ADVISOR TRANSITION GUIDE TRANSFERRING YOUR BROKER/DEALER AFFILIATION TO HD VEST

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1 ADVISOR TRANSITION GUIDE TRANSFERRING YOUR BROKER/DEALER AFFILIATION TO HD VEST

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3 WELCOME TO HD VEST We re happy to have you join our growing family of more than 4,500 Advisors. 1 We ve worked hard to build a competitive model that is focused on you from the moment you join our family and throughout each of your momentous accomplishments. We ve developed this guide with you in mind. Our main goal during the beginning stages of your transition is to help you transfer your business to HD Vest as smoothly as possible. In this guide, you will find detailed policies and procedures that will come in handy throughout your transition period. We ll cover everything from transferring your licenses to our wide array of technology tools, which will all help you run your business effectively and efficiently. At the end of this guide, you will find an easy-to-understand transition timeline you may use to navigate the steps of your transfer, as well as a list of frequently asked questions. Having successfully helped thousands of Advisors join HD Vest, we are ready to address all aspects of your business to ensure a timely and seamless transfer. 1 As of January 1, TRANSFERRING WITH EASE - TRANSITION SPECIALIST TEAM We understand that when transitioning your practice to a new broker/dealer, you need a partner focused on your success. Having successfully helped thousands of Advisors make the move, we have developed a dedicated team and approach to help you along the way. Our Transition Team will be focused on your Day One activities, account paperwork and introducing you to your new broker/dealer platform. They are supported by a team of skilled specialists across a variety of products, back-office processes and can provide general paperwork information. Our transition model brings you two areas of expertise: Our dedicated transition specialists will focus on all the paperwork and client account transfers. Transition Specialists Contact Information: Gene Woodard (866) , option 1, x6330 David Rosa (866) , option 1, x6549 Just as important is post account transition, and our transition consultant will work with you on all the tools and support available at HD Vest. Transition Consultant Contact Information: Heather Gantt (866) , option 1, x6411 Our goal is to ensure you have confidence and the knowledge to be able to focus on your clients and growing your practice with your HD Vest partnership. 1

4 TABLE OF CONTENTS STEP ONE PRIOR TO LEAVING YOUR CURRENT BROKER/DEALER Broker Protocol and Your Responsibilities STEP TWO TRANSFERRING YOUR LICENSE(S) General FINRA Licenses Insurance Licenses Advisor Number Assistant Licenses STEP THREE TRANSFERRING YOUR CLIENT ACCOUNTS Accounts Held Directly with Product Sponsors Account Record Change Form and Mutual Fund Application Form Annuities A Word about Variable Annuities and Variable Life Brokerage Account Transfers to First Clearing Consolidating Outside Fund Positions into First Clearing Advantage Check Writing Mutual Fund Periodic Investments and Systematic Withdrawals Tips to Guide You Through ACATs and Non-ACAT Transfers Reviewing Client Accounts Before the Transfer Proprietary and Non-Transferable Products Margin Requirements Account and Mutual Fund Coding Timing Your Account Transfers Trail Commissions from Accounts Held Directly at Product Sponsors Trail Commissions from Positions Held in Brokerage Accounts STEP FOUR ESTABLISHING YOUR PRESENCE Branch Office Identification Guidelines Retail Communication with the Public Business Cards and Letterhead Disclosures

5 Advertising Compliance Submission Process Communication Correspondence Correspondence Communication Standards Best Practices The Correspondence Review Process Client Notification STEP FIVE TECHNOLOGY VestWizard TM Account Setup and Processing (ASAP) Brokerage Maintenance Reports Customer Service Log (CSL) Trade Management Tool (TMT) Integrated Broker Workstation (IBW) Vest360 TM VestView TM VestVision TM HDVDocs Report Center APPENDIX ONE Transition Timeline APPENDIX TWO Frequently Asked Questions APPENDIX THREE Client Notification Letter Customer Account Transfer Form HD Vest Account Record Change Letter of Instruction Brokerage Account Application HD Vest Mutual Fund Account Application HD Vest Equity Indexed Annuity Disclosure Form HD Vest Insurance Purchasing/Exchange Disclosure (IPED) for Variable Annuities

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7 STEP ONE PRIOR TO LEAVING YOUR CURRENT BROKER/DEALER BROKER PROTOCOL AND YOUR RESPONSIBILITIES Before you resign from your current broker/dealer, you should be aware that HD Vest has signed on to The Protocol for Broker Recruiting (Protocol). The Protocol is an agreement among signatory firms that addresses the transfer of information and solicitation of clients when a registered representative (RR) changes firms. If the firm you are leaving is also a Protocol firm, you can take limited information and notify former clients of your move, if certain specific procedures are followed. We put together a list of frequently asked questions that describe the operation, procedures and specific conditions of taking Client Information according to the Protocol, as it pertains to transferring Advisors. Q: What is the principal goal of the Protocol? A: The Protocol helps to further the clients interest of privacy and freedom of choice in connection with the movement of their RR between firms. Q: If complied with, what benefit does the Protocol confer? A: The Protocol helps RRs and their new firm avoid litigation and potential monetary liability if they follow the procedures and limitations specified in the Protocol. Q: When RRs move from one firm to another and both firms are signatories to the Protocol, what may the RRs take? A: Only the following account information related to clients they sourced while at the firm (Client Information): 1. Client name 2. Address 3. Phone number 4. address 5. Account title Q: Are they prohibited from taking anything else? A: Yes. RRs are prohibited from taking any other documents or information. 5

8 Q: When RRs resign, what must they do? A: Resignations must be in writing, delivered to local branch management and must include a copy of the Client Information that the RR is taking with him or her and a list of clients the RR sourced while at the firm. Q: Could the RR s list of clients provided to the manager differ from what they can take with them? A: Yes. The RR s list delivered to the branch must include the account numbers for all clients serviced by the RR (whether or not the RR is taking the Client Information). The local branch management will send the information to the firm s back office. Q: What if the departing firm does not agree with the RR s list of clients? A: The RR will still be deemed as compliant with the Protocol, as long as the RR exercised good faith in assembling the list and substantially complied with the requirement that only Client Information related to clients he or she serviced while at the firm be taken. Q: What is HD Vest permitted to do with the Client Information brought over by its new RR? A: HD Vest will limit the use of the Client Information to the RR providing notification that he or she has changed firms. HD Vest will not permit the use of the Client Information by any other RR or for any other purpose. If a former client indicates to the RR that he/she would like the prior firm to provide account numbers or other account information to HD Vest, the former client will be asked to sign a standardized form authorizing the release of the information to HD Vest. Q: If the Protocol is complied with, how soon is the prior firm required to provide the new firm with information? And what information is required to be provided? A: The prior firm will forward HD Vest the client s account numbers and/or most recent account statements or information concerning the account s current positions within one business day, if possible, but in any event, within two business days of its receipt of the signed authorization. This information will be transmitted electronically or by fax and the requests will be processed by the central back office rather than the branch where the RR was affiliated. A client who wants to transfer his/her account only needs to sign an ACAT form. Q: If RRs comply with the Protocol, what can they do with their clients? A: They are free to solicit customers who they serviced while at their former firms, but only after their registration with HD Vest is effective. A firm would continue to be free to enforce whatever contractual, statutory or common law restrictions exist on the solicitation of customers to move their accounts by a departing RR before he or she has left the firm. Q: Is there any customer information that the departing RR can provide his/her new potential employer before resigning? A: Yes. It is not a violation of the Protocol for an RR to provide another firm with general information related to the RR s business prior to his or her resignation. As long as that information does not reveal client identity or client confidential information it is not a violation of the Protocol. 6

9 Q: What if, as is often the case at large firms, the RR is a member of a team or a partnership? How does that affect the implementation of the Protocol? A: If an RR is a member of a team or partnership and the entire team/partnership does not move together to another firm, the terms of the team/partnership agreement will govern: 1. the taking of client information 2. which clients the departing team members or partners can solicit. In no event, however, shall a team/partnership agreement be construed or enforced to prevent an RR from taking the Client Information for the clients he or she introduced to the team or partnership or from soliciting such clients. In the absence of a team or partnership written agreement on this point, the following terms shall govern where the entire team is not moving: 1. If the departing team member or partner has been a member of the team or partnership in a producing capacity for four years or more, the departing team member or partner may take the Client Information for all clients serviced by the team or partnership and may solicit those clients to move their accounts to the new firm without fear of litigation from the RR s former firm with respect to such information and solicitations. 2. If the departing team member or partner has been a member of the team or partnership in a producing capacity for less than four years, the departing team member or partner will be free from litigation from the RRs former firm with respect to client solicitations and the Client Information only for those clients who he or she introduced to the team or partnership. If your firm is not part of the Protocol, then the Protocol does not apply. If you have a non-compete agreement or confidentiality agreement with your current broker/dealer, please disclose this information immediately to HD Vest and send a copy of the agreement to your Business Development Consultant. These agreements and any implications that might affect your transfer must be discussed with our Compliance and Business Development departments in advance to avoid complications in registration and in transferring business. 7

10 STEP TWO TRANSFERRING YOUR LICENSE(S) GENERAL If you have had any complaints, disciplinary action or other disclosable events that require a yes answer on Form U-4, you must disclose all relevant information in advance to HD Vest and provide documentation regarding these matters. This disclosure will make it easier for us to process your application materials, which must contain reference to these matters. If you provide investment advisory services, please discuss this with your Business Development Consultant in advance, so that we can provide necessary licensing instructions and support services to transition your business to HD Vest s Registered Investment Adviser (RIA), HD Vest Advisory Services SM. Please submit your completed application to HD Vest at least four weeks prior to transfer, so we can ensure that everything is in good order. For Registered Representatives: HD Vest Transfer Application Fingerprinting should be completed via the Business Information Group system Promised payout application with copies of commission statements, if applying for a promised payout For Investment Adviser Representatives: HD Vest Investment Advisor Representative Application APPLICATION SUBMISSION PROCESS Your application can be submitted to your Business Development Consultant s attention via: Fax (972) Mail [email protected] HD Vest Financial Services Attn: Business Development Consultant s Name 6333 N. State Highway 161, Fourth Floor Irving, Texas FINRA LICENSES Whenever possible, HD Vest uses the Temporary Agent Transfer (TAT) system to transfer a license. TAT is an electronic transfer of your FINRA and state securities licenses that clears you to do business, usually within 48 to 72 business hours. TAT allows for the automatic electronic registration and licensing of individuals with Self-Regulatory Organizations (SROs) or jurisdictions with whom they have held a registration within the past 30 days. If your previous registration terminated more than 30 days ago, the registration will need to be manually reviewed by FINRA. 8

11 HD Vest monitors your registration and will alert you to any unusual complications. We will contact you once your registration is approved. You may not engage in any client solicitation or transactions as an HD Vest Advisor until HD Vest notifies you that your licensing has been completed. Also, you may not service any accounts in states where you remain unlicensed until new licenses are granted. INSURANCE LICENSES HD Vest Insurance Agency, LLC has selling agreements with numerous top-quality insurance companies. To transfer your current insurance appointments over to HD Vest, you must first be released from your current appointments and then be reappointed through HD Vest. Insurance Licensing with each company is crucial, as timing varies from company to company and state to state. Please feel free to contact our Insurance department at (866) , option 1, x4040 with questions regarding insurance products. Contact our Insurance Licensing department at (866) , option 1, x4609 with questions regarding appointments and insurance licenses. Variable annuity and life providers ordinarily only accept the broker/dealer change on accounts once the securities license transfer has been approved in writing by FINRA, and the appointment paperwork has been received and approved at the companies. ADVISOR NUMBER Once licensed with HD Vest, you will be assigned an Advisor number, which entitles you to process orders. HD Vest cannot assign you a number until FINRA licensing has been completed. Your Business Development Consultant will notify you when you have been approved. ASSISTANT LICENSES If you are bringing assistants with you the following must take place: Registered Income Producing Assistants These individuals will be required to go through the same application process as you. This will need to be done simultaneously with you to ensure they have systems access to assist you with the ACAT process. Registered Non-Income Producing Assistants These individuals will be required to go through the same application process as you. This will need to be done simultaneously with you to ensure they have systems access to assist you with the ACAT process. Non-Registered Assistants An Electronic Fingerprint Request form must be completed and submitted to the Licensing department. The Licensing department will coordinate with the Assistant to schedule fingerprinting through our vendor, Business Information Group. Once this has been completed, the fingerprints will be submitted electronically to FINRA for approval. Once approval has been received, the Assistant will be assigned systems access. Non-registered assistants can perform ministerial administrative tasks under your direction and supervision, but may never discuss client accounts or investments with clients, handle client funds or securities, or perform any other function that would require a securities license. 9

12 STEP THREE TRANSFERRING YOUR CLIENT ACCOUNTS Currently, your client accounts are being held in one of two ways: in a brokerage account or directly with the product sponsors. Where your client accounts are held determines the procedure you will need to follow. The three general transfer scenarios are: Accounts that are held directly with product sponsors Brokerage account transfers into HD Vest s clearing firm (First Clearing, LLC) Consolidating outside (directly held) fund positions into First Clearing Please note that block transfers are not permitted. ACCOUNTS HELD DIRECTLY WITH PRODUCT SPONSORS Your client accounts may be held in the client s name directly with a mutual fund, insurance company or other product sponsor. If this is the case, you will need to change the broker/dealer of record on these accounts. HD Vest has selling agreements with many mutual fund and insurance companies, and product sponsors will only transfer the broker of record to HD Vest if there is a current selling agreement in place. If you have significant assets with a company and are not sure whether HD Vest has a selling agreement with that company, you should discuss this with your Business Development Consultant. Account Record Change Form and Mutual Fund Application For accounts held directly with the product sponsor, clients will complete the Account Record Change Form (ARC) (see sample in Appendix Three) and the HD Vest Mutual Fund Application (see sample in Appendix Three) to authorize transferring their accounts to HD Vest. Both forms can be accessed via the Forms Gallery on HDVLink. Use one ARC form per household for all accounts at each product sponsor. For example, if you have a family with four Putnam accounts (one joint account, one custodial account and two IRAs), you can reference all of their Putnam account numbers on one ARC form with signatures of all account owners. If the accounts are spread over multiple fund companies, you will need to fill out an ARC for each fund company. The HD Vest Mutual Fund Application is also needed for each registration that the client has. For example, if the client has a joint account and an IRA, then two HD Vest Mutual Fund Applications are needed (no matter how many sponsors are involved). These forms contain important information that the Firm is required to collect and maintain to meet regulatory requirements related to suitability, customer identification and anti-money laundering. Forms Gallery Location: HDVLink > Mutual Funds > Tools > Forms Gallery Please note: As a best practice, include a recent account statement (dated within 90 days) from the product sponsor. When submitting a Trust Account Record Change Form held at directly with a mutual fund, include the first and last page of the trust document. Remote Capture the completed ARC forms along with the HD Vest Mutual Fund Applications, with original client signatures, to the HD Vest Operations department for processing. Once we process these forms they will be forwarded to the product sponsor to have the broker/dealer changed. This paperwork can also be mailed or faxed to the HD Vest home office. Please note: Remote Capture is an online tool that allows you to send forms to us electronically. As a best practice, submitting the required paperwork via Remote Capture allows for automated workflow eliminating potential delays associated with mail or facsimile. Remote Capture Location: HDVLink > Advisor Center > HDVDocs > Remote Capture 10

13 Retain copies of the forms for your records and follow up with the respective sponsors to ensure that your clients accounts have been switched to HD Vest. Most fund families facilitate these transfers in a timely manner. HD Vest offers online reporting of mutual fund accounts (such as Portfolio Reports) via HDVLink. However, please note that in most cases your client accounts will be manually added to these reports by the Operations department after the broker/dealer has been changed at the product sponsor. If you do not immediately see your client accounts on HDVLink, do not be alarmed. We also offer access to the DST Vision or Advisor Central industry websites, and through these tools you will be able to determine which accounts have been changed over to HD Vest and which have not. DST Vision and Advisor Central Location: HDVLink > Mutual Funds > Tools > Access to DST Vision/Advisor Central ANNUITIES The process to transfer variable and fixed annuities to HD Vest is very similar to mutual funds. We require an Account Record Change Form (ARC). Use one ARC form per household for all accounts at each product sponsor. In addition, for variable annuities only, the Insurance Purchase and Exchange Disclosure Form (IPED) (see sample in Appendix Three) is also needed for each registration that the client has. Note that only the clients financial information along with the signed client agreement is needed from the IPED form. Equity Indexed Annuities require the Indexed Annuity Disclosure Form (see sample in Appendix Three) and you will need to ensure that you update your Outside Business Activities under your Advisor Profile on HDVLink. You will need to list your Outside Business name as HD Vest Insurance Agency with the HD Vest home office address, select the appropriate Business Category, and the Position should indicate Equity Indexed Annuity. Advisor Profile Location: HDVLink > Advisor Center > Advisor Profile - Scroll down to Outside Business Activities EIA Approved List Location: HDVLink > Insurance > Services > Fixes and Variable Annuities > Equity Indexed Annuity Policy - EIA Approved Product List is located under Related Topics Please note: As a best practice, review approved Equity Indexed Annuity (EIA) Product List to confirm our approved EIA products. In addition, include a recent statement (dated within 90 days) from the product sponsor. A Word about Variable Annuities and Variable Life Before any variable annuity and variable life accounts can be transferred, your individual appointment with the insurance company must be transferred to HD Vest. This appointment cannot be changed until FINRA has transferred your registration to HD Vest. To expedite this process, contact the Insurance Licensing department to let them know the appointments you would like to transfer. Contact Insurance Licensing at (866) , option 1, x4609. Please note: As a general rule of thumb, life insurance policies sold as a career agent are not transferable. Qualifying is based on length of service; some career agents are vested in their books of business and are allowed an exception to the general rule. BROKERAGE ACCOUNT TRANSFERS TO FIRST CLEARING If your client accounts are currently registered in street name and held in a consolidated brokerage account, you will need to transfer these accounts using our brokerage account transfer systems. This is generally referred to as an Automated Customer Account Transfer (ACAT). You must also complete both the Customer Account Transfer form (see sample in Appendix Three) and the brokerage New Account Application (see sample in Appendix Three), using our VestWizard tool, which is used to open a new brokerage account at HD Vest. VestWizard location: Tool: HDVLink > Vest360 tab > I want to dropdown menu > Open an Account or View VestWizard Dashboard Information: HDVLink > Brokerage > VestWizard 11

14 The ACAT represents a transfer of accounts between member firms. According to industry rules, once the process has been initiated with First Clearing, member firms must process all retail and qualified account requests received in good order within seven business days. The ACAT system, generally considered faster than its non-automated counterparts, is designed to move entire or partial positions held in the account as they appear on your client s statement. Upon receipt of the transfer request, your client s previous clearing firm will cancel all open orders and restrict future trades from occurring during the transfer process. Please note: Many delivering firms will charge an account termination fee. This fee is charged to the client s account before it is delivered out. The fee varies depending on the firm. Moreover, retirement accounts may be charged an IRA closing/annual maintenance fee in addition to the termination fee. Please check with the specific firm for fee information. In addition, if the above fees cause a negative cash balance situation to occur, many brokers will transfer that negative cash balance over to First Clearing in conjunction with the other securities transfers. The debit would then need to be resolved on the First Clearing side by having the client send in additional funds for deposit, or by placing a sell order to create sufficient cash in the account. The ACAT procedure is as follows: Submit a Transfer Request in VestWizard VestWizard Location: HDVLink > Vest360 tab > I want to dropdown menu > Request Transfer into Brokerage Submit one ACAT transfer request per account number. VestWizard will designate required fields to be completed before submitting. VestWizard will generate the required forms to be submitted. Please include a recent account statement from the contra-firm (dated within 90 days) for each client. Please include a Signature Guarantee Form with each transfer submission. (The client does not have to sign this form). This will allow HD Vest to provide a signature guarantee to the contra-firm if we are requested to do so. Additional First Clearing forms may be required in certain circumstances. Contact General Support at (866) , option 2, to cover additional transfer forms required. Examples: Trust accounts require the Trustee Certification of Investment Powers (TCIP) form. All corporate accounts require a Money Services Business Questionnaire as well as the company s Corporate Resolution. In addition to corporations, all partnerships, government organizations and non-profits require due diligence forms. Please contact the HD Vest Compliance team for more details on opening these types of accounts. Accounts trading Options would require the Option Agreement. If check writing is requested, the Advantage Account Agreement is needed. (See more on Advantage Check Writing below.) CONSOLIDATING OUTSIDE FUND POSITIONS TO FIRST CLEARING (FCC) If your client accounts are held directly with a mutual fund sponsor or bank and you want to consolidate these accounts by transferring them to First Clearing, this is called a Non-ACAT transfer. To complete this transfer, use the same First Clearing Customer Account Transfer form. VestWizard tool will generate the required form for the client(s) to sign. VestWizard Location: HDVLink > Vest360 tab > I want to dropdown menu > Request Transfer into Brokerage 12

15 Advantage Check Writing If the client wants to initiate or maintain check writing and/or debit card features on the First Clearing account, an Advantage Account Agreement is necessary. Once the Advantage feature is established, new checks and/or a new debit card will be issued. Please be sure all checks have cleared before submitting the transfer paperwork. All old checks should be destroyed. Advantage Checking includes: Unlimited check writing Optional Advantage debit card with access to more than 12,000 Wells Fargo ATMs nationwide with no service fees. If non-wells Fargo ATMs are used, a surcharge fee may be assessed by the other institution. 24/7 online account access Online access to CheckFree Bill Pay services with no monthly service fee. Enhanced statements and expense tracking Easy-to-read consolidated monthly statements Payee information included on statements Expense tracking options Automated daily cash sweep All cash balances in a client s brokerage account are swept daily into the Bank Deposit Sweep or an eligible money market fund. The sweep occurs daily for new cash deposits in IRA accounts, Advantage accounts and in standard brokerage accounts when cash balances are $1,000 or more; otherwise, if new cash deposits in standard brokerage accounts are less than $1,000, the cash balance will be swept weekly. Annual summary and tax documents If a client has the debit card feature on their account or more than $50,000 in assets at year end, they will receive an annual summary that will include all transactions in the brokerage account with the Annual Summary and Tax Package. Advantage Check Writing Location: HDVLink > Brokerage > Resources > Advantage Mutual Fund Periodic Investments and Systematic Withdrawals If the account has mutual fund periodic investments (PIPs), systematic withdrawals (SWPs), or periodic money movements established, these will stop once the account is transferred and will need to be established in the new account. PIPs and SWPs can be established online in IBW and do not require paperwork to be submitted. Establishment of a periodic money movement will require a form that needs to be signed by the client and submitted to HD Vest for processing. The Asset Movement and IRA Service Request tools are available on HDVLink and will generate the required form. Please note: The position must be transferred or purchased in the account before any systematic liquidations can be established. Service Request Location: HDVLink > Brokerage > Tools > Account Setup & Maintenance > Service Requests > Asset Movement (non-retirement accounts) or IRA Service Request (retirement accounts) TIPS TO GUIDE YOU THROUGH ACAT AND NON-ACAT TRANSFERS Reviewing Client Accounts Before the Transfer Review your client accounts for any transactions that need to be completed within the next four to six weeks. Complete them to the extent possible in order to avoid the effects of any blackout period. Check your client s most recent statement for cash debit balances. Clients should pay off these debits before submitting paperwork. 13

16 When establishing a new brokerage account via VestWizard, it is important to ensure that the account registration, names and tax ID on the account at the carrying firm all match the registration of the new FCC brokerage account you will be establishing. Please note: For assistance with Non-ACAT transfers, contact our General Support department at (866) , option 2. Proprietary/Non-Transferable Products Some positions may not be transferable into a FCC brokerage account. To determine if the proprietary funds or other securities your clients hold are transferable, please contact our General Support department at (866) , option 2. If certain positions cannot be transferred, you should not recommend that they be liquidated based on this fact. A recommendation to a client to liquidate any product must be suitable based on the client s financial needs and objectives, and there must be clear benefit/need for the client to sell the investment and purchase another one. In the event that there is a clear benefit and the client does choose to liquidate the investment(s), a Letter of Acknowledgment Regarding Change in Investment Portfolio (LARCIP) form must be completed, signed by the client and submitted with the new account paperwork. LARCIP Location: HDVLink > Brokerage > Tools > Account Setup & Maintenance > New Account > Forms Gallery - In the keyword search, type in LARCIP Once the client s brokerage account is transferred, any residual monies will be transferred to the new account. Brokerage firm money market positions are automatically liquidated in the ACAT process. Margin Requirements All brokerage firms have different margin requirements. If you are transferring a margin account with obscure positions or high loan-to-value ratios, please call the General Support department at (866) , option 2, so we can verify what First Clearing s margin requirements are for that particular account or security. Account and Mutual Fund Coding When transferring mutual funds to a FCC brokerage account, the dividend coding of the mutual funds can be elected on the account transfer paperwork if it is noted on the account statement. If the reinvestment election is not made on the transfer form, the default will be set to reinvest. When the mutual fund position is received in the First Clearing account, the distribution options can be changed. In Integrated Broker Workstation (IBW), go to the Account Balances and Positions page where you can change the dividend reinvestment option for each mutual fund held in the account. IBW Location: HDVLink > Brokerage > Tools > Brokerage Trading Tools > IBW TIMING YOUR ACCOUNT TRANSFERS When transferring to a new broker/dealer, you may want to take the following into consideration when you are making a decision regarding the timing of your transfer. Trail Commissions from Accounts Held Directly with Product Sponsors For directly held accounts, product sponsors generally pay 100 percent of the trail commission payment to the broker/dealer listed on the account at the time the trail commission is calculated. However, some sponsors will prorate the quarterly trail commission between the two broker/dealers. Most commonly, but not inclusively, product sponsors calculate trail commissions on a calendar quarter basis. For specific calculation dates, please check with the product sponsor. Trail Commissions from Positions Held in Brokerage Accounts Trail commissions on positions held in brokerage accounts are generally paid to the broker/dealers on a prorated basis. For example (assuming the trails are calculated quarterly), if the brokerage account is transferred to HD Vest on March 1, then two-thirds of the first quarter trail commissions are paid to the old broker/dealer and one-third is paid to HD Vest. 14

