Non-Qualified Savings Plan FAQs

1. The upper limit on NQSP eligible excess pay is increasing from $500,000 to $600,000.
   Effective January 1, 2027, BMO is increasing the upper limit on NQSP eligible pay from $500,000 to $600,000. The IRS pay limit has increased steadily over the past several years and is expected to increase to $375,000 in 2027. With this plan limit change, eligible employees can now defer between 1% to 75% of eligible excess pay they earn between the IRS pay limit and $600,000.
2. No company core and matching contributions in 2027.
   BMO has made the decision to eliminate the company core and matching contributions to the NQSP for 2027. Eligible employees will still have the opportunity to make personal contributions between 1% to 75% of eligible excess pay, and benefit from the tax advantages of deferring your pay into the plan. If you elected to receive payment of your FY2026 STIP bonus in January 2027, you will still receive the corresponding 2% company core and 5% match at that time. Core and matching contributions earned prior to 2027 are not impacted by this change.

An NQSP is a type of tax-deferred, employer-sponsored retirement plan offered by companies to provide eligible highly compensated employees with additional retirement savings opportunities and tax benefits. Non-qualified plans supplement retirement savings that cannot be contributed to a qualified retirement plan due to IRS limits on pay.

• IRS pay limit: The IRS caps the amount of annual pay that is considered eligible for the 401(k) Savings Plan. For 2026 the IRS pay limit is $360,000. For 2027 the IRS pay limit is currently projected to increase to $375,000.
• IRS contribution limits: The IRS caps the annual amount you can personally contribute to an employer- sponsored retirement plan, like BMO’s 401(k) Savings Plan. For 2026, the contribution limit is $24,500, with higher limits starting in the year you turn 50 if you elect to make additional 401(k) catch-up contributions. For 2027, the contribution limit is currently projected to increase to $25,500.
• These limits are subject to change annually as determined by the IRS (typically announced in late October for the following calendar year).

If eligible, you may have the opportunity to contribute your own pay to the NQSP on a before-tax basis. You will receive an invitation to participate annually if BMO determines you are eligible for the plan.

To participate in the NQSP for 2027, you must take action during the election period open Wednesday, October 14 through Friday, October 30, 2026. If you do not make an election during this period, you will not be able to contribute to the NQSP in 2027. The next election opportunity will be in the fall of 2027, for the 2028 calendar year. Enrollments or changes outside the election period are not permitted.

Yes. You must enroll or re-enroll each year. Making contributions from your pay to the NQSP is voluntary. If you want to contribute for 2027, you must make an election during the election period. If you don’t have an election in place by the October 30, 2026 deadline, you’ll have to wait until the next annual election period in the fall of 2027 to begin making personal contributions to the plan. Once the election period ends your choice to participate, or not participate, for the following year is irrevocable.

BMO used a detailed analysis of past and expected future pay in our selection process. It is possible that, due to several factors, such as a recent transfer, job change, or increase to your pay, you were not selected to participate for the upcoming year. If your pay does exceed the IRS pay limit, you will likely be invited to participate in the plan with the opportunity to make personal contributions in a future year.

If you feel an error was made, you can contact an Empower Non-Qualified Savings Plan Client Service Team member at 1-800-824-0040. Explain why you believe you should participate no later than the end of the current election period. Once the election period ends, no exceptions can be made, and you will need to wait until the next annual election period.

Your eligible pay generally includes your base pay, overtime, shift differential and any variable pay that is related to work performance. Variable pay includes:

• Team-based plans (based on company, corporate, department, or unit performance, including production and productivity plans)
• Sales, incentive, and commission-based plans
• Business referral plans
• Ad hoc cash awards related to performance

However, due to certain IRS provisions that govern NQSPs, payroll deductions for your personal contributions will only be taken from your base pay (such as salary, vacation, sick pay) and your annual performance award, such as Short-Term Incentive Pay (STIP). This excludes sales incentives and commission pay. While sales incentives and commission pay are excluded for purposes of your personal contributions, it will still be used in determining your overall eligibility for the NQSP.

As it relates to the NQSP, excess pay generally refers to your eligible pay that is between the IRS pay limit and $600,000. For 2026 the pay limit is $360,000. For 2027 the pay limit is currently projected to increase to $375,000 but is subject to change each year as determined by the IRS.

