U.S. Agent Agreement Packet

Please complete and sign all forms listed below and fax to 770-248-3300:• Agent Application

• Agent SMD Approval

• W-9

• Agent Insurance Guide Acknowledgement• Background Screening Disclosure Form for Contracting Purposes

• Background Screening Authorization Form for Contracting Purposes

• World Financial Group Insurance Agency Agent Agreement (page 14 of 17)

• Credit Card Agreement

Original WFG Code # (if applicable)

WFGUS10045A/12.18

PERSONAL INFORMATION

Last Name Legal First Name

Middle Name Common Name

Social Security Number Date of Birth

Life License #

Spouse/Partner Last Name Spouse/Partner First Name

Home Phone Mobile Phone (Optional)

Email Address

Home Address

Street Apt. #

City State Zip Code

QUESTIONS

Are you a citizen or permanent resident of the United States, or are you legally eligible to work in the United States without restrictions?

Yes No

Do you have an active life insurance license? Yes No

Do you have an active securities license? Yes No

Agent Application

World Financial Group Insurance Agency

Fee

Please note that these are one-time fees separate from additional fees you are responsible for and must pay to operate your business as a licensed independent agent with World Financial Group Insurance Agency, Inc and its affiliated subsidiaries. These fees include, but are not limited to, a monthly Access Pass, charged at the beginning of each month’s commission cycle, which covers Errors & Omissions Insurance premiums, if applicable, and access to technology platforms and additional services.

Original WFG Code # (if applicable)

WFGUS10045A/12.18

PERSONAL INFORMATION

Last Name Legal First Name

Middle Name Common Name

Home Phone Mobile Phone (Optional)

Email Address

Home Address

City State

RECRUITER INFORMATION

Name of Recruiter Recruiter Code Number

I certify that:• No commission or other compensation can be paid to the applicant until the proper licenses and/or registrations

have been issued to the applicant.

• If the applicant is reinstating under a new hierarchy and has a debt balance, the debt balance will be transferred with the associate to the new hierarchy. The applicant may have incurred a debt balance during his/her time as an agent of World Financial Group Insurance Agency, Inc. and that balance may be still outstanding. I understand that it is my responsibility to discuss any potential outstanding debt with the applicant and the recruiter, and I will accept and be responsible for any such debt if this debt rolls to me pursuant to the rollup rules.

Applicant Entry Level (Check One)

Training Associate (01) Senior Associate (15) Associate (10) Other:

Senior Marketing Director’s Signature: Date:

Senior Marketing Director’s Code Number:

Agent SMD Approval

World Financial Group Insurance Agency

Please provide recruit’s personal information below for the SMD’s reference.

Form W-9(Rev. October 2018)Department of the Treasury Internal Revenue Service

Request for Taxpayer Identification Number and Certification

▶ Go to www.irs.gov/FormW9 for instructions and the latest information.

Give Form to the requester. Do not send to the IRS.

Pri

nt o

r ty

pe.

S

ee S

pec

ific

Inst

ruct

ions

on

pag

e 3.

1 Name (as shown on your income tax return). Name is required on this line; do not leave this line blank.

2 Business name/disregarded entity name, if different from above

3 Check appropriate box for federal tax classification of the person whose name is entered on line 1. Check only one of the following seven boxes.

Individual/sole proprietor or single-member LLC

C Corporation S Corporation Partnership Trust/estate

Limited liability company. Enter the tax classification (C=C corporation, S=S corporation, P=Partnership) ▶

Note: Check the appropriate box in the line above for the tax classification of the single-member owner. Do not check LLC if the LLC is classified as a single-member LLC that is disregarded from the owner unless the owner of the LLC is another LLC that is not disregarded from the owner for U.S. federal tax purposes. Otherwise, a single-member LLC that is disregarded from the owner should check the appropriate box for the tax classification of its owner.

Other (see instructions) ▶

4 Exemptions (codes apply only to certain entities, not individuals; see instructions on page 3):

Exempt payee code (if any)

Exemption from FATCA reporting

code (if any)

(Applies to accounts maintained outside the U.S.)

5 Address (number, street, and apt. or suite no.) See instructions.

6 City, state, and ZIP code

Requester’s name and address (optional)

7 List account number(s) here (optional)

Part I Taxpayer Identification Number (TIN)Enter your TIN in the appropriate box. The TIN provided must match the name given on line 1 to avoid backup withholding. For individuals, this is generally your social security number (SSN). However, for a resident alien, sole proprietor, or disregarded entity, see the instructions for Part I, later. For other entities, it is your employer identification number (EIN). If you do not have a number, see How to get a TIN, later.

Note: If the account is in more than one name, see the instructions for line 1. Also see What Name and Number To Give the Requester for guidelines on whose number to enter.

Social security number

– –

orEmployer identification number

–

Part II CertificationUnder 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); and2. 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. citizen or other U.S. person (defined below); and

4. The FATCA code(s) entered on this form (if any) indicating that I am exempt from FATCA reporting is correct.

Certification instructions. You must cross out item 2 above if you have been notified by the IRS that you are currently subject to backup withholding because you have failed to report all interest and dividends on your tax return. For real estate transactions, item 2 does not apply. For mortgage interest paid, acquisition or abandonment of secured property, cancellation of debt, contributions to an individual retirement arrangement (IRA), and generally, payments other than interest and dividends, you are not required to sign the certification, but you must provide your correct TIN. See the instructions for Part II, later.

Sign Here

Signature of U.S. person ▶ Date ▶

General InstructionsSection references are to the Internal Revenue Code unless otherwise noted.

Future developments. For the latest information about developments related to Form W-9 and its instructions, such as legislation enacted after they were published, go to www.irs.gov/FormW9.

Purpose of FormAn individual or entity (Form W-9 requester) who is required to file an information return with the IRS must obtain your correct taxpayer identification number (TIN) which may be your social security number (SSN), individual taxpayer identification number (ITIN), adoption taxpayer identification number (ATIN), or employer identification number (EIN), to report on an information return the amount paid to you, or other amount reportable on an information return. Examples of information returns include, but are not limited to, the following.

• Form 1099-INT (interest earned or paid)

• Form 1099-DIV (dividends, including those from stocks or mutual funds)

• Form 1099-MISC (various types of income, prizes, awards, or gross proceeds)

• Form 1099-B (stock or mutual fund sales and certain other transactions by brokers)

• Form 1099-S (proceeds from real estate transactions)

• Form 1099-K (merchant card and third party network transactions)

• Form 1098 (home mortgage interest), 1098-E (student loan interest), 1098-T (tuition)

• Form 1099-C (canceled debt)

• Form 1099-A (acquisition or abandonment of secured property)

Use Form W-9 only if you are a U.S. person (including a resident alien), to provide your correct TIN.

If you do not return Form W-9 to the requester with a TIN, you might be subject to backup withholding. See What is backup withholding, later.

Cat. No. 10231X Form W-9 (Rev. 10-2018)

Form W-9 (Rev. 10-2018) Page 2

By signing the filled-out form, you:

1. Certify that the TIN you are giving is correct (or you are waiting for a number to be issued),

2. Certify that you are not subject to backup withholding, or

3. Claim exemption from backup withholding if you are a U.S. exempt payee. If applicable, you are also certifying that as a U.S. person, your allocable share of any partnership income from a U.S. trade or business is not subject to the withholding tax on foreign partners' share of effectively connected income, and

4. Certify that FATCA code(s) entered on this form (if any) indicating that you are exempt from the FATCA reporting, is correct. See What is FATCA reporting, later, for further information.

Note: If you are a U.S. person and a requester gives you a form other than Form W-9 to request your TIN, you must use the requester’s form if it is substantially similar to this Form W-9.

Definition of a U.S. person. For federal tax purposes, you are considered a U.S. person if you are:

• An individual who is a U.S. citizen or U.S. resident alien;

• A partnership, corporation, company, or association created or organized in the United States or under the laws of the United States;

• An estate (other than a foreign estate); or

• A domestic trust (as defined in Regulations section 301.7701-7).

