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Client Relationship Summary – Voya Financial Advisors, Inc. Item 1. Introduction

This document is the Client Relationship Summary (“CRS”) for Voya Financial Advisors, Inc. In this CRS, Voya Financial Advisors, Inc., and its financial professionals will be referred to as “VFA,” “we,” “our,” or “us.” You, the retail investor, will be referred to as “you,” “your” or “client.” Italicized section headings are framed as if you, the client are asking us, VFA, a question.

VFA is registered with the Securities and Exchange Commission (the “SEC”) as an investment adviser and a broker-dealer.

In its role as a broker-dealer, it is a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). As explained in more detail in this CRS, VFA provides broker-dealer services through its role as a broker-dealer, and investment advisory services through its role as an investment adviser. Broker-dealer and investment advisory services and fees differ, and it is important for you to understand these differences.

Free and simple tools to research firms and financial professionals are available at Investor.gov/CRS, which also provides

educational materials about broker-dealers, investment advisers, and investing. There are conversation starters contained in blue brackets throughout this CRS. Please discuss these conversation starters with your financial professional.

Item 2. Relationships and Services

What investment services and advice can you provide me? We provide both broker-dealer services and investment advisory services to retail investors like you. Below is a list of the relevant categories of services that VFA provides as a broker-dealer and investment adviser.

Broker-Dealer Services Investment Adviser Services Brokerage accounts Non-discretionary investment advice Wrap fee programs Subscription-way accounts Discretionary investment advice Financial planning Margin accounts Third-party asset manager program

(“TAMP”) accounts

We offer these services, subject to certain exceptions, to retirement accounts, such as individual retirement accounts (“IRA”), tax-advantaged savings accounts, such as 529 college savings plans, and accounts that are not subject to any tax-advantaged status (“nonqualified accounts”). We offer equities, bonds, mutual funds, exchange-traded funds (“ETFs”), variable life insurance, variable and fixed-indexed annuities, alternative investments, and options, among other securities types, to our clients. Cash balances in brokerage and non-discretionary investment advisory accounts are deposited in the Voya Financial Advisors Insured Bank Deposit Account (“VIBD"), a cash sweep program. More information about VIBD, including the VIBD disclosure booklet, is contained at www.voyafinancialadvisors.com/banksweep, or by asking your financial professional. We recommend transactions to clients in both broker-dealer accounts and investment advisory accounts. We do not continuously monitor clients’ accounts. There are no account minimums for broker-dealer services, though each of our financial professionals may choose not to offer services to a particular client, whether due to proposed account size or otherwise. Under VFA’s broker-dealer and non-discretionary investment advisory services, you make the decision regarding the purchase and sales of products and services. We provide ongoing investment advice (but not continuous account monitoring) in investment advisory accounts, whether through us or a third party introduced by us to you in connection with your account. Our investment advisory programs contain different account minimums. Our discretionary investment advisory programs, wrap fee programs, and third party managed account programs provide discretionary authority to VFA or to a third party with regards to your account (meaning VFA, its financial professionals, or a third party can make transactions in your account without first obtaining your consent). The chart below summarizes that authority:

Program Who Has Discretion?

How is Discretion Used?

Discretionary investment advice

Us By financial professional to transact in your account, or to select among strategists in certain wrap fee programs

TAMP accounts Third party asset manager

By third party asset manager according to such manager’s management style and model(s), if any

Wrap fee programs Us VFA, to align your account with the model portfolios selected, as managed by the independent investment strategists, or if agreed to by the client, to switch among strategists

In each instance, you may place reasonable restrictions on the account at any time. Discretion is available to utilize at all times while your investment advisory agreement is in force.

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More specific information about the particular services provided under each broker-dealer and investment adviser program, including the limitations and disclosures related to such programs, are contained in the following document(s), which you should read carefully prior to investing with us.

VFA Account Agreements VFA Form ADV Part 2A and related

appendices

Disclosures provided to you upon account or product recommendation

Product and account worksheets

Our Form ADV and related appendices, as well as our Account Agreement, are available at www.voyafinancialadvisors.com.

Item 3. Fees, Costs, Conflicts, and Standard of Conduct

What Fees Will I Pay? If you invest through a broker-dealer account, you will pay a commission, mark-up, mark-down, or a sales charge. The chart below further explains these charges and the product transactions for which they are incurred:

Charge Product What is it? Who Pays? Frequency Commission Equities, options, no-load

mutual funds, ETFs A percentage of the dollar amount of each transaction or fixed charge

You Upon the transactions, both purchases and sales/redemptions

Mark-up/down

Bonds An increase in the price of a bond you buy, or decrease in the price of a bond you sell

You Assessed at the time of the bond transaction.

