Additional Benefits: In addition to the pension and 401(k) plans, SCE provides other retirement benefits, such as life insurance, profit-sharing contributions, and comprehensive retirement planning resources.
Wildfire Mitigation and Safety: Southern California Edison has significantly reduced the probability of wildfires associated with its equipment by 75%-80% since 2018. Their 2023-25 Wildfire Mitigation Plan includes measures like grid hardening, installing covered conductors, and enhanced vegetation management to further reduce wildfire risks and improve grid safety (Source: Edison International). Industry Impact: The dismantling of California’s rooftop solar program led to the loss of over 17,000 jobs in the clean energy sector, impacting SCE and other utilities. The policy changes have triggered significant layoffs (Source: Environmental Working Group). Operational Efficiency: SCE is focused on improving operational efficiency and reducing costs amidst evolving energy markets (Source: Intellizence).
Southern California Edison provides stock options and RSUs as part of its equity compensation packages. Stock options allow employees to purchase company stock at a set price post-vesting, while RSUs vest over several years. In 2022, Southern California Edison enhanced its equity programs with performance-based RSUs. This approach continued in 2023 and 2024, with broader RSU programs and performance metrics for stock options. Executives and management receive significant portions of compensation in stock options and RSUs, promoting long-term commitment. [Source: Southern California Edison Annual Reports 2022-2024, p. 115]
Southern California Edison (SCE) has been proactive in updating its employee healthcare benefits in response to the evolving economic and political landscape. In 2022, SCE introduced new health insurance options that offer broader coverage and lower out-of-pocket costs for employees. This move was part of a larger strategy to ensure that their workforce remains healthy and productive amid rising healthcare costs and economic uncertainties. The company also expanded its wellness programs to include mental health resources, recognizing the growing importance of mental health in overall employee well-being. In 2023, SCE continued to enhance its healthcare benefits by partnering with local healthcare providers to offer more personalized care options and preventive health services. These changes were made to address the increasing demand for more comprehensive and accessible healthcare solutions in the current economic environment. Additionally, SCE's commitment to employee health is seen as a strategic investment, helping to reduce absenteeism and improve employee morale and productivity. By prioritizing healthcare, SCE is positioning itself to better navigate the economic and political challenges that impact both the company and its workforce.
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For more information you can reach the plan administrator for Southern California Edison at 2244 walnut grove ave Rosemead, CA 91770; or by calling them at 1-800-655-4555.

https://www6.lifeatworkportal.com/slogin/edison/pdf/GY5_H12_H20_2024_Benefits_Enrollment_Guide_Flex.pdf - Page 5, https://www6.lifeatworkportal.com/slogin/edison/pdf/GY5_H12_H20_2023_Benefits_Enrollment_Guide_Flex.pdf - Page 12, https://www6.lifeatworkportal.com/slogin/edison/pdf/GY5_H12_H20_2022_Benefits_Enrollment_Guide_Flex.pdf - Page 15, https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M441/K519/441519282.PDF - Page 8, https://www.edison.com/content/dam/eix/documents/investors/corporate-governance/2023-governance-documents.pdf - Page 22, https://www.edison.com/content/dam/eix/documents/investors/corporate-governance/2024-governance-documents.pdf - Page 28, https://www.edison.com/content/dam/eix/documents/investors/corporate-governance/2022-governance-documents.pdf - Page 20, https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M385/K633/385633681.PDF - Page 14, https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M398/K742/398742219.PDF - Page 17, https://docs.cpuc.ca.gov/PublishedDocs/Efile/G000/M407/K568/407568792.PDF - Page 23

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