Special rules for partnerships. Partnerships that conduct a trade or business in the United States are generally required to pay a withholding tax under section 1446 on any foreign partners’ share of effectively connected taxable income from such business. Further, in certain cases where a Form W-9 has not been received, the rules under section 1446 require a partnership to presume that a partner is a foreign person, and pay the section 1446 withholding tax. Therefore, if you are a U.S. person that is a partner in a partnership conducting a trade or business in the United States, provide Form W-9 to the partnership to establish your U.S. status and avoid section 1446 withholding on your share of partnership income.

In the cases below, the following person must give Form W-9 to the partnership for purposes of establishing its U.S. status and avoiding withholding on its allocable share of net income from the partnership conducting a trade or business in the United States.

• In the case of a disregarded entity with a U.S. owner, the U.S. owner of the disregarded entity and not the entity;

• In the case of a grantor trust with a U.S. grantor or other U.S. owner, generally, the U.S. grantor or other U.S. owner of the grantor trust and not the trust; and

• In the case of a U.S. trust (other than a grantor trust), the U.S. trust (other than a grantor trust) and not the beneficiaries of the trust.

Foreign person. If you are a foreign person or the U.S. branch of a foreign bank that has elected to be treated as a U.S. person, do not use Form W-9. Instead, use the appropriate Form W-8 or Form 8233 (see Pub. 515, Withholding of Tax on Nonresident Aliens and Foreign Entities).

Nonresident alien who becomes a resident alien. Generally, only a nonresident alien individual may use the terms of a tax treaty to reduce or eliminate U.S. tax on certain types of income. However, most tax treaties contain a provision known as a “saving clause.” Exceptions specified in the saving clause may permit an exemption from tax to continue for certain types of income even after the payee has otherwise become a U.S. resident alien for tax purposes.

If you are a U.S. resident alien who is relying on an exception contained in the saving clause of a tax treaty to claim an exemption from U.S. tax on certain types of income, you must attach a statement to Form W-9 that specifies the following five items.

1. The treaty country. Generally, this must be the same treaty under which you claimed exemption from tax as a nonresident alien.

2. The treaty article addressing the income.3. The article number (or location) in the tax treaty that contains the

saving clause and its exceptions.4. The type and amount of income that qualifies for the exemption

from tax.5. Sufficient facts to justify the exemption from tax under the terms of

the treaty article.

Example. Article 20 of the U.S.-China income tax treaty allows an exemption from tax for scholarship income received by a Chinese student temporarily present in the United States. Under U.S. law, this student will become a resident alien for tax purposes if his or her stay in the United States exceeds 5 calendar years. However, paragraph 2 of the first Protocol to the U.S.-China treaty (dated April 30, 1984) allows the provisions of Article 20 to continue to apply even after the Chinese student becomes a resident alien of the United States. A Chinese student who qualifies for this exception (under paragraph 2 of the first protocol) and is relying on this exception to claim an exemption from tax on his or her scholarship or fellowship income would attach to Form W-9 a statement that includes the information described above to support that exemption.

If you are a nonresident alien or a foreign entity, give the requester the appropriate completed Form W-8 or Form 8233.

Backup WithholdingWhat is backup withholding? Persons making certain payments to you must under certain conditions withhold and pay to the IRS 24% of such payments. This is called “backup withholding.” Payments that may be subject to backup withholding include interest, tax-exempt interest, dividends, broker and barter exchange transactions, rents, royalties, nonemployee pay, payments made in settlement of payment card and third party network transactions, and certain payments from fishing boat operators. Real estate transactions are not subject to backup withholding.

You will not be subject to backup withholding on payments you receive if you give the requester your correct TIN, make the proper certifications, and report all your taxable interest and dividends on your tax return.

Payments you receive will be subject to backup withholding if:

1. You do not furnish your TIN to the requester,

2. You do not certify your TIN when required (see the instructions for Part II for details),

3. The IRS tells the requester that you furnished an incorrect TIN,

4. The IRS tells you that you are subject to backup withholding because you did not report all your interest and dividends on your tax return (for reportable interest and dividends only), or

5. You do not certify to the requester that you are not subject to backup withholding under 4 above (for reportable interest and dividend accounts opened after 1983 only).

Certain payees and payments are exempt from backup withholding. See Exempt payee code, later, and the separate Instructions for the Requester of Form W-9 for more information.

Also see Special rules for partnerships, earlier.

What is FATCA Reporting?The Foreign Account Tax Compliance Act (FATCA) requires a participating foreign financial institution to report all United States account holders that are specified United States persons. Certain payees are exempt from FATCA reporting. See Exemption from FATCA reporting code, later, and the Instructions for the Requester of Form W-9 for more information.

Updating Your InformationYou must provide updated information to any person to whom you claimed to be an exempt payee if you are no longer an exempt payee and anticipate receiving reportable payments in the future from this person. For example, you may need to provide updated information if you are a C corporation that elects to be an S corporation, or if you no longer are tax exempt. In addition, you must furnish a new Form W-9 if the name or TIN changes for the account; for example, if the grantor of a grantor trust dies.

PenaltiesFailure to furnish TIN. If you fail to furnish your correct TIN to a requester, you are subject to a penalty of $50 for each such failure unless your failure is due to reasonable cause and not to willful neglect.

Civil penalty for false information with respect to withholding. If you make a false statement with no reasonable basis that results in no backup withholding, you are subject to a $500 penalty.

Form W-9 (Rev. 10-2018) Page 3

Criminal penalty for falsifying information. Willfully falsifying certifications or affirmations may subject you to criminal penalties including fines and/or imprisonment.

Misuse of TINs. If the requester discloses or uses TINs in violation of federal law, the requester may be subject to civil and criminal penalties.

Specific InstructionsLine 1You must enter one of the following on this line; do not leave this line blank. The name should match the name on your tax return.

If this Form W-9 is for a joint account (other than an account maintained by a foreign financial institution (FFI)), list first, and then circle, the name of the person or entity whose number you entered in Part I of Form W-9. If you are providing Form W-9 to an FFI to document a joint account, each holder of the account that is a U.S. person must provide a Form W-9.

a. Individual. Generally, enter the name shown on your tax return. If you have changed your last name without informing the Social Security Administration (SSA) of the name change, enter your first name, the last name as shown on your social security card, and your new last name.

Note: ITIN applicant: Enter your individual name as it was entered on your Form W-7 application, line 1a. This should also be the same as the name you entered on the Form 1040/1040A/1040EZ you filed with your application.

b. Sole proprietor or single-member LLC. Enter your individual name as shown on your 1040/1040A/1040EZ on line 1. You may enter your business, trade, or “doing business as” (DBA) name on line 2.

c. Partnership, LLC that is not a single-member LLC, C corporation, or S corporation. Enter the entity's name as shown on the entity's tax return on line 1 and any business, trade, or DBA name on line 2.

d. Other entities. Enter your name as shown on required U.S. federal tax documents on line 1. This name should match the name shown on the charter or other legal document creating the entity. You may enter any business, trade, or DBA name on line 2.

e. Disregarded entity. For U.S. federal tax purposes, an entity that is disregarded as an entity separate from its owner is treated as a “disregarded entity.” See Regulations section 301.7701-2(c)(2)(iii). Enter the owner's name on line 1. The name of the entity entered on line 1 should never be a disregarded entity. The name on line 1 should be the name shown on the income tax return on which the income should be reported. For example, if a foreign LLC that is treated as a disregarded entity for U.S. federal tax purposes has a single owner that is a U.S. person, the U.S. owner's name is required to be provided on line 1. If the direct owner of the entity is also a disregarded entity, enter the first owner that is not disregarded for federal tax purposes. Enter the disregarded entity's name on line 2, “Business name/disregarded entity name.” If the owner of the disregarded entity is a foreign person, the owner must complete an appropriate Form W-8 instead of a Form W-9. This is the case even if the foreign person has a U.S. TIN.

Line 2If you have a business name, trade name, DBA name, or disregarded entity name, you may enter it on line 2.

Line 3Check the appropriate box on line 3 for the U.S. federal tax classification of the person whose name is entered on line 1. Check only one box on line 3.

IF the entity/person on line 1 is a(n) . . .

THEN check the box for . . .

• Corporation Corporation

• Individual • Sole proprietorship, or • Single-member limited liability company (LLC) owned by an individual and disregarded for U.S. federal tax purposes.