Sales Load Mutual Fund A percentage of the dollar amount invested in the mutual fund. The amount varies by share class.

You Upon purchase and/or redemption, depending upon share class

Commission Annuities and life insurance

A percentage of the total dollar amount invested. The amount varies by share class.

The issuing insurance company

Upon purchase and subsequent premium payments

Commission Alternative investments A percentage of the dollar amount of each transaction.

You Upon your purchase of the alternative Investment

In addition to the charges listed above, mutual funds and insurance products may pay an asset-based fee to your financial professional on an annual basis. For mutual funds, this fee is a distribution or a shareholder servicing fee (e.g. a 12b-1 fee) that is paid by you from your investment in the mutual fund, and varies by the mutual fund share class purchased. Insurance companies pay asset-based trail commissions to financial professionals. These charges are found in each product’s respective prospectus. There are conflicts of interest inherent in acting in a broker-dealer capacity.

We have an incentive to trade more often in your account when acting as a broker-dealer because we’re compensated for each transaction.

Each product’s commission or sales load varies, and some charge you higher ongoing fees (such as C-share mutual funds), which incentivize financial professionals to pick those high-cost/higher commission products.

Disclosures provided to you by your financial professional at the time of recommendation explain other conflicts of interest applicable to your relationship with your financial professional. The following principal fees are applicable to investment advisory accounts:

- Given my financial situation, should I choose an investment advisory service? Should I choose a broker-dealer service? Why or why not? - How will you choose investments to recommend to me? - What is your relevant experience, including your licenses, education and other qualifications? What do these qualifications mean?

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Program Fees Explanation Discretionary and Non-discretionary investment advice

Advisory Fee Annualized percentage fee paid to us for our investment advice

TAMP accounts Advisory Fee + Solicitor Fee

Annualized percentage fee paid to third party asset manager for investment advice, and solicitor fee paid to us for referring your account to the TAMP.

Wrap fee programs Wrap Program Fee, incl. strategist & custody fees

Annualized percentage fee paid to us and shared with investment strategists and service providers for investment advice, custodial services, and other services.

Financial planning Financial Planning Fee Fee determined by your financial professional for financial planning services. Fees for investment advisory services are disclosed in VFA’s Form ADV Part 2A, and on the investment advisory agreement you sign before receiving investment advisory services. Please consult those documents to determine the exact fee(s) applicable to your account. Wrap program fees include most transaction costs and fees to a broker-dealer or bank that has custody of your assets, and therefore are higher than a typical asset-based investment advisory fee.

There are conflicts of interest inherent in acting in an investment advisory capacity:

We earn more fees if you invest a larger dollar amount of funds with us; and In wrap fee programs, the fee may be greater, in total, than the individual fees you would pay for the wrap fee services

separately. The conflicts to which VFA is subject as an investment adviser are contained in Form ADV Part 2A and its related appendices.

Miscellaneous Fees and Expenses Mutual funds, ETFs, alternative investments, and insurance products have internal fees and expenses that the product provider charges you, but are not payable to us. Each product’s respective prospectus or offering document contains information regarding these charges. Additionally, you will pay ticket charges, which pay for the execution of your securities transactions, in certain investment advisory programs. Other fees are associated with actions taken in your account, and include, but are not limited to, the following:

IRA Maintenance Fee Wire transfer fees Paper surcharges You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying. More detailed information regarding the fees and costs you will pay in our Form ADV Part 2A, if you choose and investment advisory service, in our Account Agreements for broker-dealer accounts, and on our Schedule of Miscellaneous Account and Service Fees for all account types. These documents may be found at www.voyafinancialadvisors.com by clicking on “Client Information.” What are your legal obligations to me when providing recommendations to me as my broker-dealer or when acting as my investment

adviser? How else does your firm make money and what conflicts of interest do you have? When we provide you with a recommendation as your broker-dealer or act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates conflicts with your interests. You should understand and ask us about these conflicts because they can affect the recommendations and investment advice we provide. Here are some examples that help you understand what this means:

Our affiliates (other Voya companies) issue, sponsor, and/or manage securities, investment, and insurance products, which we sell. We have a conflict of interest when recommending these products to you, as our affiliates earn more compensation for the sale of Voya products by us, rather than our sale of products issued, sponsored, or managed by non-affiliates.

Third parties, such as product sponsors, invite your financial professional to attend training and educational meetings, or reimburse your financial professional for the purchase of software that your financial professional uses for his or her business. This incentivizes your financial professional to recommend products sponsored, issued, or managed by third parties that sponsor these training and education meetings, or reimburse for software expenses.

Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?”

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Our clearing firm, Pershing, LLC (“Pershing”) provides compensation to us for assets held on the Pershing platform. This

incentivizes us to place assets on the Pershing platform.

