Pinnacle Oak Grove Eanrings Limit Trust

“The bank of new york mellon serves as the sole directed trustee of this trust. The plan sponsor is cliffs natural resources, inc. The trust is administered by the plan sponsor in accordance with the terms of the trust agreement. As such the veba does not have a governing body that exercises discretion.”

“These questions are not applicable to the trust. Additionally, the trust does not have any employees, therefore, no processes related to employee compensation are in place.”

“Process for reviewing form 990 a complete electronic copy of the organization's form 990 was provided to the trustee for review prior to filing with the irs.”

“As a 501(c)(9) organization the trust is not required to make the documents referenced in question 19 available to the general public.”

“AVERAGE HOURS PER WEEK DEVOTED TO POSITION: AS TRUSTEE, THE BANK OF NEW YORK MELLON PROVIDES ADMINISTRATIVE SERVICES SUCH AS ACTING AS INVESTMENT MANAGER FOR Pinnacle/Oak Grove Earnings Limit Tr 15823-Pinoak. THESE SERVICES REQUIRE NUMEROUS INDIVIDUAL BANK EMPLOYEES' INVOLVEMENT IN THE ACTIVITIES OF THE ORGANIZATION AND THUS CANNOT BE QUANTIFIED ON AN HOURLY BASIS. THEREFORE, THE TRUSTEE FEES ARE NOT BASED UPON FACTORS SUCH AS THE MARKET VALUE OF THE ACCOUNT AND IN ACCORDANCE WITH THE BANK OF NEW YORK MELLON'S AGREEMENT WITH CLIFFS NATURAL RESOURCES, INC.”

“To provide reimbursement of certain medical costs, including COBRA premiums, for certain eligible retirees, the surviving spouses of certain retirees and eligible dependents thereof who are covered under the terms of the collective bargaining agreement between the UMWA and Pinnacle Mining Company, LLC, Pinnacle Land Company, LLC, Oak Grove Resources, LLC and Oak Grove Land Company, LLC.”