17 STEP FOUR ESTABLISHING YOUR PRESENCE BRANCH OFFICE IDENTIFICATION When you become an Advisor with HD Vest, you will be designated as a branch office, unless you are joining the existing branch office of another Advisor. A branch office is a location identified, by any means, to the public or customers as a location at which the Advisor conducts securities business. Advisors must be careful not to identify any location, other than the branch office, as a place where securities business is conducted. The HD Vest Licensing department handles your branch registration when you affiliate. You will be registered with FINRA and with your state (depending on certain state requirements). Guidelines FINRA branch offices are required to display the HD Vest Investment Services SM and SIPC signs. These signs will be sent to you upon registration and must be displayed prominently in your office location. Securities files and investment records must be kept separately from files related to other business activities and must contain the required information. Compliance Required Files Location: HDVLink > Compliance & Sales Supervision > HD Vest Branch Exams > Branch Exams Advisors offices are subject to inspection by the SEC, FINRA, state regulators, and HD Vest. RETAIL COMMUNICATIONS WITH THE PUBLIC HD Vest policies state that various investment-related communications with the public must be approved prior to distribution. The review of Advisor s submissions is handled by a dedicated team at the home office, Advertising Compliance. Advertising Compliance utilizes the Customer Service Log (CSL) system to facilitate the review of any material you submit. Submissions received each day prior to 2 PM. Central Time will have a CSL opened the same day. Submissions received after 2 PM. Central Time will have a CSL opened the next business day. Within the CSL tool you can view your open and closed logs or perform a search of your logs by entering a date range. CSL Location: HDVLink > Advisor Center > Tools > Customer Service Log (CSL) All submissions are reviewed in order of receipt. The initial review of your submission will typically occur within five business days. All compliance review comments and the status of your submission will be communicated via CSL. Please monitor your logs closely for any required revisions you must submit for re-review. Items that are required to be re-submitted for review and final approval will typically be reviewed within two business days. 15

18 Business Cards and Letterhead One of your compliance requirements is to have an approved investment related business card and letterhead. You can access information pertaining to the necessary procedures to order business cards and stationery on HDVLink. You should have these in place within six weeks of your effective date. Not only does this bring you into compliance immediately but these templates can be printed on card stock from your own home computer or you can take them to your local printer to have a supply printed. Business Cards and Letterhead Samples Location: HDVLink > Sales & Marketing > Sales & Marketing Ideas > Advertising/PR Samples Please note: Any material change such as an add or drop of any securities licenses, addition of an address, business name, title, website, etc. requires you to submit the new version to Advertising Compliance for review and approval prior to distribution. DISCLOSURES Depending on your licensure, the following disclosure is required to be included on any investment-related item, such as letterhead and business cards: Securities Licensed Only If you only hold securities registration, the following disclosure is required on your investment related item: Securities offered through HD Vest Investment Services SM, Member SIPC 6333 N. State Highway 161, Fourth Floor, Irving, TX (972) If you have your FINRA branch office address on your submission, you have the option of removing the home office address from the above listed disclosure. Securities and Advisory Licensed If you hold both a securities and advisory registration, the following disclosure is required on your investment related item: Securities offered through HD Vest Investment Services SM, Member SIPC Advisory services offered through HD Vest Advisory Services SM 6333 N. State Highway 161, Fourth Floor, Irving, TX (972) If you have your FINRA branch office address on your submission, you have the option of removing the home office address from the above listed disclosure. Outside Company Name Used If you mention an outside business name in your submission, the following disclosure is required: (INSERT COMPANY NAME HERE) is not a registered broker/dealer or independent investment advisory firm. Below are the standards for the font size of the disclosure in your submission. 16

19 Item Business Cards Letterhead Signs Directory Advertisements Other Items Disclosure Font Size Minimum six point disclosure font size Minimum eight point disclosure font size The disclosure font size must be relative to the verbiage font size used on the sign for example, if the text of your sign is 30 point font size then the disclosure should be 25 point not eight point The disclosure font size must be relative to the verbiage font size used in the ad for example, if the text of your ad is 12 point font size then the disclosure should be 10 point not six point The disclosure font size must be relative to the font size used in the main body of the advertisement ADVERTISING COMPLIANCE SUBMISSION PROCESS Materials may be submitted to Advertising Compliance via: Fax (972) Mail Advertising Compliance 6333 N. State Highway 161, Fourth Floor Irving, Texas COMMUNICATION Policy HD Vest policies state that any investment related correspondence should be sent from your hdvest.net address. If you use an outside address, you are required to carbon copy (cc:) your hdvest.net address on all incoming and outgoing correspondence related to your securities business. It is your responsibility to comply with this regulatory requirement, and failure to do so may result in serious regulatory issues and possible termination from HD Vest. Outside Address Requirements Any address you utilize for investment communication must be disclosed, as well as your outside address. Location to Disclose Your Address: HDVLink > Advisor Center > Advisor Profile - Scroll down to section Additionally, you are required to submit your signature for this address for review and approval prior to use. The approval must be maintained in your office in the Advertising Compliance required file and the signature must be reviewed annually per HD Vest policies. HDVest.net Accounts Communications sent from your hdvest.net account have the appropriate HD Vest standard disclosure included. Any additional signature that is more than your individual name and the title HD Vest Advisor is required to be submitted to Advertising Compliance for review and approval prior to use. The approval must be maintained in your office Advertising Compliance required file and the signature must be reviewed annually per HD Vest policies. 17

20 Websites All websites must be disclosed on your Advisor Profile on HDVLink and submitted to Advertising Compliance annually for review. This includes non-investment related websites and websites for outside businesses. You may maintain a discounted web site through our strategic partnerships with industry leaders for Advisor websites, which provide a compliance interface with our teams. Location to Disclose Your Website: HDVLink > Advisor Center > Advisor Profile - scroll down to website section A website is deemed investment-related if it contains any information regarding investment services or products. Websites might include tax information as it relates to investments; however, the inclusion of this information for any purpose by an Advisor requires it to be compliant with current FINRA regulatory rules and firm policies. Please note: If you intend to use a website to advertise the investment services and products you offer through your affiliation with HD Vest, outside of those offered by through strategic partnership vendors, you must complete an outside website agreement, pay all associated fee(s) and make all necessary changes as directed by the Advertising Compliance department. Due to the increased level of supervision and oversight required on advertising with potentially unlimited and non-targeted audiences, such as websites, there is an annual fee for an outside investment related website of $750. This cost does not include the potential FINRA filing cost that may be incurred. The outside website agreement is available upon request from the Advertising Compliance team. Social Networking and Online Advertising Due to the potentially unlimited and non-targeted nature of online audiences, our oversight of the use of these tools requires that you participate in an Attestation & Training requirement and provide these services through our approved provider. Social networking websites such as Facebook, LinkedIn and Twitter are covered in this training. CORRESPONDENCE Overview Q: What is correspondence? A: Correspondence is any written letter or electronic mail message distributed to a single client; this includes letters, s, memos, notes, etc. including incoming correspondence from clients (this is not an all-inclusive list). Q: Do I need to submit correspondence for review prior to use? A: Correspondence does not require pre-approval. Q: How is correspondence different than investment communication? A: Correspondence is any letter or sent to a single client. If you send the same letter or to multiple clients it will be considered investment communication and requires pre-approval prior to distribution. Q: What are the requirements for submitting correspondence to HD Vest home office for review? A: All incoming and outgoing client correspondence must be forwarded to HD Vest for review within seven business days of receipt or of being sent. Q: Do I need to send the hard copy of the I sent to a client? A: No. Electronic investment related messages must be sent from your hdvest.net account or if using a disclosed outside address you must cc your hdvest.net account. 18

21 Q: Where can I send correspondence for review? A: Any written letter can be scanned and ed to [email protected] or faxed to (972) Correspondence can also be mailed to the home office: HD Vest Advertising Compliance Attn: Correspondence Review 6333 N. State Highway 161, Fourth Floor Irving, Texas Correspondence Communication Standards Q: What are the content standards for client correspondence? A: Traditional standards for communications with the public apply to correspondence. Communications may not contain any untrue, false or misleading statement, any promises of specific results, or exaggerated, flamboyant or unwarranted claims; or, opinions for which there is no reasonable basis, or projections or forecasts of the future. All claims must be able to be substantiated. Any claims that cannot be substantiated are considered misleading and should be removed from any communications. Q: What disclosures should I use on correspondence? A: At a minimum you need to have your broker/dealer disclosure present on all communications. Any written correspondence must be done on approved investment related letterhead. All electronic messages that are not sent from your hdvest.net account must include an approved signature. Q: I have included enclosures with the correspondence, should I send these for review? A: Enclosures are required to be included when submitting correspondence for review. Prospectuses, HD Vest or product sponsor account forms do not need to be forwarded. Q: How do the recent changes to customer reporting rules impact correspondence? A: Custom or consolidated reporting are not permitted by Advisors. Approved reports for use with clients include those found on HDVLink, Morningstar, Black Diamond, or product sponsor/fund family websites. You can give your client their account balance as long as you give the account type, date and source of the information, for example your IRA account balance is XXX as of 04/01/2014 per DST vision. Best Practices Q: How do Advisors ensure they are forwarding correspondence in time for review? A: Advisors with both high and low volumes of client correspondence often will create a weekly task to forward any correspondence not previously forwarded to HD Vest for review. You can keep all correspondence in a single secure location in your office, then once a week make copies/send into the home office and file away in your correspondence file. must be forwarded to your hdvest.net address for archival and review purposes. Q: How do I ensure the content is fair and balanced? A: Please discuss all costs and risks of any investment strategy or product whenever giving a recommendation. To make this easier, we have a list of disclosures available on HDVLink which can be used when talking to your clients about the benefits of certain products/strategies. You must ensure all claims can be substantiated; this can be done by quoting sources on the item in footnotes, for example the market has continued to make progress in the last quarter 1 footnote: 1 Source Bloomberg issue XXX date XXX. Common Disclosures Location: HDVLink > Compliance & Sales Supervision > Advertising Compliance > Common Disclosures 19

22 THE CORRESPONDENCE REVIEW PROCESS Q: What happens if there are issues with my correspondence? A: For most issues Advertising Compliance will open a Customer Service Log (CSL) to communicate what the issue is, and how it can be avoided in the future. No action is required on your part. The log is for your information as guidance for future reference. If further information is required regarding the content of the correspondence, a log will be forwarded to your sales supervisor for review and follow up. Q: Why has my correspondence been referred to another team in Compliance? A: Based on the content of your correspondence and any potential issues related to the activity described within it may require Advertising Compliance to refer your item for follow up by another Compliance team. For example, if your correspondence references a client who is residing in Brazil (a non-permissible foreign country) this item would be referred to our Anti-Money Laundering (AML) Team for further review. CLIENT NOTIFICATION We recommend that you send clients a letter of notification indicating that you have joined HD Vest. A pre-approved letter is available through MarketingPro, Inc., a strategic partner that offers thousands of marketing messages you can send to your clients. Note that this is a subscription-based service with several options available for Advisors. Location: HDVLink > Sales & Marketing > Marketing Tools > MarketingPro, Inc. 20

23 STEP FIVE TECHNOLOGY HD Vest offers a wide array of technology and tools to operate your business effectively and efficiently. Below is an overview of some of these tools. More information and training on these tools are available on HDVLink. VESTWIZARD TM The VestWizard tool will help ensure your brokerage accounts are established quickly and accurately while mitigating Not in Good Order (NIGO) items. With intuitive navigation and real time integration with Vest360, VestWizard prompts you for the client information needed to efficiently and successfully open each new account, minimizes the number of forms clients must sign, and reduces the re-keying of data. This creates a seamless process for completing brokerage account opening. This initial launch of VestWizard will also allow for the creation of transfer requests. Additionally, you will be able to establish accounts 24 hours a day, seven days a week and print account documents before final submission. VestWizard location: HDVLink > Vest360 tab > I want to dropdown menu > Open an Account or View VestWizard Dashboard To facilitate your introduction to VestWizard, a training demo is built directly into the tool or you can view the FAQs on HDVLink > Brokerage > VestWizard. ACCOUNT SETUP AND PROCESSING (ASAP) ASAP is an online application that allows you to establish new directly held mutual fund accounts at fund sponsors. You can also process most fund purchases through ASAP as well as apply for fund features such as checkwriting or systematic investments. ASAP is a rules-based tool that allows you to open new mutual fund accounts and eliminate paperwork errors in the process. Currently ARC forms are not supported via ASAP. However, once the new account information is added, you simply print out the account forms, get client signatures, submit the account and forward to the HD Vest Operations department for processing. ASAP Location: HDVLink > Mutual Funds > Tools > ASAP 21

24 BROKERAGE MAINTENANCE REPORTS A variety of reports are available to you to help maintain your client s brokerage accounts. These reports include accounts: with debit balances, with insufficient funds to process a scheduled distribution, that become restricted, and/or that may be subject to maintenance fees, etc. You will be notified of these items via the Action Items dashboard on HDVLink. Brokerage Report Location: HDVLink > Report Center > Brokerage Reports CUSTOMER SERVICE LOG (CSL) If you need to make HD Vest aware of a service-related item, or simply have a question, you can submit the inquiry via the CSL system. It takes just minutes to open a log, and we have dedicated professionals who are assigned for proper resolution. You are able to view the CSL along with any comments that are placed in the log online. You are also given an approximate time frame as to how long the inquiry will take to resolve. Some departments at HD Vest also use the CSL to proactively notify you of different issues, such as compliance issues, not in good order (NIGO) items, advertising approvals, operational issues, etc. The CSL will notify you by action item or when logs are opened, closed and when comments are made. CSL Location: HDVLink > Advisor Center > Tools > Customer Service Log TRADE MANAGEMENT TOOL (TMT) TMT is a robust trading and management tool available to assist you in managing your clients investments. The tool allows you to group accounts, establish models with assigned portfolio weightings, and systematically rebalance your clients accounts according to the assigned models. TMT Location: HDVLink > Advisory Services > Tools > Advisory Trading Tools > Trade Management Tool INTEGRATED BROKER WORKSTATION (IBW) IBW is an online account servicing and trading tool that will assist you in servicing your clients brokerage accounts. This tool, if you are appropriately licensed, allows you to place mutual fund, equity and option trades, and also gives you access to information pertaining to each brokerage account such as registration, account features, balance/positions, account history and account suitability. IBW Location: HDVLink > Brokerage > Tools > Brokerage Trading Tools > IBW

25 VEST360 TM Vest360 gives you access to complete client account level data and a 360-degree view within a dashboard of all client assets. You will have access to three different pages or views: across your entire client base, for a particular client and by account. The platform delivers a user-friendly interface built with the latest website design standards. It s accessible via mobile devices and tablets, as well as across multiple browsers. Vest360 provides you with quick access to the most important information and actions you need to take from one central location. Since Vest360 is your centralized hub of information, this is where you will access tools such as VestWizard, the 1040 Analyst TM and VestVision TM. Client Center Location: HDVLink > Vest360 tab VESTVIEW TM VestView is the one-stop shop for Advisor Business, which houses all important information about you and your business. You can expect to find: A drop-down menu that will help you perform the most common Advisor tasks. A way to view commission statements more clearly by month and year. You can also search for specifics within your statement, export and save it. A dashboard that will provide easy access to information about your 1099s, licenses, annual business requirements, rolling gross, reports, rankings, and more! VESTVISION TM VestVision is a comprehensive eight-step planning process that was designed from your clients point of view and allows them to be involved in every step of their investment plan. This investment and retirement planning system provides you with the tools and technology you need to help your clients identify and prioritize their life goals, decide on an appropriate investment strategy, monitor their progress, and make revisions whenever necessary. Through VestVision you can help your clients bring their future into focus. HDVDOCS Through HDVDocs, you will be able to scan, search, view, and obtain the status of your submitted client account paperwork through Advisor Center and Vest360 on HDVLink. Once account documents arrive in the HD Vest mail room, either from Remote Capture in HDVDocs or via overnight mail, the paperwork is sorted manually or electronically, scanned (if applicable) and electronically routed to the appropriate processing area. As soon as we have launched your client s paperwork to the workflow system, you can see the paperwork s real-time status through Document Search or Vest360 on HDVLink. HDVDocs Location: HDVLink > Advisor Center > HDVDocs > Document Search or Remote Capture REPORT CENTER Using Report Center, HD Vest presents the available reports by most commonly accessed groupings including Client, Advisory, Brokerage, and Consolidated. The Client report categories include Analytical, Portfolio Summary, Performance, and Advisory Account Detail. The Advisory report categories include VestAdvisor/Select, WFA and Archived. The Brokerage report categories include Balances, Activity, Action Items, and Account Search & Review. The Consolidated report categories include Positions, Transactions and Archives. Report Center Location: HDVLink > Report Center 23

26 APPENDIX ONE TRANSITION TIMELINE TIMELINE STEP ONE STEP TWO STEP THREE STEP FOUR FOUR WEEKS BEFORE TRANSFER Complete your transfer application and submit it to your Business Development Consultant. Organize and review client files in preparation to complete HD Vest new account forms, upon successful registration. Verify if your current broker/dealer will be charging transfer fees on clients accounts. Check accounts for available cash to cover fees before transferring. ONE WEEK BEFORE TRANSFER WELCOME ABOARD AS A NEW HD VEST ADVISOR Compose your letter of resignation. Once your licenses have transferred to HD Vest, you ll receive a call from your Business Development Consultant. As clients receive your mailing, they will be calling your office. Prepare and train your staff to handle your clients immediate questions and concerns. Contact your Business Development Consultant to discuss how you would like to proceed with your transfer on resignation day. Licensing will assign you a representative number and a branch number. Use HDVLink to keep track of account transfer paperwork sent to and received from your clients. Submit a copy of your resignation letter to your Business Development Consultant. Start calling clients to let them know you about your new affiliation, send out client mailing and instruct your clients to mail all forms back to you as soon as possible. Familiarize yourself with HD Vest s Compliance Manual. Once you have completely read the Compliance Manual, please sign the acknowledgement form and return it to Compliance. Provide a name and telephone number of a person at your current broker/dealer so we can confirm your resignation. Look for an from your Wealth Management Consultant with your personalized password to HDVLink. Prepare new client files, set up branch office compliance files and send out your approved thankyou letter to clients who have returned their transfer forms. Prepare a friendly follow-up letter to send to clients who are slow mailing back transfer forms and submit the letter to Advertising Compliance for approval. 24

27 APPENDIX TWO FREQUENTLY ASKED QUESTIONS In order to make this transition as seamless as possible, we ve compiled a list of our frequently asked questions regarding the transfer process. These questions highlight the main topics in this guide and more. Q: When should I submit all my licensing materials to HD Vest? A: You should send everything in at least four weeks prior to the day you wish to transfer. This enables us to review the application for approval and check to see that everything is complete and in good order. Q: Will you notify my current broker/dealer prior to my resignation? A: No, we only contact your broker/dealer after we receive a copy of your resignation letter, to confirm your resignation has been processed. Q: How long does it take to transfer my licenses to HD Vest once I resign from my current broker/dealer? A: Generally, your securities license can transfer via the TAT system in 48 to 72 hours. However, some states may take longer if they do not participate in the FINRA TAT process. Also, if you have any disclosures, the process can take considerably longer. Q: Does HD Vest offer Errors and Omissions (E&O) insurance? A: HD Vest has arranged for a competitive and affordable E&O program for its Advisors. The policy is brokered by Aon Risk Services and is underwritten by Continental Casualty Company, a highly rated insurance company that is very familiar with the broker/dealer business. Optional coverage is also available to cover tax and accounting services. Contact the Plan Administrator at the number below for quotes or further details. Affinity Insurance Services, Inc. 159 E. County Line Road Hatboro, PA Phone: (866) [email protected] Q: How often do you pay commissions? A: Commissions are processed twice per month, on the 15th and last business day of the month. Payments are made approximately five business days after the 15th and the last day of the month. There is a commission schedule available on HDVLink showing the exact dates. Commission Schedule Location: HDVLink > VestView tab > Commission Statements Direct deposit instructions should be provided with your initial paperwork package so that commissions can be sent by ACH. If ACH is not established, a $10 fee is assessed for manual checks. Direct Deposit Location: HDVLink > Mutual Funds > Tools > Forms Gallery - In keyword search field, type in direct deposit, and select Authorization Agreement for Direct Deposit form. 25

28 Q: Will I be viewed as a branch office? A: Unless you are joining the same office as another HD Vest Advisor, you will be established as your own branch office. Q: What is fidelity bonding? A: HD Vest is required by FINRA to maintain a surety bond. The total cost of the bond is shared equally among all Advisors and included in the annual affiliation fee. The surety bond covers employees of HD Vest and protects your clients against losses which may arise on the premises of the broker/dealer, in transit to the broker/dealer, from misplacement, as a result of forgery and alteration, and/or as a result of fraudulent trading. Q: How often do I pay licensing fees? A: Whenever you request a new state registration or need to take a FINRA exam, you will be charged the appropriate fee. Annual renewal fees are automatically charged to your September commission statement for the following calendar year. If you wish to pay the fees by check or credit card, then your statement is credited for that amount. The Licensing department makes certain that all Representatives registrations are renewed annually. Q: To whom do I speak to get licensed with insurance and variable annuity companies that I currently do business with, or that I wish to do business with? A: You will need to contact our Insurance Licensing department at (866) , option 1, x4609. Q: Can I use a DBA name? A: The use of doing business as (DBA) names in conjunction with HD Vest is permissible, subject to including appropriate disclosures; however, if you do choose to use a business name, please be sure that it does not create the impression that you are a broker/dealer or an investment adviser. All outside business activities and letterhead or business cards using a DBA must be disclosed on the Other Business Disclosure Reporting Page and submitted to the Compliance department for review prior to use. Other Business Disclosure Reporting Page is included in your application to affiliate with HD Vest. Other Business Disclosure Update Location: HDVLink > Advisor Center > Advisor Profile - Scroll down to Outside Business Activities & Outside Brokerage Accounts Q: Do you have any material I can use to send to my clients to let them know I m now with HD Vest? A: Yes! We provide pre-approved client letters (see sample in Appendix Three) within HDVLink specifically for this use. Once you have joined our firm, we can introduce you to our approved strategic marketing partner options for additional ease-ofmarketing. Q: When can I send out a letter to my clients to notify them of my new affiliation and have them sign transfer forms? A: Once you have resigned from your former broker/dealer and your license with HD Vest has been approved by FINRA, we recommend that you send clients a letter of notification indicating that you have joined HD Vest. The notification letter should accompany any formal paperwork to be signed by the client. Prior to distribution, please send us the actual letter you plan to use so you can obtain Advertising Compliance approval, unless you are using a pre-approved letter through MarketingPro, Inc. Any contact with clients must be undertaken in compliance with applicable regulations and legal requirements. 26

29 Q: What is the standard account transfer turnaround time? A: For ACAT transfers, the standard transfer time is 10 business days. For Non-ACAT transfers, the standard transfer time is four to six weeks. These timeframes are industry standards. Please note that block transfers are not permitted. Q: If my client is holding proprietary products in another brokerage account, can these be transferred to First Clearing? A: No. Proprietary mutual funds of a brokerage firm are not transferable. If your client s intentions are to liquidate these nontransferable positions, it may be best to have your client liquidate prior to the submission of the transfer paperwork. Your client can also request to liquidate through their Customer Account Transfer form. Please note: Many firms will not accept written liquidation requests and instead require verbal authorization from the client. Q: Can Fidelity Funds be transferred into First Clearing accounts? A: Yes, simply fill out the Customer Account Transfer form. Q: What happens when an account is transferred over to First Clearing through the ACAT system and a dividend is paid to the old account? A: Through the ACAT process, the delivering firm will do a residual sweep of its accounts on a weekly, semi-monthly, or monthly cycle. The residual sweep cycle varies with each delivering firm. Any cash balances will be transferred over at this time. Q: Can I complete forms online? A: Yes. Most forms can be completed online using the Adobe Acrobat Reader (free download available on HDVLink). Simply click on the form, fill it in, print it and present it to your clients for their signature. All forms are available on HDVLink in the Forms Gallery. Forms can be easily located by searching by form name or by clicking on the appropriate HD Vest category. Forms Gallery Location: HDVLink > Mutual Funds > Tools > Forms Gallery Q: How do I order additional supplies, forms and brochures? A: All forms can be printed from the Forms Gallery on HDVLink. Brochures can be ordered using the Online Catalog on HDVLink. Brochure Location: HDVLink > Sales & Marketing > Marketing Tools > Marketing Materials - Online Catalog PDF Previews and Launch Online Catalog are located under Related Topics Q: How do I get a password to HDVLink? A: Once you are licensed, you will receive a user name and password for HDVLink from your assigned Wealth Management Consultant. 27