VFA earns fees from product sponsors in exchange for reporting, marketing/sponsorship/engagement opportunities with VFA and its financial professionals, enhanced communication, education, access to key contacts at VFA, and relationship management. The fee paid by these product sponsors to VFA creates a conflict of interest, as it incentivizes us to recommend these product sponsors’ products to you, as opposed to product sponsors that do not pay these fees to us.

A more detailed list of our conflicts of interest is available in our Form ADV Part 2A and related appendices, our Account Agreement, in the disclosures provided to you by your financial professional at the time of account or product

recommendation, and on our website, www.voyafinancialadvisors.com, under “Client Information.” Please read these documents carefully.

How do your financial professionals make money? With the exception of our telephone based Investor Channel, who earn a salary and incentive compensation tied to product sales and service, our financial professionals are compensated in the following ways, depending on the type of business conducted: Broker-Dealer Accounts

A commission, chosen by the financial professional in accordance with our policies, for equities, ETFs, and options. A flat commission is earned for no-load mutual fund transactions. Financial professionals earn either a commission or mark-up/mark-down for bond transactions.

A sales load or pre-set commission and trail payments for load mutual fund transactions, insurance products, and alternative investments

Investment Advisory Accounts An investment advisory fee, chosen by the financial professional and agreed upon by you, based on a percentage of your

assets managed by the financial professional. A financial planning fee, chosen by the financial professional and agreed upon by you, for financial planning services.

We pay our financial professionals the above fees at a stated payout percentage, meaning that VFA retains a portion of these charges and fees, and pays the remainder to the financial professional. Compensation derived from the financial professional’s activity is calculated to qualify them for incentive trips we offer. The receipt of compensation and the potential to qualify for trips are conflicts of interest that incentivize the financial professional to sell more products, or retain higher assets in investment advisory accounts. Item 4. Disciplinary History

Do you or your financial professionals have legal or disciplinary history? Yes. Please visit Investor.gov/CRS for a free and simple search tool to research us and your financial professional.

Item 5. Additional Information You can find additional information about our broker-dealer and investment advisory services by visiting our website at www.voyafinancialadvisors.com and clicking on “Client Information.” There, you can obtain important documents about investing through VFA, including the most recent copy of the CRS. You may also call us at (800) 356-2906 to obtain a copy.

As a financial professional, do you have any disciplinary history? For what type of conduct?

Who is my primary contact person? Is he or she a representative of an investment adviser or a broker-dealer? Who can I talk to if I have concerns about how this person is treating me?

How might your conflicts of interest affect me, and how will you address them?

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*175486--------*

FINANCIAL PLANNING AND SERVICESCLIENT AGREEMENT

Voya Financial Advisors, Inc.Member SIPC699 Walnut Street, Ste. 1000Des Moines, IA 50309-3975800-356-2906

This agreement is made by and between Voya Financial Advisors, Inc. (“VFA”), a broker-dealer and registered investment adviser, and the above-named client (“Client”) for the limited purposes of providing financial planning services as described below (the “Agreement”). The investment adviser representative establishing this Agreement is ___________________________________________________.

1. SERVICES AND TERMS (SELECT EITHER ONE-TIME OR ANNUAL): VFA, through one of its investment adviser representatives (“IAR”) agrees to meet with Client for the purpose of acquiring information concerning Client’s assets, liabilities, present and anticipated obligations and present and future income and financial goals. Client agrees to provide full and accurate information to IAR in connection with the financial planning services. Within a reasonable time after receipt of the information, and in reliance upon the accuracy and completeness thereof, VFA, through IAR, will furnish Client with the following (the “Financial Planning Services”). Please reference Appendix A for a description of the planning services:

c One-time Financial Planning Services: VFA, through IAR, will furnish Client with a written evaluation addressing the topics checked below. Delivery of the written evaluation constitutes completion of this Agreement and shall occur within 90 days of signing this Agreement. Divorce planning, estate distribution services and special needs planning are allowed to extend beyond 90 days but not longer than 365 days pursuant to a written agreement between Client and VFA.

NO ONGOING MONITORING: The One-time Financial Planning Services shall not require VFA or IAR to monitor Client’s assets on an ongoing basis, nor shall it require that VFA or IAR update recommendations to reflect changes in Client circumstances. The One-time Financial Planning Services will not require VFA or IAR to monitor financial markets and conditions for Client and will not require that VFA or IAR perform ongoing analysis of Client assets for factors that may impact performance.