Individual/sole proprietor or single-member LLC

• LLC treated as a partnership for U.S. federal tax purposes, • LLC that has filed Form 8832 or 2553 to be taxed as a corporation, or • LLC that is disregarded as an entity separate from its owner but the owner is another LLC that is not disregarded for U.S. federal tax purposes.

Limited liability company and enter the appropriate tax classification. (P= Partnership; C= C corporation; or S= S corporation)

• Partnership Partnership

• Trust/estate Trust/estate

Line 4, ExemptionsIf you are exempt from backup withholding and/or FATCA reporting, enter in the appropriate space on line 4 any code(s) that may apply to you.

Exempt payee code.

• Generally, individuals (including sole proprietors) are not exempt from backup withholding.

• Except as provided below, corporations are exempt from backup withholding for certain payments, including interest and dividends.

• Corporations are not exempt from backup withholding for payments made in settlement of payment card or third party network transactions.

• Corporations are not exempt from backup withholding with respect to attorneys’ fees or gross proceeds paid to attorneys, and corporations that provide medical or health care services are not exempt with respect to payments reportable on Form 1099-MISC.

The following codes identify payees that are exempt from backup withholding. Enter the appropriate code in the space in line 4.

1—An organization exempt from tax under section 501(a), any IRA, or a custodial account under section 403(b)(7) if the account satisfies the requirements of section 401(f)(2)

2—The United States or any of its agencies or instrumentalities

3—A state, the District of Columbia, a U.S. commonwealth or possession, or any of their political subdivisions or instrumentalities

4—A foreign government or any of its political subdivisions, agencies, or instrumentalities

5—A corporation

6—A dealer in securities or commodities required to register in the United States, the District of Columbia, or a U.S. commonwealth or possession

7—A futures commission merchant registered with the Commodity Futures Trading Commission

8—A real estate investment trust

9—An entity registered at all times during the tax year under the Investment Company Act of 1940

10—A common trust fund operated by a bank under section 584(a)

11—A financial institution

12—A middleman known in the investment community as a nominee or custodian

13—A trust exempt from tax under section 664 or described in section 4947

Form W-9 (Rev. 10-2018) Page 4

The following chart shows types of payments that may be exempt from backup withholding. The chart applies to the exempt payees listed above, 1 through 13.

IF the payment is for . . . THEN the payment is exempt for . . .

Interest and dividend payments All exempt payees except for 7

Broker transactions Exempt payees 1 through 4 and 6 through 11 and all C corporations. S corporations must not enter an exempt payee code because they are exempt only for sales of noncovered securities acquired prior to 2012.

Barter exchange transactions and patronage dividends

Exempt payees 1 through 4

Payments over $600 required to be reported and direct sales over $5,0001

Generally, exempt payees 1 through 52

Payments made in settlement of payment card or third party network transactions

Exempt payees 1 through 4

1 See Form 1099-MISC, Miscellaneous Income, and its instructions.2 However, the following payments made to a corporation and reportable on Form 1099-MISC are not exempt from backup

withholding: medical and health care payments, attorneys’ fees, gross proceeds paid to an attorney reportable under section 6045(f), and payments for services paid by a federal executive agency.

Exemption from FATCA reporting code. The following codes identify payees that are exempt from reporting under FATCA. These codes apply to persons submitting this form for accounts maintained outside of the United States by certain foreign financial institutions. Therefore, if you are only submitting this form for an account you hold in the United States, you may leave this field blank. Consult with the person requesting this form if you are uncertain if the financial institution is subject to these requirements. A requester may indicate that a code is not required by providing you with a Form W-9 with “Not Applicable” (or any similar indication) written or printed on the line for a FATCA exemption code.

A—An organization exempt from tax under section 501(a) or any individual retirement plan as defined in section 7701(a)(37)

B—The United States or any of its agencies or instrumentalities

C—A state, the District of Columbia, a U.S. commonwealth or possession, or any of their political subdivisions or instrumentalities

D—A corporation the stock of which is regularly traded on one or more established securities markets, as described in Regulations section 1.1472-1(c)(1)(i)

E—A corporation that is a member of the same expanded affiliated group as a corporation described in Regulations section 1.1472-1(c)(1)(i)

F—A dealer in securities, commodities, or derivative financial instruments (including notional principal contracts, futures, forwards, and options) that is registered as such under the laws of the United States or any state

G—A real estate investment trust

H—A regulated investment company as defined in section 851 or an entity registered at all times during the tax year under the Investment Company Act of 1940

I—A common trust fund as defined in section 584(a)

J—A bank as defined in section 581

K—A broker

L—A trust exempt from tax under section 664 or described in section 4947(a)(1)

M—A tax exempt trust under a section 403(b) plan or section 457(g) plan

Note: You may wish to consult with the financial institution requesting this form to determine whether the FATCA code and/or exempt payee code should be completed.

Line 5Enter your address (number, street, and apartment or suite number). This is where the requester of this Form W-9 will mail your information returns. If this address differs from the one the requester already has on file, write NEW at the top. If a new address is provided, there is still a chance the old address will be used until the payor changes your address in their records.

Line 6Enter your city, state, and ZIP code.

Part I. Taxpayer Identification Number (TIN)Enter your TIN in the appropriate box. If you are a resident alien and you do not have and are not eligible to get an SSN, your TIN is your IRS individual taxpayer identification number (ITIN). Enter it in the social security number box. If you do not have an ITIN, see How to get a TIN below.

If you are a sole proprietor and you have an EIN, you may enter either your SSN or EIN.

If you are a single-member LLC that is disregarded as an entity separate from its owner, enter the owner’s SSN (or EIN, if the owner has one). Do not enter the disregarded entity’s EIN. If the LLC is classified as a corporation or partnership, enter the entity’s EIN.

Note: See What Name and Number To Give the Requester, later, for further clarification of name and TIN combinations.

How to get a TIN. If you do not have a TIN, apply for one immediately. To apply for an SSN, get Form SS-5, Application for a Social Security Card, from your local SSA office or get this form online at www.SSA.gov. You may also get this form by calling 1-800-772-1213. Use Form W-7, Application for IRS Individual Taxpayer Identification Number, to apply for an ITIN, or Form SS-4, Application for Employer Identification Number, to apply for an EIN. You can apply for an EIN online by accessing the IRS website at www.irs.gov/Businesses and clicking on Employer Identification Number (EIN) under Starting a Business. Go to www.irs.gov/Forms to view, download, or print Form W-7 and/or Form SS-4. Or, you can go to www.irs.gov/OrderForms to place an order and have Form W-7 and/or SS-4 mailed to you within 10 business days.

If you are asked to complete Form W-9 but do not have a TIN, apply for a TIN and write “Applied For” in the space for the TIN, sign and date the form, and give it to the requester. For interest and dividend payments, and certain payments made with respect to readily tradable instruments, generally you will have 60 days to get a TIN and give it to the requester before you are subject to backup withholding on payments. The 60-day rule does not apply to other types of payments. You will be subject to backup withholding on all such payments until you provide your TIN to the requester.

Note: Entering “Applied For” means that you have already applied for a TIN or that you intend to apply for one soon.

Caution: A disregarded U.S. entity that has a foreign owner must use the appropriate Form W-8.

Part II. CertificationTo establish to the withholding agent that you are a U.S. person, or resident alien, sign Form W-9. You may be requested to sign by the withholding agent even if item 1, 4, or 5 below indicates otherwise.

For a joint account, only the person whose TIN is shown in Part I should sign (when required). In the case of a disregarded entity, the person identified on line 1 must sign. Exempt payees, see Exempt payee code, earlier.

Signature requirements. Complete the certification as indicated in items 1 through 5 below.

Form W-9 (Rev. 10-2018) Page 5

1. Interest, dividend, and barter exchange accounts opened before 1984 and broker accounts considered active during 1983. You must give your correct TIN, but you do not have to sign the certification.

2. Interest, dividend, broker, and barter exchange accounts opened after 1983 and broker accounts considered inactive during 1983. You must sign the certification or backup withholding will apply. If you are subject to backup withholding and you are merely providing your correct TIN to the requester, you must cross out item 2 in the certification before signing the form.

