Foreign Account Tax Compliance Act Frequently Asked Questions

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1 FATCA - The Basics (an overview) 1. What is FATCA? FATCA, which became effective July 1, 2014, stands for the Foreign Account Tax Compliance Act. It was created by the U.S. Internal Revenue Service (IRS) to ensure that persons subject to U.S. Income Tax Laws (U.S. Taxpayers) report all worldwide income by preventing U.S. persons from using insurance companies, banks and other financial organizations to avoid U.S. taxation on their income and assets. A substantial number of countries worldwide have entered or are expected to enter into intergovernmental agreements (IGAs) with the United States government to comply with FATCA. The countries local laws adopt the FATCA legislation as a result of the IGAs. 2. When does the FATCA legislation become effective? FATCA became effective July 1, What is the impact of FATCA? On an annual basis, life insurance companies are required to report certain information on financial accounts (e.g., life insurance policies with cash value and annuities) held directly or indirectly by U.S. persons. FATCA is impacting all Foreign (non-u.s.) Financial Institutions, including insurance companies. Therefore, FATCA may affect Policy Owners of cash value and annuity policies in Pan-American Life s branches and affiliates outside of the United States. Pan-American Life became FATCA compliant as of July 1, 2014, in all countries where we operate. Other life insurance companies and financial organizations will also be affected. However, their approach to FATCA compliance may differ from that of Pan-American Life. Pan- American Life will be reviewing our existing client base to confirm our clients FATCA status, and where necessary, we may have to contact our clients for further information and documentation. 4. How do I know if I am affected? FATCA affects policy owners of cash value life insurance policies and/or annuities who are considered U.S. persons for U.S. tax purposes. FATCA also affects certain types of policy owners who are businesses/entities with U.S. owners. U.S. Person includes the following, but is not limited to: A citizen of the United States, including an individual born in the U.S. but is a resident in another country (who has not renounced their U.S. citizenship) A dual citizen (U.S. and another country) A person residing in the U.S. (including Green Card holders) Certain persons who spend a significant number of days in the U.S. each year U.S. corporations, U.S. partnerships, U.S. estates and U.S. trusts

2 As a Policy Owner or potential Policy Owner, you will be asked to provide documentation or information regarding your U.S. Taxpayer Status at the time of application, at the time of a policy service request, or when your policy is reviewed as required by FATCA. Required documentation may include a simple questionnaire or the appropriate U.S. tax form (also referred to as IRS certificates or W forms ). For more information regarding FATCA, please contact the IRS website or your tax professional. 5. Is Pan-American Life the only life insurance company affected by FATCA? No. All life insurance companies and other financial institutions are affected by FATCA; however, their approach to complying with FATCA may differ from that of Pan-American Life. Pan-American life is committed to being FATCA compliant in all countries in which we operate. 6. What does Pan-American Life have to do to comply with FATCA? To comply with the FATCA regulations: Pan-American Life will conduct a review of new and existing policy owners who own cash value life policies and/or annuities to identify those who may be reportable under FATCA Pan-American Life will report general information to the IRS or local tax authority on all cash value policies or annuities owned by U.S. Taxpayers. In addition, Pan-American Life may also be required to report information about Policy Owners who do not provide the requested information and potentially apply 30% U.S. withholding tax on certain types of distributions made to such clients Am I affected by FATCA? 7. Is FATCA applicable to individual or entity policy owners? FATCA impacts both individual and entity policy owners who have a cash value life policy or annuity with a Pan-American Life branch or affiliates located outside of the United States. 8. Am I only affected if I am a citizen of the United States? No. If a policy owner has any of the following criteria, Pan-American Life may request further information or documentation to determine U.S. taxpayer status: U.S. citizenship or U.S. residency, including dual citizens (U.S. and another country) U.S. place of birth U.S. address including U.S. P.O. boxes U.S. telephone number Instructions to pay amounts to a U.S. address or an account maintained in the U.S. Current Power of Attorney or signatory authority granted to a person with a U.S. address In care of or hold mail address which is the sole address for the account holder