As discussed in Section 5, below, IAR is not providing and cannot provide ongoing investment advisory services pursuant to the One-time Financial Planning Services in this Agreement.

c Annual/ongoing Financial Planning Services: VFA, through IAR, will furnish Client with a written evaluation addressing the topics checked below. This Agreement begins on the date of the signature below and will automatically renew on the first day of the month following the anniversary date of this Agreement (the “Renewal Date”) for a period of one (1) year unless terminated by either party pursuant to Section 8 below. Delivery of the written evaluation does not constitute completion of this Agreement and shall occur within ninety (90) days of the initial planning year and within ninety (90) days of the Renewal Date for each subsequent renewal year. The IAR shall offer to meet with the Client at least twice annually after the initial meeting to provide ongoing advice regarding the annual plan and its execution to the Client.

Planning fees cannot be assessed for performing beneficiary updates and reregistration updates for portfolio assets, accounts or insurance contracts where VFA is listed as broker-dealer of record and/or investment advisor representative is the agent of record or broker of record. Compensation for services already included through accounts affiliated with a VFA advisory agreement or under other existing agreements with VFA are strictly prohibited under this Agreement.

Client Name Client Name

Address Address (if different)

City, State, Zip City, State, Zip

Phone Phone

E-mail E-mail

c Client attests to having received the Client Relationship Summary.

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(Check all services that apply.)

Individual planning services Specialty planning services

c Cash flow, budgeting, and major purchase buy/sell decisions

c Education planning and funding choices c Business planning services

c Individual savings goals, asset allocation and insurance planning

c Estate planning and gifting strategies c Special needs planning

c Retirement accumulation planning c Qualified plan and IRA distribution analysis c Executive planning with stock option and deferred compensation evaluations

c Retirement income planning c Retirement Social Security benefit analysis c Divorce planning1

(one time service only)

c Plan Reviews c Investment planning2

c Estate distribution services2

(one time service only)

1 Client may not be a VFA investment advisory client to be eligible for divorce planning services. Clients must complete the Divorce Planning Addendum to this Agreement prior to receiving divorce planning services.

2 Investment planning services and estate distribution are not available for assets held under a VFA brokerage account or VFA investment advisory account.

2. FEES: As compensation for rendering the services described above, Client agrees to pay VFA the following which is negotiable and Client hereby agrees: (check one):

c One-time planning services: $_____________ flat fee for initial planning services. $_____________ per hour with an estimated completion time of ______ hours.

One-time planning services payment (select one): c Full payment – copy of plan (if not attached) to follow within 90 days of this Agreement c 100% Up Front (upon signature of the Agreement) c 100% At Delivery of the Plan c Partial payment – a percentage of the planning fee paid upon signing of this agreement and the balance paid within thirty days

of delivery of the plan (ACH not available) Amount due upon signature of the Agreement $_____________ Amount due within 30 days of Delivery of the Plan $_____________

c Annual planning services: $_____________ flat fee for initial year planning services and _______ flat fee for renewal year(s) planning services

Annual planning services payment frequency (select one): c Annual payment c Quarterly payment c Monthly payment

Planning service fees are billed and due in advance for the services provided under this Agreement.

Payment method (select one): c Check payable to Voya Financial Advisors, Inc. (annual payment frequency option only) c Debit from Client’s non-qualified Pershing brokerage account (all payment frequencies) Pershing Account Number _______________________ Date first payment expected _______________________ c ACH Authorization – Electronic transfer of funds between your financial institution account and VFA. Additional client authorization

form required (all payment frequencies except one time planning partial payment)

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Upon termination of this Agreement, any fees collected by VFA for One-time Financial Planning Services will be reimbursed in full if a plan has not been delivered. Any annual planning fees collected but not earned will be reimbursed to Client at a pro-rata share based on the amount of days remaining in the installment period. Reimbursement will be provided through check regardless of payment method.

For Retirement Readiness Clients Only: If your employer participates in the Voya Retirement Readiness program, you are eligible to receive a Retirement Snapshot at no cost. The Retirement Snapshot provides you with a retirement analysis and guidance appropriate for your personal financial situation. The Retirement Snapshot is not a substitute for a holistic financial plan. Completion of this Agreement is not required to receive your Retirement Snapshot.

3. TAXES: VFA and IAR do not provide tax advice pursuant to this Agreement. You should consult with an independent tax professional regarding the tax implications of any financial decision.

4. LIMITATIONS ON SERVICES: VFA acts as fiduciary under this Agreement with regards to financial planning advice provided to the Client. However, VFA and IAR do not undertake by this Agreement to have fiduciary or investment adviser status for Client’s assets or any account(s) maintained with VFA or with any other broker-dealer.