3. Real estate transactions. You must sign the certification. You may cross out item 2 of the certification.

4. Other payments. You must give your correct TIN, but you do not have to sign the certification unless you have been notified that you have previously given an incorrect TIN. “Other payments” include payments made in the course of the requester’s trade or business for rents, royalties, goods (other than bills for merchandise), medical and health care services (including payments to corporations), payments to a nonemployee for services, payments made in settlement of payment card and third party network transactions, payments to certain fishing boat crew members and fishermen, and gross proceeds paid to attorneys (including payments to corporations).

5. Mortgage interest paid by you, acquisition or abandonment of secured property, cancellation of debt, qualified tuition program payments (under section 529), ABLE accounts (under section 529A), IRA, Coverdell ESA, Archer MSA or HSA contributions or distributions, and pension distributions. You must give your correct TIN, but you do not have to sign the certification.

What Name and Number To Give the RequesterFor this type of account: Give name and SSN of:

1. Individual The individual

2. Two or more individuals (joint account) other than an account maintained by an FFI

The actual owner of the account or, if combined funds, the first individual on

the account1

3. Two or more U.S. persons (joint account maintained by an FFI)

Each holder of the account

4. Custodial account of a minor (Uniform Gift to Minors Act)

The minor2

5. a. The usual revocable savings trust (grantor is also trustee) b. So-called trust account that is not a legal or valid trust under state law

The grantor-trustee1

The actual owner1

6. Sole proprietorship or disregarded entity owned by an individual

The owner3

7. Grantor trust filing under Optional Form 1099 Filing Method 1 (see Regulations section 1.671-4(b)(2)(i)(A))

The grantor*

For this type of account: Give name and EIN of:8. Disregarded entity not owned by an

individualThe owner

9. A valid trust, estate, or pension trust Legal entity4

10. Corporation or LLC electing corporate status on Form 8832 or Form 2553

The corporation

11. Association, club, religious, charitable, educational, or other tax-exempt organization

The organization

12. Partnership or multi-member LLC The partnership

13. A broker or registered nominee The broker or nominee

For this type of account: Give name and EIN of:14. Account with the Department of

Agriculture in the name of a public entity (such as a state or local government, school district, or prison) that receives agricultural program payments

The public entity

15. Grantor trust filing under the Form 1041 Filing Method or the Optional Form 1099 Filing Method 2 (see Regulations section 1.671-4(b)(2)(i)(B))

The trust

1 List first and circle the name of the person whose number you furnish. If only one person on a joint account has an SSN, that person’s number must be furnished.2 Circle the minor’s name and furnish the minor’s SSN.3 You must show your individual name and you may also enter your business or DBA name on the “Business name/disregarded entity” name line. You may use either your SSN or EIN (if you have one), but the IRS encourages you to use your SSN.4 List first and circle the name of the trust, estate, or pension trust. (Do not furnish the TIN of the personal representative or trustee unless the legal entity itself is not designated in the account title.) Also see Special rules for partnerships, earlier.

*Note: The grantor also must provide a Form W-9 to trustee of trust.

Note: If no name is circled when more than one name is listed, the number will be considered to be that of the first name listed.

Secure Your Tax Records From Identity TheftIdentity theft occurs when someone uses your personal information such as your name, SSN, or other identifying information, without your permission, to commit fraud or other crimes. An identity thief may use your SSN to get a job or may file a tax return using your SSN to receive a refund.

To reduce your risk:

• Protect your SSN,

• Ensure your employer is protecting your SSN, and

• Be careful when choosing a tax preparer.

If your tax records are affected by identity theft and you receive a notice from the IRS, respond right away to the name and phone number printed on the IRS notice or letter.

If your tax records are not currently affected by identity theft but you think you are at risk due to a lost or stolen purse or wallet, questionable credit card activity or credit report, contact the IRS Identity Theft Hotline at 1-800-908-4490 or submit Form 14039.

For more information, see Pub. 5027, Identity Theft Information for Taxpayers.

Victims of identity theft who are experiencing economic harm or a systemic problem, or are seeking help in resolving tax problems that have not been resolved through normal channels, may be eligible for Taxpayer Advocate Service (TAS) assistance. You can reach TAS by calling the TAS toll-free case intake line at 1-877-777-4778 or TTY/TDD 1-800-829-4059.

Protect yourself from suspicious emails or phishing schemes. Phishing is the creation and use of email and websites designed to mimic legitimate business emails and websites. The most common act is sending an email to a user falsely claiming to be an established legitimate enterprise in an attempt to scam the user into surrendering private information that will be used for identity theft.

Form W-9 (Rev. 10-2018) Page 6

The IRS does not initiate contacts with taxpayers via emails. Also, the IRS does not request personal detailed information through email or ask taxpayers for the PIN numbers, passwords, or similar secret access information for their credit card, bank, or other financial accounts.

If you receive an unsolicited email claiming to be from the IRS, forward this message to phishing@irs.gov. You may also report misuse of the IRS name, logo, or other IRS property to the Treasury Inspector General for Tax Administration (TIGTA) at 1-800-366-4484. You can forward suspicious emails to the Federal Trade Commission at spam@uce.gov or report them at www.ftc.gov/complaint. You can contact the FTC at www.ftc.gov/idtheft or 877-IDTHEFT (877-438-4338). If you have been the victim of identity theft, see www.IdentityTheft.gov and Pub. 5027.

Visit www.irs.gov/IdentityTheft to learn more about identity theft and how to reduce your risk.

Privacy Act NoticeSection 6109 of the Internal Revenue Code requires you to provide your correct TIN to persons (including federal agencies) who are required to file information returns with the IRS to report interest, dividends, or certain other income paid to you; mortgage interest you paid; the acquisition or abandonment of secured property; the cancellation of debt; or contributions you made to an IRA, Archer MSA, or HSA. The person collecting this form uses the information on the form to file information returns with the IRS, reporting the above information. Routine uses of this information include giving it to the Department of Justice for civil and criminal litigation and to cities, states, the District of Columbia, and U.S. commonwealths and possessions for use in administering their laws. The information also may be disclosed to other countries under a treaty, to federal and state agencies to enforce civil and criminal laws, or to federal law enforcement and intelligence agencies to combat terrorism. You must provide your TIN whether or not you are required to file a tax return. Under section 3406, payers must generally withhold a percentage of taxable interest, dividend, and certain other payments to a payee who does not give a TIN to the payer. Certain penalties may also apply for providing false or fraudulent information.

A Transamerica Company For internal use only. Not for public distribution.

Agent Insurance GuideWorld Financial Group Insurance Agency, Inc.

World Financial Insurance Agency, Inc.World Financial Group Insurance Agency of Hawaii, Inc.

World Financial Group Insurance Agency of Massachusetts, Inc.WFG Insurance Agency of Puerto Rico, Inc.

Introduction

Congratulations on choosing to be a licensed agent with World Financial Group Insurance Agency, Inc., World Financial Insurance Agency, Inc., World Financial Group Insurance Agency of Hawaii, Inc., World Financial Group Insurance Agency of Massachusetts, Inc. and/or WFG Insurance Agency of Puerto Rico, Inc. (collectively WFGIA). As you know WFGIA is a unique business that is dedicated to helping families achieve their goals. Offering the right product(s) to the right people in a professional and transparent manner is important in helping you and WFGIA be successful. As you build strong relationships with your customers and look to address their unique financial needs, remember that you are in business for yourself but you are not by yourself. There is a team of individuals ready to assist and answer your questions.

Understanding the requirements of local, state and federal regulations is important. It is up to you to familiarize yourself with any and all rules that may apply to you being a licensed insurance agent conducting your business. You should also be mindful of any requirements in your contracting with product providers. Maintaining high ethical standards can help you not only exceed customer expectations, but can also help you protect your business from potential customer complaints.

Thank you for your commitment in making WFGIA a unique and successful organization, and for adhering to the highest standards in helping families achieve their dreams.

