MEMORANDUM. The following states have enacted regulations requiring annuity suitability training:

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1 11140 Rockville Pike Suite 00 Rockville, MD Tel: or Fax: MEMORANDUM DATE: July 7, 2011 TO: FROM: All Annuity Agents National Brokerage Associates, Inc. RE: NAIC Annuity Suitability Regulation Several states have recently enacted, or have legislation pending, that will impact producers selling or soliciting individual annuity products. The following states have enacted regulations requiring annuity suitability training: Iowa 1/1/2011 D.C. 6/24/2011 Colorado 4/1/2011 Ohio 7/1/2011 Wisconsin 5/1/2011 Oregon 7/1/2011 Rhode Island 6/1/2011 West Virginia 7/1/2011 North Dakota 8/1/2011 South Carolina 9/25/2011 Maryland 11/1/2011 New Jersey 6/06/2011 It is expected that this annuity suitability course will be required by nearly every jurisdiction in the near future. In addition to carrier product specific training, each state is also requiring 4 hours of additional CE to be completed before any annuity product is solicited (for example, RegEd).The 4 hours of training must be completed through an approved vendor whereas product-specific training will be provided by the insurance carrier themselves. A good example is ANICO, which has developed a separate website for the product specific training For further questions please contact our Licensing Coordinator - Pat ext Thank you for working with National Brokerage Associates, Inc. We appreciate your business! Please feel free to call me if you need anything else or have any questions.

2 Important s NEW STATE ADOPTIONS South Carolina SC Reg /25/2011 0/25/2012 SC agents who obtain a life insurance line of authority on or after 9/25/2011 must complete both SC agents holding a life insurance line of authority issued prior to 9/25/2011 will be given six months to complete BOTH training requirements, provided such producers are in compliance with Aviva s current standards for product training at the time the annuity application is taken. West Virginia B WV agents who obtain a life insurance line of authority on or after 7/01/2011 must complete both WV agents holding a life insurance line of authority issued prior to 7/1/11 will be given six months to complete BOTH training requirements, provided such producers are in compliance with Aviva s current standards for product training at the time the annuity application is taken. PREVIOUSLY ANNOUNCED STATE ADOPTIONS Colorado /01/ /01/2011 CO producers who obtain a life insurance line of authority on or after 4/01/2011 must complete both CO producers holding a life insurance line of authority issued prior to 4/1/11 will be given six months Iowa IAC /01/ /01/2011 IA producers appointed after January 1, 2011, must complete both the 4 hour CE course and the product-specific training prior to soliciting an annuity application. IA producers appointed prior to effective date must have completed BOTH trainings by May 1, 2011, in order to avoid interruption with processing applications. North Dakota Section /01/ /01/2012 ND producers who obtain a life insurance line of authority on or after 8/01/2011 must complete both ND producers holding a life insurance line of authority issued prior to 8/1/11 will be given 12 months Ohio OH producers who obtain a life insurance line of authority on or after 7/01/2011 must complete both OH producers holding a life insurance line of authority issued prior to 7/1/11 will be given six months (continued)

3 Important s Continued PREVIOUSLY ANNOUNCED STATE ADOPTIONS Oklahoma 25 07/1/ /14/2011 OK producers that held a life insurance line of authority prior to July 1, 2010, must complete the four-hour continuing education course by July 14, OK producers who had a life insurance line of authority on or after July 14, 2010, must complete the training prior to selling an annuity. In addition, all producers regardless of license date must complete the Aviva product specific training requirements by July 14, 2011 to continue to sell annuity products. If either training is not completed by July 14, 2011, your business will be returned. Oregon OR producers who obtain a life insurance line of authority on or after 7/01/2011 must complete both OR producers holding a life insurance line of authority issued prior to 7/1/11 will be given six months Rhode Island Washington DC Wisconsin 12 06/01/ /01/ /24/ /24/2011 WI Stat /01/ /01/2011 RI producers who obtain a life insurance line of authority on or after 6/01/2011 must complete both RI producers holding a life insurance line of authority issued prior to 6/1/11 will be given six months DC producers who obtain a life insurance line of authority on or after 6/24/2011 must complete both DC producers holding a life insurance line of authority issued prior to 6/24/11 will be given six months WI producers who obtain a life insurance line of authority on or after 5/01/2011 must complete both WI producers holding a life insurance line of authority issued prior to 5/1/11 will be given six months 1 Please refer to existing communications for Iowa, Colorado and Wisconsin training that is currently required. 2 Oklahoma required training law was effective prior to solicitation for any agent licensed after July 14, Refer to existing communication. Please refer to existing communications for North Dakota, Ohio, Oregon, Rhode Island and Washington DC training that is currently required. (continued)

4 Product-Specific Modules December, 2010 Below are links to the product-specific training. The training must be completed prior to the solicitation for any product. If you have additional questions regarding this training, please contact the number indicated below for the product(s) you will be soliciting. Thank you for choosing ING as your annuity carrier! Non-Registered Fixed Annuities Issued by ING USA Annuity and Life Insurance Company ING Secure Index 5 & 7: ING Secure Index Opportunties Plus: ING Envoy: ING Guarantee Choice & SPIA: For more information, please contact the ING Fixed Annuities Sales Desk at

5 F The Lincoln National Life Insurance Co. 100 S. Clinton Street Fort Wayne, IN Toll Free: 800 2LINCOLN *** Licensing & Appointment Bulletin *** New NAIC Annuity Disclosure Model Regulation Lincoln Annuity Products April 2011 New Annuity Suitability Requirement for New York - 6/0/11 New York has adopted an annuity suitability regulation inspired by the 2010 Suitability in Annuity Transactions Model Regulation (the Model). The New York regulation requires product-specific training, but unlike the Model, does not require general annuity training. Employer-sponsored products are exempt from this regulation. Product Specific Requirement The product specific training courses are required beginning 6/0/11 in the state of New York and are provided on the LIMRA website. Please click on the link below to take the Lincoln specific product course(s): There are four Lincoln annuity training modules provided. s can take one course or multiple courses as applicable to the type of annuity business solicited. Fixed Annuity Fixed Indexed Annuity Variable Annuity SPIA Single Premium Immediate Annuity Please know that the above is Lincoln s current interpretation of New York s Annuity Suitability Regulation. We welcome your inquiry should you have a question or desire to confirm this specific regulation. The insurance companies of Lincoln Financial Group, referred to as Lincoln, strive to assist our distribution partners with information about regulatory changes and trends that may impact the sale of insurance products. As more states adopt annuity education requirements, there will be heightened scrutiny on the products and for requiring specific standards for the licensing and appointment of agents selling annuity products. Please contact our Licensing Team Distribution Gateway at , Option 1, Option 2 with any questions. Lincoln Financial Group is the marketing name for Lincoln National Corporation and its affiliates. LLA For agent or broker use only. Not for use with the general public.

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