30 APPENDIX THREE SAMPLE FORMS AND LETTERS Client Notification Letter...30 Customer Account Transfer Form...31 To transfer a brokerage account into First Clearing, LLC HD Vest Account Record Change Letter of Instruction To change name of broker/dealer for accounts held with mutual fund sponsors only Brokerage Account Application...37 To establish a brokerage account into First Clearing, LLC, Customer Service Agreement included HD Vest Mutual Fund Account Application...42 To establish accounts held with mutual fund sponsors only HD Vest Indexed Annuity Disclosure Form This form is required for all initial purchases of indexed annuities, account record changes, and some subsequent investments into an already existing indexed annuity. This document is required per indexed annuity contract established. If a client is setting up multiple annuity contracts for a client, a separate form is required per contract. HD Vest Insurance Purchasing/Exchange Disclosure (IPED) for Variable Annuities This form is required per variable annuity contract established; if a client has multiple group insurance contracts for a client, a separate IPED for Variable Annuities is required per contract. 28

31 Most forms can be accessed on HDVLink through Forms Gallery. The process to print the form or pre-fill the form online is a 4 step process as outlined below: 1. Search for the form in the Keywords field 2. Check the box next to client info unknown and click zoom. 3. Click print or save to desktop (for online form filling) 4. Complete the form Keep in mind that the Brokerage Account Application and the Customer Account Transfer Form can be processed directly through VestWizard. Forms Gallery Location: HDVLink > Brokerage > Tools > Account Setup & Maintenance > Forms Gallery or HDVLink > Mutual Funds > Tools > Forms Gallery Please note: The sample forms provided in this appendix may appear different than they would when you fill out the form online via Forms Gallery. 29

32 SAMPLE Access via MarketingPro, Inc. October 24, 2012 Joann Advisor, Inc. 123 Business Address Irving, TX Phone: (972) Fax: (972) Mr. John Client 500 Client Street Suite 400 Houston, TX Dear John: As your financial professional, I have always been interested in helping you minimize your tax bill and maximize the amount you keep. Therefore, to ensure I can provide you with a broader range of tax and financial services, I am extremely pleased to announce that I have affiliated with a new broker/dealer HD Vest Investment Services SM. HD Vest has been serving the needs of individual investors and small businesses since 1983 exclusively through independent financial professionals such as myself. I am now able to offer my clients a vast array of financial services using a total investment plan that considers a more comprehensive approach. These services include: college planning, retirement planning, brokered CDs* and tax-savings ideas. You have already placed a great deal of confidence in me by allowing me to become familiar with your financial situation, either by preparing your tax return or helping you pursue your financial goals. I greatly value your trust in me. I look forward to further strengthening our relationship with the enhanced client services afforded to us by my new alliance with HD Vest. If you have any questions please feel free to call me any time at (972) Sincerely, Joann Advisor Joann Advisor *CDs are FDIC insured up to $250,000 and offer a fixed rate of return. They do not necessarily protect against a rising cost of living. The FDIC insurance on CDs applies in cases of insolvency of the bank, but does not protect market value. Other investments are not insured and their principal and yield may fluctuate with the market conditions. A Insurance License No «RFname» «RLname», Registered Representative Securities offered through H.D. Vest Investment Services SM Member SIPC 6333 North State Highway 161 Fourth Floor Irving, Texas (972)

33 Customer Account Transfer (Please Use a Separate Form for Each Transfer) FCC Account You are Transferring TO Social Security or Tax ID Number Secondary Social Security FCC Clearing Number Brokerage Account Number Sub Firm # Rep Code or Tax ID Number 0141 Full Name or Account Title SAMPLE Access via HDVLink, Process Online Account You are Transferring FROM Delivery Organizations: See Delivery Instructions on Page 2. Account Name Account Number Name of Firm or Fund Company Currently Holding Your Account Clearing Number Address of Firm Check here if this Account is a: QRP IRA OTA (different account registration) DRT (direct rollover transfer) Type of Transfer 1 Full Brokerage Account Transfer. (Check one at right) Transfer all assets or shares in my account as is Liquidate and transfer cash 2 Partial or Non-Brokerage Transfer. A Trust Company, Bank, Credit Union, Savings & Loan, Annuities, Life Insurance, DRIP Plan Shares or Certificates of Deposit Liquidate all assets and transfer as cash. Transfer all assets or shares in my account as is. Liquidate Certificates of Deposit IMMEDIATELY. (I acknowledge the penalty I may incur from an early withdrawal.) Liquidate Certificates of Deposit AT MATURITY. (Submit this transfer no earlier than 30 days prior to maturity.) Maturity Date B Partial Brokerage, Trust Company or Annuity Transfer. (Transfer only the assets or shares listed below) (Choose one for each Item) Quantity Description of Asset and Cusip or Symbol Liquidate and Transfer cash Transfer Shares As Is *For additional assets please attach a separate sheet 3 Mutual Fund Company Transfer. (One form per Fund Family). Quantity Symbol/ CUSIP Shares or Dollars Name of Mutual Fund Liquidate & Transfer Cash Transfer Shares As Is Fund Account Number (Choose one for each Item) Dividend STG LTG S D C R C R C R S D C R C R C R S D C R C R C R S D C R C R C R S D C R C R C R S D C R C R C R *For additional assets please attach a separate sheet (Rev 07-11/14) Page 1 of 5 31

34 Cash Sweep I/We consent to having uninvested cash included in your Cash Sweep Program. For most accounts, the Bank Deposit Sweep will be used for uninvested cash balances, for which no interest is otherwise earned or paid. Advisory ERISA and accounts for banks, credit unions, mutual fund and insurance companies, and government entities will sweep to a Money Market Mutual Fund, which may be affiliated with First Clearing. I/We acknowledge that First Clearing and its affiliates may charge fees and receive certain benefits on the cash sweeps. I/We further acknowledge that if First Clearing changes the Cash Sweep Program on my/our account I/we will be provided with prior written notice. Bank Deposit and Money Market Mutual Fund sweeps are subject to different risks and account protection. The Bank Deposit Sweep is subject to FDIC insurance and Money Market SAMPLE Mutual Funds are covered by SIPC. Details about the Cash Sweep Program, including the different risks and enhanced account protection, are covered in the sweep program disclosure statement, which will be included in your new account package and can be found online at Access via HDVLink, Process Online IRA Direct Rollover from Qualified Retirement Plan (QRP) Irrevocable Election A direct rollover is a reportable distribution from a QRP to an IRA or another QRP. Due to the important tax consequences associated with rolling over funds or property to an IRA from an employer held plan, when you sign this Customer Account Transfer form, you acknowledge the following: the IRA Custodian is not responsible for providing you with tax or other legal advice; you have been advised to see a tax professional and no broker or other employee is authorized to give such advice. You are aware that the rollover from the QRP is an irrevocable election and you are certifying that all information provided on this form is true and correct. You are certifying that you understand the rules and conditions associated with making a direct rollover and that the assets being moved from the QRP are eligible for rollover into an IRA or another QRP. You are also assuming full responsibility for this direct rollover transaction and will not hold the IRA Custodian liable for any adverse consequences that may result. Age 70½ Required Minimum Distribution (RMD) Retirement Account Reminder If you are age 70½ or older, or if you will attain age 70½ this year, the IRS requires that the first monies withdrawn from your retirement account be your required minimum distribution (RMD) for the year. Although the IRS permits you to transfer your RMD between like IRAs, you are not permitted to roll over an RMD even as a direct rollover from a QRP. Be sure to satisfy your RMD before requesting a direct rollover. If you need additional information about this requirement, please contact your legal or tax advisor. Reminder for Clients Who Are Joining Their Financial Advisor at Our Firm Please note that if we cannot hold certain investments, then your options include maintaining those assets at your former firm. Please review this decision with your Advisor. Auction Rate Securities: Account Transfer Acknowledgement You understand and agree to the following in connection with the auction rate securities held in your account: Your auction rate securities were purchased prior to the transfer of your account to us. As a result, we are not responsible or liable for any prior recommendations or advice with respect to these securities nor are we under any obligation to provide you with any investment recommendation or advice with respect to the disposition or continued holding of these securities in your account following the transfer of your account. You also understand and agree that we are not under any obligation to you (i) to provide loans under margin agreements or otherwise secured in whole or part by the auction rate securities in your account, (ii) to purchase or continue to purchase any auction rate securities in periodic rate setting auctions or in secondary market transactions, or (iii) to provide liquidity for such securities. Many auctions for these securities are in failed status meaning that holders of these securities are not able to sell these securities in the periodic rate setting auctions or in secondary market transactions and as a result, liquidity for these securities currently is greatly impaired. We provide no assurance that you will be able to sell or otherwise dispose of these securities following the transfer of your account to us. You understand that we take actions in connection with other customers that we do not offer you in connection with your auction rate securities. ** A COPY OF YOUR MOST RECENT STATEMENT IS REQUIRED TO PROCESS THIS TRANSFER ** One and Same Name Certification By completing this section you are authorizing a transfer between unlike account registrations only. The delivering firm may require a copy of the marriage certificate or divorce decree if the names are different. This is to certify that (print name) and (print name) are one and the same person. Sign as both ways Accounts are Registered: Signature X Signature X Print Name Print Name Date Date (Rev 07-11/14) Page 2 of 5 32

35 Authorization to Change Registration By completing this section you are authorizing a transfer between unlike account registrations and ownership. Not applicable for retirement accounts. Note: The delivering firm may require additional paperwork to transfer between unlike account registrations. Delivering Firm/Mutual Fund Co Account Title SAMPLE Receiving Firm/Mutual Fund Co Account Title I/We, the undersigned, acknowledge that I/we have read, understand, and agree to be bound by the terms & conditions detailed above. Client Signature Date Joint Account Holder Signature Date X For Office Use Only Sub Firm # Rep Code Account Number Account Number X Medallion Signature Guarantee By Account Social Security Number / Tax ID Account Social Security Number / Tax ID I understand and accept the change of registration and ownership and hold Wells Fargo Advisors, First Clearing, LLC and the delivering firm Access harmless via HDVLink, from actingprocess on the above Online instruction. This may not be applicable in all cases. Acknowledgement & Signatures All Account Holders must sign and date. If acting as a fiduciary (such as Power of Attorney, Trustee, Executor), please sign in that capacity. Advisor Name PLEASE BE ADVISED THAT FIRST CLEARING, LLC ("FCC") ACCEPTS APPOINTMENT AS SUCCESSOR CUSTODIAN. Successor Custodian Signature Date Contact Name Phone Number X Signature Guarantee Form I,, certify that the signature of (Printed Name of Representative) (Printed Name of Person Signing) on the attached is the genuine (Describe Document(s) Signed by Signer) signature of the signer named above. This signer is an appropriate person and has legal capacity to sign the document(s). I personally witnessed the signing of the described document(s) on (Date of Signature) and verified the identity and signature of the person signing the document(s) through the following form of identification (check one): Driver's License Passport Other Government Photo ID (Signature of Representative) For Internal Use Only SM Securities offered through HD Vest Investment Services, Member SIPC, Advisory services offered through SM HD Vest Advisory Services, 6333 N. State Highway 161, Fourth Floor, Irving, TX 75038, (972) (Rev 07-11/14) Page 3 of 5 33

36 Signature Guarantee Form In order for HD Vest to provide a signature guarantee for client signatures, Representatives (including advisory agents and insurance licensees) MUST complete and sign the following form. Incomplete SAMPLE documentation will be cause for declining a signature guarantee. This will delay processing Access via HDVLink, the transaction. Process Online Directions: 1. Fill in your name. 2. Fill in the name of the client whose signature will be guaranteed. Fill out a separate form for each client whose signature will be guaranteed (e.g., a separate form for each joint account holder, etc.). 3. Describe the document being signed by the client. Example: Transfer Letter. 4. Fill in the date. The date on the Signature Guarantee Form must match the date of the client signature. 5. Verify the identity of the client and signature by personally viewing a form of identification containing the client s signature. Place a check in the box next to the form of identification used to verify identity. If neither a driver s license nor passport are available, check Other Government Photo ID" and describe the form of identification provided by the client. You must verify identity and signature even if you know the client from previous experience. 6. Sign the form and submit it with the document requiring signature guarantee (Rev 07-11/14) Page 4 of 5 34

37 Receiving Firm Information: FIRST CLEARING, LLC ONE NORTH JEFFERSON AVENUE ST. LOUIS, MO SAMPLE Tax ID Number: FCC Retail and IRA Delivery Instructions (All deliveries MUST include the client name and FCC account number.) Wire Instructions Access via HDVLink, Process Online Wells Fargo Bank 420 Montgomery Street, San Francisco, CA ABA Beneficiary: First Clearing, LLC One North Jefferson, St. Louis, MO Account #: Further Credit: Client Name, 8-digit brokerage account number All DTC Eligible Securities DTC #: 0141 Client Name and Client Account Number Physical Certificates *If only statement, see DRS Statements section below Book-Entry GNMA Securities PTC Or Fed Book-Entry Government Securities Euroclear Eligible Bonds (must notify Security Clearance 2 days prior to settlement) Foreign Equities: (must notify Security Clearance in order for them to instruct) Forward Checks* to the Address Indicated *Must include Client Name and First Clearing, LLC Account Number FIRST CLEARING, LLC Attn: Physical Receives H One North Jefferson Avenue St. Louis, MO Further Credit to Client Account Number BK of NYC/FCCORP ABA# Further Credit to Client Account Number EUROCLEAR #10665 Further Credit to Client Account Number JPMorgan Chase Bank A/C # CHASGBZLST Account of First Clearing, LLC Further Credit to Client Account Number FIRST CLEARING, LLC Attn: Cash Management H One North Jefferson Avenue St. Louis, MO Further Credit to Client Account Number ACAT Mutual Fund Registration Instructions - FCC IRA Mutual Fund Broker-Dealer DRS Statements FIRST CLEARING, LLC FBO: Client Name and Client Account Number One North Jefferson Avenue St. Louis, MO First Clearing, LLC FIRST CLEARING, LLC FAO: Client Account Number Client Address on File Re-Registration Letter Mail Original to: Agent on Record Send a copy to First Clearing: Fax to: (Rev 07-11/14) Page 5 of 5 35

38 SAMPLE Access via HDVLink Sponsor: HD VEST ACCOUNT RECORD CHANGE LETTER OF INSTRUCTION USE TO CHANGE SHAREHOLDER ADDRESS OR NAME OF BROKER/DEALER OR ADVISOR (For accounts held with mutual fund sponsors only) Fund: Account Registration: Custodian (if any): Account Number: Social Security Number: PERMANENT ADDRESS CHANGE Old Address New Address Street City State ZIP Street City State ZIP BROKER/DEALER OR ADVISOR CHANGE Old Broker/Dealer / Advisor Broker/Dealer: Broker/Dealer Number: New Broker/Dealer / Advisor Broker/Dealer: HD Vest Investment Services SM Broker/Dealer Number: Advisor: Advisor Number: Address: City State ZIP I hereby authorize the above change(s) on my account. Shareholder Signature : Date: (All parties registered on the account must sign as registered.) NOTE: For brokerage accounts, a Transfer of Assets form is required. For custodian changes, mark in kind on the Transfer of Assets form. INVESTMENT AND INSURANCE PRODUCTS: NOT FDIC INSURED NO BANK GUARANTEE MAY LOSE VALUE SECURITIES OFFERED THROUGH HD VEST INVESTMENT SERVICES SM, MEMBER SIPC ADVISORY SERVICES OFFERED THROUGH HD VEST ADVISORY SERVICES SM N. STATE HIGHWAY 161, FOURTH FLOOR, IRVING, TX 75038, (972) HDVCD-I 11/14 Reset Print 36

39 Sub Firm # Rep Code (Office Use Only) Account Classification Tax Status SAMPLE Primary Owner Information Account Number Will this account have Third Party Authorization? Yes New Update No Account Application U.S. Citizen U.S. Non Individual Account Resident Alien Non-Resident Alien Individual Account Registration Types (select type) Non-Personal Account Registration Types (select type) Access via HDVLink, Process Individual Joint Tenants Online in Common IRA Types C-Corporate Estate (Certificate of Qualification Custodian/Minor** Joint Tenants with Rights Traditional IRA Simple S-Corporate must be attached/affidavit of Domicile must be provided) Guardian/Conservatorship of Survivorship* Education Savings Roth Non-Profit Organization Limited Liability Company (must attach appointment) Joint Tenants by Entirety Account Partnership Municipal/Government/Public Funds Sole Proprietorship (if permitted by your State law) SEP Usufruct (LA Only) Foreign Tax Exemption Organization Inherited Coogan (CA/NY Only) Foreign Corporation Community Property with Community Property Rights of Survivorship (if required by your State law) Outside IRA Bank/Trust/Credit Union Foreign Estate Foreign Individual Minor IRA Limited Liability Partnership Other Foreign Joint Other: Minor Roth Qualified Plan or Profit Sharing Plan: Prototype Trust Under Agreement Other * If two or more owners, Joint Tenants with Rights of Survivorship will Under Will be selected automatically if you fail to select one of the above. Trust Date: Number of Trustee(s): ** Primary is the minor on a custodian account. Mr. Mrs. Ms. Dr. Rev. Senator Justice Other Name and Address Name Legal Address (cannot be a P.O. Box) Customer Identity Verification Did the Advisor prepare and file the most recent tax return for this person? Y N (If "No", please complete a-e below.) a. Govt ID Type (Reference Govt ID Codes on page 6) b. Govt ID No. City State ZIP Country of Residence c. Date of Issue Home Phone 1 Business Phone 1 Cell Phone 1 Fax Number Date of Birth Home Phone 2 Business Phone 2 Cell Phone 2 Other Phone Country of Citizenship d. Date of Expiration e. Place of Issue SSN/TID Tenants In Common Ownership % (must equal 100%) Name % Name % Owner Information Details Source of A-Savings (From Earnings) B-Inheritance Funds: G-Sale of Asset H-Legal/Ins Settlements Person of Interest / High Risk Indicators US Non Individual (Select up to five (5) indicators that apply to this account owner.) US Individual (Select all that apply.) Foreign Non Individual (Select up to five (5) indicators that apply to this account owner.) Foreign Individual (Select all that apply.) (Rev 00-07/14) CASINO (5B) GEM/PREC MTL DLRS (5C) GUN DLR/FIREARMS (5E) PEP (1A) CASINO (6B) FFI (6L) FOR FIN INTERMEDIARY (6M) FOR OPERATING CO (6G) C-Business Revenue I-Asset Appreciation MONEY SERVICE BUS (5D) NON-GOVT ORG (5F) PEP-FOREIGN (5G) FOREIGN TRUST (6I) GEM/PREC MTL DLRS (6C) GUN DLR/FIREARMS (6F) D-Donations (Trusts Only) J-Other NOT APPLICABLE (00) FOR PERS INV/HOLDING CO (6H) TRAVEL AGENT (5A) NOT APPLICABLE (00) MONEY SERVICE BUS (6D) NON-GOVT ORG (6K) PEP-FOREIGN (6N) TRAVEL AGENT (6A) E-Sale of Business K-Associated Persons NOT APPLICABLE (00) F-Sale of Real Estate FOR FIN INTERMEDIARY (3B) PEP (3A) NON-RESIDENT ALIEN (3C) NOT APPLICABLE (00) Page 1 of 5 37

40 Sub Firm # Rep Code Account Number Owner Information Details Continued Rule 144: Is authorized person, or member of their immediate family a director, policy-making officer, or 10% stockholder in any publicly traded company? Y N If Yes, Indicate Ticker Symbol, Cusip or Name: FINRA SAMPLE Insider Information: Is Client, Client's Spouse or immediate relative employed by FINRA Member? Q - Account owner or associated party is an internal HD Vest employee, V - Account owner or associated party is an extended family member of an HD Vest or a dependent family member of an internal HD Vest employee Advisor Access R - Account via owner HDVLink, or associated Process party is Online an extended family member W - Account owner or associated party is employed by another Broker/Dealer or of an internal HD Vest employee FINRA/NYSE member (other than HD Vest), or a dependent family member of an U - Account owner or associated party is an HD Vest Advisor, or a employee of another Broker/Dealer or FINRA/NYSE member (other than HD Vest) dependent family member of an HD Vest Advisor X - Account owner or associated party is an extended family member of an employee of another Broker/Dealer or FINRA/NYSE member (other than HD Vest) Occupation/Title: A-Proprietor, Professional, Manager F-Public Service B-Info Tech Sys G-Personal Service Provider C-Craftsman, Skilled Worker H-Farming, Fishing, Forestry D-Sales I-Education E-Admin, Clerical J-Clergy K-Other* L-Unemployed M-Retired (If retired, complete questions N-Student P-Homemaker *(Business Nature code is required.) based on the firm from which you retired.) Business Nature: A-Agriculture B-Consumer & Business Services C-Construction D-Energy S-Estate E-Financial Services F-Government G-Healthcare H-Industrial I-Media J-Non-profit R-Other K-Personal Investment Company L-Real Estate M-Retail N-Technology O-Telecommunications P-Transportation T-Trust Q-Wholesale Employer Name Employer Phone Years with Employer Employer Address City State ZIP Country Position Account Registration & Instructions Registration Title (if different from page 1) Primary Owner must match information for tax certification Mailing Address (if different from Legal Address) City State ZIP Country Suitability Data Collected Should be for the Account (Reference tables provided on page 5) 1.Is primary owner a registered investment advisor/ company either with the SEC or state securities Y commission? 2.Does the account holder have total assets of at least $50 Y million? Initial Transaction Amount: Investment Objective Other Investments: (Table 1) Annual Income - All Sources: (Table 1) Liquid Net Worth: (Table 1) Net Worth - Excluding Residence: (Table 1) N N Income & Conservative - A Income & Moderate - G Income & Long Term - I Growth & Income + Conservative - B Growth & Income + Moderate - D Growth & Income + Long Term - K Growth & Conservative - H Growth & Moderate - C Growth & Long Term - E Trading & Speculation - L AML Compliance Field (For Corporation and Partnership Accounts Only) Is this customer a casino, travel agency, or money remitter? If "yes," provide TIN: *AML Checklist and Enhanced Due Diligence forms are required and Compliance approval must be obtained before submitting the account for opening. Y N Tax Bracket 10% 15% 25% 28% Other % Standing Instructions Margin Cash 33% 35% If requested, does Client want us to provide name and address to an issuer in which we hold securities in street name? SEC Rule 14b-1 prohibits from using name and address for any purpose other than corporate communications. Y N Primary Owner Demographics Female Male Own Rent Single Married Education Level High School Graduate College Graduate Divorced Widowed Number of Dependents: (If field is left blank, 0 will be assumed) Post Secondary Study Post Graduate Study Two-Year Degree Advanced Degree Other Investment Experience (Indicate Years of Experience for each category) Stocks Bonds Options Annuities-Life Ins Mutual Funds (Rev 00-07/14) Margin Account All Qualified Accounts are Opened as Margin Accounts. YOU WILL HAVE A MARGIN ACCOUNT UNLESS YOU ARE INELIGIBLE OR DECLINE BELOW. An ineligible account is defined as: Custodian, Guardian, ERISA, IRAs, and Pension and Profit-Sharing accounts. Margin trading entails greater risk and is not suitable for all investors. If the market value of eligible securities in your account declines, you may be required to deposit more money or eligible securities in order to maintain your line of credit. By signing this Application, I acknowledge that I have received and read the Margin Disclosure Statement, the General or Basic Account Agreement and Disclosure and Statement of Interest Charges and Margin Account Policy documents. I understand that my securities may be pledged, repledged, hypothecated or rehypothecated by HD Vest Investment Services SM (HD Vest) as deemed necessary. I DECLINE margin privileges. Please open my account as a cash account only. I understand that I will not have overdraft protection. Page 2 of 5 38