Tom Dempsey

WFGIA is committed to the following ethical principles in the sale of insurance products:

• To conduct business according to high standards of honesty and fairness and to treat customers as we would expect to be treated

• To provide competent and customer-focused sales and service

• To compete fairly

• To provide advertising and sales material whose content is clear, honest, and fair

• To handle customer complaints and disputes fairly and promptly

• To maintain a system of supervision and review reasonably designed to achieve these goals

WFGUS10045C/12.18 4 of 41

Contents

Ethical Sales Practice Guidelines 7Before You Make a Sales Call or Schedule a Meeting with a Customer 7When Meeting a Customer or Prospect 7Know the Customer 7Presentations and Proposals 7During a Meeting 7Following Your Meeting 8Know Your Limits: Tax & Legal Advice 8Policy Delivery: Why it’s Important 8

Basing the Sale on Customer’s Needs and Financial Objectives 8Fact Finding 9Selling to Senior Adults 9

Communicating with Seniors 9High Pressure Sales Tactics / Creating Sense of Urgency 9Suitability 10Diminished Capacity 10Suspected Abuse or Financial Exploitation 11

State Specific Requirement 11California 11

Solicitation of Military Personnel 12Guidelines for Solicitation of and Sales to Military Personnel 12

Life Insurance as a Tool to Meet the Needs of Customers 13Identify the Need for Death Benefit Protection 13

Determining the Death Benefit Need 13Identify and Quantify any Goals or Needs for Cash Value 13

Long-Term Care Insurance as a Tool to Meet the Needs of Customers 13Long Term Care Insurance Accelerated Death Benefit Riders 14

Annuities as a Tool to Meet the Needs of Customers 14Determine the Customer’s Financial Objectives 14Calculate the Need for Annuities 15

Retirement Goals 15Estimate Financial Situation at Desired Retirement Age 15Determine the Additional Monthly Income Desired from the Annuity 15Rule Out Certain Products 15Determine What’s Affordable 15Put the Customer First 15

Buying a Qualified Deferred Annuity 16Buying a Non-Qualified Deferred Annuity 16

Special Considerations for Indexed Annuities and Indexed Life Insurance 16Privacy Regulations 17

Protecting Financial Information 17Protecting Health Information 17Do You Sell Health Plans? 17Even If You Don’t Sell Health Plans 18

WFGUS10045C/12.18 5 of 41

Licensing and Appointment 18What’s Required 18Have the Right Kind of Insurance License 18Wait Until You Are Properly Authorized 18Be Licensed and Appointed in the Right State for Out-of-State Business 19Just in Time Appointment Processing 19Maintain and Renew Your License and Appointments to Continue Sales 19Appointment and Background Checks 19

Errors & Omissions (E&O) Insurance 19Non-Licensed Staff 20Training and Education 20

Titles with Seniors 20Ethics and Compliance Training 20Meeting and Training Standards 20Product Training 21Continuing Education 21

Information Security 21Customer Information Security Standards 21Physical Security Standards 21Electronic Records Security Standards 22Agent Security Standards 22Reporting Data Breaches 22

Trade Practices 22Boycott, Coercion or Intimidation 22Defamation 22Discrimination 22False or Deceptive Advertising 22Illegal Premiums or Charges 23Insurance Churning 23Misrepresentation in Insurance Applications 23Misrepresentation of an Insurance Policy 23Rebating 23Twisting 23Borrowing from or Loaning Money to Customers 23Tie-Ins 23

Examples of Inappropriate Actions 23Quick Reference Do’s and Don’ts 23Business Practices 25

New York State Regulation 194 – Producer Compensation Transparency 25Telemarketing 26Use of Prerecorded, Autodialed Call/Texts or Fax Machines for Marketing 26Email Marketing 26

Customer Funds 27Forms of Payments 27

Policy Replacements 27Overview 27

Life Insurance Replacement in New York 27

WFGUS10045C/12.18 6 of 41

General Guidelines 27Life Insurance 27Annuities 28Long Term Care Insurance 28Other Points to Remember Regarding Replacements 28Regulations for Financed Sales 28

Advertising 29Guidelines for Creating Advertising Materials 29Instructions for Advertising Review 30Advertising Requiring Review 30Approved Social Media Sites 30Protecting the WFG Brand and the use of the Transamerica Name, Image or Logo 30Use of Professional Designations 31Sales Illustrations 31

General Guidelines for Sales Illustrations 31Guidelines for Traditional Life Insurance 32Guidelines for Sales Illustrations for Deferred Annuities 32

Insurance Fraud 32Fraud and Deception 32

Identifying Suspicious Activity 33Potential Warning Signs of Fraud 33Life Insurance Fraud Indicators 33Application Fraud Indicators 34

Anti-Bribery & Corruption Policy 34Bribery 34Gifts & Entertainment 34Facilitation Payments & Kickbacks 35

Anti-Money Laundering and the USA PATRIOT Act 35Money Laundering and Terrorist Financing Defined 35Customer Identification Program (CIP) or “Know Your Customer” 35Red Flags 35Awareness Alert 36AML and Know Your Customer 36Willful Blindness 36

WFGIA Anti-Money Laundering Requirement 36Handling Complaints and Other Special Customer Communications 37

Lawsuits and Policy Claims 37Handling Customer Communications 37

Supervision 38Code of Professional Conduct for Agents 38

Principles 38Use Qualified and Trained Agents 39Compete Fairly 39Sell Fairly and Use Clear and Accurate Sales Materials 39Appropriately Handle and Monitor Complaints 39

WFGUS10045C/12.18 7 of 41

Ethical Sales Practice Guidelines

As a licensed WFGIA insurance agent (“agent” or “you”), you have certain legal, ethical and professional responsibilities to fulfill every day and with every customer. Every customer has unique needs, but by maintaining a structured and consistent ethical approach in servicing your customers and prospects you are much more likely to be successful in the long-term. In addition to the WFGIA Agent Insurance Guide, agents should also check with product providers to see if they have any specific policies and procedures that must be followed in the sale of their products or services.

Before You Make a Sales Call or Schedule a Meeting with a Customer

• Do your homework. Educate yourself about your responsibilities as an insurance professional and make doing business the right way a priority.

• Offer only products that you are authorized to distribute. Make sure you are properly licensed and appointed in the right state(s). Some states require special training in annuities, indexed products, and LTC products before an agent may sell such products.

• Do not use professional designations that indicate or imply that you have special certification or training in such a way that it may mislead individuals.

• Know your product and only offer products where you have sufficient knowledge, training and experience.

• Check the National, State and Company specific Do Not Call Lists before making solicitation calls.

When Meeting a Customer or Prospect

• Properly identity yourself as a life insurance agent and your affiliation with WFGIA.

Know the Customer

• Knowing who your customer is and their needs is important. You should always follow a thorough fact-finding and needs-analysis process to understand the customer’s insurable needs and financial goals and objectives.

Presentations and Proposals

• Put the needs of the customer first. Base any recommendations on the customer’s circumstances and objectives and maintain notes and other documentation supporting your recommendation(s).

• Use only WFGIA approved sales material.

• Use words, terms, and symbols that accurately describe the features, benefits and limitations of the products you are licensed and appointed to sell. Avoid incomplete, misleading statements, or prohibited words.

• Disclose all relevant information about a product or service that you recommend accurately and comprehensively.

• Explain a product’s features, benefits, loads, fees, limitations, and any charges in a balanced and fair way.

• Fully explain the hypothetical nature of illustrations. Point out their assumptions and limitations. Be sure to explain guaranteed and non-guaranteed elements. Do not imply a guarantee or a product feature unless it is specifically built into the product that the customer chooses.

• Policy replacements should only be recommended after a careful, thorough (and well-documented) analysis has been done by an agent comparing short and long-term advantages and disadvantages to the customer. Be familiar with the replacement requirements where you are licensed and conduct business.

During a Meeting

• Reconfirm the customer’s reason(s) for purchasing the product. Reconfirm the financial objective the product addresses and the explicit insurance need it satisfies.

• Provide the customer with a copy of any sales illustration(s) you present. Have the customer sign a copy of the illustration that can be kept in your file.

• Provide the customer with any state mandated notices, buyer guides, and other required notices or receipts at the appropriate time during the sales process.

WFGUS10045C/12.18 8 of 41

• Review with the customer any state mandated, or otherwise required, or optional disclosure forms verifying that you have discussed all relevant information with the customer. Obtain customer signatures where appropriate.

• Make sure the customer carefully and thoroughly answers all questions on the application. If you must record answers, the best practice is to read each question to the customer out loud and make a note in your customer notes to this effect.

• Always instruct the customer to make the check payable to the life insurance company. Do not accept checks made payable to you or to WFGIA. Checks made payable to WFGIA or the agent must be returned to the customer.