Clients that are pension, retirement, profit sharing or other plans governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) agree that VFA does not provide investment advice under this Agreement, as that term is defined in ERISA. VOYA FINANCIAL ADVISORS, INC. CANNOT AND WILL NOT ACCEPT THE LEGAL STATUS OF INVESTMENT ADVISER OR FIDUCIARY FOR ANY ASSETS OF THE CLIENT OUTSIDE THE SCOPE OF THIS AGREEMENT. Client acknowledges and agrees that VFA and IAR do not undertake fiduciary or investment adviser status in relationship to assets not placed in an investment advisory account. This Agreement is not to be used as the basis for an ongoing investment advisory arrangement or relationship. VFA and IAR do not and will not practice law or accounting nor are they acting as casualty insurance brokers, agents or representatives in giving advice to Client or in providing any advisory services under this Agreement. None of the fees for Financial Planning Services under this Agreement relate to accounting, legal or insurance services. The Financial Planning Services rendered under this Agreement will be restricted only to the particular services described herein. Any other services are the responsibility of Client.

5. DISCLOSURE OF INTEREST AND CAPACITY: IAR may recommend that Client purchase or sell investments and/or enter into other financial transactions. If Client chooses to implement such recommendations through VFA, VFA will act in its capacity as a broker-dealer, pursuant to a separate written contract, or as a registered investment adviser, pursuant to a separate written contract. VFA will be entitled to its usual and customary commissions or fees in addition to any described above. A portion of those commissions may be paid to IAR acting in his capacity as a registered representative. Such commissions may be reduced or waived but VFA is under no obligation to do so. Any such reductions or waivers are fully negotiable. In addition, certain mutual funds in which Client may invest may distribute service payments to broker-dealers, including VFA. The amount of such fees is described in the fund’s prospectus and are not considered in the calculation of the fees set forth above nor are they credited back to the Client.

Therefore, VFA and IAR have a conflict of interest in recommending the purchase of products through VFA, as does any commission- based broker-dealer. Further, affiliates of VFA sponsor insurance and investment products, such as mutual funds. Those affiliates receive compensation and other fees in relation to sponsored investment or insurance products sold through VFA. Therefore, there is also a conflict of interest for VFA and IAR in recommending those products.

6. NO OBLIGATION: Client is under no obligation to act on the advice of VFA, IAR or any other affiliated persons. Client must decide whether to implement any advice or recommendations made by VFA, IAR or any other affiliated person. If Client does follow such recommendation, Client acknowledges that he/she is under no obligation to effect the transactions through VFA or its affiliates. Client should carefully review all sales charges, front-end or deferred, and ongoing expenses and loads charged in all products or service programs before investing.

7. CLIENT’S RESPONSIBILITIES: Client represents that all financial and other information furnished to VFA and/or IAR relating to Client’s assets, liabilities and other information is true and correct and may be relied upon by VFA and IAR for the purpose of providing the services described in this Agreement. Client agrees to inform VFA and IAR in writing of any material changes in Client’s circumstances, which might affect the services to be provided pursuant to this Agreement. VFA shall not have any liability for Client’s failure to inform the firm in a timely manner of any material change in Client’s financial circumstances. Client further acknowledges that the recommendations developed by VFA and IAR are based upon the professional judgment of IAR and neither VFA nor IAR can guarantee the results of any recommendations made. Client further acknowledges that VFA and IAR obtain information from a wide variety of publicly available sources and that VFA and IAR have no sources, and do not claim to have sources of inside or private information. Client should consult with tax or legal advisors on any references in the plan(s) regarding tax or legal decisions prior to any implementation.

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8. TERMINATION: This Agreement may be terminated by VFA or Client at any time without penalty upon written notice to the other party. Client agrees that such termination will not affect the liabilities or obligations of the parties under this Agreement which arise from transactions initiated prior to termination. Notwithstanding anything to the contrary herein, Client shall have the right to terminate this Agreement without penalty within five (5) business days of the date set forth below after Client’s signature of this Agreement. For One-time Financial Planning Services, this Agreement terminates at the time the services referenced in Section 1 have been rendered to the Client. This Agreement will not terminate in the event that the IAR establishing this Agreement is no longer associated with VFA or is otherwise removed from this Agreement. VFA reserves the right to replace the IAR providing services under this Agreement, with or without cause.

9. PREDISPUTE ARBITRATION CLAUSE: This Agreement contains a pre-dispute arbitration clause. To the extent permitted by law, all controversies which may arise between Client and VFA and/or IAR or any of their affiliated companies or persons concerning any transaction arising out of or relating to this Agreement, any account maintained by the Client, or the purchase of any insurance or investment products through, sponsored by, issued by or recommended by any of them, or the construction, performance, or breach of this or any other Agreement between the parties shall be submitted to arbitration conducted under the rules, then in effect, of the Financial Industry Regulatory Authority, Inc. (“FINRA”) or, if FINRA will not assume jurisdiction of the matter, the American Arbitration Association.