41 Sub Firm # Rep Code Account Number Non-Advantage Cash and Sweep Options and Codes* For Personal and Corporate Account Types, Including IRAs and For Government Accounts, Insurance Accounts, Banks and Accounts using Advisory Products (excludes Advisory ERISAs): Credit Unions: SAMPLE BDS Bank Deposit Sweep Option WMM WF Advantage Money Market - Daily Class For Advisory ERISAs**: WTP WF Advantage Treasury Plus Money Market - Sweep Class Access via HDVLink, Process Online JPT JP Morgan Prime Money Market Fund - Capital Class (for WGA WF Advantage Government Money Market - Sweep Class Advisory ERISA only) WMU WF Advantage Municipal Money Market - Sweep Class Foreign Business Clients including Personal Investment Companies: WNT WF Advantage National Tax-Free Money Market - Sweep Class WAE Wells Fargo (LUX) Worldwide Fund US Dollar Short Term Fun WTM WF Advantage 100% Treasury Money Market - Sweep Class Class A * Please check with your Advisor for Fund Availability ** This sweep is offered exclusively to ERISA accounts using WFA Advisory programs only. Money Market Dividend Distributions: Pay out money market fund distributions Reinvest money market fund distributions Stock Instructions: Register in street name and hold Cost Basis Elections (Reference table provided on page 6) Tax Lot Relief Method*: *The default method is FIFO (First In First Out) Election for Rights/Warrants Apportionment (if applicable) Yes No Proceed Instructions: Net Account and pay proceeds Pay proceeds on each sale Hold funds*** *** If the stock instructions, trade balance instructions, and/or dividend instructions are left blank, the account will default to hold stocks in street name, hold balances, and/or hold dividends. Average Cost Elections (If you choose N do not enter the date) Mutual Funds Election Date: Client Identification Program Has the Broker advised the party establishing this account that information collected on parties associated with this account is subject to verification as mandated by the USA PATRIOT Act and outlined in our Client Identification Program? Y Dividend Standing Instructions: Post dividends and interest into free credit Mail type 1 and 2 dividends and interest semi-weekly (Tuesdays and Fridays, over $10) Dividend Reinvestment Plans Election Date: Mail dividends daily Mail type 1 and 2 dividends and interest monthly (first business day, over $10) Pay type 1 dividends and interest semi-weekly, credit type 2 dividends and interest to type 2 account Pay type 1 dividends and interest monthly, credit type 2 dividends and interest to type 2 account Equity Dividend Reinvestment Instructions: All eligible dividends will be reinvested for this account. Cash dividends will be paid for this account unless the security is coded for reinvest. No dividends will be reinvested for this account. Cash dividends will be paid for all new trades. Reinvest all new dividends for this account unless the security is coded for cash dividends. Principal Instructions: Principal payment to free credit for reinvestment Process principal payments according to trade standing instructions Display cost basis on statements? Y N Investment and Insurance Products: Not Insured by FDIC or any Federal Government Agency May Lose Value Not a Deposit of or Guaranteed by a Bank or any Bank Affiliate Securities offered through HD Vest Investment Services SM, Member SIPC, Advisory services offered through HD Vest Advisory Services SM, 6333 N. State Highway 161, Fourth Floor, Irving, TX 75038, Brokerage account(s) carried by First Clearing, LLC, Member FINRA/SIPC (Rev 00-07/14) Page 3 of 5 39

42 Investment Objectives & Risk Tolerance All investors have objectives or goals, such as seeking income, growth & income, growth, or trading or speculating. All investors also have risk tolerance, which is the amount of risk of loss they are willing and able to tolerate in order to achieve their investment goals. Although all investments involve risk, including the potential loss of principal, some securities, such as equities (stock), among others, involve more risk. Higher risk investments may have the potential for higher returns, but also have the potential for greater losses. Generally speaking, investment objectives are on a spectrum, with "Income" investors generally holding the smallest percentage of higher risk investments and "Trading and Speculation" investors holding the largest percentage of higher risk investments. Similarly, risk tolerances are on a spectrum such that an investor with a "Conservative" risk tolerance will accept less risk than an investor with a "Moderate" risk tolerance; a SAMPLE "Moderate" investor less than a "Long Term" investor; and a "Long Term" investor less than a "Trading & Speculation" investor. The "Long Term" investor accepts short term market volatility associated with a large proportion of higher risk investments because he or she has a long term time horizon and seeks the higher Access long term via HDVLink, return potential Process associated Online with these higher risk investments. Below are descriptions of the combined Investment Objective and Risk Tolerance, listed in order of least aggressive to most aggressive for both (Investment Objective and Risk Tolerance) categories. Please carefully consider your Investment Objective and Risk Tolerance for your account. Your selection is your representation that you meet all the criteria described in the profile. Investment Objective - Income: Income investors seek a maximum amount of income given their risk tolerance, and are willing to forgo capital appreciation and growth of income. Risk Tolerance - Conservative: Conservative Income investors seek the maximum amount of income consistent with a modest degree of risk. They are willing to accept a lower level of income in exchange for lower risk. Higher risk investments, such as high yield bonds and some equities, are typically not a large percentage of the account. Risk Tolerance - Moderate: Moderate Income investors seek to balance the potential risk of capital loss with increased income potential. Higher risk investments, such as high yield bonds and some equities, may be some percentage of the account. Risk Tolerance - Long Term: Long Term Income investors seek a significant level of income, are financially able and willing to risk losing a substantial portion of investment capital, and, due to their long term horizon or other factors, they employ higher risk, more aggressive strategies that may offer higher potential income. Higher risk investments, such as high yield bonds and some equities, may be a significant percentage of the account. Investment Objective - Growth & Income: Growth and Income investors seek current income, but also seek income and capital growth over time. These investors are willing to forgo a portion of current income in order to seek potential future growth. Risk Tolerance - Conservative: Conservative Growth and Income investors seek the maximum growth and income consistent with a relatively modest degree of risk. They are willing to accept lower potential returns in exchange for lower risk. Equities, generally dividend paying equities, may be some percentage of the account. Risk Tolerance - Moderate: Moderate Growth and Income investors seek to balance the risk of capital loss with higher potential growth and income. High yield bonds and equities, generally dividend paying equities, may be a significant percentage of the account. Risk Tolerance - Long Term: Long Term Growth and Income investors seek a significant level of growth and income, are financially able and willing to risk losing a substantial portion of investment capital, and due to their long term horizon or other factors they pursue high risk, more aggressive strategies that may offer higher potential returns. High yield bonds and equities, generally dividend paying equities, may be the primary assets in the account. Investment Objective - Growth: Growth investors do not seek account income and their primary objective is capital appreciation. Risk Tolerance - Conservative: Conservative Growth investors seek maximum growth consistent with a relatively modest degree of risk. They are willing to accept lower potential returns in exchange for lower risk. Equities may be a significant percentage of the account. Risk Tolerance - Moderate: Moderate Growth investors seek to balance the potential risk of capital loss with their goal of higher potential growth. Equities may be the primary asset in the account. Risk Tolerance - Long Term: Long Term Growth investors seek a significant level of growth, are financially able and willing to risk losing a substantial portion of investment capital, and due to their long term time horizon or other factors, they employ higher risk, more aggressive strategies that may offer higher potential returns. Higher risk investments such as equities may be as much as 100% of the account. Trading & Speculation: Trading and Speculation investors seek out maximum return through a broad range of investment strategies, which generally involve a high level of risk, including potential for significant loss of investment capital. Standing Instructions Stock Instructions 4 Register in street name and hold 5 DVP Trade Balance Instructions A Pay net credit balance B Pay and Pay C Hold all balances Dividend Instructions 1 Into Free Credit 3 Semi-Weekly 4 Daily 5 Monthly 6 Credit Type 2 Pay Type 1 Semi-Weekly 7 Credit Type 2 Pay Type 1 Monthly Dividend Reinvestment A Reinvest all trades for this account. All current positions and future trades for eligible positions will be reinvested automatically. C Cash dividends will be paid for this account unless the security is coded for reinvestment on RDIV. N Dividends will not be reinvested for this account; cash dividends will be paid for all new trades. Note: RIN default. Table 1 A-$0 - $49,999 B-$50,000 - $99,999 C-$100,000 - $199,999 D-$200,000 - $499,999 E-$500,000 - $999,999 G-$1,000,000 - $4,999,999 H-$5,000,000 - $9,999,999 I-$10,000,000 or more (Rev 00-07/14) R Dividends will be reinvested for all new trades for this account, unless the security is coded for cash dividends on RDIV. Account Category Codes 001 Individual US Citizen/Resident Alien 002 Sole Proprietorship 003 Guardian/Conservator/Committee 004 Joint 005 Prime Broker 006 C-Corporation/S-Corporation 007 Limited Liability Company 008 Estate 012 Partnership 013 Bank/Trust Company/Credit Union 014 FCC Traditional/Roth IRA 015 FCC SEP IRA/FCC SIMPLE IRA 017 Insurance Company 018 Mutual Fund/Money Manager 019 Personal Trust 020 Prototype Retirement Plan 021 Retirement Trust/Pension, Profit Sharing Plan 022 Non-Profit Organization Cash Sweep Options and Codes* 023 Uniform Gift/Transfer to Minor 025 Numbered Account 026 Non-FCC IRA 027 ERISA (Investment Advisor Use only) 028 Municipal/Government/Public Funds 031 Personal DVP 032 Education Saving Account 034 Prototype QRP w/1099 Reporting 040 Individual Non-Resident Alien, with Treaty 041 Individual Non-Resident Alien, no Treaty 042 Custodian for Non-Resident Alien, with Treaty 043 Custodian for Non-Resident Alien, no Treaty 073 Trust 529 College Plan For Personal and Corporate For Government Accounts, Insurance Account Types, including IRAs Accounts, Banks and Credit Unions: and Accounts using Advisory WTM WF Advantage 100% Treasury Money Products: Market - Sweep Class BDS Bank Deposit Sweep Option WAE WF(LUX) Worldwide U.S. Dollar Liquidity Fund - Class A For Advisory ERISAs**: JPT JP Morgan 100% U.S. Treasury Money Market - Capital Class * Additional options may be available based on product type, please check with your Financial Advisor for fund availability. ** This sweep is offered exclusively to ERISA accounts using WFA Advisory programs only. 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43 F L H C S T R M Cost Basis Election Codes FIFO - First In First Out - If the account is set up for First In First Out, the first security purchased is assumed to be the first security sold. If the trade requires additional units to be closed, the process will be repeated sequentially until the required number of shares is reached. LIFO - Last In First Out - If the account is set up for Last In First Out, the most recent tax lot purchased will be the first closed. If the trade requires additional units to be closed, the process will be repeated sequentially until the required number of shares is reached. HIFO - Highest In First Out - If the account is set up for Highest In First Out, the tax lot with the highest cost basis will be the first closed. If the trade requires additional units to be closed, the process will be repeated sequentially until the required number of shares is reached. LOFO - Lowest Cost First Out - If the account is set up for Lowest Cost First Out, the tax lot with the lowest unit cost will be closed first, regardless of the holding period. If the trade requires additional units to be closed, the process will be repeated sequentially until the required number of shares is reached. HCST - Highest Cost Short Term - If the account is set up for Highest Cost Short Term, the process will pick only the short term tax lots and the tax lot with the highest unit cost will be closed first. If the trade requires additional units to be closed, the process will be repeated sequentially until the required number of shares is reached. If no short term lots are found, or if the number of short term units is insufficient to cover the sale, the process will look at long term lots and continue to close HCLT. HCLT - Highest Cost Long Term - If the account is set up for Highest Cost Long Term, the process will pick only the long term tax lots and the tax lot with the highest unit cost will be closed first. If the trade requires additional units to be closed, the process will be repeated sequentially until the required number of shares is reached. If no long term lots are found, or if the number of long term units is insufficient to cover the sale, the process will look at the short term lots and continue to close HCST. LCLT - Lowest Cost Long Term - If the account is set up for Lowest Cost Long Term, the process will pick only the long term tax lots and the tax lot with the lowest unit cost will be closed first. If the trade requires additional units to be closed, the process will be repeated until the required number of shares is reached. If no long term lots are found, or if the number of long-term units is insufficient to cover the sale, the process will look at the short term lots and continue to close LCST. LCST - Lowest Cost Short Term - If the account is set up for Lowest Cost Short Term, the process will pick only the short term tax lots and the tax lot with the lowest unit cost will be closed first. If the trade requires additional units to be closed, the process will be repeated sequentially until the required number of shares is reached. If no short term lots are found, or if the number of short term units is insufficient to cover the sale, the process will look at the long term lots and continue to close LCLT. SAMPLE Access via HDVLink, Process Online Average Cost Basis Accounting Codes N O M No Average Cost on Mutual Funds, accounting is lot by lot. All; Post-Effective Date, All mutual fund tax lots acquired after 1/1/2012 will be averaged. Mixed/Specific Security, Client will specify which mutual fund securities they hold will get average cost basis methodology applied. Government ID Codes AI Articles of Incorporation HC Health Insurance Card (not a Medicare Card) AO Articles of Organization (LLC) LP Life Insurance Policy AR Adoption Record MD Marriage or Divorce Record BC Birth Certificate MR Military Records CD Court Document PA Partnership Agreement DL Drivers License PP Passport EC Employer ID Card RA Resident Alien ID Card (Green Card) FD Foreign ID Card SC School ID Card (e.g. Drivers License, Visa or Green Card) ST State ID Card HC Health Insurance Card (not a Medicare Card) TR Trust Agreement or Trust Deed Educational Level A High School Graduate B Post Secondary Study C Two-Year Degree D College Graduate E Post Graduate Study F Advanced Degree G Other Interested Party - Additional Client Reporting Statements Confirmations 1099 Statements Confirmations 1099 Statements Confirmations 1099 Statements Confirmations 1099 Page 5 of 5 41

44 HD VEST MUTUAL FUND ACCOUNT APPLICATION This form is required for all HD Vest Investment Services SM clients who wish to establish investment accounts with mutual fund companies directly. For certain account registrations, additional information and documents may be required to establish the account. Use the Additional Client Information Form as needed. Contact General Support or refer to the Mutual Fund Operations Manual for detailed instructions. SAMPLE Forward the New Account Application and Client Agreement to HD Vest. HD Vest Advisor must sign form in order to process application. Access via HDVLink, Process Online ACCOUNT REFERENCE NUMBER: Individual Account Individual Joint Account Joint Tenants WROS Tenants in Common Tenants by Entirety Community Property Transfer on Death Account Individual - Transfer on Death Joint Tenants WROS - Transfer on Death Foundation/Organization Account Foundation Nonprofit Organization ACCOUNT REGISTRATION INFORMATION Fiduciary/Custodial Account Trust Account Unif. Transfer To Minor Act Trust (Revocable) Unif. Gift To Minor Act Trust (Irrevocable) Custodian - Other Other Investment Account Guardianship Deferred Compensation Plan Conservatorship Employee Savings/Payroll Estate Account Deduction Plan Administrator Other Executor IRA Account Personal Representative IRA Company Account Spousal IRA Corporation Rollover IRA Partnership SEP-IRA Sole Proprietorship SAR-SEP IRA College Savings Simple IRA 529 Roth Contributory IRA PRIMARY OWNER INFORMATION ( OR TRUST INFO) Roth Conversion IRA Educational IRA Beneficiary IRA Retirement/Qualified Plan Account Money Purchase Plan Profit-Sharing Plan 401(k) Plan Solo/Single K 403(b) Plan 457 (Municipality) Plan Keogh Plan (P.S.P. or M.P.P.) Defined Benefit Plan Thrift Plan OTHER FUNCTION OF CLIENT: Owner/Grantor Custodian Trustee Fiduciary Organization (Non-Profit) Decedent Minor/Ward Beneficiary Contact Company Plan Participant Trust CLIENT FULL NAME (NO INITIALS) NICKNAME SOCIAL SECURITY NO./TAX ID BIRTH DATE/ESTABLISHED DATE HOME PHONE WORK PHONE ADDRESS PERCENTAGE OF OWNERSHIP: MARITAL STATUS: Single Married NUMBER OF DEPENDENTS: (if unknown, default to zero) CITIZENSHIP: U.S. Resident Alien: EMPLOYMENT: EMPLOYER (COUNTRY OF CITIZENSHIP) OCCUPATION (type of business and position/title) EMPLOYER ADDRESS CITY STATE ZIP AFFILIATIONS: (supply any securities firm, exchange or agency affiliation; if not selected, default to none) None Company: IS THIS CLIENT A SENIOR FOREIGN POLITICAL FIGURE OR FAMILY MEMBER OR ASSOCIATE OF A SENIOR FOREIGN POLITICAL FIGURE: Yes No (IF LEFT UNCHECKED, NO WILL BE ASSUMED) I CERTIFY THAT I HAVE PREPARED AND FILED THE MOST RECENT TAX RETURN FOR THIS CLIENT: Yes No (if no, please supply ID information below) ISSUED PICTURE ID TYPE: ID NO.: STATE/COUNTRY OF ISSUANCE: ISSUE DATE: EXPIRATION DATE: INVESTMENT EXPERIENCE (PRIMARY OWNER) IF LEFT UNCHECKED, NONE WILL BE ASSUMED STOCKS MUTUAL FUNDS BONDS OPTIONS ANNUITIES-LIFE INS. NONE NONE NONE NONE NONE LESS THAN 5 YRS LESS THAN 5 YRS LESS THAN 5 YRS LESS THAN 5 YRS LESS THAN 5 YRS 5-10 YRS 5-10 YRS 5-10 YRS 5-10 YRS 5-10 YRS OVER 10 YRS OVER 10 YRS OVER 10 YRS OVER 10 YRS OVER 10 YRS ACCOUNT INFORMATION MAILING ADDRESS (OR P.O. BOX) CITY STATE ZIP COUNTRY ( If using a P.O. Box for mailing, you must indicate client s legal or residential address below) LEGAL/RESIDENTIAL ADDRESS (if different from mailing address) CITY STATE ZIP COUNTRY Investment and Insurance Products: NOT FDIC Insured NO Bank Guarantee MAY Lose Value Securities offered through HD Vest Investment Services SM, 6333 N. State Highway 161, Fourth Floor, Irving, Texas (972)

45 SAMPLE HD VEST MUTUAL FUND ACCOUNT APPLICATION INVESTMENT INFORMATION (FOR THIS ACCOUNT) INVESTMENT OBJECTIVE: (check only one) CONSERVATIVE INCOME MODERATE INCOME LONG-TERM INCOME CONSERVATIVE GROWTH & INCOME MODERATE GROWTH & INCOME LONG-TERM GROWTH & CONSERVATIVE GROWTH INCOME MODERATE GROWTH LONG-TERM GROWTH TRADING & SPECULATION Access via HDVLink, Process Online PRIMARY SOURCE OF FUNDS USED TO FUND ACCOUNT: ALIMONY DISABILITY INSURANCE ESTATE ASSETS INHERITANCE/GIFT INVESTMENT INCOME OPERATIONS RETIREMENT FUNDS SALARY/WAGES SOCIAL SECURITY UNEMPLOYMENT OTHER: FINANCIAL INFORMATION (IF JOINT OWNERS, PLEASE COMBINE THE CLIENT S FINANCIAL INFORMATION) ANNUAL INCOME (ALL SOURCES): $0 - $49,999 $50,000 - $99,999 $100,000 - $199,999 $200,000 - $499,999 $500,000 - $999,999 $1,000,000 - $4,999,999 $5,000,000 - $9,999,999 $10,000,000 OR MORE NET WORTH (EXCLUDING RESIDENCE): $0 - $49,999 $50,000 - $99,999 $100,000 - $199,999 $200,000 - $499,999 $500,000 - $999,999 $1,000,000 - $4,999,999 $5,000,000 - $9,999,999 $10,000,000 OR MORE LIQUID NET WORTH: $0 - $49,999 $50,000 - $99,999 $100,000 - $199,999 $200,000 - $499,999 $500,000 - $999,999 $1,000,000 - $4,999,999 $5,000,000 - $9,999,999 $10,000,000 OR MORE ESTIMATED VALUE OF INVESTMENTS: $0 - $49,999 $50,000 - $99,999 $100,000 - $199,999 $200,000 - $499,999 $500,000 - $999,999 $1,000,000 - $4,999,999 $5,000,000 - $9,999,999 $10,000,000 OR MORE TAX BRACKET: 0% 1-10% 11-15% 16-25% 26-28% 29-33% 34-35% OVER 35% SECONDARY OWNER INFORMATION (OR TRUSTEE INFO) FUNCTION OF CLIENT: Owner/Grantor Custodian Trustee Fiduciary Organization (Non-Profit) Decedent Minor/Ward Beneficiary Contact Company Plan Participant Trust CLIENT FULL NAME NICKNAME SOCIAL SECURITY NO./TAX ID BIRTH DATE/ESTABLISHED DATE HOME PHONE WORK PHONE ADDRESS PERCENTAGE OF OWNERSHIP: MARITAL STATUS: Single Married NUMBER OF DEPENDENTS: (if unknown, default to zero) CITIZENSHIP: U.S. Resident Alien: EMPLOYMENT: EMPLOYER (COUNTRY OF CITIZENSHIP) OCCUPATION (type of business and position/title) EMPLOYER ADDRESS CITY STATE ZIP AFFILIATIONS: (supply any securities firm, exchange or agency affiliation; if not selected, default to none) None Company: IS THIS CLIENT A SENIOR FOREIGN POLITICAL FIGURE OR FAMILY MEMBER OR ASSOCIATE OF A SENIOR FOREIGN POLITICAL FIGURE: Yes No (IF LEFT UNCHECKED, NO WILL BE ASSUMED) I CERTIFY THAT I HAVE PREPARED AND FILED THE MOST RECENT TAX RETURN FOR THIS CLIENT: Yes No (if no, please supply ID information below) ISSUED PICTURE ID TYPE: ID NO.: STATE/COUNTRY OF ISSUANCE: ISSUE DATE: EXPIRATION DATE: INVESTMENT EXPERIENCE (SECONDARY OWNER) IF LEFT UNCHECKED, NONE WILL BE ASSUMED STOCKS MUTUAL FUNDS BONDS OPTIONS ANNUITIES-LIFE INS NONE NONE NONE NONE NONE LESS THAN 5 YRS LESS THAN 5 YRS LESS THAN 5 YRS LESS THAN 5 YRS LESS THAN 5 YRS 5-10 YRS 5-10 YRS 5-10 YRS 5-10 YRS 5-10 YRS OVER 10 YRS OVER 10 YRS OVER 10 YRS OVER 10 YRS OVER 10 YRS ADVISOR SIGNATURE ADVISOR NO. PRINT ADVISOR NAME DATE / / HD VEST AUTHORIZED SIGNATURE / / HOME OFFICE USE ONLY DATE Investment and Insurance Products: NOT FDIC Insured NO Bank Guarantee MAY Lose Value Securities offered through HD Vest Investment Services SM, 6333 N. State Highway 161, Fourth Floor, Irving, Texas (972)

46 HD VEST ONLINE CLIENT AGREEMENT SAMPLE HD Vest Privacy Policy for Individuals This policy is effective as of September 30, Access via HDVLink, Process Online This policy is provided to you on behalf of H.D. Vest, Inc. d/b/a HD Vest Financial Services and the family of HD Vest companies ( HD Vest ). This policy applies to consumers who have, or have had, a customer relationship with one or more of the companies with HD Vest in their names, including HD Vest Investment Services SM, HD Vest Advisory Services SM, and HD Vest Insurance Agency, LLC. Please read the following information carefully to understand HD Vest s policies about protection and use of customer information. Information Protection We are committed to protecting customer information. The security and integrity of customer information is protected through procedures and technology designed for this purpose. For example: We limit employee access to customer information to those who need to know this information in order to service customer relationships; We require our employees to honor our code of conduct, which includes standards to protect customer confidentiality; We require independent contractors and outside companies who work with us to adhere to strict privacy standards through their contracts with us; We maintain policies and procedures covering the proper physical security of workplaces and records; We protect against unauthorized access or alterations to customer data through standard technological means (such as backup files, virus detection and eradication software, firewalls, and other computer software and hardware); and We comply with federal standards for physical, electronic and procedural protection of customer information. The policies and practices described in this disclosure are subject to change, but we will communicate any significant changes to you as required by applicable law. These disclosures replace all previous notices or statements regarding this matter. Information Collection We collect and maintain customer information as part of servicing your account. In the course of serving you, we collect information about you from a variety of sources, such as: Information you provide to us on applications or forms, such as your name, address, Social Security number, birth date, assets and income; Information we receive from an outside company, such as a credit bureau, regarding your creditworthiness and credit history if you apply for credit products; or Information about your transactions or experiences with HD Vest companies, including interactions with our customer service staff. Information Use and Disclosure Within HD Vest: The customer information we collect is used to service your accounts and help you meet your financial goals. Information may be used or shared within HD Vest for a number of purposes, such as: To protect your accounts from unauthorized access or identity theft; To process your requests such as trading securities or insurance purchases; To service your accounts by issuing checks and account statements; To provide you with customer service, responding to questions and requests you may have regarding your account(s) or the services provided through HD Vest; To provide you information about financial services and products that can help you meet your needs now and in the future, and to determine your eligibility to receive such products and services offered through HD Vest; and To improve the products and services offered through HD Vest. HD Vest will continue to utilize systems, services and processes provided and maintained by Wells Fargo & Company affiliated companies ( Wells Fargo ) until it converts its systems processing to another provider. HD Vest may share information with Wells Fargo for the purpose of servicing your account through these systems or providing you information about your accounts (e.g., consolidated statements). Investment and Insurance Products: NOT FDIC Insured NO Bank Guarantee MAY Lose Value Securities offered through HD Vest Investment Services SM, 6333 N. State Highway 161, Fourth Floor, Irving, Texas (972)