Following Your Meeting

• Promptly submit the policy application, replacement forms (if applicable), and premium to the insurance company.

• Provide copies of the application and replacement forms to the customer.

• Promptly deliver the policy in person to the customer and again review the main features and terms of the policy. Obtain a signed policy delivery receipt and a signed copy of any required amendments, if applicable. Keep copies of the documents for your records and forward originals to the insurance company. If it is necessary to mail the policy to the owner, you should send it certified mail, return receipt requested. Once you receive the receipt back from the post office, send a copy to the insurance company.

• As a best practice, you should consider following up with the customer with a letter or communication thanking the customer for their purchase and restating the customer’s reasons for buying the policy and the needs and objectives it helps meet.

• Maintain a complete file for each customer and be aware of any compliance related policies and procedures of WFGIA and any insurance companies with which you are appointed.

• Always try to respond to customers in a timely and professional manner. Provide any written complaints or grievances immediately to your Senior Marketing Director (“SMD”) and/or WFGIA Compliance as soon as you receive them.

Know Your Limits: Tax & Legal Advice

• Generally, an agent may comment upon the tax treatment or features of the insurance product that is being offered. But, offering tax or legal advice is beyond your scope as a WFGIA agent. WFGIA does not give tax or legal advice and you are not authorized to provide such advice on behalf of WFGIA. WFGIA always recommends that individuals consult a tax and/or legal specialist that can sufficiently understand a customer’s unique tax or legal requirements.

Policy Delivery: Why it’s Important

• Acceptance of the policy or contract is one of the last acts that must occur (along with payment of premium) in order for the policy or contract to be placed in-force. All policies include a “right to examine” (also called “right to cancel” or “free look”) provision clause that allows the customer a period of time (usually 10-30 days) to examine the policy and, if they choose, return the policy for a full refund.

• Prompt delivery of the policy, along with obtaining a delivery receipt, is critical to allow the customer their right to examine the policy.

• Delivery in person is an opportunity to review the product features with the customer and build the relationship.

• Deliver the policy to the customer in the state the product was solicited and written.

• In any subsequent complaint or dispute over the policy, proof of delivery may be a key factor in establishing whether the customer was afforded the “right to examine” and failed to exercise it.

Basing the Sale on Customer’s Needs and Financial Objectives

As a WFGIA insurance agent, it is your professional and ethical responsibility to know your customers. You need to put customers first. Understanding the needs of the customer and their unique circumstances is important. Only after understanding your customer’s circumstances and needs should you begin to discuss how an appropriate product may work in meeting those needs and objectives.

WFGUS10045C/12.18 9 of 41

• Developing the relationship with the customer and focusing on their needs will help develop better expectations, greater understanding and trust, lead to higher persistency and renewals, and establish the framework from which you can continue to build a successful practice.

Some of the factors to consider as you are getting to know your customer include:

• Understanding the customer’s financial status and circumstances: This would include age, occupation, marital status, dependents, annual gross income, future earnings expectations, income and estate tax status, discretionary income, assets, liabilities, budget or expenses, value of portfolio, net worth, emergency reserves, retirement savings, etc.

• Insurance needs: Amount(s) of any existing insurance, health status, amount of death benefit protection, cash value for estate liquidity, mortgage, family income, education, business planning, retirement, accelerated death benefits, etc.

• Investment objectives: Determine the customer’s investment objective (e.g., income, tax deferral, accumulation, retirement savings, etc.).

• Time horizon for investment: When does the customer expect to need access to the investment (e.g., immediately, 1-3 years, 3-5 years, greater than 5 years, etc.).

• Risk tolerance: Determine how much risk the customer’s willing to accept with his/her investment. For customers who are seeking capital appreciation or growth, an equity indexed annuity may not be the appropriate investment vehicle.

• Affordability of premium: Whether the customer can afford the required or planned premium and whether the customer has sufficient discretionary income or assets to sustain payments over the long term without lapsing the policy.

Fact Finding

While working with customers you will gather a lot of information about them. Agents are required to document and record customers’ responses and maintain such information in your customer file. Agents should make note of the customers’ needs, products discussed, products recommended, the basis for any recommendation(s), and whether or not the recommendation was followed.

Selling to Senior Adults

Communicating with Seniors

Regulators are increasingly concerned about the way financial services professionals communicate and interact with senior prospects or customers. When an agent works with a senior customer they should:

• Provide ample opportunity to ask questions about the products discussed.

• Avoid using industry jargon. Instead, use plain language and marketing materials with large font, if available.

• Test the customer’s understanding of the proposed solution.

• Use communications that offer a fair evaluation of the product(s) features, benefits, limitations, fees, expenses and risks. Communication must be based on the merits of a product or service, company or agent, and not on dire predictions about the future, unwarranted claims about the need to act quickly, or any other methods of creating a false sense of urgency.

• Document your conversations in the event there are problems with lack of recall or to help resolve any misunderstandings/misinterpretations.

High Pressure Sales Tactics / Creating Sense of Urgency

All communications must be fair and balanced in nature and based on principals of good faith and fair dealing. Communications should not create a sense of urgency or pressure to take action with respect a product or service. Agents may not employ any marketing that may induce the purchase of a product or service through force, threat, fright or undue pressure. Terms or phrases such as these are generally not acceptable and should not be used with seniors:

• Take advantage of this offer today or it may expire

WFGUS10045C/12.18 10 of 41

• Limited time offer

• Don’t delay

• Don’t become a statistic

• Act now

Suitability

Determining the appropriateness of a product or service is a regulatory requirement and requires a careful analysis to determine the customer’s financial needs, investment goals/objective, risk tolerance, and time horizon.

When doing business with senior customers, you have a heightened obligation to make sure that such customer fully understands all aspects of the product being recommended. While you should always know all of the essential facts related to every customer prior to any sale that you make, when making sales to seniors you should take extra care to:

• Clearly explain that you are an insurance agent and that you are soliciting a life insurance policy or annuity. Try to avoid using any confusing terms or misleading names or titles.

• Do not use any professional designations that indicate or imply that you have special training or certification in such a way as to mislead any person.

• Determine a senior’s needs, objectives, and risk tolerance, as well as the appropriateness of the product for the circumstances. A senior’s advanced age and special circumstances are significant factors in making these determinations.

• Understand the customer’s expenses (e.g., mortgage, medical expenses, college expenses, etc.).

• Determine customer’s liquidity needs.

• Avoid high-pressure selling tactics. Some seniors may be vulnerable and easily frightened, intimidated, or confused. While it is important to help such a customer identify and meet real needs, take extra care not to imply, suggest, or cause alarm or fright.

• Avoid using statistics or facts that will mislead, confuse, or give false impressions.

• Reconsider the sale if the senior seems confused or unable to understand it.

• Avoid any appearance of “overselling” or “stacking.” Many agents have been investigated and fined, suspended, or sued for selling more insurance than a senior needs or can afford. Protect yourself by being conservative when determining the reasons, needs, and suitability of the purchase and by careful documentation.

• Maintain good documentation and notes. This could include having the customer sign-off on copies of notes and other types of meeting summaries.

You must ensure that a customer fully understands the impacts of any transaction executed on his/her behalf. It is important for you to ensure the customer fully understands the potential risks and ramifications of a financial decision.

Diminished Capacity

One of the most troubling and sensitive issues agents face in dealing with seniors involves customers who exhibit signs of diminished mental capacity. In these situations, a customer may no longer be capable of making his/her own financial decisions.

Agents should be aware of the warning signs that may indicate diminished mental capacity and learn to recognize the potential signs of a customer who is impaired due to a physical, mental, or sensory disability. If a customer exhibits any of the following behaviors or characteristics, or any behaviors or characteristics that raise concerns, agents should contact the Compliance Department or SMD for guidance. Customers with diminished capacity may exhibit the following behaviors which indicate their inability to properly weigh financial decisions (not an exhaustive list):

• The customer has difficulty communicating with you.

• The customer appears unable to process simple concepts. His/her questions and comments seem disconnected or contradictory.

• The customer’s spouse/partner is answering questions for him/her.

• The customer appears unable to appreciate the consequences of decisions.

• The customer does not remember details from prior discussions including requests to process transactions.