By agreeing to an arbitration clause, 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 an 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 request for an explained

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. Unless otherwise agreed to in writing, each party in this Agreement agrees that any dispute between them arising out of this

Agreement shall be submitted to arbitration conducted under the then applicable provisions of the code of arbitration procedure of FINRA. Arbitration must be commenced within the applicable statute of limitations. The arbitration award shall be final and judgment may be entered on the award in any court, state or federal, having jurisdiction. Federal and state securities laws provide certain rights to sue in courts of law and therefore nothing herein shall in any way constitute a waiver or limitation of any such rights which Client may have under federal or state securities laws. No party 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; (ii) the class is decertified; or (iii) the customer 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.

10. ASSIGNMENT: This Agreement may not be assigned by either party without the consent of the other party, provided that VFA may transfer its rights and obligations under this Agreement if such transaction does not constitute an “assignment” for purposes of the Investment Advisers Act of 1940.

11. MODIFICATION: VFA may amend this Agreement by modifying or rescinding any of its existing provisions or by adding new provisions. Any such amendment shall be effective as of thirty (30) days after VFA has notified Client in writing of any change or such later date as VFA may establish, provided, however, that if such amendment is required by law, it shall be effective upon written notice by VFA. If Client provides notice to VFA of Client’s rejection of any amendment proposed by VFA, this Agreement shall be considered terminated upon VFA’s receipt of such notice. No amendment to this Agreement requested by Client shall be effective until it is agreed to in writing by VFA.

12. DISCRETIONARY POWER: This Agreement does not grant discretionary power to VFA or IAR to direct any investments owned by Client or otherwise act on Client’s behalf.

13. RECEIPT OF WRITTEN INFORMATION: By signing this Agreement, Client acknowledges receipt of VFA’s Form ADV Part 2A Disclosure Brochure, IAR’s Form ADV Part 2B Brochure Supplement, and VFA’s Privacy Promise. These documents contain important information, including but not limited to information regarding the nature of VFA’s business, the services it offers, and the fees it charges for such services. Please read these documents carefully and contact your IAR if you have any questions.

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TO THE CLIENT: PLEASE READ CAREFULLY BEFORE SIGNING:Client acknowledges that VFA is relying upon the following representations of Client in undertaking this assignment. By signing below, Client represents:

1. Client has carefully read this Agreement and the Form ADV Part 2A, Form ADV Part 2B and/or any disclosure brochure of VFA, especially as related to conflicts of interest and the specific roles of VFA and IAR;

2. Client will not rely, and is not relying upon, any oral or other representations or understandings that are contrary to this Agreement or the disclosures of Form ADV Part 2A, Form ADV Part 2B or any disclosure brochure of VFA;

3. VFA terminates its role under this Agreement upon delivery of the mutually agreed-upon services subject to this contract unless there is another agreement executed with VFA;

4. Should Client execute transactions related to this advice or otherwise through VFA, Client understands that VFA will be acting as a broker-dealer or registered investment adviser pursuant to a separate written agreement, and not pursuant to this Agreement; and

5. Client understands this Agreement contains a pre-dispute arbitration clause on page 4, Section 9 above and Client has reviewed it carefully. This pre-dispute arbitration clause applies to all contracts, services and transactions with Client by VFA, IAR or their affiliates.

Client Signature Date

Print Client Name Client Social Security Number/Tax Identification Number

Second Client Signature (if applicable) Date

Print Second Client Name (if applicable) Client Social Security Number

Investment Adviser Representative Signature Date

Print Investment Adviser Representative Name Rep Number

Advisory Supervisor Signature Date

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Individual planning servicesCash flow, budgeting,and major purchase buy/sell decisions (personal balance sheet and net worth analysis, may include cash flow analysis and budgeting)

Provide a consolidated view of everything you own and everything you owe, creating your personal balance sheet and net worth statement. Evaluate spending habits, cash flow and help identify the right financial path. Set budgets to assist in reaching current and long-term financial goals. We will assist you in determining how monthly and large purchase financing decisions may affect your overall financial objectives. Services may include guidance on how to pay off debt early, the potential impacts of downsizing your home, the various types of sales transactions (cash, lease-back and installment sales) and guidance on how to manage overall debt.

Individual savings goals, asset allocation and insurance planning

Identify your individual risk tolerance and align it with your investment objectives/goals.1. Assess your progress toward your savings goals. Through the asset allocation plan, we will help

you see if you are on track to reach your savings goals. By answering a series of investment-related questions, we can compile those answers and align with a suggested asset allocation model. Based on the model, we assign a reasonable “savings growth rate” assumption based on historical or projected returns of the sample asset allocation profile. That rate of growth assumption is utilized to help calculate your progress toward your savings goal.