47 HD VEST ONLINE CLIENT AGREEMENT SAMPLE With Non-affiliated Third Parties: We share information with non-affiliated third parties providing services for us when they are acting on our behalf. We may disclose all of the information we collect, as described above, with non-affiliated third parties that are acting on our behalf or are providing services for us, including: Companies that perform services for us, such as our clearing firm (First Clearing, LLC), data processors, technical systems consultants and programmers, check printers, data aggregators, and mail fulfillment; and Others as permitted or required by law such as government entities, in responding to regulatory inquiries, subpoenas and other legal processes, and those with whom you have requested or authorized us to share information. Access via HDVLink, Process Online It is important to note that when we do share information with outside companies that are performing services on our behalf, we do so only after that company has agreed not to use or disclose the information for any other purpose. We do not share information with non-affiliated parties for the purpose of those companies marketing products and services to you. Your HD Vest Advisor will obtain confidential information about you during the course of servicing your HD Vest accounts, and will retain that confidential information after leaving HD Vest. That information remains subject to contractual and regulatory restrictions that prohibit the use or disclosure of the information (except as permitted or required by law) without your explicit consent. HD Vest is Committed to Your Privacy Respect for our customers privacy has long been valued at HD Vest. Not only is it what our customers expect, it s the right way to do business. The trust of our customers is our most valuable asset and the reason we are in business. This trust is built, in part, upon the proper handling of your personal information. In an age of electronic commerce and communication, the need for a strong commitment to the protection of consumer information is critical. Although technology has changed the way information is gathered, used and stored, the importance of preserving the confidentiality of information remains a core value to us and the responsibility of every HD Vest employee. We want you to know that you can count on us to protect the privacy and security of your customer information, and to provide you with the responsive, professional service you deserve. HD Vest was built on trust. We want to continue earning your trust and your business for years to come. Online Privacy HD Vest considers privacy and security to be essential for all our customers, including users of our online services. That is why HD Vest created and implemented a separate privacy policy governing the collection of information obtained through the HD Vest websites. For a detailed discussion of the privacy practices applicable to users of the HD Vest websites, users are encouraged to review the privacy policy governing the online collection of information at the link for Online Privacy Policy on Tips to Help Protect Your Account Information Assistance to Victims of Identity Theft If you suspect that someone has had unauthorized access to your account with us, please notify us immediately so we can take action to protect you. Call HD Vest Risk Management at (866) In addition, if you suspect that someone has had unauthorized access to your accounts, or access to your personal identifying information such as your Social Security number or credit card information, you should report the crime to your local law enforcement agency and to the Federal Trade Commission (FTC). To speak with a trained FTC telephone counselor, call toll-free at (877) IDTHEFT or (877) Or, visit for additional consumer education materials. Investment and Insurance Products: NOT FDIC Insured NO Bank Guarantee MAY Lose Value Securities offered through HD Vest Investment Services SM, 6333 N. State Highway 161, Fourth Floor, Irving, Texas (972)

48 HD VEST ONLINE CLIENT AGREEMENT 1. About HD Vest. HD Vest Investment Services SM ( HD Vest ) is a broker/dealer, which places or makes, on behalf of its clients, securities trades of investment companies (such as mutual funds) and other entities, as well as approved transfers and liquidations. Many of our Advisors own or are involved in their own accounting, tax planning and preparation, legal or other business ( Separate Business ) for which such Advisors are solely responsible. HD Vest does not supervise or control these Separate Businesses and does not supervise its Advisors' activities in connection with these Separate Businesses. These Separate Businesses are not affiliated with or controlled by HD Vest, and HD Vest will not be responsible or liable for any claim or loss arising from such Separate Businesses or Advisors' activities in connection with such businesses. SAMPLE Access via HDVLink, Process Online 2. Payment for Trades. For transactions made through HD Vest, payment must be made by check payable to HD Vest Investment Services SM, or by direct ACH deposit if elected below. If direct ACH deposit is elected, you are not restricted from payment by check. No check for a transaction through HD Vest should be made payable to a Registered Representative or entity other than HD Vest or FCC. Transactions in brokerage accounts through FCC must be made payable to FCC. By providing the information below, you hereby authorize HD Vest to initiate debit entries to your account at the depository institution ( Depository ) set forth below, and to debit such account based on any transactions conducted through HD Vest. You agree that HD Vest will be fully protected in honoring such transactions. You agree that HD Vest may make additional attempts to debit your account if the initial attempt fails and that you will be liable for any associated costs. You understand that this standing ACH instruction will remain effective until you revoke it by sending a written notice of revocation to HD Vest s home office referencing your name and account number. THE ACCOUNT YOU DESIRE HD VEST TO DEBIT IS A: (check one) Checking Savings Corporate Checking Corporate Savings NAME(S) ON ACCOUNT ACCOUNT NUMBER DEPOSITORY NAME ABA ROUTING NUMBER (LAST 9 DIGITS AT BOTTOM LEFT OF CHECK) If the owner of the depository account from which ACH debits will be made is different from the person opening the HD Vest account, the owner of the depository account must sign in the space below. By signing below, the owner of the depository account agrees to the ACH terms set forth in this Section 2. SIGNATURE OF OWNER OF DEPOSITORY ACCOUNT PLEASE ATTACH A VOIDED CHECK APPLICABLE TO YOUR ACCOUNT TO THIS FORM. 3. PRE-DISPUTE ARBITRATION AGREEMENT. THIS AGREEMENT CONTAINS A PRE-DISPUTE ARBITRATION CLAUSE. BY SIGNING AN ARBITRATION AGREEMENT THE PARTIES AGREE AS FOLLOWS: (a) ALL PARTIES TO THIS AGREEMENT ARE GIVING UP THE RIGHT TO SUE EACH OTHER IN COURT, INCLUDING THE RIGHT TO A TRIAL BY JURY, EXCEPT AS PROVIDED BY THE RULES OF THE ARBITRATION FORUM IN WHICH A CLAIM IS FILED. (b) ARBITRATION AWARDS ARE GENERALLY FINAL AND BINDING; A PARTY S ABILITY TO HAVE A COURT REVERSE OR MODIFY ARBITRATION AWARD IS VERY LIMITED. (c) THE ABILITY OF THE PARTIES TO OBTAIN DOCUMENTS, WITNESS STATEMENTS AND OTHER DISCOVERY IS GENERALLY MORE LIMITED IN ARBITRATION THAN IN COURT PROCEEDINGS. (d) THE ARBITRATORS DO NOT HAVE TO EXPLAIN THE REASON(S) FOR THEIR AWARD UNLESS, IN AN ELIGIBLE CASE, A JOINT REQUST FOR AN EXPLIANED DECISION HAS BEEN SUBMITTED BY ALL PARTIES TO THE PANEL AT LEAST 20 DAYS PRIOR TO THE FIRST SCHEDULED HEARING DATE. (e) THE PANEL OF ARBITRATORS WILL TYPICALLY INCLUDE A MINORITY OF ARBITRATORS WHO WERE OR ARE AFFILIATED WITH THE SECURITIES INDUSTRY. (f) THE RULES OF SOME ARBITRATION FORUMS MAY IMPOSE TIME LIMITS FOR BRINGING A CLAIM IN ARBITRATION. IN SOME CASES, A CLAIM THAT IS INELIGIBLE FOR ARBITRATION MAY BE BROUGHT IN COURT. (g) THE RULES OF THE ARBITRATION FORUM IN WHICH THE CLAIM IS FILED, AND ANY AMENDMENTS THERETO, SHALL BE INCORPORATED INTO THIS AGREEMENT. NO PERSON SHALL BRING A PUTATIVE OR CERTIFIED CLASS ACTION TO ARBITRATION, NOR SEEK TO ENFORCE ANY PRE- DISPUTE ARBITRATION AGREEMENT AGAINST ANY PERSON WHO HAS INITIATED IN COURT A PUTATIVE CLASS ACTION; OR WHO IS A MEMBER OF A PUTATIVE CLASS WHO HAS NOT OPTED OUT OF THE CLASS WITH RESPECT TO ANY CLAIMS ENCOMPASSED BY THE PUTATIVE CLASS ACTION UNTIL: (i) THE CLASS CERTIFICATION IS DENIED; OR Investment and Insurance Products: NOT FDIC Insured NO Bank Guarantee MAY Lose Value Securities offered through HD Vest Investment Services SM, 6333 N. State Highway 161, Fourth Floor, Irving, Texas (972)

49 (ii) (iii) SAMPLE HD VEST ONLINE CLIENT AGREEMENT THE CLASS IS DECERTIFIED; OR THE CLIENT IS EXCLUDED FROM THE CLASS BY THE COURT. SUCH FORBEARANCE TO ENFORCE AN AGREEMENT TO ARBITRATE SHALL NOT CONSTITUTE A WAIVER OF ANY RIGHTS UNDER THIS AGREEMENT EXCEPT TO THE EXTENT STATED HEREIN. Access via HDVLink, Process Online YOU AGREE THAT ALL CLAIMS, CONTROVERSIES AND OTHER DISPUTES BETWEEN YOU AND H.D. VEST INVESTMENT SERVICES AND ITS AFFILIATED ENTITIES, INCLUDING H.D. VEST INSURANCE AGENCY, LLC (COLLECTIVELY REFERRED TO AS H.D. VEST ) AND ANY OF THEIR DIRECTORS, OFFICERS, EMPLOYEES, REGISTERED REPRESENTATIVES OR AGENTS ARISING OUT OF OR RELATING TO THIS AGREEMENT OR ANY ORDERS OR TRANSACTIONS THEREIN OR THE CONTINUATION, PERFORMANCE OR BREACH ANY AGREEMENT BETWEEN YOU AND H.D. VEST, WHETHER ENTERED INTO BEFORE, ON, OR AFTER THE DATE THIS ACCOUNT IS OPENED, SHALL BE DETERMINED BY ARBITRATION CONDUCTED BY, AND SUBJECT TO THE ARBITRATION RULES THEN IN EFFECT OF, FINRA. IF FINRA DECLINES JURISDICTION, THEN YOU AGREE TO HAVE THE ARBITRATION CONDUCTED BY AND SUBJECT TO THE RULES THEN IN EFFECT OF THE AMERICAN ARBITRATION ASSOCIATION. THIS AGREEMENT TO ARBITRATE SHALL BE SPECIFICALLY ENFORCEABLE UNDER PREVAILING LAW AND PROCEDURES. ALL FEDERAL AND STATE STATUTES OF LIMITATION, DOCTRINES OF REPOSE AND TIME BARS SHALL APPLY TO ANY ARBITRATION PROCEEDING, AND NOTHING IN THIS AGREEMENT SHALL BE DEEMED TO LIMIT OR WAIVE THE APPLICATION OF ANY SUCH STATUTE OR DOCTRINE. THE AWARD RENDERED BY THE ARBITRATORS SHALL BE FINAL, AND JUDGMENT MAY BE ENTERED UPON IT IN ANY COURT HAVING JURSIDICTION OVER THE PARTIES. COUNSEL CAN ADVISE YOU ON HOW THIS PROVISION MAY AFFECT YOU. 4. Acknowledgment of Investment Information and Receipt of this Agreement. You acknowledge that all information on the HD Vest Mutual Fund New Account Application is correct to the best of your knowledge. By your signature on the HD Vest Mutual Fund New Account Application, you acknowledge receipt of a copy of this Agreement. UNDER PENALTIES OF PERJURY, I CERTIFY THAT: 1. the number shown on this form is my correct taxpayer identification number (or I am waiting for a number to be issued to me), and 2. I am not subject to backup withholding because: (a) I am exempt from backup withholding, or (b) I have not been notified by the Internal Revenue Service (IRS) that I am subject to backup withholding as a result of a failure to report all interest or dividends, or (c) the IRS has notified me that I am no longer subject to backup withholding, and 3. I am a U.S. person (including a U.S. resident alien). I ACKNOWLEDGE that I received, read, and understand the HD Vest Client Agreement. I/WE ACKNOWLEDGE RECEIPT OF A COPY OF THE HD VEST CLIENT AGREEMENT WHICH CONTAINS A PRE-DISPUTE ARBITRATION CLAUSE ON PAGE 3, PARAGRAPH 3. / / / / SIGNATURE (AUTHORIZED INDIVIDUAL) DATE ADDITIONAL CLIENT SIGNATURE (if applicable) DATE CLIENT NAME REGISTRATION TYPE SOCIAL SECURITY/TAX ID NO. ACCOUNT REFERENCE NUMBER/BIN If you have any questions regarding your accounts or transactions through HD Vest Investment Services SM, and your Advisor is unable to assist you, please contact our offices at: HD Vest Investment Services SM 6333 North State Highway 161, Fourth Floor Irving, Texas HDVEST1 or Client Identification Disclosure. To help the government fight the funding of terrorism and money-laundering activities, U.S. Federal law requires financial institutions to obtain, verify, and record information that identifies each person (individuals and businesses) who opens an account. What this means for you: When you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We may also ask for your driver's license or other identifying documents. FOR CLIENTS AUTHORIZING PAYMENT BY ACH, PLEASE ATTACH A VOIDED CHECK HERE Investment and Insurance Products: NOT FDIC Insured NO Bank Guarantee MAY Lose Value Securities offered through HD Vest Investment Services SM, 6333 N. State Highway 161, Fourth Floor, Irving, Texas (972)

50 SAMPLE Access via HDVLink PRIMARY OWNER INFORMATION ( OR TRUST INFO) Indexed Annuity Disclosure Form FUNCTION OF CLIENT: Owner/Grantor Custodian Trustee Fiduciary Organization (Non-Profit) Decedent Minor/Ward Beneficiary Contact Company Plan Participant Trust CLIENT FULL NAME (NO INITIALS) NICKNAME SOCIAL SECURITY NUMBER/TAX ID BIRTH DATE/ESTABLISHED DATE HOME PHONE WORK PHONE ADDRESS MARITAL STATUS: SINGLE MARRIED NUMBER OF DEPENDENTS: CITIZENSHIP: U.S. RESIDENT ALIEN: (IF UNKNOWN, DEFAULT TO ZERO) COUNTRY OF CITIZENSHIP EMPLOYMENT: EMPLOYER OCCUPATION (TYPE OF BUSINESS AND POSITION TITLE) EMPLOYER ADDRESS CITY STATE ZIP AFFILIATIONS: (SUPPLY ANY SECURITIES FIRM, EXCHANGE OR AGENCY AFFILIATION, IF NOT SELECTED, DEFAULT TO NONE) NONE COMPANY: IS THIS CLIENT A SENIOR FOREIGN POLITICAL FIGURE OR FAMILY MEMBER OR ASSOCIATE OF A SENIOR FOREIGN POLITICAL FIGURE: YES NO (IF LEFT UNCHECKED, NO WILL BE ASSUMED) I CERTIFY THAT I HAVE PREPARED AND FILED THE MOST RECENT TAX RETURN FOR THIS CLIENT: YES NO (IF NO, PLEASE SUPPLY ID INFORMATION BELOW) ISSUED PICTURE ID TYPE: ID NUMBER: STATE/COUNTRY OF ISSUANCE: ISSUE DATE: EXPIRATION DATE: INVESTMENT EXPERIENCE (PRIMARY OWNER) IF LEFT UNCHECKED, NONE WILL BE ASSUMED STOCKS MUTUAL FUNDS BONDS OPTIONS ANNUITIES-LIFE INS NONE NONE NONE NONE NONE LESS THAN 5YRS LESS THAN 5YRS LESS THAN 5YRS LESS THAN 5YRS LESS THAN 5YRS 5-10 YRS 5-10 YRS 5-10 YRS 5-10 YRS 5-10 YRS OVER 10 YRS OVER 10 YRS OVER 10 YRS OVER 10 YRS OVER 10 YRS ACCOUNT INFORMATION MAILING ADDRESS (OR P.O. BOX) CITY STATE ZIP COUNTRY LEGAL/RESIDENTIAL ADDRESS (IF DIFFERENT FROM MAILING ADDRESS) CITY STATE ZIP COUNTRY INVESTMENT INFORMATION INVESTMENT OBJECTIVE: (check only one) CONSERVATIVE INCOME MODERATE INCOME LONG TERM INCOME CONSERVATIVE GROWTH & INCOME MODERATE GROWTH & INCOME LONG TERM GROWTH & INCOME CONSERVATIVE GROWTH MODERATE GROWTH LONG TERM GROWTH TRADING & SPECULATION INVESTMENT AND INSURANCE PRODUCTS: NOT FDIC INSURED NO BANK GUARANTEE MAY LOSE VALUE SECURITIES OFFERED THROUGH HD VEST INVESTMENT SERVICES SM, MEMBER SIPC ADVISORY SERVICES OFFERED THROUGH HD VEST ADVISORY SERVICES SM N. STATE HIGHWAY 161, FOURTH FLOOR, IRVING, TX 75038, (972)

51 SAMPLE Access via HDVLink ANNUAL HOUSEHOLD INCOME : FINANCIAL INFORMATION (IF JOINT OWNERS, PLEASE COMBINE THE CLIENT S FINANCIAL INFORMATION) Indexed Annuity Disclosure Form NET WORTH (EXCLUDING RESIDENCE): LIQUID NET WORTH: ESTIMATED VALUE OF INVESTMENTS: TAX BRACKET: 0% 1 10% 11 15% 16 25% 26 28% 29 33% 34 35% OVER 35% SECONDARY OWNER INFORMATION ( OR TRUSTEE INFO) FUNCTION OF CLIENT: Owner/Grantor Custodian Trustee Fiduciary Organization (Non-Profit) Decedent Minor/Ward Beneficiary Contact Company Plan Participant Trust CLIENT FULL NAME (NO INITIALS) NICKNAME SOCIAL SECURITY NUMBER/TAX ID BIRTH DATE/ESTABLISHED DATE HOME PHONE WORK PHONE ADDRESS MARITAL STATUS: SINGLE MARRIED NUMBER OF DEPENDENTS: CITIZENSHIP: U.S. RESIDENT ALIEN: (IF UNKNOWN, DEFAULT TO ZERO) COUNTRY OF CITIZENSHIP EMPLOYMENT: EMPLOYER OCCUPATION (TYPE OF BUSINESS AND POSITION TITLE) EMPLOYER ADDRESS CITY STATE ZIP AFFILIATIONS: (SUPPLY ANY SECURITIES FIRM, EXCHANGE OR AGENCY AFFILIATION, IF NOT SELECTED, DEFAULT TO NONE) NONE COMPANY: IS THIS CLIENT A SENIOR FOREIGN POLITICAL FIGURE OR FAMILY MEMBER OR ASSOCIATE OF A SENIOR FOREIGN POLITICAL FIGURE: YES NO (If Left Unchecked, no will be assumed) I CERTIFY THAT I HAVE PREPARED AND FILED THE MOST RECENT TAX RETURN FOR THIS CLIENT: YES NO (IF NO, PLEASE SUPPLY ID INFORMATION BELOW) ISSUED PICTURE ID TYPE: ID NUMBER: STATE/COUNTRY OF ISSUANCE: ISSUE DATE: EXPIRATION DATE: FUNCTION OF CLIENT: STOCKS MUTUAL FUNDS BONDS OPTIONS ANNUITIES-LIFE INS NONE NONE NONE NONE NONE LESS THAN 5YRS LESS THAN 5YRS LESS THAN 5YRS LESS THAN 5YRS LESS THAN 5YRS 5-10 YRS 5-10 YRS 5-10 YRS 5-10 YRS 5-10 YRS OVER 10 YRS OVER 10 YRS OVER 10 YRS OVER 10 YRS OVER 10 YRS INVESTMENT AND INSURANCE PRODUCTS: NOT FDIC INSURED NO BANK GUARANTEE MAY LOSE VALUE SECURITIES OFFERED THROUGH HD VEST INVESTMENT SERVICES SM, MEMBER SIPC ADVISORY SERVICES OFFERED THROUGH HD VEST ADVISORY SERVICES SM N. STATE HIGHWAY 161, FOURTH FLOOR, IRVING, TX 75038, (972)

52 SAMPLE Indexed Annuity Disclosure Form SECTION 1 - SOURCE OF FUNDS (IF LIQUIDATING MORE THAN ONE INVESTMENT, PLEASE COMPLETE A NEW PAGE FOR EACH INVESTMENT LIQUIDATED) WHAT IS THE SOURCE OF INVESTED FUNDS? (ANNUITY ASSETS LIQUIDATED WITHIN THE LAST 6 MONTHS SHOULD BE CONSIDERED AN EXCHANGE-REPLACEMENT) SECURITIES OTHER THAN VARIABLE ANNUITIES OR INSURANCE TIME DEPOSITS EXCHANGE-REPLACEMENT, LIFE INSURANCE CONTRACT INHERITANCE/GIFTS/ESTATE ASSETS PARTIAL 1035 EXCHANGE OR PARTIAL LIQUIDATION QUALIFIED ROLLOVER (401(K), SIMPLE, SEP) Access via HDVLink OTHER - DETAIL SOURCE NAME OF SPECIFIC INVESTMENT EXITED: DATE EXITING PRODUCT WAS ORIGINALLY PURCHASED: IS THE SOURCE OF FUNDS COMING FROM A SALE/LIQUIDATION WHERE YOU WERE THE SELLING AGENT ON THE ORIGINAL PRODUCT? YES NO IF THIS ANNUITY IS FUNDED FROM THE LIQUIDATION OF ANOTHER INVESTMENT PRODUCT, WHAT IS THE SURRENDER CHARGE INCURRED TO GET OUT OF THE EXISTING INVESTMENT? NO SURRENDER CHARGE 0.1%-2.99% % 4% OR MORE SECTION 2 - ANNUITY EXCHANGE AND REPLACEMENT (TO BE COMPLETED IF EXCHANGE-REPLACEMENT OR PARTIAL 1035 HAS BEEN CHECKED) POLICY BEING SURRENDERED PROPOSED POLICY MARKET VALUE (PLUS APPLICABLE BONUS): $ $ EXISTING POLICY SURRENDER CHARGES: $ % CASH SURRENDER VALUE (MARKET VALUE LESS SURRENDER CHARGES): $ SURRENDER PERIOD: YRS YRS AMOUNT OF DEATH BENEFIT: $ $ TOTAL ANNUAL CHARGES (M&E, ADMIN., AND ADD-ON FEATURES): % % CHECK ALL DEATH BENEFIT OPTIONS THAT APPLY: PREMIUM GUARANTEE (STANDARD) STEP-UP TO ACCOUNT VALUE (I.E. MAV) GUARANTEE STEP-UP (I.E. 4%, 5%, 6%) EARNINGS ENHANCEMENT BENEFIT (EEB) POLICY BEING SURRENDERED LIST THE GUARANTEED AMOUNTS OF ANY EXISTING LIVING BENEFIT. CLICK ALL LIVING BENEFITS ELECTED IN THE PROPOSED POLICY. POLICY BEING SURRENDERED GUARANTEED MINIMUM INCOME BENEFIT (GMIB) $ GUARANTEED MINIMUM WITHDRAWAL BENEFIT (GMWB) $ PRINCIPAL GUARANTEE (GMAB) $ OTHER: $ OTHER: $ IS THIS AN ANNUITY REPLACEMENT FOR A RESIDENT OF NEW YORK OR A REPLACEMENT WHERE THE PAPERWORK IS BEING SIGNED IN OR DELIVERED IN NEW YORK? IF SO, PLEASE ATTEST BY ANSWERING "YES" THAT THE REQUIRED REG 60 PROCESS WAS OR WILL BE FOLLOWED WITH TWO MEETINGS WITH THE CLIENT. YES NO N/A (NOT AN EXCHANGE) INVESTMENT AND INSURANCE PRODUCTS: NOT FDIC INSURED NO BANK GUARANTEE MAY LOSE VALUE SECURITIES OFFERED THROUGH HD VEST INVESTMENT SERVICES SM, MEMBER SIPC ADVISORY SERVICES OFFERED THROUGH HD VEST ADVISORY SERVICES SM N. STATE HIGHWAY 161, FOURTH FLOOR, IRVING, TX 75038, (972)