WFGUS10045C/12.18 11 of 41

• The customer’s physical appearance suggests an inability to care for himself/herself.

• The customers seems confused, nervous or afraid.

• The customer is disoriented with his/her surroundings or social setting.The customer’s home seems unusually disorderly (e.g., piles of unopened mail).

• The customer is making decisions that are inconsistent with his/her current long-term goals or commitments.

• The customer cannot manage his/her own checkbook, financial affairs or other personal matters.

• The customer appears to be concerned or confused about missing funds in his/her account.

Suspected Abuse or Financial Exploitation

Another issue that agents must be aware of is the potential for financial, mental or physical abuse of a senior customer. Financial abuse is the unauthorized use or illegal taking of funds or property by a relative, a caregiver, or an individual in a position of trust. If a customer exhibits any of the following behaviors or characteristics, or any other behaviors that raise concerns, the agents should contact his SMD or Compliance for guidance.

Red flags of suspected abuse include (not an exhaustive list):

• Customer gives power of attorney to someone that appears highly inappropriate

• Customer indicates that he/she does not have control over or access to his/her money

• Customer does not appear to have knowledge of transactions or requests that were supposedly initiated on his/her behalf

• Customer’s mailing address has been changed to an unexplained address

• An individual requests information about the customer’s account(s) without customer’s consent

• Customer appears to be isolated from family and friends

• A sudden, unusual change in the customer’s transaction patterns (e.g., unplanned distributions/withdrawals, wires to a third party, etc.)

• Inability to speak directly to the customer, despite multiple attempts

State Specific Requirement

California

Senior Consumer Protection and Suitability Law

The California Senior Protection and Suitability law for life and annuities sets forth guidelines for marketing to seniors in the state. These guidelines are noted below.

Meeting in a Senior Customer’s Residence

When setting up an appointment with a senior prospect, California requires the California Senior Sales Presentation Disclosure form to be provided to anyone age 65 or older at least 24 hours and no more than 14 days before meeting in their home. As a result, you should schedule the appointment to allow time for the notice to arrive. You are required to provide the disclosure to all potential and existing California senior customers and retain a copy in the respective customer file to evidence it was provided.

California law also requires an agent to do the following when visiting a senior’s residence:

• Immediately after greeting and before any other statements or questions, state that the purpose of the visit is to talk about insurance or gather specific information for a follow up visit.

• State the name and titles of all person(s) arriving at the senior’s residence and the name of the insurance agency represented.

• Each person attending the meeting must provide the senior with a business card, which states their name, business address, telephone number, and license number.

• If and when asked to leave the residence by the senior, immediately end discussion and leave.

WFGUS10045C/12.18 12 of 41

If the senior has an existing insurance relationship with you and requests a meeting with you the same day, you must deliver the notice the same day, as long as the delivery is prior to the actual meeting. If the meeting with senior takes place in a location other than his/her residence, the Disclosure requirements do not apply. You should document in their customer file (meeting notes) the location of the meeting.

Annuities – Medi-Cal Eligibility

California law also prohibits the sale of an annuity if the senior’s purpose in purchasing the annuity contract is to affect his/her Medi-Cal eligibility and the following are true:

• Senior’s assets are equal to or less than the community spouse resource allowance established annually

• Senior would otherwise qualify for Medi-Cal

• Senior’s purpose in purchasing the annuity contract is to affect Medi-Cal eligibility and after the purchase the senior or the seniors’ spouse would not qualify for Medi-Cal

Solicitation of Military Personnel

Guidelines for Solicitation of and Sales to Military Personnel

The Federal Government and several states have enacted laws and regulations regarding sales to military personnel, including the Military Personnel Financial Services Protection Act of 2006 and state variations of the NAIC Military Sales Practices Model Regulation, which aims to curb abusive sales practices targeted at members of the military. Recently, state and federal regulators have taken action against insurance companies for their roles in allegedly abusive sales practices in the sale of life insurance to military personnel.

Who is Considered Military Personnel?

Military personnel refers to an active duty service member of the United States Armed Forces, i.e. all components of the Army, Navy, Air Force, Marine Corps and Coast Guard. “Active Duty” means full-time duty in the active U.S. military service and includes members of the reserve component, including National Guard and Reserve, while serving under published orders for active duty or full-time training. It does not include members of the reserve component who are performing active duty or active duty for training under military calls or orders specifying periods less than 31 calendar days.

You must adhere to the following sales practices if you solicit and sale life insurance to military personnel:

Prohibited Sales Practices

• Placement of an advertisement that is limited to military personnel only or refers to military personnel

• Placement of any advertising materials in any media that is directed primarily toward military personnel, which includes base newsletters, military newspapers or periodicals, or publications oriented primarily toward military personnel

• Having a seminar or conduct a presentation on a military installation

• Conducting any activity on any military installation including recruiting, sales presentations or solicitations

• Conducting any seminars or public appearances or engaging in any speaking engagements on any military installation

• Targeting military personnel for purposes of sales, solicitations, referrals or any other reasons.

Allowable Sales Practices

• Placement of a WFG or WFGIA approved advertisement in a newspaper or publication that has a public circulation, which also may include military personnel.

• Conducting a sales presentation to a military person at a WFG office or public location.

WFGUS10045C/12.18 13 of 41

Life Insurance as a Tool to Meet the Needs of Customers

Identify the Need for Death Benefit Protection

The need for death benefit protection is primary in most sales of life insurance. Most customers buy life insurance because they have a need for death benefit protection. Other needs such as accumulating cash value, investment purposes or receiving a favorable tax treatment are usually secondary considerations. It is important not only to identify the customer’s insurable needs and financial objectives (usually including a need for death benefit protection), but to also document them. If a customer’s lawyer or accountant is involved in discussions or determining the needs of the customer, it is important to document this fact and any discussions that you may participate in with a customer’s advisors.

Generally, insurance death benefits can address situations or needs such as:

• Burial expenses

• Income continuation for a spouse or family members

• College funding for surviving children

• Retirement funds for surviving spouse

• Asset protection

• Debt coverage

• Accelerated death benefits in the event of terminal illness

• Business planning

• Estate taxes and estate planning

Agents should always help customers identify their death benefit needs.

Determining the Death Benefit Need

A good starting point is to review the factors listed above and then consider what benefits may be available to the customer from existing sources, such as, individual or group policies, annuities, and employee benefit plans. You may also want to recommend to a customer a range of possible face values or death benefits.

Identify and Quantify any Goals or Needs for Cash Value

Help customers determine and quantify any pre-death goals or contingent needs for the life insurance policy’s cash value. These could include funding a child’s education, supplementing retirement funds, funding a business, providing tax-deferred income, or other long-term goals or needs.

If you illustrate or recommend partial withdrawals or policy loans to help meet these needs, make sure the customer understands all of the associated limitations, costs, policy charges along with the effect on the net death benefit. Remember that any policy loan values and fees/charges will reduce the amount of the benefit.

Long Term Care Insurance as a Tool to Meet the Needs of Customers

Long Term Care Insurance policies may not be suitable for everyone. While for some individual’s it may be an affordable and attractive form of insurance, there may be others for whom the cost is too great or the benefits may be insufficient to meet their needs. As an agent helping your customer determine their needs and financial objectives, you should make sure that you help the customer carefully examine their needs and their available resources. If the customer cannot afford a policy or the policy would cause financial hardship, then the customer is probably not a good candidate for long term care insurance.

Whether a person should buy a policy may depend on his or her:

• Age

• Overall retirement objectives

WFGUS10045C/12.18 14 of 41

• Health status

• Income and assets

If a person’s only source of income is a Social security benefit, he or she is likely not a good candidate for long term care insurance. As well, people that have trouble meeting their basic needs such as utilities, food or medicine are likely not good candidates.

On the other hand, people with significant assets may want to buy a long term care insurance policy to preserve those assets. Others may choose to buy long term care insurance to pay for their own care and not burden others with nursing home bills.

Whatever the reason, people should not buy a long-term care policy if they cannot afford the premium or cannot reasonably predict that they will be able to afford the premium for the rest of their lives.

The NAIC Shopper’s Guide to Long Term Care Insurance contains fact finding tools that may assist you in assessing a customers’ insurable needs or financial objectives.