2. Identify your personal willingness to take investment risk. There are many different investments and each investment carries different types of risk (e.g. interest

rate, market, business, currency, credit, liquidity, political, inflation) and different levels of risk (some investments have high levels of value fluctuation and some have low levels of value fluctuation). Whether you want to preserve your savings through very low risk investments or aggressively grow your savings through very high risk investments, or somewhere in between, it is essential for you to identify your own personal willingness to take investment risk.

Completing a risk tolerance questionnaire (RTQ) will help assess your personal willingness or comfort level with overall investment risk. Based on the answers you provided on the RTQ, your investments will be associated with a suggested rate of return, indicated as “savings growth rate” that reflects an investment approach based upon your time horizon, investment objective and tolerance for risk.We will analyze the appropriate amount of insurance (e.g. disability income, life insurance, long-term care insurance) needed to protect your family, and plan for how your financial resources or income may be impacted through unexpected events. We will review your current coverage and needs, estimate consequences to personal savings, calculate appropriate insurable levels, and review non-product specific insurance product types.

Retirement accumulation planning

Develop a savings and asset allocation plan to forecast and plan for a potential lifetime income stream. This plan may involve clarifying your optimal retirement age, savings rate, tax location of future savings and asset allocation based upon your personal willingness to take investment risk. We will review strategies to address shortages and manage surpluses based upon your confidence level.

Retirement income planning

Develop a savings and asset allocation plan to forecast and plan for a potential lifetime income stream. Our services may include, but are not limited to: organizing your financial information; cash flow analysis; identifying and prioritizing your short-, medium- and long-term goals; estimating annual out-of-pocket health care costs; estimating Medicare premium costs due to taxable income and your total cost of retirement; asset allocation based on your personal willingness to take investment risk; defining your current situation based on a non-strategic sequence of withdrawal of personal savings through a Monte Carlo simulation; reviewing pension and Social Security benefit options; reviewing the potential impact of taxation of Social Security benefits; clarifying an optimal retirement age and savings rate for your remaining working years; developing a strategic income allocation of your household resources; evaluating possible tax location and tax-sensitive distribution strategies; identifying key retirement risks (e.g. inflation, unexpected health care costs, reduction of benefits, life expectancy changes) and reviewing strategies to help mitigate them. Outline a view for general understanding of year-by-year cash flow projection on income from different sources of accounts with different tax implications (after-tax, tax-deferred, capital gains, dividends, annuity exclusion ratios, Roth IRA, distributions from life insurance contracts and distributions from trust accounts).

Plan reviews(one time service only)

Review your financial plan periodically to make any savings rate, asset allocation and portfolio rebalancing adjustments to help keep you on track. Your review may include strategies to overcome shortages and manage surpluses based upon your confidence level and optimize resources to mitigate key financial risks. In addition, this service may include coordinating reviews of tax-efficient accumulation or distribution options and legal documents (e.g. wills, trusts, medical directives, powers-of-attorney) with your tax or legal advisors to help ensure they are up to date.

Education planning and funding choices

Identify the estimated cost of attendance based on averages (or a specific education institution), and your potential funding sources (e.g. scholarships, grants, employment income, employer tuition reimbursement plans, family gifting, and parental support).This service will help you plan for funding future college expenses, and understand strategies for your personal circumstances and priorities.

Appendix A

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Estate planning and gifting strategies

Provide guidance to help you pass your legacy to your heirs and fulfill your philanthropic aspirations according to your terms. We assist with: reviewing your estate planning strategy, financial account ownership structure and beneficiary designations, reviewing and developing gifting plan strategies.

Qualified plan and IRAdistribution analysis

Analyze various retirement plan and IRA distribution scenarios and beneficiary structures to determine how to optimize distribution options from retirement accounts, including Roth conversions, net unrealized appreciation calculations, required minimum distribution calculations, qualified charitable distributions, early distributions subject to IRS penalties, early distributions eligible for an exception from IRS penalties (death, disability, age 59.5, first-time homebuyer, qualified educational expenses, substantially equal periodic payments, 457(b) plan public safety officer provisions and qualified plan age 55 separation of service provision), required minimum distributions during life, required minimum distributions after death for generational planning, incorporating life insurance concepts to align with required minimum distributions, income in respect of decedent itemized deductions eligible for designated beneficiaries of deceased IRA owners subject to estate tax.

Retirement Social Security benefit analysis

Provide a review of the personal Social Security statement you provide to us to illustrate potential retirement, dependent and survivor benefit options based on your unique characteristics (such as birth date, earnings history, and type of benefit). We will deliver analysis which covers the estimated lifetime benefits based on your own projected life expectancy, cost-of-living adjustments, and break-even point estimates of available benefit claiming options. (This planning service does not determine eligibility for ANY government entitlement benefit.)