You may be eligible to make personal, before-tax contributions to the plan from 1% to 75% of your eligible excess pay. The money you contribute is deducted from your pay each pay period.

IMPORTANT. Due to certain IRS provisions that govern non-qualified savings plans, payroll deductions for your personal contributions will only be taken from your base pay (such as salary, vacation, sick pay) and your annual performance award, such as Short-Term Incentive Pay (STIP), but exclude sales incentives, commission pay and certain bonuses. You cannot make personal contributions from any pay you earn under a sales, incentive, or commission-based plan, but these types of pay will still be used in determining your overall eligibility for the plan.

Your personal contributions are vested immediately. If you participated in the NQSP prior to 2027, any BMO core contributions continue to vest after three years of BMO service (including prior service).

Payment of Federal income tax and most state/local income tax is not applicable until you receive your account distribution on NQSP contributions made by you or BMO. You will pay current FICA taxes (Social Security and Medicare), as applicable, on amounts you contribute to the plan at the time they are deducted from your pay.

By paying FICA taxes on the contributions at the time they are contributed to the plan, you will benefit from not needing to pay FICA taxes on these contributions, or the investment earnings on these contributions, when you receive your distribution from the plan in the future.

At the time you begin to receive your distribution from the NQSP you may be asked to complete a tax Form W-9 (if you are a U.S. citizen or resident alien residing outside the U.S.) or W-8BEN (if you are a non-U.S. citizen and the beneficial owner of an amount subject to U.S. withholding) before we will issue your payment.

If your annual Short-Term Incentive Pay (STIP) makes up most, or all, of your compensation that exceeds the limit on eligible pay, then you likely will not see your first NQSP contribution until your STIP is paid, either in December or January.

You can invest your NQSP contributions in a variety of investment funds offered within the plan. You can change your investment election at any time. If you do not choose an investment fund, contributions will be automatically invested in the BlackRock LifePath target date retirement fund nearest to the date you turn age 65. The investment line-up is:

Unlike other retirement plans, when you participate in a NQSP, you must also choose in advance how your account balance will be paid to you during the election period. You can choose:

• Lump Sum: You will receive your full account balance in one payment made approximately 60 days following your retirement or date you otherwise leave BMO for any reason.
• Installments: You will receive your full account balance in annual payments made over five or ten years. Payments will be made at the beginning of the calendar year following the year you retire or otherwise leave BMO for any reason, and every January thereafter.

The choice applies to your contributions and any investment earnings. During each subsequent election period, you can make a new distribution choice for the following year only.

If you do not make a distribution election, or if your vested account balance is less than $50,000 when you retire or otherwise leave BMO for any reason, you will receive your account balance in a lump sum.

Your distribution is not eligible for a roll-over to an IRA or other qualified retirement plan (like a 401(k) plan).

You access your NQSP account the same way you access your 401(k) Savings Plan account. The most convenient way to connect to your account is online through Workday.

• Empower from Workday
1. Login to Workday, and open the My Benefits & Retirement app.
2. Under Quick Actions, select Empower 401K & NQSP – US Employees to connect to your online Empower account.
3. Choose Account from the menu and select the BMO Financial Corp. Non-Qualified Savings Plan > Overview from the account list.
4. Select View Account or Visit Website and click Continue.
5. During the annual enrollment period, choose Enroll Now to submit your annual elections.
• Empower Online – from any internet enabled device (user name/password required). Access your account online with your Empower username and password. Go to Empower.
• Empower App – from any mobile device. Download the Empower app from the App Store or Google Play. Note: To register, click the Register button, select I do not have a PIN and follow the prompts to create a username and password.

You will have access to your NQSP account statements through Empower. The site allows you to view real-time data about your account or print PDF statements.

If you have more questions about the NQSP or the upcoming election period, you may contact an Empower NQSP Client Service Team member at 1-800-824-0040.

Follow the menu prompts to be directly connected with a Client Service Team member, Monday to Friday, 7 a.m. to 9 p.m. CT, or Saturday, 8 a.m. to 4:30 p.m. CT.

In this example, David earns a $120,000 base salary and has earned commission pay of $315,000. Therefore, to maximize his savings potential under the NQSP, David elects a higher contribution percent of 60%, which only applies to base-pay, but not his commission pay.