ING MAP Select SM Comparison of Unbundled Service Models

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1 ING MAP Select SM Comparison of Unbundled Service Models Description of Customer Service Model Combination of ING and TPA with TPA providing plan-related services Combination of ING and TPA with ING providing fully integrated Loan Administration and Vesting Calculations Available MAP Select Fund Menus Product Eligibility Menu 2 Menu 3 Contour Endeavor Discover Core Explorer Charter $50,000 or more in transferred assets plus annual flow Custom pricing available at $10M in transferred assets, and a minimum average per participant balance of $30K. *Initial pricing based solely on transferred assets received within 90 days of first payment Contract Type Allocated - Funding Agreement (except Group Annuity in state of Washington) Mainframe System ACES Vantage OmniPlus - Sungard Fixed Options ING Fixed Account ING Guaranteed Accumulation Account (GAA) ING Stable Value Fund (Available for new cases with at least $XM in transferred assets) Equity Wash Option Maximum Number of Funds Required Funds Policy Transferred Asset Benefit (TAB)/ Transfer Bonus no Competing Investment Options or Self Directed Brokerage Account are allowed (90 day rule currently not supported on ACES) 30 Note: Participant can only have money invested in a maximum of 18 funds at any one time ING Fixed Account or an ING stable value alternative investment where available. Not available with Self-Directed Brokerage Account, Split Funding or with certain compensation options Menu 2 Menu 3 Contour Endeavor Discover Core Explorer Charter $400,000 or more in transferred assets Custom pricing available at $10M in transferred assets, and a minimum average per participant balance of $30K. *Initial pricing based solely on transferred assets received within 90 days of first payment Allocated - Funding Agreement (except Group Annuity in state of Washington) ING Fixed Account ING Stable Asset Fund (custom-priced cases only) ING Stabilizer (custom-priced cases only) ING Stable Value Fund (Available for new cases with at least $XM in transferred assets) 30 Note: Participant can only have money invested in a maximum of 25 funds at any one time ING Fixed Account or an ING stable value alternative investment where available. Not available with Self-Directed Brokerage Account or with certain compensation options

2 Split Funding Producer Compensation Options Commission Payments to Brokers. Not available with TAB, Self-Directed Brokerage Account or with certain compensation options 18 options Deposit Based (up to 2%) Asset Based (up to 100 basis points on assets) Combinations (Deposit Based and Asset Based) Hybrid Options When contributions are received Enroll-by-Phone Enroll-by-Internet Online Enrollment Center Mailing of Participant Statements Systematic Allocation: - Dollar Cost Averaging - Account Rebalancing Within 5 business days after quarter end Installation Charge Sponsor level: $0 up to $10,000 in $250 increments (paid at the time the application is submitted to ING) Participant level: $0 up to $100 in $1 increments (deduct only cannot be billed to Sponsor) Fees can be converted to other billables based on Sponsor buying preference Account (Maintenance) Fee Plan Services Installation Charge Annual Asset-Based Recordkeeping Fee on Variable Assets Sponsor level: $0 up to $5,000 in $250 increments (paid separately by the sponsor or deducted from a Trustee Account) Participant level: Varies from $0 to $25 quarterly; $0 - $100 annually in $1 increments (deduct only cannot be billed to Sponsor) Minimum $1,000 annual fee applies if less than $750,000 in transferred assets and less than $10,000 average participant account balance, or less than $100,000 in transferred assets. Minimum annual fee is assessed on each contract anniversary until contract anniversary following plan's attainment of either $125,000 or more in contract assets and $15,000 or more average participant account balance, or $750,000 or more in contract assets Fees vary by plan characteristics Not available 18 options Deposit Based (up to 2%) Asset Based (up to 100 basis points on assets) Combinations (Deposit Based and Asset Based) Hybrid Options When contributions are allocated at the participant level Within 5 business days after quarter end No No Same Same

3 Annual Recordkeeping Fee Daily Asset Charge (DAC) on Variable Options Deferred Sales Charge (DSC) Participant Distribution Fees Loan Administration Fee (OMNI Only) Billing Options DAC is flexible Maximum base DAC is currently 2.00% DAC on variable options only DAC varies depending on compensation, elections made and case characteristics Ability to add on to the DAC for items such as TAB, TPA Fee Payment Basis Point Option, Portfolio Blueprint SM, Morningstar Advice Online SM Fund fee adjustment can range from -0.15% to 0.70%, depending on fund menu and funds selected DAC changes may result in a corresponding change in the Fixed Account credited interest rate Custom pricing at over $15 million DSC schedule usually applies to cases under $400,000; DSC buyout available No DSC or MVA for payments paid pro-rata from all investments at retirement, death, disability, severance from employment, hardship, loans or in-service withdrawals after 59 ½ Applicable DSC or MVA will apply to nonbenefit surrenders No charge See ING Loan Program under Optional Services Plan Sponsor pays all Participants pay all Various options in between the above two Same DSC option available as alternative to compensation chargebacks for cases over $400,000. Schedule varies (5 or 6 year period) depending upon compensation option selected. No chargeback or DSC on certain compensation schedules Market Value Adjustment (MVA) may apply to Stable Value Option No DSC or MVA for payments paid pro-rata from all investments at retirement, death, disability, severance from employment, hardship, loans or in-service withdrawals after 59 ½ Applicable DSC or MVA will apply to nonbenefit surrenders $25 one-time charge per disbursement (applies to rollovers, distributions, excess deferrals, excess contributions and in-service withdrawals and mailing of applicable 1099 reports) $50 one-time charge per loan Plan Sponsor pays all Participants pay all Various options in between the above two