3 9. What does FATCA mean for me if I am a U.S. person? If you are considered a U.S. person, you may be asked to supply Pan-American Life with additional information or documentation. You may also wish to visit the IRS website to determine if you need to complete and submit any additional IRS forms. If you are a U.S. Person, Pan-American Life may be required to report information about you and your cash value policy or annuity to the local tax authority or the IRS on an annual basis. While we will correspond with affected Policy Owners, Pan-American Life Insurance Group and its branches and affiliates are unable to provide any tax advice. Therefore, we recommend you consult your legal counsel or tax advisor should you require any tax advice. 10. What does FATCA mean for me if I am not a U.S. Person? For most policy owners, FATCA will have minimal impact, and there will be no action required. Pan-American Life may still contact you to confirm your status as a non-u.s. person. If you refuse to provide the requested information, we may have to report and/or withhold 30% from any distributions made to you. 11. Am I only affected if I am a U.S. company? No. The impacts of FATCA are broader than just U.S. companies. Pan-American Life will be reaching out to many entity/business policy owners world-wide to determine their status under FATCA. The goal of this exercise is to identify clients which are reportable under FATCA. We will be communicating with clients who need to take further action. 12. What do I need to do as an entity/business policy owner? In order to establish your tax status under FATCA, we may need you to provide additional information or documentation. This documentation could be a simple questionnaire or a U.S. tax form from the IRS. We will be communicating with affected clients that need to complete these forms, detailing when they will need to be completed by. 13. What happens if a cash value life policy or annuity is owned by a U.S. person and a non-u.s. person? A cash value life policy or annuity which has one U.S. owner is treated as a U.S. account and, therefore, the entire account may be subject to reporting under FATCA. 14. How frequently will I have to provide information for FATCA purposes? FATCA is an ongoing process. If your policy information changes, we may be required to contact you to obtain additional information so that we are able to update your policy classification under FATCA.

4 In addition, some of the IRS forms expire three years following the signature date. Therefore, we may need to obtain an updated IRS form from time to time. 15. What information will Pan-American Life report to my local tax authority or the IRS? The information reported to the IRS or to the Policy Owner s local tax authority will depend on the FATCA classification of the Policy Owner. This information will typically be of a personal nature (e.g., name, address, U.S. taxpayer identification number), and of a financial nature (e.g., policy number, policy balance/cash value). What do I need to do? 16. What types of information and/or documentation can I expect to supply to Pan-American Life? We will be communicating with the affected policy owners and provide full details of the information/documentation Pan-American Life needs for FATCA purposes. Documents may include U.S. Tax Forms (W-9, W-8BEN or W-8BEN-E) or FATCA Status Questionnaires. 17. Will Pan-American Life supply me with all the forms I need to complete? Yes. If Pan-American Life requires further information from you, we will either send you the relevant forms or direct you to a website where you can download them. 18. When do I have to provide the requested information and/or documentation for FATCA? In general, clients should supply the requested documentation and information by the date contained within the communication or as requested. 19. What will Pan-American Life do if I do not provide the information required under FATCA? Pan-American Life is committed to being fully compliant with FATCA. Pan-American Life may not issue new cash value policies or annuities to clients who choose not to comply with Pan-American Life s requests for documentation to establish a proposed policy owner s status under FATCA. Pan-American Life may also need to report information about customers who do not provide the required documentation to us. In addition, we may also be required to withhold tax on certain payments made to you. 20. What do I need to do if I am affected by FATCA? Over the next few months we will continue to review the impact of the legislation for our clients and will correspond with affected clients in due course. For more information regarding FATCA,

5 please visit the IRS website (see useful links), or consult your legal counsel or tax advisor should you require any tax advice. Please note, that you may receive more than one request for documentation if you have multiple policies and/or annuities with different members of the Pan-American Life Insurance Group. It is important that you respond to all requests, even if you believe you have already requested information. Pan-American Life cannot offer tax advice therefore we recommend you speak with your professional tax advisor.