53 Indexed Annuity Disclosure Form SECTION 3 - PLEASE COMPLETE THE FOLLOWING QUESTIONS REGARDING THE ANNUITY BEING PURCHASED SAMPLE NAME OF NEW INVESTMENT BEING PURCHASED: Access via HDVLink IS THIS TRANSACTION? AN INITIAL PURCHASE OF AN ANNUITY AMOUNT OF PREMIUM: A SUBSEQUENT OR ADD-ON TO AN EXISTING ANNUITY IF THERE IS A JOINT OWNER LISTED ON PAGE 1, WHAT IS THE RELATIONSHIP TO THE OWNER? THERE IS NO CO-OWNER SPOUSE CHILD OTHER HOW LONG DOES THE CLIENT ANTICIPATE HOLDING THIS ANNUITY CONTRACT? LESS THAN 5 YEARS MORE THAN 5 YEARS THE CLIENT ANTICIPATES USING THIS ANNUITY CONTRACT FOR? (PLEASE CHECK ALL THAT APPLY) INCOME NOW (0 TO 3 YEARS) INCOME LATER (4 OR MORE YEARS) PASS TO BENEFICIARY LUMP SUM IF THE OBJECTIVE IS TO PASS ON THE INVESTMENT TO BENEFICIARIES, HAS LIFE INSURANCE BEEN CONSIDERED AS AN ALTERNATIVE TO THIS ANNUITY? YES NO N/A (REPLACEMENT, UNINSURABLE, IRA, ETC.) WHAT IS THE CLIENT'S TOTAL HOLDINGS IN ANNUITIES, INCLUDING THIS PURCHASE, AS A PERCENTAGE OF THE CLIENT'S LIQUID NET WORTH? (LNW SHOULD INCLUDE CASH, SECURITIES, OTHER ANNUITIES AND RETIREMENT FUNDS) 0-25% 26%-50% 51%-60% 61%-75% 76% OR MORE CURRENTLY, WHAT ARE THE CLIENT'S ANNUAL INCOME NEEDS (IN DOLLARS) FROM THEIR INVESTMENTS ABOVE AND BEYOND PENSION, SOCIAL SECURITY, AND EMPLOYMENT INCOME? PLEASE INDICATE THE TOTAL NUMBER OF OTHER ANNUITY REPLACEMENTS THE CLIENT HAS TRANSACTED WITHIN THE PAST 36 MONTHS. 0 REPLACEMENTS 1 REPLACEMENTS 2 REPLACEMENT 3 REPLACEMENTS 4 OR MORE REPLACEMENTS WHAT TYPE OF INVESTMENTS HAS THE CLIENT OWNED WITHIN THE PAST 5 YEARS? (PLEASE CHECK ALL THAT APPLY) 1-SAVINGS ACCOUNTS, CD'S, MONEY MARKETS 2- FIXED INCOME MUTUAL FUNDS (TAXABLE OR TAX-FREE), INDIVIDUAL BONDS (FEDERAL, MUNI, CORPORATE, ETC), FIXED ANNUITIES, WHOLE LIFE INSURANCE, TERM LIFE INSURANCE 3-EQUITY MUTUAL FUNDS, INDIVIDUALS EQUITIES, VARIABLE ANNUITIES, VARIABLE LIFE INSURANCE, OTHER OTHER THAN THE ANNUITY YOU ARE PROPOSING, HAVE OTHER PRODUCTS BEEN DISCUSSED? YES (PLEASE EXPLAIN IN SECTION 4 ON FOLLOWING PAGE) NO WHAT INDEX OR INDEXES IS THIS ANNUITY S PERFORMANCE BASED UPON? WHAT IS THE PARTICIPATION RATE ASSOCIATED WITH THIS ANNUITY? % IS THE PARTICIPATION RATE RESET DURING THE LIFE OF THE ANNUITY? YES NO IF YES, WHEN IS THE RATE RESET? WHAT PERCENTAGE DOES THIS ANNUITY CAP THE INTEREST RATE GAIN? % CAN THE INTEREST RATE CAP BE ADJUSTED? YES NO IF YES, WHEN CAN THE INTEREST RATE CAP BE ADJUSTED? WHAT INDEXING METHOD IS USED TO CALCULATE THE AMOUNT OF INTEREST TO BE CREDITED TO THE CONTRACT? ANNUAL RESET (RATCHET) HIGH WATER MARK POINT TO POINT OTHER: INDEX ANNUITIES (IAS) ARE LONG TERM INVESTMENTS. MANY IAS HAVE SURRENDER CHARGE WHICH MAY BE A PERCENTAGE OF OR A REDUCTION IN THE INTEREST RATE CREDITED TO THE IA. DOES THIS ANNUITY HAVE A SURRENDER CHARGE AFTER THE DEATH OF THE OWNER? YES NO INVESTMENT AND INSURANCE PRODUCTS: NOT FDIC INSURED NO BANK GUARANTEE MAY LOSE VALUE SECURITIES OFFERED THROUGH HD VEST INVESTMENT SERVICES SM, MEMBER SIPC ADVISORY SERVICES OFFERED THROUGH HD VEST ADVISORY SERVICES SM N. STATE HIGHWAY 161, FOURTH FLOOR, IRVING, TX 75038, (972)

54 Indexed Annuity Disclosure Form SURRENDER CHARGES EQUITY INDEX ANNUITIES GENERALLY HAVE SURRENDER CHARGES FOR A SPECIFIED PERIOD OF TIME. SAMPLE THE SURRENDER CHARGE MEANS THAT YOU MAY NOT GET ALL YOUR MONEY BACK IF YOU SURRENDER YOUR Access CONTRACT. via HDVLink IN THE CASE OF A FULL OR PARTIAL SURRENDER (DEFINED AS WITHDRAWALS IN EXCESS OF THE ALLOWABLE AMOUNT SPECIFIED BY THE ISSUING INSURANCE COMPANY), YOU WILL INCUR THE FOLLOWING PENALTIES DURING THE SURRENDER CHARGE PERIOD, AS SET FORTH IN THE ANNUITY CONTRACT OR DISCLOSURE DOCUMENT, AND SUMMARIZED BELOW: YEAR THEREAFTER PENALTY % % % % % % % % % % CHECK CONTRACT SECTION 4 PLEASE EXPLAIN HOW THIS TRANSACTION CAME ABOUT AND WHY THIS PRODUCT WAS RECOMMENDED. ALSO, PLEASE EXPLAIN THE CLIENT S FINANCIAL, SITUATIONAL AND LIQUIDITY NEEDS. IF ADDITIONAL SPACE IS NECESSARY, PLEASE ATTACH ANOTHER DOCUMENT TO THE IPED. (THIS SHOULD BE COMPLETED AND REVIEWED WITH THE CLIENT PRIOR TO THE CLIENT SIGNING.) INVESTMENT AND INSURANCE PRODUCTS: NOT FDIC INSURED NO BANK GUARANTEE MAY LOSE VALUE SECURITIES OFFERED THROUGH HD VEST INVESTMENT SERVICES SM, MEMBER SIPC ADVISORY SERVICES OFFERED THROUGH HD VEST ADVISORY SERVICES SM N. STATE HIGHWAY 161, FOURTH FLOOR, IRVING, TX 75038, (972)

55 SAMPLE CLIENT ACKNOWLEDGEMENT Indexed Annuity Disclosure Form I UNDERSTAND THAT MY ADVISOR AND HD VEST WILL BE COMPENSATED FOR THE SALE OF THIS PRODUCT. (FOR SPECIFIC INFORMATION ABOUT THE COMPENSATION PAID, PLEASE CONTACT YOUR ADVISOR.) Access via HDVLink I HAVE DETERMINED THAT I HAVE A NEED FOR THIS PRODUCT. I HAVE DETERMINED THAT THIS PRODUCT IS CONSISTENT WITH MY RISK TOLERANCE AND OVERALL STRATEGY. I HAVE BEEN INFORMED THAT ANY GUARANTEES ASSOCIATED WITH THIS PRODUCT ARE BACKED BY THE ONGOING CLAIMS PAYING ABILITY OF THE ISSUER. I HAVE DETERMINED THAT THE COSTS ASSOCIATED WITH THIS PRODUCT ARE ACCEPTABLE GIVEN MY OBJECTIVES. I UNDERSTAND THAT THIS PRODUCT MAY HAVE A CONTINGENT DEFERRED SALES CHARGE AND I MAY HAVE TO HOLD THE PRODUCT FOR A CERTAIN PERIOD SPECIFIED BY THE INSURANCE CARRIER IN ORDER TO AVOID A PENALTY ON FUNDS WITHDRAWN. IF REQUESTING A 1035 EXCHANGE, I HAVE DISCUSSED WITH MY ADVISOR OR I HAVE BEEN SHOWN A COMPARISON OF THE FEES AND EXPENSES BETWEEN THE PRODUCT BEING EXITED AND THE PRODUCT BEING PURCHASED. I UNDERSTAND THAT TAKING WITHDRAWALS FROM THIS PRODUCT MAY DECREASE THE AMOUNT OF INCOME RECEIVED. I UNDERSTAND NON-ANNUITIZED WITHDRAWALS FROM VARIABLE ANNUITIES PURCHASED AFTER AUGUST 1982 ARE TAXED AS EARNINGS FIRST, PRINCIPAL LAST (LAST IN FIRST OUT LIFO). ADDITIONALLY, THE EARNINGS COMPONENT OF ANY VARIABLE ANNUITY WITHDRAWALS IS TAXED AS ORDINARY INCOME. I UNDERSTAND THAT H.D. VEST INVESTMENT SECURITIES, INC. DOES NOT PROVIDE TAX ADVICE AND I SHOULD CONTACT MY TAX ADVISOR ON THE SUBJECT. I UNDERSTAND INTEREST IN THIS PRODUCT GROWS TAX-DEFERRED. IF THIS PRODUCT IS PLACED IN A RETIREMENT ACCOUNT, I DO NOT GAIN ANY ADDITIONAL TAX- DEFERRED ADVANTAGES. I UNDERSTAND THAT IF I HAVE ANY QUESTIONS ABOUT THE INFORMATION CONTAINED IN THIS DOCUMENT, AND I WOULD LIKE TO SPEAK WITH SOMEONE AT THE HD VEST HOME OFFICE, I CAN CONTACT THE SALES SUPERVISION DEPARTMENT AT (800) , X4721. MY HD VEST AGENT WILL BE NOTIFIED AND GIVEN THE OPPORTUNITY TO PARTICIPATE IN THE CONVERSATION. I AGREE THAT THIS AGREEMENT SHALL BE GOVERNED BY THE LAWS OF THE STATE OF TEXAS WITHOUT REGARD TO ITS CONFLICT OF THE LAW S PROVISIONS AND SHALL INURE TO THE BENEFIT OF MY AND H,D. VEST INVESTMENT SECURITIES, INC. S RESPECTIVE SUCCESSORS AND ASSIGNS, AND SHALL BE BINDING ON ME AND MY REPRESENTATIVES, ATTORNEYS-IN-FACT, HEIRS, EXECUTORS, ADMINISTRATORS, AND ASSIGNS. HD VEST CLIENT PRE-DISPUTE ARBITRATION AGREEMENT THIS AGREEMENT CONTAINS A PRE-DISPUTE ARBITRATION CLAUSE. BY SIGNING AN ARBITRATION AGREEMENT THE PARTIES AGREE AS FOLLOWS: (i.) ALL PARTIES TO THIS AGREEMENT ARE GIVING UP THE RIGHT TO SUE EACH OTHER IN COURT, INCLUDING THE RIGHT TO A TRIAL BY JURY, EXCEPT AS PROVIDED BY THE RULES OF THE ARBITRATION FORUM IN WHICH A CLAIM IS FILED. (ii.) ARBITRATION AWARDS ARE GENERALLY FINAL AND BINDING; A PARTY S ABILITY TO HAVE A COURT REVERSE OR MODIFY ARBITRATION AWARD IS VERY LIMITED. (iii.) THE ABILITY OF THE PARTIES TO OBTAIN DOCUMENTS, WITNESS STATEMENTS AND OTHER DISCOVERY IS GENERALLY MORE LIMITED IN ARBITRATION THAN IN COURT PROCEEDINGS. (iv.) THE ARBITRATORS DO NOT HAVE TO EXPLAIN THE REASON(S) FOR THEIR AWARD UNLESS, IN AN ELIGIBLE CASE, A JOINT REQUST FOR AN EXPLIANED DECISION HAS BEEN SUBMITTED BY ALL PARTIES TO THE PANEL AT LEAST 20 DAYS PRIOR TO THE FIRST SCHEDULED HEARING DATE. (v.) THE PANEL OF ARBITRATORS WILL TYPICALLY INCLUDE A MINORITY OF ARBITRATORS WHO WERE OR ARE AFFILIATED WITH THE SECURITIES INDUSTRY. (vi.) THE RULES OF SOME ARBITRATION FORUMS MAY IMPOSE TIME LIMITS FOR BRINGING A CLAIM IN ARBITRATION. IN SOME CASES, A CLAIM THAT IS INELIGIBLE FOR ARBITRATION MAY BE BROUGHT IN COURT. (vii.) THE RULES OF THE ARBITRATION FORUM IN WHICH THE CLAIM IS FILED, AND ANY AMENDMENTS THERETO, SHALL BE INCORPORATED INTO THIS AGREEMENT. NO PERSON SHALL BRING A PUTATIVE OR CERTIFIED CLASS ACTION TO ARBITRATION, NOR SEEK TO ENFORCE ANY PRE-DISPUTE ARBITRATION AGREEMENT AGAINST ANY PERSON WHO HAS INITIATED IN COURT A PUTATIVE CLASS ACTION; OR WHO IS A MEMBER OF A PUTATIVE CLASS WHO HAS NOT OPTED OUT OF THE CLASS WITH RESPECT TO ANY CLAIMS ENCOMPASSED BY THE PUTATIVE CLASS ACTION UNTIL: (i) THE CLASS CERTIFICATION IS DENIED; OR (ii) THE CLASS IS DECERTIFIED; OR (iii) THE CLIENT IS EXCLUDED FROM THE CLASS BY THE COURT. SUCH FORBEARANCE TO ENFORCE AN AGREEMENT TO ARBITRATE SHALL NOT CONSTITUTE A WAIVER OF ANY RIGHTS UNDER THIS AGREEMENT EXCEPT TO THE EXTENT STATED HEREIN. YOU AGREE THAT ALL CLAIMS, CONTROVERSIES AND OTHER DISPUTES BETWEEN YOU AND HD VEST INVESTMENT SERVICES AND ITS AFFILIATED ENTITIES, INCLUDING HD VEST INSURANCE AGENCY, LLC (COLLECTIVELY REFERRED TO AS HD VEST ) AND ANY OF THEIR DIRECTORS, OFFICERS, EMPLOYEES, REGISTERED REPRESENTATIVES OR AGENTS ARISING OUT OF OR RELATING TO THIS INVESTMENT AND INSURANCE PRODUCTS: NOT FDIC INSURED NO BANK GUARANTEE MAY LOSE VALUE SECURITIES OFFERED THROUGH HD VEST INVESTMENT SERVICES SM, MEMBER SIPC ADVISORY SERVICES OFFERED THROUGH HD VEST ADVISORY SERVICES SM N. STATE HIGHWAY 161, FOURTH FLOOR, IRVING, TX 75038, (972)

56 Indexed Annuity Disclosure Form AGREEMENT OR ANY ORDERS OR TRANSACTIONS THEREIN OR THE CONTINUATION, PERFORMANCE OR BREACH ANY AGREEMENT BETWEEN YOU AND HD VEST, WHETHER ENTERED INTO BEFORE, ON, OR AFTER THE DATE THIS ACCOUNT IS OPENED, SHALL BE DETERMINED BY ARBITRATION CONDUCTED BY, AND SUBJECT TO THE ARBITRATION RULES THEN IN EFFECT OF, FINRA. IF FINRA SAMPLE DECLINES JURISDICTION, THEN YOU AGREE TO HAVE THE ARBITRATION CONDUCTED BY AND SUBJECT TO THE RULES THEN IN EFFECT OF THE AMERICAN ARBITRATION ASSOCIATION. THIS AGREEMENT TO ARBITRATE SHALL BE SPECIFICALLY ENFORCEABLE UNDER Access PREVAILING via HDVLink LAW AND PROCEDURES. ALL FEDERAL AND STATE STATUTES OF LIMITATION, DOCTRINES OF REPOSE AND TIME BARS SHALL APPLY TO ANY ARBITRATION PROCEEDING, AND NOTHING IN THIS AGREEMENT SHALL BE DEEMED TO LIMIT OR WAIVE THE APPLICATION OF ANY SUCH STATUTE OR DOCTRINE. THE AWARD RENDERED BY THE ARBITRATORS SHALL BE FINAL, AND JUDGMENT MAY BE ENTERED UPON IT IN ANY COURT HAVING JURSIDICTION OVER THE PARTIES. COUNSEL CAN ADVISE YOU ON HOW THIS PROVISION MAY AFFECT YOU. TO HELP THE GOVERNMENT FIGHT THE FUNDING OF TERRORISM AND MONEY-LAUNDERING ACTIVTIES, U.S. FEDERAL LAW REQUIRES FINANCIAL INSTITUTIONS TO OBTAIN, VERIFY, AND RECORD INFORMATION THAT IDENTIFIES EACH PERSON (INDIVIDUALS AND BUSINESSES) WHO OPENS AN ACCOUNT. WHAT THIS MEANS FOR YOU: WHEN YOU OPEN AN ACCOUNT, WE WILL ASK FOR YOUR NAME, ADDRESS, DATE OF BIRTH, AND OTHER INFORMATION THAT WILL ALLOW US TO IDENTIFY YOU. WE MAY ALSO ASK FOR YOUR DRIVER S LICENSE OR OTHER IDENTIFYING DOCUMENTS. I/WE ACKNOWLEDGE REVIEW AND APPROVAL OF ALL OF THE INFORMATION CONTAINED ON ALL 7 PAGES OF THIS INDEXED ANNUITY DISCLOSURE FORM. THIS AGREEMENT CONTAINS A PRE-DISPUTE ARBITRATION CLAUSE, WHICH BEGINS ON THE PREVIOUS PAGE. I/WE ACKNOWLEDGE RECEIPT OF A COPY OF THIS AGREEMENT, INCLUDING THE H.D. VEST PRE-DISPUTE ARBITRATION CLAUSE. CLIENT SIGNATURE: DATE: CLIENT SIGNATURE (JOINT OWNER): DATE: AGENT SIGNATURE: DATE: AGENT NAME (PRINTED): AGENT NUMBER: INTERNAL USE ONLY APPROVE REJECT REASON FOR REJECTION : SALES SUPERVISOR: SALES SUPERVISOR SIGNATURE: DATE: INVESTMENT AND INSURANCE PRODUCTS: NOT FDIC INSURED NO BANK GUARANTEE MAY LOSE VALUE SECURITIES OFFERED THROUGH HD VEST INVESTMENT SERVICES SM, MEMBER SIPC ADVISORY SERVICES OFFERED THROUGH HD VEST ADVISORY SERVICES SM N. STATE HIGHWAY 161, FOURTH FLOOR, IRVING, TX 75038, (972)

57 Insurance Purchasing/ Exchange Disclosure (IPED) For Variable Annuities IF ANY OF THIS FORM IS LEFT BLANK, THE TRANSACTION WILL NOT BE PROCESSED AND PAPERWORK WILL BE RETURNED TO YOU FOR COMPLETION SAMPLE FUNCTION OF CLIENT: Access via HDVLink PRIMARY OWNER INFORMATION ( OR TRUST INFO) Owner Custodian Trustee Fiduciary Organization (Non-Profit) Decedent Minor/Ward Beneficiary Contact Company Plan Participant Trust CLIENT FULL NAME (NO INITIALS) NICKNAME SOCIAL SECURITY NO/TAX ID BIRTH DATE/ESTABLISHED DATE HOME PHONE WORK PHONE ADDRESS MARITAL STATUS: SINGLE MARRIED NUMBER OF DEPENDENTS: CITIZENSHIP: U.S. RESIDENT ALIEN: (IF UNKNOWN, DEFAULT TO ZERO) COUNTRY OF CITIZENSHIP EMPLOYMENT: EMPLOYER OCCUPATION (TYPE OF BUSINESS AND POSITION TITLE) EMPLOYER ADDRESS CITY STATE ZIP AFFILIATIONS: PLEASE IDENTIFY ANY AFFILIATION CLIENT HAS WITH A SECURITIES FIRM, EXCHANGE OR AGENCY: IS CLIENT A SENIOR FOREIGN POLITICAL FIGURE OR FAMILY MEMBER OR ASSOCIATE OF A SENIOR FOREIGN POLITICAL FIGURE (DEFAULT= NO ): YES I CERTIFY THAT I HAVE PREPARED AND FILED THE MOST RECENT TAX RETURN FOR THIS CLIENT: YES NO (IF NO, PLEASE SUPPLY ID INFORMATION BELOW) ISSUED PICTURE ID TYPE: ID NO: STATE/COUNTRY OF ISSUANCE: ISSUE DATE: EXPIRATION DATE: INVESTMENT EXPERIENCE IF LEFT UNCHECKED, NONE WILL BE ASSUMED STOCKS MUTUAL FUNDS BONDS OPTIONS ANNUITIES-LIFE INS NONE NONE NONE NONE NONE LESS THAN 5YRS LESS THAN 5YRS LESS THAN 5YRS LESS THAN 5YRS LESS THAN 5YRS 5-10 YRS 5-10 YRS 5-10 YRS 5-10 YRS 5-10 YRS OVER 10 YRS OVER 10 YRS OVER 10 YRS OVER 10 YRS OVER 10 YRS ACCOUNT INFORMATION MAILING ADDRESS (OR P.O. BOX) CITY STATE ZIP COUNTRY LEGAL/RESIDENTIAL ADDRESS (IF DIFFERENT FROM MAILING ADDRESS) CITY STATE ZIP COUNTRY INVESTMENT INFORMATION INVESTMENT OBJECTIVE OF SUB ACCOUNTS: (check only one) CONSERVATIVE INCOME MODERATE INCOME LONG TERM INCOME CONSERVATIVE GROWTH & INCOME MODERATE GROWTH & INCOME LONG TERM GROWTH & INCOME CONSERVATIVE GROWTH MODERATE GROWTH LONG TERM GROWTH TRADING & SPECULATION SECURITIES OFFERED THROUGH HD VEST INVESTMENT SERVICES SM, MEMBER SIPC ADVISORY SERVICES OFFERED THROUGH HD VEST ADVISORY SERVICES SM, 6333 N. STATE HIGHWAY 161, FOURTH FLOOR, IRVING, TX 75038, (972)

58 Insurance Purchasing/ Exchange Disclosure (IPED) For Variable Annuities IF ANY OF THIS FORM IS LEFT BLANK, THE TRANSACTION WILL NOT BE PROCESSED AND PAPERWORK WILL BE RETURNED TO YOU FOR COMPLETION SAMPLE FINANCIAL INFORMATION GROSS ANNUAL HOUSEHOLD* INCOME: (WAGES, COMMISSIONS, BONUSES, SOCIAL SECURITY, PENSION/ RETIREMENT BENEFITS, INVESTMENT INTEREST AND DIVIDENDS, DISABILITY, UNEMPLOYMENT COMPENSATION, AND RENTAL INCOME) $ Access via HDVLink TOTAL NET WORTH OF HOUSEHOLD*: NET WORTH IS THE VALUE OF YOUR ASSETS MINUS YOUR LIABILITIES. FOR PURPOSES OF THIS APPLICATION, DO NOT INCLUDE YOUR PRIMARY RESIDENCE AMONG YOUR ASSETS AND FOR LIABILITIES, DO NOT INCLUDE THE MORTGAGE ON YOUR PRIMARY RESIDENCE. $ TOTAL LIQUID NET WORTH OF HOUSEHOLD*: LIQUID NET WORTH IS YOUR TOTAL NET WORTH OF HOUSEHOLD MINUS ASSETS THAT CANNOT BE CONVERTED QUICKLY AND EASILY TO CASH, SUCH AS REAL ESTATE, BUSINESS EQUITY, PERSONAL PROPERTY, AUTOMOBILES, EXPECTED INHERITANCES, ASSETS EARMARKED FOR OTHER PURPOSES. WHEN YOU INCLUDE INVESTMENT ACCOUNTS IN THE TOTAL LIQUID NET WORTH OF HOUSEHOLD CALCULATION, YOU MUST SUBTRACT ANY SURRENDER CHARGES, FEES, AND PENALTIES FOR EARLY WITHDRAWAL. $ VALUE OF HOUSEHOLD* INVESTMENTS: STOCKS, BONDS, MUTUAL FUNDS, ANNUITIES AND OTHER SECURITIES INVESTMENTS HELD IN QUALIFIED AND NON QUALIFIED REGISTRATIONS SHOULD BE INCLUDED. YOU MUST SUBTRACT ANY SURRENDER CHARGES, FEES, AND PENALTIES FOR EARLY WITHDRAWAL. DO NOT INCLUDE THE PENDING PURCHASE HERE. $ CASH & CASH EQUIVALENTS OF HOUSEHOLD*: (E.G. CHECKING, SAVINGS, CDS, ETC.) $ TAX BRACKET: 0% 1 10% 11 15% 16 25% 26 28% 29 33% 34 35% OVER 35% * HOUSEHOLD SHOULD INCLUDE THE COMBINED FIGURES OF THE PURCHASER AND SPOUSE. SECONDARY OWNER INFORMATION ( OR TRUSTEE INFO) FUNCTION OF CLIENT: Owner Custodian Trustee Fiduciary Organization (Non-Profit) Decedent Minor/Ward Beneficiary Contact Company Plan Participant Trust CLIENT FULL NAME (NO INITIALS) NICKNAME SOCIAL SECURITY NO/TAX ID BIRTH DATE/ESTABLISHED DATE HOME PHONE WORK PHONE ADDRESS MARITAL STATUS: SINGLE MARRIED NUMBER OF DEPENDENTS: CITIZENSHIP: U.S. RESIDENT ALIEN: (IF UNKNOWN, DEFAULT TO ZERO) COUNTRY OF CITIZENSHIP EMPLOYMENT: EMPLOYER OCCUPATION (TYPE OF BUSINESS AND POSITION TITLE) EMPLOYER ADDRESS CITY STATE ZIP AFFILIATIONS: PLEASE IDENTIFY ANY AFFILIATION CLIENT HAS WITH A SECURITIES FIRM, EXCHANGE OR AGENCY: IS CLIENT A SENIOR FOREIGN POLITICAL FIGURE OR FAMILY MEMBER OR ASSOCIATE OF A SENIOR FOREIGN POLITICAL FIGURE (DEFAULT= NO ): YES I CERTIFY THAT I HAVE PREPARED AND FILED THE MOST RECENT TAX RETURN FOR THIS CLIENT: YES NO (IF NO, PLEASE SUPPLY ID INFORMATION BELOW) ISSUED PICTURE ID TYPE: ID NO: STATE/COUNTRY OF ISSUANCE: ISSUE DATE: EXPIRATION DATE: SECURITIES OFFERED THROUGH HD VEST INVESTMENT SERVICES SM, MEMBER SIPC ADVISORY SERVICES OFFERED THROUGH HD VEST ADVISORY SERVICES SM, 6333 N. STATE HIGHWAY 161, FOURTH FLOOR, IRVING, TX 75038, (972)

