WELCOME KIT SLINGERLAND OSJ GROUP TODD A. SLINGERLAND, OSJ 2010 INTERNAL REP USE ONLY

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1 WELCOME KIT SLINGERLAND OSJ GROUP TODD A. SLINGERLAND, OSJ 2010 INTERNAL REP USE ONLY Securities and investment advisory services offered through ING Financial Partners, Member SIPC. Capital Financial Planning is not a subsidiary of nor controlled by ING Financial Partners.

2 Welcome to the Slingerland OSJ Group of ING Financial Partners. It is a pleasure to have you on board with us. We take very seriously the value proposition that we provide to our advisors and hope that you will take advantage of the many programs and services we offer. Our OSJ office team considers each advisor our client, and we are focused on helping you to build, grow, and manage your practice. Please let us know how we can be of service to you. Together, we look ahead toward a bright future. The following information is designed to assist you as you become acquainted with our broker/dealer and with our OSJ organization, Capital Financial Planning. We value relationships, and invite you to call upon us at any time with your questions and concerns. We look forward to working with you. Sincerely yours, Todd A. Slingerland, CFP President and CEO Clare Mertz, MBA Executive Vice President Laura Sausville Risk Management Director Christina Camp Executive Assistant Brittany Lutes Office Manager Securities and investment advisory services offered through ING Financial Partners, Member SIPC. Capital Financial Planning is not a subsidiary of nor controlled by ING Financial Partners.

3 OSJ Office Contact List The following roster will assist you in knowing who to contact within the OSJ office for assistance.

4 Todd Slingerland, OSJ General Contact Roster Toll Free: fax for office private fax for Todd and Clare Mailing address: Capital Financial Planning, LLC 6 Tower Place Albany, NY Todd Slingerland, OSJ x105 [email protected] - Senior compliance oversight/practice supervision as OSJ registered principal - Contact for guidance/followup for difficult cases/concerns as liaison to INGFP Senior Mgt and fixed insurance or annuity companies for major issues ( goes to bat for you ) - Commission issues - Training and development - Sales and marketing support and tools (including certain industry software tools, presentation books, opportunities for co-op, etc.) - Signature guarantees for INGFP business (such a signature guarantees on insurance, client statements, letters to banks, etc.) - Recruiting assistance - Senior management decision-making - Fixed insurance general agent advanced case design - Will help with case prep and investment review for complex cases

5 Clare Mertz, Executive Vice President/sub OSJ x104 - Sub OSJ - assists Todd with execution of OSJ compliance responsibilities and practice supervision; registered principal - Advertising compliance approval coordination with ING Shared Services (fax with signed advertising compliance submittal form) - Correspondence approvals (fax to Clare for prompt turnaround) - Annual compliance inspections, meetings, mandatory requirements - surveillance monitoring - Securities licensing - Collects/reviews trade blotters monthly (send/fax by third business day of month) - Nationally published author who can assist you with ghost-writing financial articles, press releases, marketing materials, presentations and seminars - Signature guarantees for INGFP business - Primary contact for assistance with routine questions and concerns INGFP liaison, daily operations, marketing, etc. generally your first point of contact - Recruiting assistance and transition - Provides weekly update to keep Advisors informed of announcements, etc. Laura Sausville, Risk Management Director x112 [email protected] - Insurance appointments and licensing - Coordinates fixed insurance-related questions and resolutions - Underwriting status follow-up (weekly update to Advisors) - Assists with insurance presale and illustrations - Insurance related CE - Insurance marketing support - Insurance commission preparation for CFPLLC agency Brittany Lutes, Office Manager x0 [email protected] - Receptionist for Todd, Clare, Laura - Manages front desk, equipment, supplies, physical plant for 6 Tower Place location - Runs corporate books on Quickbooks; commissions - Event planning awards banquet, spring symposium, advisor events, other event logistics - General administrative assistance - Marketing fulfillment - Prepares ODA statements for group office advisors - Contest tracking/statistics (e.g. 100 day charge) Christina Camp, Executive Assistant x122 [email protected] - Executive assistant for Todd and Clare (sales assistant for Todd s practice) - Assists with compliance administration, events, projects

6 OSJ OFFICE VALUE PROPOSITION The following information will help to introduce you to some of the services offered by the Slingerland OSJ Team.