4 TPA Fee Service Reimbursement Program (Alliance & Partners Programs) Bank for Wire Transfers. Please note: The Partners Program is not available with all broker dealers The Chase Manhattan Bank ABA Number Bank Account Name Electronic Premium Collection FBO Separate Account/General Account as their interest appears Customer Services Telephone Number for Plan Sponsors. Please note: The Partners Program is not available with all broker dealers Wachovia Bank of Winston Salem, North Carolina ING National Trust/ Premium Collection Bank Account Number Hartford: (888) (800) Phoenix: (877) Customer Services Telephone Number for Participants (800) (800) OPTIONAL SERVICES Directed Trustee and Custodial Services Monthly Mailing of Statements to Participants Homes Monthly Sponsor Statements of Activity Blended Fixed Fund Rate Accounting TPA Fee Payment Basis Point Option (Available to all TPAs) ING National Trust Agreement $750 billed annually $1 per participant per month $250 per year $250 per year Not available Options include from 0.05% to 0.50% DAC add on (in 5 basis points increments) Corresponding reduction in Fixed Account credited interest rate Additional payment options available: Flat Dollar Amount Pro Rata Amount Fee taken at time of Request ING National Trust Agreement $750 billed annually $1 per participant per month Not available Options include from 0.05% to 0.50% DAC add on (in 5 basis points increments) Corresponding reduction in Fixed Account credited interest rate Additional payment options available: Flat Dollar Amount Pro Rata Amount Fee taken at time of request

5 OPTIONAL SERVICES Continued ING Loan Program Self-Directed Brokerage Account (SDBA) 1 For cases with at least $1 million in total assets Two loan repayment methods available: Payroll Deduct repayments automatically deducted by employer from participant s paycheck (bi-weekly, weekly, semi-monthly, or monthly) Direct Bill participants responsible for remitting their own loan repayments Loan request initiated via ING Access Website or ING Automated Loan Line Summary loan information included on quarterly participant statements 24 X 7 Internet and phone access to loan information ING per participant fees $50 installation fee; $50 annual fee thereafter; fees waived for takeover loans ING Ultimate (Provided through ING Financial Advisers, LLC) $50 per year for participants electing this account (deducted on Contract Anniversary Date). Applicable brokerage account transaction fees apply. Not available with Transferred Asset Benefit (TAB), Equity Wash option, or Split Funding or with certain compensation schedules. Not Applicable Loans for plans serviced on OMNI are available under a different program and fee structure. Ameritrade Corporate Services TM $50 per year for participants electing this account (deducted on November 1st of each year). Applicable brokerage account transaction fees apply. Not available with Transferred Asset Benefit (TAB) or with certain compensation schedules. 1 You must be registered with ING Financial Advisers in order to offer the Self-Directed Brokerage Account. Registered Representatives (Series 6) may provide only marketing materials and general information. General Securities Representatives (Series 7) may discuss this option. Other than the ING companies identified, no other entities, whether distributing or listed on the material, are affiliated with the ING family of companies. Brokerage services provided by TD AMERITRADE, Division of TD Ameritrade, Inc., member NASD/SIPC. TD AMERITRADE is a trademark jointly owned by TD AMERITRADE IP Company, Inc. and The Toronto-Dominion Bank. TD AMERITRADE is an independent entity and not a corporate affiliate of ING Financial Advisers, LLC (Member SIPC).

6 OPTIONAL SERVICES Continued Morningstar Advice Online SM Participant Investment Guidance Service 2 Portfolio Blueprint SM With Investment and Fiduciary Solutions from Morningstar Associates 2 $5 per participant annually* or 0.05% DAC add on and 0.05% credited rate reduction *May be billed to the Sponsor or deducted from participant accounts 0.10% DAC add on for cases with less than $2.5 million 0.05% DAC add on for cases with $2.5 million or more Corresponding reduction in Fixed Account credited interest rate $5 per participant annually* or 0.05% DAC add on and 0.05% credited rate reduction *May be billed to the Sponsor or deducted from participant accounts 0.10% DAC add on for cases with less than $2.5 million 0.05% DAC add on for cases with $2.5 million or more Corresponding reduction in Fixed Account credited interest rate 2 Through a strategic relationship with Morningstar Associates, LLC, a registered investment advisor and wholly owned subsidiary of Morningstar, Inc., ING makes available Portfolio BlueprintSM, a service offering investment solutions and fiduciary support from Morningstar Associates for plan sponsors. Morningstar Associates makes its fund selections from the fund platform that is available under the applicable ING product, which is a subset of the broad fund universe. The fund platform includes both proprietary and non-proprietary funds. Only ING proprietary options are made available in the money-market and stable-value categories. ING may at times request that Morningstar Associates reconsider specific fund selections but the final decision on which funds are selected for Portfolio Blueprint is Morningstar Associates. For Advice Online, Morningstar's service relates solely to the investment options offered under the plan. ING provides Morningstar with information about the plan's investment options and participants but the decisions regarding the advice provided is Morningstar's. The Morningstar name and logo are registered marks of Morningstar, Inc. All other logos and marks are the property of their respective owners. ING and its companies are not affiliated with the Morningstar family of companies and receive no fee or other direct financial benefits from Morningstar in connection with the use of its services. Insurance products issued by ING Life Insurance and Annuity Company, One Orange Way, Windsor, CT Securities offered through ING Financial Advisers, LLC (member SIPC) and other broker dealers with which it has a selling agreement ING North America Insurance Corporation C (9/07) Retirement Insurance Investments Your future. Made easier. SM

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