59 Insurance Purchasing/ Exchange Disclosure (IPED) For Variable Annuities IF ANY OF THIS FORM IS LEFT BLANK, THE TRANSACTION WILL NOT BE PROCESSED AND PAPERWORK WILL BE RETURNED TO YOU FOR COMPLETION SAMPLE SECTION 1 - SOURCE OF FUNDS (IF LIQUIDATING MORE THAN ONE INVESTMENT, PLEASE COMPLETE A NEW PAGE FOR EACH INVESTMENT LIQUIDATED) WHAT IS THE SOURCE OF INVESTED FUNDS? (ANNUITY ASSETS LIQUIDATED WITHIN THE LAST 6 MONTHS SHOULD BE CONSIDERED AN EXCHANGE/REPLACEMENT) SECURITIES OTHER THAN VARIABLE ANNUITIES OR INSURANCE CD FULL EXCHANGE OR REPLACEMENT OF ANNUITY/INSURANCE CONTRACT INHERITANCE/GIFTS/ESTATE ASSETS PARTIAL EXCHANGE OR PARTIAL LIQUIDATION OF ANNUITY/INSURANCE CONTRACT EMPLOYER SPONSORED PLAN ROLLOVER (401K, SIMPLE, SEP) Access via HDVLink OTHER - DETAIL SOURCE NAME OF SPECIFIC INVESTMENT EXITED: DATE EXITING PRODUCT WAS ORIGINALLY PURCHASED: IS THE SOURCE OF FUNDS COMING FROM A SALE/LIQUIDATION WHERE YOU WERE THE SELLING AGENT ON THE ORIGINAL PRODUCT? YES NO IF THIS ANNUITY IS FUNDED FROM THE LIQUIDATION OF ANOTHER INVESTMENT PRODUCT THAT IS SUBJECT TO A CDSC, WHAT IS THE SURRENDER CHARGE THAT WILL BE INCURRED? NO SURRENDER CHARGE 0.1%-2.99% % 4% OR MORE SECTION 2 - ANNUITY EXCHANGE AND REPLACEMENT (TO BE COMPLETED IF FULL OR PARTIAL EXCHANGE/REPLACEMENT HAS BEEN CHECKED) MARKET VALUE (PLUS APPLICABLE BONUS): POLICY BEING SURRENDERED $ EXISTING POLICY SURRENDER CHARGES: $ % CASH SURRENDER VALUE (MARKET VALUE LESS SURRENDER CHARGES): $ PROPOSED POLICY $ SURRENDER PERIOD: (PROVIDE ORIGINAL SURRENDER SCHEDULE FOR POLICY BEING EXITED; NOT REMAINING SCHEDULE ON POLICY BEING EXITED) YRS YRS AMOUNT OF DEATH BENEFIT: $ $ TOTAL ANNUAL CHARGES (M&E, ADMIN., AND ADD-ON FEATURES): % % CHECK ALL DEATH BENEFIT OPTIONS THAT APPLY: POLICY BEING SURRENDERED PROPOSED POLICY PREMIUM GUARANTEE DEATH BENEFIT BASE (E.G. STANDARD) STEP-UP TO ACCOUNT VALUE DEATH BENEFIT BASE (E.G. MAV) GUARANTEE STEP-UP DEATH BENEFIT BASE (E.G. 4%, 5%, 6%) EARNINGS ENHANCEMENT DEATH BENEFIT BASE (EEB) NO GUARANTEED DEATH BENEFIT (BENEFICIARIES RECEIVE CONTRACT VALUE WHICH MAY BE LOWER THAN AMOUNT INVESTED) IF THE PROPOSED EXCHANGE/REPLACEMENT WILL RESULT IN A REDUCTION OF THE DEATH BENEFIT, PLEASE EXPLAIN WHY THIS IS SUITABLE: LIST THE GUARANTEED AMOUNTS OF ANY EXISTING LIVING BENEFIT. CHECK ALL LIVING BENEFITS ELECTED IN THE PROPOSED POLICY. POLICY BEING SURRENDERED PROPOSED POLICY GUARANTEED MINIMUM INCOME BENEFIT BASE (GMIB) $ GUARANTEED MINIMUM WITHDRAWAL BENEFIT BASE (GMWB) $ PERCENTAGE OF WITHDRAWAL ALLOWED (GMIB OR GMWB; USE PERCENTAGE ALLOWED FOR TIME PERIOD WHEN CLIENT ANTICIPATES STARTING WITHDRAWAL) % % PRINCIPAL GUARANTEE BASE (GMAB) $ NO INCOME GUARANTEE OTHER: IS THE EXISTING CONTRACT ELIGIBLE FOR ENHANCED RIDERS? YES NO $ $ IF THE PROPOSED EXCHANGE/REPLACEMENT WILL RESULT IN A REDUCTION OF THE LIVING BENEFIT, PLEASE EXPLAIN WHY THIS IS SUITABLE. SECURITIES OFFERED THROUGH HD VEST INVESTMENT SERVICES SM, MEMBER SIPC ADVISORY SERVICES OFFERED THROUGH HD VEST ADVISORY SERVICES SM, 6333 N. STATE HIGHWAY 161, FOURTH FLOOR, IRVING, TX 75038, (972)

60 Insurance Purchasing/ Exchange Disclosure (IPED) For Variable Annuities IF ANY OF THIS FORM IS LEFT BLANK, THE TRANSACTION WILL NOT BE PROCESSED AND PAPERWORK WILL BE RETURNED TO YOU FOR COMPLETION SAMPLE SECTION 3 - PLEASE COMPLETE THE FOLLOWING QUESTIONS REGARDING THE ANNUITY BEING PURCHASED Access via HDVLink NAME OF NEW INVESTMENT BEING PURCHASED: AMOUNT OF INVESTMENT: 1) IS THIS TRANSACTION? AN INITIAL PURCHASE OF A VARIABLE ANNUITY A SUBSEQUENT OR ADD-ON TO AN EXISTING ANNUITY 2) HOW LONG DOES THE CLIENT ANTICIPATE HOLDING THIS ANNUITY CONTRACT? LESS THAN 5 YEARS 5 OR MORE YEARS 3) IS THE INITIAL ALLOCATION OF FUNDS TO THE SUB-ACCOUNT CONSISTENT WITH THE CUSTOMER S STATED INVESTMENT OBJECTIVE? YES NO (PLEASE EXPLAIN) 4) THE CLIENT ANTICIPATES USING THIS ANNUITY INVESTMENT FOR? (PLEASE CHECK ALL THAT APPLY) CURRENT INCOME FUTURE INCOME LUMP SUM PAYMENT PASS TO BENEFICIARY 5) IF THE CLIENT INTENDS TO USE THIS ANNUITY FOR INCOME, WHEN DOES THE CLIENT ANTICIPATE STARTING DISTRIBUTIONS? WITHIN THE 1 ST YEAR BETWEEN 1 AND 5 YEARS BETWEEN 6 AND 10 YEARS MORE THAN 10 YEARS INCOME IS NOT INTENT 6) WHAT ARE THE CLIENT'S CURRENT ANNUAL INCOME NEEDS (IN DOLLARS) THAT ARE REQUIRED FROM THEIR INVESTMENTS ABOVE AND BEYOND PENSION, SOCIAL SECURITY, AND EMPLOYMENT INCOME? $ 7) DOES THE CLIENT HAVE LIFE INSURANCE? YES NO IF YES, WHAT IS THE IN-FORCE DEATH BENEFIT? IF YES, WHAT IS THE CASH VALUE? 8) IF THE OBJECTIVE IS TO OBTAIN A DEATH BENEFIT FOR BENEFICIARIES, HAS LIFE INSURANCE BEEN CONSIDERED AS AN ALTERNATIVE TO THIS ANNUITY? YES NO N/A (DEATH BENEFIT IS NOT PRIMARY OBJECTIVE) IF YES, PLEASE EXPLAIN WHY LIFE INSURANCE WAS NOT SELECTED: 9) WHAT PERCENTAGE OF THE CLIENT S TOTAL LIQUID NET WORTH (SEE PAGE 2) IS BEING USED FOR THIS PURCHASE? 0-25% 26%-50% 51%-60% 61%-75% 76% OR MORE 10) WHAT PERCENTAGE OF THE CLIENT S TOTAL LIQUID NET WORTH WILL BE IN VARIABLE ANNUITIES AFTER THIS PURCHASE? (THIS % INCLUDES ANY PENDING OR IN TRANSIT BUSINESS) (SEE PAGE 2) 0-25% 26%-50% 51%-60% 61%-75% 76% OR MORE 11) BASED ON THE PERCENTAGE SELECTED IN RESPONSE TO QUESTION 10, PLEASE EXPLAIN WHY THE PERCENTAGE OF TOTAL LIQUID NET WORTH INVESTED IN ANNUITIES IS APPROPRIATE GIVEN THE CLIENT S INVESTMENT OBJECTIVES AND LIQUIDITY NEEDS? 12) PLEASE INDICATE THE TOTAL NUMBER OF ANNUITY EXCHANGE/REPLACEMENTS THE CLIENT HAS TRANSACTED WITHIN THE PAST 36 MONTHS. 0 REPLACEMENTS 1 REPLACEMENTS 2 REPLACEMENT 3 REPLACEMENTS 4 OR MORE REPLACEMENTS 13) IF THE CLIENT ANSWERED YES TO 1 OR MORE REPLACEMENTS IN QUESTION 12, IDENTIFY: (PRODUCT NAMES) CONTRACT SURRENDERED CONTRACT SURRENDERED CONTRACT PURCHASED CONTRACT PURCHASED CONTRACT PURCHASED WERE YOU THE ADVISOR ON THE SURRENDERED CONTRACT? WERE YOU THE ADVISOR ON THE SURRENDERED CONTRACT? WERE YOU THE ADVISOR ON THE SURRENDERED CONTRACT? YES NO YES NO CONTRACT SURRENDERED YES NO 14) WHAT TYPE OF DEATH BENEFIT IS BEING PURCHASED ON THIS ANNUITY CONTRACT? PREMIUM GUARANTEE (STANDARD DB) STEP-UP TO ACCOUNT VALUE (I.E. MAV) GUARANTEE STEP-UP (I.E. 4%, 5%, 6%) EARNINGS ENHANCEMENT BENEFIT (EEB) NONE MARKET VALUE/CONTRACT VALUE 15) OTHER THAN TAX DEFERRAL, SELECT THE ANY ADDITIONAL FEATURE / ATTRIBUTE THAT IS THE PRIMARY REASON FOR THIS PURCHASE? (PLEASE SELECT ONE) DEATH BENEFITS LIVING BENEFITS (I.E. GMWB, GMIB, GMAB, ETC.) OTHER:( EXPLAIN) SECURITIES OFFERED THROUGH HD VEST INVESTMENT SERVICES SM, MEMBER SIPC ADVISORY SERVICES OFFERED THROUGH HD VEST ADVISORY SERVICES SM, 6333 N. STATE HIGHWAY 161, FOURTH FLOOR, IRVING, TX 75038, (972)

61 Insurance Purchasing/ Exchange Disclosure (IPED) For Variable Annuities IF ANY OF THIS FORM IS LEFT BLANK, THE TRANSACTION WILL NOT BE PROCESSED AND PAPERWORK WILL BE RETURNED TO YOU FOR COMPLETION SAMPLE SECTION 3 QUESTIONS REGARDING THE ANNUITY BEING PURCHASED CONTINUED 16) EXPLAIN HOW THE PROPOSED ANNUITY AND ANY RIDERS ARE CONSISTENT WITH THE CLIENT S AGE, INVESTMENT TIME HORIZON AND NEEDS/OBJECTIVES, TAKING INTO ACCOUNT SURRENDER PERIODS, AGE RESTRICTIONS, OR WAITING PERIODS BEFORE LIFETIME BENEFITS CAN BE EXERCISED, AND ANY OTHER MATERIAL FEATURES OF THE ANNUITY: Access via HDVLink 17) IF THIS IS AN EXCHANGE/REPLACEMENT, PLEASE EXPLAIN WHY THE EXISTING CONTRACT CANNOT MEET THE CLIENT S NEEDS/OBJECTIVES: 18) DESCRIBE THE CLIENT S CURRENT AND ANTICIPATED LIQUIDITY NEEDS AND EXPLAIN HOW THE PROPOSED ANNUITY IS CONSISTENT WITH THOSE NEEDS: 19) IF THE CLIENT S GROSS HOUSEHOLD INCOME IS LESS THAN $25,000 AND/OR THE TOTAL LIQUID NET WORTH OF THE HOUSEHOLD IS LESS THAN $50,000, PLEASE EXPLAIN HOW THE PURCHASE OF THIS ANNUITY IS FINANCIALLY SUITABLE(SEE FIGURES ON PAGE 2): 20) TO ASSIST IN THE PROMPT REVIEW AND APPROVAL OF THIS TRANSACTION, PLEASE PROVIDE ANY ADDITIONAL INFORMATION YOU CONSIDERED IN DETERMINING THAT THE ANNUITY IS APPROPRIATE FOR THE CLIENT: SECURITIES OFFERED THROUGH HD VEST INVESTMENT SERVICES SM, MEMBER SIPC ADVISORY SERVICES OFFERED THROUGH HD VEST ADVISORY SERVICES SM, 6333 N. STATE HIGHWAY 161, FOURTH FLOOR, IRVING, TX 75038, (972)

62 Insurance Purchasing/ Exchange Disclosure (IPED) For Variable Annuities IF ANY OF THIS FORM IS LEFT BLANK, THE TRANSACTION WILL NOT BE PROCESSED AND PAPERWORK WILL BE RETURNED TO YOU FOR COMPLETION SAMPLE Access via HDVLink SECTION 4 FEES AND EXPENSES FEES AND EXPENSES - FOR A VARIABLE ANNUITY, CONSIDER ANY CHARGES AND FEES, INCLUDING MORTALITY AND EXPENSE CHARGES, ADMINISTRATIVE CHARGES, AND INVESTMENT MANAGEMENT FEES AND APPLICABLE 12B-1 FEES FOR THE PORTFOLIO OPTIONS. IF YOU HAVE SELECTED A RIDER, OR OPTIONAL FEATURE, THERE MAY BE AN ADDITIONAL COST. VARIABLE ANNUITY CONTRACTS ARE GENERALLY AVAILABLE IN FOUR SHARE CLASSES: SHARE CLASS TYPICAL M&E/A/D 1 AVERAGE CDSC B BONUS L C 1.10% % 1.40% % 1.60% % 1.65% % 7 YEARS 9 YEARS 4 YEARS NONE 1 M&E/A/D IS A TOTAL OF THE MORTALITY AND EXPENSE FEE, ADMINISTRATIVE FEE, AND DISTRIBUTION FEE. a. CLASS B SHARE ANNUITIES TYPICALLY DO NOT CONTAIN A FRONT-END SALES CHARGE IN MOST CASES. THIS TYPE OF ANNUITY WILL HOWEVER CONTAIN A CONTINGENT-DEFERRED SALES CHARGE ( SURRENDER CHARGE ) IF A PARTIAL OR FULL SURRENDER OF THE ANNUITY IS TAKEN WITHIN THE DEFINED SURRENDER PERIOD. b. C/L SHARE - WHEN PURCHASING AN OPTIONAL RIDER, YOU SHOULD CONSIDER THE LONG TERM NATURE OF THE RIDER WHEN DECIDING WHETHER OR NOT YOU WANT TO PAY AN ADDITIONAL COST FOR A SHORTER CDSC. c. BONUS SHARE - INCLUDES A PREMIUM BONUS THAT IS ADDED TO YOUR CONTRACT VALUE. YOU SHOULD CONSIDER WHETHER OR NOT THE BONUS RECEIVED OUTWEIGHS THE ADDITIONAL COSTS OF THE PRODUCT. SELECT THE SHARE CLASS BEING PURCHASED: CLASS B SHARE CLASS BONUS SHARE CLASS L SHARE CLASS C SHARE PLEASE EXPLAIN HOW THE SHARE CLASS BEING PURCHASED MEETS THE CLIENT S NEEDS AND OBJECTIVES: PLEASE INDICATE THE M&E/A/D 1 COST = % 1 + RIDER NAME COST = % 2 + RIDER NAME COST = % 3 = TOTAL ADD LINES 1-3 COST = % THE CONTINGENT DEFERRED SALES CHARGE IS IN EFFECT FOR: YEARS A CONTINGENT DEFERRED SALES CHARGE ( SURRENDER CHARGE ) IS A FEE PAID BY YOU WHEN YOU LIQUIDATE A CONTRACT (OR MAKES A PARTIAL WITHDRAWAL IN EXCESS OF A SPECIFIED AMOUNT) DURING THE SURRENDER-CHARGE PERIOD. THE SURRENDER CHARGE IS GENERALLY A PERCENTAGE OF THE AMOUNT WITHDRAWN AND MAY DECLINE GRADUALLY DURING THE SURRENDER PERIOD. DEPENDING ON THE INSURANCE COMPANY, THIS FEE MAY ALSO BE CALLED AN EXIT FEE OR A REDEMPTION CHARGE. SECURITIES OFFERED THROUGH HD VEST INVESTMENT SERVICES SM, MEMBER SIPC ADVISORY SERVICES OFFERED THROUGH HD VEST ADVISORY SERVICES SM, 6333 N. STATE HIGHWAY 161, FOURTH FLOOR, IRVING, TX 75038, (972)

63 Insurance Purchasing/ Exchange Disclosure (IPED) For Variable Annuities IF ANY OF THIS FORM IS LEFT BLANK, THE TRANSACTION WILL NOT BE PROCESSED AND PAPERWORK WILL BE RETURNED TO YOU FOR COMPLETION SAMPLE Access via HDVLink ADDITIONAL PRODUCT SPECIFIC VARIABLE ANNUITY DISCLOSURE ADDENDUMS INDEX LINKED VARIABLE ANNUITIES CLIENT SIGNATURE REQUIRED IF PURCHASING ONE OF THE FOLLOWING PRODUCTS: AXA STRUCTURED CAPITAL STRATEGIES METLIFE SHIELD LEVEL SELECTOR ALLIANZ INDEX ADVANTAGE PLEASE REFER TO THE PRODUCT PROSPECTUS FOR CONTRACT TERMS AND CONDITIONS. THE PROSPECTUS CONTAINS IMPORTANT INFORMATION ABOUT CONTRACT FEATURES AND RISK FACTORS YOU SHOULD CONSIDER BEFORE INVESTING. IN CONSIDERING AN INVESTMENT IN AN INDEXED LINKED VARIABLE ANNUITY YOU SHOULD CONSIDER YOUR INDIVIDUAL FINANCIAL CONDITION AND RISK TOLERANCE. YOU MAY LOSE MONEY INVESTING IN THE INDEX LINKED OPTIONS. THE EXISTENCE AND TERMS OF THE INDEX LINKED OPTIONS AND THE LIMITATIONS ON THE GAINS AND LOSSES, AMONG OTHER THINGS, DIFFERENTIATE THE INDEX LINKED VARIABLE ANNUITY FROM THE RISK AND FEATURES OF OTHER VARIABLE ANNUITY SUB ACCOUNTS. EACH INDEXED LINKED VARIABLE ANNUITY IS A COMBINATION OF A LEVEL OF PROTECTION, INDEX, TERM AND CAP ON GAINS. PLEASE SEE PROSPECTUS FOR MORE SPECIFIC INFORMATION. INDEX LINKED OPTIONS ARE GENERALLY INTENDED TO BE HELD FOR THE ENTIRE LENGTH OF INDEX TERM PERIOD. IF YOU DIE, MAKE WITHDRAWALS, OR SURRENDER YOUR CONTRACT BEFORE THE INDEX TERM, YOU MAY ONLY RECEIVE THE INTERIM VALUE WHICH MAY BE LESS THAN THE AMOUNT RECEIVED IF THE INDEX OPTION WAS HELD TO MATURITY AND YOU WILL FORFEIT SOME OR ALL OF YOUR DOWNSIDE PROTECTION. YOU SHOULD CAREFULLY CONSIDER THIS RISK IF YOU ANTICIPATE MAKING WITHDRAWALS BEFORE THE INDEX MATURITY. INDEXED LINKED VARIABLE ANNUITIES MAY NOT CONTAIN A GUARANTEED DEATH BENEFIT. IF A GUARANTEED DEATH BENEFIT IS NOT AVAILABLE, BENEFICIARIES MAY ONLY RECEIVE THE CONTRACT VALUE, WHICH MAY BE LESS THAN THE AMOUNT INVESTED. INDEXED LINKED VARIABLE ANNUITIES OFFER NO GUARANTEED LIVING OR WITHDRAWAL BENEFIT. THE CONTRACT MAY LOSE VALUE AND YOU ARE NOT GUARANTEED TO RECEIVE BACK THE AMOUNT YOU INVESTED. THE INSURANCE CARRIER RESERVES THE RIGHT TO REMOVE CERTAIN INDEX OPTIONS IN THE FUTURE THEREFORE LIMITING YOU TO INVESTING IN THE REMAINING INDEX OPTIONS. YOU MAY NOT BE ABLE TO TRANSFER OUT OF AN INDEX OPTION UNTIL THE END OF THE TERM. ONCE THE TERM MATURES YOU WILL NEED TO SELECT A NEW INDEX OPTION, OTHERWISE YOU WILL AUTOMATICALLY BE ALLOCATED TO A DEFAULT INDEX OPTION. THEREFORE YOU MUST MONITOR THE CONTRACT TO ENSURE YOUR INDEX OPTIONS AND TERMS CONTINUE TO BE CONSISTENT WITH YOUR INVESTMENT GOALS. THE INDEX LINKED VARIABLE ANNUITY DOES NOT INVOLVE AN INVESTMENT IN ANY UNDERLYING PORTFOLIO. INSTEAD, IT IS AN OBLIGATION OF AND SUBJECT TO THE CLAIMS PAYING ABILITY OF THE INSURANCE CARRIER. I HAVE READ AND UNDERSTAND THE ABOVE PRODUCT DISCLOSURES: CLIENT SIGNATURE: INVESTMENT ONLY VARIABLE ANNUITIES CLIENT SIGNATURE REQUIRED IF PURCHASING ONE OF THE FOLLOWING PRODUCTS: JACKSON NATIONAL ELITE ACCESS AXA INVESTMENT EDGE LINCOLN FINANCIAL INVESTOR ADVANTAGE PLEASE REFER TO THE PRODUCT PROSPECTUS FOR CONTRACT TERMS AND CONDITIONS. THE PROSPECTUS CONTAINS IMPORTANT INFORMATION ABOUT CONTRACT FEATURES AND RISK FACTORS YOU SHOULD CONSIDER BEFORE INVESTING. INVESTMENT ONLY VARIABLE ANNUITIES MAY CONTAIN NO GUARANTEED DEATH BENEFIT. IF NO GUARANTEED DEATH BENEFIT IS AVAILABLE, BENEFICIARIES WILL RECEIVE THE CONTRACT VALUE, WHICH MAY BE LESS THAN THE AMOUNT INVESTED. INVESTMENT ONLY VARIABLE ANNUITIES MAY NOT OFFER GUARANTEED LIVING BENEFITS. THE CONTRACT MAY LOSE VALUE AND YOU ARE NOT GUARANTEED TO RECEIVE BACK THE VALUE YOU INVESTED. INVESTMENT ONLY VARIABLE ANNUITIES MAY CONTAIN ALTERNATIVE INVESTMENT OPTIONS WHICH HAVE DIFFERENT RISK THAN OTHER TRADITIONAL EQUITY AND FIXED INCOME VARIABLE OPTIONS. IN CONSIDERING THIS INVESTMENT YOU SHOULD CONSIDER YOUR INDIVIDUAL FINANCIAL CONDITION AND RISK TOLERANCE. I HAVE READ AND UNDERSTAND THE ABOVE PRODUCT DISCLOSURES: CLIENT SIGNATURE: SECURITIES OFFERED THROUGH HD VEST INVESTMENT SERVICES SM, MEMBER SIPC ADVISORY SERVICES OFFERED THROUGH HD VEST ADVISORY SERVICES SM, 6333 N. STATE HIGHWAY 161, FOURTH FLOOR, IRVING, TX 75038, (972)