7 Slingerland OSJ Group Value Proposition We strive to provide value to our advisors every day. We take that mission very seriously. Below please find an overview of the elements comprising our value proposition: President s Cabinet Representatives of our constituencies in Albany, North Haven, and detached locations provide feedback, assist in the shaping of policy, the addition/enhancement/refinement of services, and the overall betterment of our value proposition. Business Builders This group meets twice per month, every other Tuesday at 9 am. Dial in available at passcode: Focused on providing a forum for advisors to share, learn what s working, and receive the techniques and tools to assist them in working on specific cases and on overall prospecting and client service. Vay(k) Vacation savings account toward group trip. Match provision available. Portfolio Design Meeting Periodic meetings addressing portfolio composition are offered so that advisors can discuss with each other what products and services are working well for specific client situations. One on One Business Plan Reviews Having a plan helps an advisor to stay on course, run the practice like a business, and make important adjustments along the way. Plan reviews help to clarify and focus goals as well as establish accountability. When a business plan is submitted, we prepare one for you. OSJ Overview This is an internal quarterly publication to help provide additional ideas that are working to help support sales and marketing efforts. Group Offices Albany, NY and North Haven, CT group offices are attractive, cost-effective, and professional. We support a full time front desk office manager in both locations to assist you with client reception and phones. With ample meeting space, office equipment, and group camaraderie, the group office is an ideal setting for those advisors who wish to be independent but enjoy the energy of a group setting. Website promotes our advisors and lists their contact information and a brief bio. Year of Letters Monthly letters packet that only requires advisors to submit for personalization approval. This was created to encourage advisors to contact their clients with ease. Annual Awards Banquet Held in January, this event recognizes our high achievers in many different business categories. Life, Long Term Care, and Disability Insurance for Advisors Own Policies (100% comp) To encourage advisors to mitigate their own personal risks, all comp will be provided to the advisor Insurance Marketing Ideas Return of Premium, Trust Owned Life, Field Underwriting Guide Insurance General Agents ING, Security Mutual, Hartford, NYLTCB aggregation = higher payouts to reps

8 Spring Symposium Held at the Cranwell in Lenox MA each spring, this annual event discusses industry developments, sales and marketing ideas, hosts panels of experts, and provides networking opportunities with other advisors. Free Compliance Meeting The cost of a compliance meeting at ING is approximately $25-$100. Where possible, we offer compliance meetings at no cost to advisors, including at the Spring Symposium. Raffle at Symposium to ING Conference A raffle is held at the Spring Symposium to offer advisors the opportunity to win a free trip to the ING National Sales Conference. Television Advertising We are running a series of commercials in the Albany headquarters area to get the name out. AMP Dollars This reimbursement program, known as Advisor Marketing Program (AMP) is available to advisors making between $50K and $100K for business building services such as lead programs and seminars. Prior approval of the activity is required. Annualized Life Insurance Commissions Capital Financial Planning (not INGFP or any other provider) annualizes life insurance commissions for the advisor s convenience. Please note if the policy does not stay in force for 1 year there is a payback situation on ING business only. Community Leadership Awards Advisors may nominate clients who, through their significant volunteerism, make a positive impact on their communities. Volunteers only person cannot be a paid professional working for the organization. No denominational or political organizations. There are 5 awards of $1,000 each available each year (Through CFP Charitable Foundation). Community Service Initiatives Wherever possible, we encourage community service and seek to get behind initiatives such as food drives at the holidays, domestic violence shelter clothing drives, etc. Customized Writing Services Professional writing services are available for difficult letters, client advisory boards, marketing initiatives and other special projects at no cost to the advisor. 90 Day Free Trial at Horsesmouth.com The typical trial period is 60 days, we were able to get it extended. A group discount will be offered for those who wish to subscribe at the end of the trial period. Client Appreciation Events Cinco de Mayo, Day at the Track, Economic Speakers, etc. Watch for even more services as we enhance our value proposition each year.

9 COMPLIANCE BASICS - MANDATORY COMPLIANCE FILES - ADVERTISING REVIEW - ANNUAL COMPLIANCE REQUIREMENTS - - SIGNAGE

10 Compliance Basics When you joined ING Financial Partners, you were asked to affirm that you read the online compliance manual on (IARs also signed off that they read the IAR compliance manual). Regular reference to the compliance manual is helpful. Each year, each advisor will be asked to complete several compliance requirements. These requirements are mandatory and are assigned by our broker/dealer. We work with advisors to simplify the process and to provide education wherever possible to help you keep pace with changes and developments in regulatory compliance. Please be mindful of all announced deadlines. Annual Compliance Requirements: Annual Business Questionnaire This annual affirmation is a questionnaire that you will be asked to read and answer online. It generally is distributed in the early spring. Read carefully each question or statement and answer accordingly. Annual Statement of Holdings (IAR) Investment Advisory Representatives will be asked to provide a listing of all securities holdings in their personal investment accounts. Annual Compliance Meeting The annual compliance meeting is offered in conjunction with our Spring Symposium. Additionally, we hold one phone meeting after tax season for those advisors who are unable to attend the Symposium. These meetings cover important updates in regulatory compliance as well as key reminders. Advisors must complete an annual compliance meeting by October 31. If an advisor is unable to participate in the two free meetings we offer, additional meetings are available from ING Financial Partners (a fee may apply). Annual Inspection - You will receive an annual inspection from a compliance principal from our OSJ office (Todd, Clare, or an appointed delegate). This inspection is a review of your practices and procedures as well as your client files. We typically provide the questionnaire so that each advisor can review his/her practice at the beginning of the year. Inspections may be announced or unannounced. If any material deficiencies are noted, they must be corrected immediately. All inspections must be completed by October 31. Firm Element Continuing Education ING Financial Partners will prepare online courses for each advisor to complete. These are generally available online in late June/early July and must be completed no later than October 31. Your individual licenses will determine which courses you are required to take. Each advisor will automatically receive their courses when they log in to the continuing education website. The courses will have reading material followed by a