Specialty planning servicesBusiness planning services Provide planning techniques for business owners to help preserve the value of your business or to pass on

ownership.In conjunction with your legal, tax and other advisors, assist in the review of business structure, business succession plans, non-qualified deferred compensation plans strategies, executive bonus arrangements, buy-out agreements, key person protection strategies, business liability protection strategies and business valuation process.IAR will not provide tax or legal advice pursuant to this service.This financial planning and service agreement IS NOT valid for establishment, structuring, monitoring and maintenance of the business-controlled ERISA qualified retirement and employee benefit plans.

Special needs planning Preparing and assisting caregivers in preparing for the financial future of their dependent with special needs. Each person’s circumstance with disabilities is unique. Services may include, but are not limited to:1. Plan for future medical, educational and housing needs for your dependent. Identify your

dependent’s needs (medical treatments, education funding, group home or individual living expenses) could be in the future – and develop your financial strategy and cash flow based on these projections.

2. Review beneficiary designations. Coordinate appropriate beneficiary accounts and special needs trusts. Develop a process to evaluate any inheritance or insurance benefits received by your dependent, including from friends and family.

3. Coordinate contact with local nonprofit organizations for additional resource support. Your local nonprofit may be able to provide resources that can help with planning or that supplement the standard services provided by government agencies. A good starting place is to contact a nonprofit dedicated to your dependent’s special need.

4. Assist with applying for government benefits. Government benefits – such as Medicaid and Social Security (www.ssa.gov) – may help provide for your dependent’s needs in the form of medical treatments and supplies, equipment, financial assistance and more. Visit your local Social Security Office to find out what benefits your dependent may qualify for; call or visit their website first to find out what documents you should have with you for your visit.

5 Review your Last Will and Testament. Coordinate with your attorney to update your will to declare how you want your estate to be distributed and allow you to select a guardian for your dependent(s) when you die. Coordinate with a trust company in administrating a special needs trust.

6. Apply for guardianship and conservatorship, if applicable. Coordinate with your attorney for the caregivers to apply for a guardianship or conservatorship to maintain legal control over financial and healthcare decisions once a dependent reaches the age of 18.

7. Prepare a letter of intent. Coordinate with your attorney to provide additional clarity and direction for the person or persons who will care for your dependent with special needs.

Executive planning with stock option and deferred compensation evaluations

Provide corporate executives with customized tax, estate and financial planning guidance to help maximize the value of company-provided compensation and benefits. Services may include guidance on minimizing potential income and estate tax liabilities, enhancing cash flow, developing strategies for stock option/ incentive compensation benefits, non-qualified pension plan, and other non-qualified deferred compensation plans. We can assist with wealth management, survivor planning, minimizing taxes, wealth accumulation and optimizing your resources to mitigate key financial risks.

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Divorce planning (one time service only)

Assist individuals subject to current or potential divorce proceedings with financial planning prior to divorce and post-marital transfers of assets. Services may include, but are not limited to: financial statement preparation; budgeting and analysis; financial discovery assistance; assistance with completing financial account forms following separation agreements, decrees, stipulations and post-marital agreements; possible tax impact of retirement assets, potential property distributions and alternative support scenarios; analysis of financial and tax issues related to the marital residence disposition of property; assisting tax advisors with review of tax returns to identify filing status, assets, sources of income, undisclosed, transferred, hidden or obligated assets or carryover credits or refunds; identify and analyze career assets, such as insurance, retirement assets, stock options; review and analysis of estate planning documents; analysis of long-term needs and paying abilities in different post-divorce or post-separation contexts; participation in strategic planning or settlement conferences; assisting in post divorce or post-separation transfers of assets, changes of beneficiaries, trustees or owners of wills, trusts, retirement plans and insurance policies and execution of qualified domestic relation orders.

Investment planning Develop a plan to help maximize your potential investment returns for a given level of risk. This begins with understanding your risk aversion and building a portfolio of traditional and non-traditional asset classes diversified and managed to minimize your overall risk and maximize returns over time.This is for investment management services for portfolio assets and accounts where VFA is not listed as broker-dealer of record or where VFA provides investment advisory services pursuant to an investment advisory contract. This service CANNOT be provided with accounts where this investment advisor representative is agent or representative of record on the account or contract, ERISA regulated employer sponsored retirement plans (e.g. 401(k), profit-sharing or defined benefit plans).The process helps you select the investment vehicles and investment managers and provides you the tools to monitor and evaluate their qualitative and quantitative analysis.

Estate distribution services(one time service only)

Assist estate attorneys, executors, trustees and designated beneficiaries in post-death transfers of assets. For the orderly transfer of assets, we assist in reviewing distribution options, updating beneficiary forms, and facilitating death claim process for insurance contracts, financial accounts and retirement plans.