e as described in Proposal One. • 409A Risk. Same as described in Proposal One. 3 EFTA_R1_01971652 EFTA02677252 Proposal Three—Sale of AIF and Creation of New LLC (MWE Proposal 11/18/13) Steps: 1. 2006 Trust decants assets to each of the 2011 Trusts. 2. For tax reasons, Debra resigns as Trustee of 2011 Trust