64 Insurance Purchasing/ Exchange Disclosure (IPED) For Variable Annuities IF ANY OF THIS FORM IS LEFT BLANK, THE TRANSACTION WILL NOT BE PROCESSED AND PAPERWORK WILL BE RETURNED TO YOU FOR COMPLETION SAMPLE CLIENT ACKNOWLEDGEMENT SURRENDER I UNDERSTAND THAT IF I CHANGE MY MIND REGARDING THIS PURCHASE I MAY CANCEL THE CONTRACT WITHIN A PREDETERMINED PERIOD OF TIME AS PROVIDED FOR BY THE FREE LOOK PROVISION SPECIFIED IN THE PROSPECTUS, WHICH ALLOWS ME TO SURRENDER THE CONTRACT FOR ANY REASON WITHOUT INCURRING ANY CHARGES (ACCOUNT VALUE MAY FLUCTUATE IF PROCEEDS ARE INVESTED DURING FREE LOOK PERIOD). I UNDERSTAND THAT SHOULD I SURRENDER MY CONTRACT, THE RIDERS I HAVE PURCHASED WILL BE FORFEITED AND I WILL ONLY BE ABLE TO REDEEM OR TRANSFER THE SURRENDER CONTRACT VALUE. I UNDERSTAND THAT IF THIS PRODUCT HAS A SURRENDER CHARGE, I WILL PAY THAT CHARGE DURING THE SURRENDER PERIOD ON ANY WITHDRAWALS IN EXCESS OF PERMITTED AMOUNTS. Access via HDVLink WITHDRAWALS I UNDERSTAND THAT, UNDER CURRENT TAX LAWS, WITHDRAWALS FROM MY INVESTMENT MADE PRIOR TO AGE 59½ GENERALLY ARE SUBJECT TO ORDINARY INCOME TAXES AND A 10% IRS TAX PENALTY. I UNDERSTAND NON-ANNUITIZED WITHDRAWALS FROM VARIABLE ANNUITIES PURCHASED AFTER AUGUST 1982 ARE TAXED AS EARNINGS FIRST, PRINCIPAL LAST (LAST IN FIRST OUT OR LIFO ), AND THAT WHEN I WITHDRAW MY EARNINGS THEY WILL BE TAXED AS ORDINARY INCOME. I UNDERSTAND THAT TAKING WITHDRAWALS FROM THIS PRODUCT MAY DECREASE THE AMOUNT OF GUARANTEED INCOME RECEIVED AND/OR LOWER THE GUARANTEED INCOME OR DEATH BENEFIT AMOUNT I WOULD BE ELIGIBLE TO RECEIVE. GENERAL I HAVE RECEIVED A PROSPECTUS FOR THE PRODUCT BEING PURCHASED AND HAVE HAD AMPLE OPPORTUNITY TO REVIEW THE INFORMATION IN THE PROSPECTUS. I HAVE DETERMINED THAT MY INVESTMENT PORTFOLIO SHOULD INCLUDE THIS PRODUCT. I HAVE DETERMINED THAT THIS INVESTMENT IS CONSISTENT WITH MY RISK TOLERANCE AND OVERALL INVESTMENT STRATEGY. I HAVE BEEN INFORMED THAT ANY GUARANTEES ASSOCIATED WITH THIS PRODUCT ARE SUBJECT TO THE ONGOING CLAIMS PAYING ABILITY OF THE ISSUER. I UNDERSTAND THAT IF I ELECT TO PURCHASE A RIDER, THE EXPENSES WILL BE CHARGED AS LONG AS I HOLD THE CONTRACT AND MAY INCREASE AFTER ISSUE. THE PROSPECTUS CONTAINS DETAILED INFORMATION ABOUT RIDERS. IF REQUESTING A 1035 EXCHANGE, I HAVE BEEN SHOWN A COMPARISON IN SECTION 2 ABOVE OF THE FEES AND EXPENSES BETWEEN THE PRODUCT BEING SURRENDERED AND THE PRODUCT BEING PURCHASED. I HAVE BEEN INFORMED OF ANY APPLICABLE FEES AND EXPENSES ASSOCIATED WITH THIS PRODUCT. I HAVE DETERMINED THAT THE COSTS ASSOCIATED WITH THIS PRODUCT ARE ACCEPTABLE GIVEN MY INVESTMENT OBJECTIVES. I HAVE BEEN GIVEN THE OPPORTUNITY TO ASK QUESTIONS AND RECEIVE ANSWERS CONCERNING THE TERMS AND CONDITIONS OF THIS INVESTMENT AND HAVE RECEIVED ANY ADDITIONAL INFORMATION I DEEM NECESSARY TO EVALUATE MY INVESTMENT. I UNDERSTAND THAT THE GAINS IN THIS PRODUCT GROW TAX-DEFERRED, AND THAT IF THIS PRODUCT IS PLACED IN A QUALIFIED RETIREMENT ACCOUNT, I WOULD NOT GAIN ANY ADDITIONAL TAX-DEFERRAL ADVANTAGES. I UNDERSTAND THAT HD VEST INVESTMENT SERVICES SM DOES NOT PROVIDE TAX ADVICE AND I SHOULD CONSULT MY TAX ADVISOR REGARDING ANY TAX-RELATED MATTERS. I UNDERSTAND THAT MY ADVISOR AND HD VEST INVESTMENT SECURITIES, INC. WILL BE COMPENSATED FOR THE SALE OF THIS PRODUCT AND THAT SPECIFIC INFORMATION ABOUT HD VEST S COMPENSATION IS AVAILABLE IN THE PROSPECTUS OR BY ASKING MY ADVISOR. I UNDERSTAND THAT IF I HAVE ANY QUESTIONS ABOUT THE INFORMATION CONTAINED IN THIS DOCUMENT, AND I WOULD LIKE TO SPEAK WITH SOMEONE AT THE HD VEST HOME OFFICE, I CAN CONTACT THE SALES SUPERVISION DEPARTMENT AT (800) , X4721. UNLESS I REQUEST OTHERWISE, MY HD VEST ADVISOR MAY BE NOTIFIED AND/OR GIVEN THE OPPORTUNITY TO PARTICIPATE IN THE CONVERSATION. I AGREE THAT THIS AGREEMENT SHALL BE GOVERNED BY THE LAWS OF THE STATE OF TEXAS WITHOUT REGARD TO ITS CONFLICT OF THE LAW S PROVISIONS AND SHALL INURE TO THE BENEFIT OF MY AND HD VEST INVESTMENT SECURITIES, INC. S RESPECTIVE SUCCESSORS AND ASSIGNS, AND SHALL BE BINDING ON ME AND MY REPRESENTATIVES, ATTORNEYS-IN-FACT, HEIRS, EXECUTORS, ADMINISTRATORS, AND ASSIGNS. HDVEST CLIENT PRE-DISPUTE ARBITRATION AGREEMENT THIS AGREEMENT CONTAINS A PRE-DISPUTE ARBITRATION CLAUSE. BY SIGNING AN ARBITRATION AGREEMENT THE PARTIES AGREE AS FOLLOWS: (i.) ALL PARTIES TO THIS AGREEMENT ARE GIVING UP THE RIGHT TO SUE EACH OTHER IN COURT, INCLUDING THE RIGHT TO A TRIAL BY JURY, EXCEPT AS PROVIDED BY THE RULES OF THE ARBITRATION FORUM IN WHICH A CLAIM IS FILED. (ii.) ARBITRATION AWARDS ARE GENERALLY FINAL AND BINDING; A PARTY S ABILITY TO HAVE A COURT REVERSE OR MODIFY ARBITRATION AWARD IS VERY LIMITED. (iii.) THE ABILITY OFTHE PARTIES TO OBTAIN DOCUMENTS, WITNESS STATEMENTS AND OTHER DISCOVERY IS GENERALLY MORE LIMITED IN ARBITRATION THAN IN COURT PROCEEDINGS. (iv.) THE ARBITRATORS DO NOT HAVE TO EXPLAIN THE REASON(S) FOR THEIR AWARD UNLESS, IN AN ELIGIBLE CASE, A JOINT REQUST FOR AN EXPLIANED DECISION HAS BEEN SUBMITTED BY ALL PARTIES TO THE PANEL AT LEAST 20 DAYS PRIOR TO THE FIRST SCHEDULED HEARING DATE. (v.) (vi.) (vii.) THE PANEL OF ARBITRATORS WILL TYPICALLY INCLUDE A MINORITY OF ARBITRATORS WHO WERE OR ARE AFFILIATED WITH THE SECURITIES INDUSTRY. THE RULES OF SOME ARBITRATION FORUMS MAY IMPOSE TIME LIMITS FOR BRINGING A CLAIM IN ARBITRATION. IN SOME CASES, A CLAIM THAT IS INELIGIBLE FOR ARBITRATION MAY BE BROUGHT IN COURT. THE RULES OFTHE ARBITRATION FORUM IN WHICH THE CLAIM IS FILED, AND ANY AMENDMENTS THERETO, SHALL BE INCORPORATED INTO THIS AGREEMENT. NO PERSON SHALL BRING A PUTATIVE OR CERTIFIED CLASS ACTION TO ARBITRATION, NOR SEEK TO ENFORCE ANY PRE-DISPUTE ARBITRATION AGREEMENT AGAINST ANY PERSON WHO HAS INITIATED IN COURT A PUTATIVE CLASS ACTION; OR WHO IS A MEMBER OF A PUTATIVE CLASS WHO HAS NOT OPTED OUT OF THE CLASS WITH RESPECT TO ANY CLAIMS ENCOMPASSED BY THE PUTATIVE CLASS ACTION UNTIL: (i) (ii) (iii) THE CLASS CERTIFICATION IS DENIED; OR THE CLASS IS DECERTIFIED; OR THE CLIENT IS EXCLUDED FROM THE CLASS BY THE COURT. SUCH FORBEARANCE TO ENFORCE AN AGREEMENT TO ARBITRATE SHALL NOT CONSTITUTE A WAIVER OF ANY RIGHTS UNDER THIS AGREEMENT EXCEPT TO THE EXTENT STATED HEREIN. SECURITIES OFFERED THROUGH HD VEST INVESTMENT SERVICES SM, MEMBER SIPC ADVISORY SERVICES OFFERED THROUGH HD VEST ADVISORY SERVICES SM, 6333 N. STATE HIGHWAY 161, FOURTH FLOOR, IRVING, TX 75038, (972)

65 Insurance Purchasing/ Exchange Disclosure (IPED) For Variable Annuities IF ANY OF THIS FORM IS LEFT BLANK, THE TRANSACTION WILL NOT BE PROCESSED AND PAPERWORK WILL BE RETURNED TO YOU FOR COMPLETION SAMPLE YOU AGREE THAT ALL CLAIMS, CONTROVERSIES AND OTHER DISPUTES BETWEEN YOU AND HD VEST INVESTMENT SERVICES AND ITS AFFILIATED ENTITIES, INCLUDING HD VEST INSURANCE AGENCY, LLC (COLLECTIVELY REFERRED TO AS HD VEST ) AND ANY OF THEIR DIRECTORS, OFFICERS, EMPLOYEES, REGISTERED REPRESENTATIVES OR AGENTS ARISING OUT OF OR RELATING TO THIS AGREEMENT OR ANY ORDERS Access OR via TRANSACTIONS HDVLink THEREIN OR THE CONTINUATION, PERFORMANCE OR BREACH ANY AGREEMENT BETWEEN YOU AND HD VEST, WHETHER ENTERED INTO BEFORE, ON, OR AFTER THE DATE THIS ACCOUNT IS OPENED, SHALL BE DETERMINED BY ARBITRATION CONDUCTED BY, AND SUBJECT TO THE ARBITRATION RULES THEN IN EFFECT OF, FINRA. IF FINRA DECLINES JURISDICTION, THEN YOU AGREE TO HAVE THE ARBITRATION CONDUCTED BY AND SUBJECT TO THE RULES THEN IN EFFECT OF THE AMERICAN ARBITRATION ASSOCIATION. THIS AGREEMENT TO ARBITRATE SHALL BE SPECIFICALLY ENFORCEABLE UNDER PREVAILING LAW AND PROCEDURES. ALL FEDERAL AND STATE STATUTES OF LIMITATION, DOCTRINES OF REPOSE AND TIME BARS SHALL APPLY TO ANY ARBITRATION PROCEEDING, AND NOTHING IN THIS AGREEMENT SHALL BE DEEMED TO LIMIT OR WAIVE THE APPLICATION OF ANY SUCH STATUTE OR DOCTRINE. THE AWARD RENDERED BY THE ARBITRATORS SHALL BE FINAL, AND JUDGMENT MAY BE ENTERED UPON IT IN ANY COURT HAVING JURSIDICTION OVER THE PARTIES. COUNSEL CAN ADVISE YOU ON HOW THIS PROVISION MAY AFFECT YOU. TO HELP THE GOVERNMENT FIGHT THE FUNDING OF TERRORISM AND MONEY-LAUNDERING ACTIVTIES, U.S. FEDERAL LAW REQUIRES FINANCIAL INSTITUTIONS TO OBTAIN, VERIFY, AND RECORD INFORMATION THAT IDENTIFIES EACH PERSON (INDIVIDUALS AND BUSINESSES) WHO OPENS AN ACCOUNT. WHAT THIS MEANS FOR YOU: WHEN YOU OPEN AN ACCOUNT, WE WILL ASK FOR YOUR NAME, ADDRESS, DATE OF BIRTH, AND OTHER INFORMATION THAT WILL ALLOW US TO IDENTIFY YOU. WE MAY ALSO ASK FOR YOUR DRIVER S LICENSE OR OTHER IDENTIFYING DOCUMENTS. THE HD VEST AFFILIATED COMPANIES EXCLUSIVELY PROVIDE FINANCIAL PRODUCTS AND SERVICES, AND DO NOT PROVIDE TAX OR ACCOUNTING SERVICES. ADVISORS MAY PROVIDE TAX, ACCOUNTING OR OTHER SERVICES THROUGH THEIR INDEPENDENT OUTSIDE BUSINESSES, BUT THESE SERVICES ARE SEPARATE AND APART FROM, AND ARE NOT SUPERVISED BY, HD VEST. ALL PAYMENTS FOR THE PURCHASE OF ANNUITIES SHOULD BE MADE BY CHECK OR ACH TRANSFER PAYABLE TO THE INSURANCE COMPANY, NOT TO AN HD VEST ADVISOR OR HIS/HER INDEPENDENT COMPANY. WHEN YOU PURCHASE AN ANNUITY THOROUGH HD VEST YOU WILL RECEIVE PERIODIC ACCOUNT STATEMENTS REFERENCING HD VEST DIRECTLY FROM THE INSURANCE COMPANY. IF YOU BELIEVE YOU MADE AN INVESTMENT THROUGH HD VEST BUT DID NOT RECEIVE A CONFIRMATION OR STATEMENTS, PLEASE CALL US TOLL-FREE AT (866) , OPTION 2. I/WE ACKNOWLEDGE REVIEW AND APPROVAL OF ALL OF THE INFORMATION CONTAINED ON ALL 9 PAGES OF THIS INSURANCE PURCHASING/EXCHANGE DISCLOSURE (IPED) FOR VARIABLE ANNUITIES DOCUMENT, INCLUDING MY FINANCIAL INFORMATION INCLUDED ON PAGE 2. THIS AGREEMENT CONTAINS A PRE-DISPUTE ARBITRATIONCLAUSE,WHICHBEGINS ON THE PREVIOUS PAGE. I/WE ACKNOWLEDGE RECEIVING A COPY OF THIS AGREEMENT, INCLUDING THE HD VEST PRE-DISPUTE ARBITRATION CLAUSE. CLIENT SIGNATURE: DATE: CLIENT SIGNATURE (JOINT OWNER): DATE: SECURITIES OFFERED THROUGH HD VEST INVESTMENT SERVICES SM,MEMBER SIPC ADVISORY SERVICES OFFERED THROUGH HD VEST ADVISORY SERVICES SM, 6333 N. STATE HIGHWAY 161, FOURTH FLOOR,IRVING, TX 75038, (972)

66 Insurance Purchasing/ Exchange Disclosure (IPED) For Variable Annuities IF ANY OF THIS FORM IS LEFT BLANK, THE TRANSACTION WILL NOT BE PROCESSED AND PAPERWORK WILL BE RETURNED TO YOU FOR COMPLETION ADVISOR USE ONLY SAMPLE Access via HDVLink BY SIGNING BELOW, I ATTEST THAT: 1. I HAVE THE PROPER INSURANCE LICENSE/APPOINTMENTS (3 STATE RULE). 2. I HAVE THE PROPER SECURITIES LICENSING (3 STATE RULE). 3. I HAVE COMPLETED THE REQUIRED TRAINING FOR THE ANNUITY PRODUCT BEING SOLD. 4. I VERIFY THAT THE APPLICATION IS COMPLETE (INCLUDING PRODUCT NAME, SUBACCOUNTS, RIDERS, SIGNATURES, ETC.). 5. I VERIFY THAT IF THE FUNDS ARE COMING FROM THE LIQUIDATION OF ANOTHER PRODUCT AND THERE IS A CDSC OF 3% OR MORE THAT PROPER DOCUMENTATION HAS BEEN PROVIDED EXPLAINING WHY THIS IS APPROPRIATE. 6. I VERIFY THAT IF THE CLIENT PURCHASING THIS ANNUITY IS EITHER 65 OR OLDER OR YOUNGER THAN 46 THAT PROPER DOCUMENTATION HAS BEEN PROVIDED EXPLAINING WHY THIS IS APPROPRIATE. 7. I VERIFY THAT IF THE CLIENT HAS INCOME LESS THAN $25,000 OR A LNW UNDER $50,000 THAT PROPER DOCUMENTATION HAS BEEN PROVIDED EXPLAINING WHY THIS IS APPROPRIATE (SEE QUESTION 20 ON PAGE 5). 8. I VERIFY THAT IF THE CLIENT HAS A TIME HORIZON OF LESS THAN 5 YEARS THAT PROPER DOCUMENTATION HAS BEEN PROVIDED EXPLAINING WHY THIS IS APPROPRIATE. 9. I VERIFY THAT THE SUBACCOUNT ALLOCATIONS MATCH THE INVESTMENT OBJECTIVES OF THE CLIENT AND THAT THE SUBACCOUNT ALLOCATION IS NOT 100% INTO THE MONEY MARKET OR THAT PROPER DOCUMENTATION HAS BEEN PROVIDED EXPLAINING WHY THIS IS APPROPRIATE. 10. I VERIFY THAT THE CLIENT DOES NOT HAVE AN OVER CONCENTRATION IN ANNUITIES OR THAT PROPER DOCUMENTATION HAS BEEN PROVIDED EXPLAINING WHY THIS IS APPROPRIATE. 11. I VERIFY THAT IF THE CLIENT IS DOING AN EXCHANGE/REPLACEMENT THAT PROPER DOCUMENTATION HAS BEEN PROVIDED EXPLAINING WHY THIS IS APPROPRIATE. 12. I VERIFY THAT THE IPED FORM IS COMPLETE INCLUDING SIGNATURE AND DATE SIGNED. 13. I VERIFY THAT FOR THE PRODUCT SPECIFIC ANNUITIES LISTED ON PAGE 7 THAT THE ACKNOWLEDGEMENT HAS BEEN SIGNED ON PAGE 7 FOR THAT PRODUCT. 14. I VERIFY THAT FOR THE PRODUCT SPECIFIC ANNUITIES LISTED ON PAGE 7 THAT THE CLIENT HAS 25% OR LESS OF THEIR LNW INVESTED IN THIS PRODUCT AND LESS THAN 50% OF THEIR LNW IN THESE OR SIMILAR NON TRADITIONAL ANNUITIES. 15. I VERIFY THAT I HAVE COMPLETED THE REQUIRED TRAINING FOR THE PRODUCT SPECIFIC ANNUITIES LISTED ON PAGE 7. I HAVE A REASONABLE BASIS TO BELIEVE THE PURCHASE OF THIS ANNUITY IS SUITABLE AND THE CUSTOMER HAS BEEN INFORMED OF ALL MATERIAL FACTS AND EXPENSES, INCLUDING BUT NOT LIMITED TO: THE POTENTIAL SURRENDER PERIOD AND SURRENDER CHARGE; POTENTIAL TAX PENALTY IF THEY SELL OR REDEEM THIS ANNUITY BEFORE REACHING THE AGE OF 59½; MORTALITY AND EXPENSE FEES; INVESTMENT ADVISORY FEES; POTENTIAL CHARGES FOR AND FEATURES OF RIDERS; THE INSURANCE AND INVESTMENT COMPONENTS OF ANNUITIES; AND MARKET RISK. ADVISOR SIGNATURE: DATE: ADVISOR NAME (PRINTED): ADVISOR NUMBER: SECURITIES OFFERED THROUGH HD VEST INVESTMENT SERVICES SM, MEMBER SIPC ADVISORY SERVICES OFFERED THROUGH HD VEST ADVISORY SERVICES SM, 6333 N. STATE HIGHWAY 161, FOURTH FLOOR, IRVING, TX 75038, (972)

67 Insurance Purchasing/ Exchange Disclosure (IPED) For Variable Annuities IF ANY OF THIS FORM IS LEFT BLANK, THE TRANSACTION WILL NOT BE PROCESSED AND PAPERWORK WILL BE RETURNED TO YOU FOR COMPLETION SAMPLE INTERNAL USE ONLY APPROVE REJECT REASON FOR REJECTION : 1. I HAVE VERIFIED THAT THE APPLICATION IS COMPLETE (INCLUDING PRODUCT NAME, SUBACCOUNTS, RIDERS, YES SIGNATURES, ETC.). Access via HDVLink 2. I HAVE VERIFIED THAT THE IPED FORM IS COMPLETE INCLUDING SIGNATURE AND DATE SIGNED. YES 3. IS THE PRODUCT BEING EXITED HAVE A CDSC GREATER THAN 3%? YES NO 4. IS THE CLIENT PURCHASING THIS ANNUITY AGE 65 AND OLDER OR YOUNGER THAN 46? YES NO 5. DOES THE CLIENT HAVE INCOME LESS THAN $25,000 OR A LNW UNDER $50,000? YES NO 6. DOES THE CLIENT HAVE A TIME HORIZON OF LESS THAN 5 YEARS? YES NO 7. DOES THE SUBACCOUNT ALLOCATION MATCH THE INVESTMENT OBJECTIVE? YES NO 8. IS THE SUBACCOUNT ALLOCATION 100% INVESTED IN THE MONEY MARKET? YES NO 9. DOES THE CLIENT HAVE MORE THAN 50% OF LNW INVESTED IN ANNUITIES? YES NO 10. FOR EXCHANGE/REPLACEMENTS, IS THE CLIENT LOSING OR REDUCING ANY BENEFITS TO EXIT THEIR CURRENT POLICY? 11. FOR PRODUCT SPECIFIC ANNUITIES LISTED ON PAGE 7 HAS THE ACKNOWLEDGEMENT BEEN SIGNED ON PAGE 7 FOR THAT PRODUCT? (IF APPLICABLE). 12. I HAVE VERIFIED THAT FOR PRODUCT SPECIFIC ANNUITIES LISTED ON PAGE 7 THAT THE CLIENT HAS 25% OR LESS OF THEIR LNW INVESTED IN THE PRODUCT AND LESS THAN 50% OF THEIR LNW IN CERTAIN NON TRADITIONAL ANNUITIES. (IF APPLICABLE). 13. I HAVE VERIFIED THAT THE ADVISOR HAS COMPLETED THE REQUIRED TRAINING FOR THE PRODUCT SPECIFIC ANNUITIES LISTED ON PAGE 7 (IF APPLICABLE). YES YES YES YES IN APPROVING THIS DEFERRED ANNUITY PURCHASE, I HAVE A REASONABLE BASIS TO BELIEVE THAT THIS TRANSACTION IS SUITABLE IN ACCORDANCE WITH FINRA S GENERAL SUITABILITY RULE AND MEETS THE GUIDELINES SET FORTH IN FINRA RULE SALES SUPERVISOR: NO NO NO NO SALES SUPERVISOR SIGNATURE: SUPERVISOR NOTES: DATE: SECURITIES OFFERED THROUGH HD VEST INVESTMENT SERVICES SM, MEMBER SIPC ADVISORY SERVICES OFFERED THROUGH HD VEST ADVISORY SERVICES SM, 6333 N. STATE HIGHWAY 161, FOURTH FLOOR, IRVING, TX 75038, (972)

68 Source Advertising Compliance Contact Information Fax: (972) Business Development (Recruiting) Phone: (800) Fax: (972) Correspondence Review Fax: (972) Errors & Omissions Insurance (Affinity Insurance Services, Inc.) Mailing Address: 159 E. County Line Road Hatboro, PA Phone: (866) General Support Phone: (866) , option 2 Fax: (972) HD Vest Mailing Address Insurance Licensing Insurance Products Licensing Help Desk HD Vest Financial Services Attn: (Name of Department) 6333 North State Highway 161, 4 th Floor Irving, Texas (866) , option 1, x4609 (866) , option 1, x4040 (866) , option 1, x4730 (800) , x4740 Wealth Management Support (WMS) (866) , option 3 66

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70 HD Vest Financial Services is the holding company for the group of companies providing financial services under the HD Vest name. Securities offered through HD Vest Investment Services SM, Member SIPC Advisory services offered through HD Vest Advisory Services SM 6333 N. State Highway 161, Fourth Floor, Irving, TX (972)