11 multiple choice test. A score of 70% or higher is required to pass. The courses are broken down into modules. If a passing score is not acquired, the same questions will repeat in a new order. Regulatory Element Continuing Education On certain anniversaries of your registration, you will be requested to go to a Prometric testing center to complete regulatory continuing education. You will receive a notice 120 days in advance of the deadline. It is important that you schedule your appointment promptly with Prometric, as testing centers can be busy at certain times of the year. These modules typically consist of videos showing certain industry scenarios after which you answer questions. No advance study is required. This is completion only course no grade is assigned. In addition to these annual requirements, the following are of key importance: Mandatory Compliance Files - Each advisor must maintain compliance files in his/her office: Registration This file will be the largest. It will contain all of the paperwork you completed to join our broker/dealer, copies of your insurance license, copies of past compliance inspection letters, IAR items such as the annual statement of holdings and quarterly holdings reports, test score confirmations from licensing exams, and other registration-related information. Trade/Check Blotter Each month, you will provide to the OSJ office a copy of your direct business trade blotter and all checks received. You will document buys, sells, exchanges. Pershing (brokerage) trades do not have to be entered on the blotter. All checks, however, no matter if they are direct business or brokerage must be copied and entered on the blotter. Check copies must be attached. Gift Log - If you give to or receive from clients, prospects, centers of influence, wholesalers any gifts valued at $25 or more, they must be entered on the gift log. This includes dinners or entertainment tickets from wholesalers, gift baskets/wine/flowers sent to clients, tickets for a client appreciation event you held for your clients, etc. Correspondence Log Faxes and letters sent to or received from clients must be entered on the correspondence log and copies of correspondence (including any referenced enclosures) must be attached. s do not have to be logged because we review s on the retention system. Complaints - If you get a verbal or written complaint from a client, notify the OSJ immediately! Do not make any attempt to settle the matter yourself. The complaint file must be maintained even if you have no complaints. If you do have complaints, this file is where all documentation should be maintained. Associated Persons Report This report is furnished annually from INGFP s licensing department. It is important to review the report for accuracy. This report will list all administrative personnel in your

12 practice. If changes need to be made, write the changes on the report and scan and it to Advertising - Advertising includes all form letters sent to more than 9 persons, stationery (business cards, letterhead, fax cover sheets, signature block), signs/billboards, television and radio appearances, commercials, yellow page or directory listings, print ads, brochures, speaking engagements, seminars, logos, telemarketing scripts, websites, newsletters, articles, market commentary, research, rep bio, greeting cards, etc. All advertising must be first submitted along with the Advertising Review Submittal form to the OSJ office. We will coordinate with INGFP s Ad Review Department. Only approved advertising can be utilized. You cannot make any changes to an approved piece without resubmitting. If a piece is approved with a sunset date, it must be resubmitted again before 12 months is up in order to continue using. All advertising reviews must be kept in this file. Cash/Noncash Compensation This file will contain any requests to use sponsor funds to pay for an event or seminar. The Use of Sponsor Funds form and the Reimbursement Request Form must be utilized and submitted to the OSJ for compliance review and submittal. Please wait for approval before undertaking any costs. Do Not Call - If you call or contact a person by mail or and they ask you to not contact them, you must write down their name, address, phone and address and submit this notification to ING Financial Partners. A set of these files will be provided to you. Please note the following important information concerning computers and All computers must be encrypted. All computers must have up to date anti-virus software. s must be registered with ING Financial Partners typically, s will be 4cfp.net or ingfp.com. The use of public domain names such as yahoo, hotmail, aol, comcast, gmail, and the like is not permitted. You must use the registered/retained address for all business communications including to clients, prospects, assistants, OSJ office personnel, other advisors, INGFP, vendors, and any other professional communication. Please refrain from jokes, chain letters, inappropriate language or other non-professional communication on the business . s are retained forever. They are read by a compliance principal. Do not write anything on that you would not write on your business letterhead.

13 Signage Regardless of your office location, whether in a group office or a solo location, you must display the ING Financial Partners disclaimer sign and SIPC sign. If you are not an IAR, your sign should say Registered Representative of If you are an IAR, your sign should begin Investment advisory services Please post the enclosed signs in a visible place within your office such as at the door, in the conference room, or any place where you meet clients (e.g. your private office). Certain states, such as Texas, also require additional signage.

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