Long Term Care Insurance Accelerated Death Benefit Riders

Utilizing a rider attached to a life insurance policy that accelerates death benefits to cover long-term care expenses is another common approach to help customers meet their insurable needs. These riders are subject to many of the same laws and regulations that apply to “stand-alone” Long Term Care (LTC) policies. In some states, this includes such things as:

• Specific LTC replacement regulations;

• Requiring a health and/or LTC license and possibly special continuing education requirements;

• Requiring companies and agents to meet HIPAA privacy requirements;

• Special suitability requirements and Shopper’s Guides;

• Special advertising laws and regulations, including the requirement that all LTC advertising be filed and approved in most states; and

• Make sure you are aware of all of the LTC laws and regulations in each state you write business.

Annuities as a Tool to Meet the Needs of Customers

Determine the Customer’s Financial Objectives

If you sell annuities, you are well acquainted with the insurable needs and financial objectives they can serve. For example, deferred annuities may be appropriate for customers seeking tax-deferred asset accumulation for retirement or other long-term goals, or individuals needing annuitized payments at some future date. Many deferred annuities also provide certain insurance benefits such as guaranteed or enhanced death benefits and nursing home waivers. Immediate annuities may be appropriate for customers needing an immediate stream of payments lasting for a certain number of years or for their lifetime.

An annuity may not be appropriate for someone who doesn’t plan to hold on to it for long-term needs. This is due to product design and tax treatment. Many deferred annuity products contain substantial surrender or withdrawal charges for several years or are designed to give the best value or benefit to the customer after many years (e.g., at maturity date).

Tax treatment also favors long-term ownership. Distributions may be subject to income tax and a 10 percent federal income tax penalty on earnings if taken prior to age 59 ½ for situations other than death, disability, and certain periodic distributions based on life expectancy.

It’s likely helpful to help customers consider an annuity as money set aside for financial goals envisioned beyond age 59 ½. As such, customers should have sufficient income, assets, and financial resources to cover current expenses and foreseeable short and intermediate-term needs.

A customer’s participation in a qualified retirement plan will affect his or her need for non-qualified deferred annuity. Most people are better off contributing the maximum amount permitted under their qualified retirement plans before considering a non-qualified annuity. (Qualified plans include, for example, 401(k), 403(b), profit-sharing, Individual Retirement Accounts, or similar plans.)

WFGUS10045C/12.18 15 of 41

Many states have adopted the National Association of Insurance Commissioners (NAIC) suitability of annuity transactions model regulation. Three primary requirements to review when recommending annuities are:

• Recommendations to buy or exchange an annuity must be appropriate

• Sales of annuities must be supervised to ensure the recommendations are appropriate

• Records must be maintained

Calculate the Need for Annuities

Agents should make recommendations to purchase annuities based upon relevant information obtained from the customer. Such information includes:

• Financial status

• Investment time horizon

• Risk tolerance

• Tax status

• Financial objectives

Help the customers determine the amount of “nest egg” they want or retirement income needed to sustain a desired standard of living. To do so you may also consider relevant information such as annual income, net worth, liquidity needs, etc. Generally, most retirees need income from all sources of at least two-thirds of their pre-retirement income to maintain their planned standard of living. While there is no single formula, below are some questions that customers should consider in determining future financial needs. If the customer refuses to provide some or all of the information you request then you should indicate on the file that the customer refused to provide the information.

Retirement Goals

What type of lifestyle does the customer plan to adopt during retirement? For example, does the customer want to travel? Buy a smaller home? Pursue hobbies or special interests? Provide financial support to family or fund a grandchild’s college education?

Estimate Financial Situation at Desired Retirement Age

Does the customer expect to have lower living expenses during retirement? Factor in all sources of income, including Social Security, pensions and other benefits, along with assets, expenses, and liabilities, including outstanding debt and mortgage payments and projected income tax bracket.

Determine the Additional Monthly Income Desired from the Annuity

Calculate additional monthly income needed to fund the customer’s projections. Based on this amount, determine how much the customer would like to have accumulated in a deferred annuity by the projected retirement date.

Rule Out Certain Products

Once you’ve determined the customer’s need for life insurance or an annuity, there are a few other steps needed before selecting a particular product type, face amount, or premium amount. Understanding the customer’s circumstances allows you to “rule out” certain types, levels, or amounts of product that may be inappropriate.

Determine What’s Affordable

Customers should determine how much disposable or discretionary income they can realistically dedicate to the expected or required premium payments.

Put the Customer First

Does the customer have an adequate safety net? Generally, most households should maintain a cash fund of at least three months’ salary or living expenses for unforeseen financial emergencies. The customer should also have separate savings or investments that are accessible for short or mid-term financial goals, such as a down payment for a home or college tuition.

WFGUS10045C/12.18 16 of 41

By including these factors in an overall review of the customer’s situation helps in determining the amount of disposable income a customer may have available for deferred annuities or to pay for a life insurance policy.

Buying a Qualified Deferred Annuity

Agents who recommend that a customer rollover his/her retirement plan or IRA into a qualified deferred annuity are subject to the Fiduciary standard set forth in the Department of Labor’s Fiduciary rule. Agents acting as a fiduciary are required to follow these standards:

• Place the interest of the customer first

• Make full and fair disclosure to the customer of all material facts and when a conflict of interest or potential conflict of interest exist

• Provide advice that is suitable to the customer’s needs, goals, objectives and personal circumstances

To assist the Agents in meeting the requirements noted above, WFGIA policy requires Agents to provide customers with the Fixed Indexed Annuity and Fixed Annuity Disclosure Form (discloses all conflicts of interests to the customer) and complete the TFN Agent Qualified Recommendation Form (Agent documents how the annuity transaction is in the best interest of the customer).

Buying a Non-Qualified Deferred Annuity

Here are some questions helpful for customers to ask themselves before buying a non-qualified deferred annuity.

• Am I buying the annuity primarily for long-term needs (e.g., retirement)?

• Do I have enough money set aside to cover emergencies and short-term savings needs?

• Will I have other funds available to cover important intermediate financial goals, such as a down payment for a home or college tuition?

• Am I contributing the maximum amount to the qualified retirement plans available to me?

• Can I afford to delay withdrawals until at least 59 ½?

• Is deferral of income tax on the annuity’s earnings important to me?

• Do I expect to be in a lower income tax bracket after retirement?

• When paid out, annuity earnings are taxed as ordinary income, not capital gains. Does this fit my tax strategy?

• Does it fit my tax strategy that the annuity death benefit is subject to federal income tax as opposed to life insurance policy death benefits, which generally are not?

If a customer answers “yes” to most of these questions above, it may indicate that a deferred annuity may be an appropriate part of the customer’s portfolio and may be worth further review and consideration.

Special Considerations for Indexed Annuities and Indexed Life Insurance

“Indexed” annuity and indexed life insurance products are those that credit non-guaranteed interest rates based on a formula tied to data or an index outside of the contract or policy. Important points to keep in mind if you sell indexed products include:

• While non-guaranteed interest may be credited based on an external index, these products are not “investment” products and may not be sold as such.

• Gather information such as financial status, tax status, and financial objectives to help determine if an indexed product will meet the customer’s financial goals and objectives, but do not give tax or legal advice.

• Due, in part, to the unique nature of indexed products, the customer must be provided with the required disclosures [as required by the product manufacturer]. This would describe things such as: - Surrender charges and how the cash surrender value is calculated - How the market value adjustment (if any) is calculated - How interest is calculated and credited - Bonus interest and/or premium bonuses - Withdrawal provisions - Minimum guaranteed surrender values

WFGUS10045C/12.18 17 of 41

- Annuitization payout options - Any additional riders - How the death benefit is calculated

The customer must acknowledge receipt of this disclosure.

Privacy Regulations

Protecting Financial Information

In November 1999, the Financial Services Modernization Act, also referred to as the Gramm-Leach-Bliley Act (GLBA) became law. Title V of GLBA contains certain provisions (“Privacy provisions”) that limit the way in which financial institutions, including insurance companies, can use information they obtain from consumers. Enforcement of the Privacy Provisions is left to the “functional regulator” of the various financial institutions. For example, the Securities and Exchange Commission (SEC) created Regulation S-P to enforce the privacy provisions for brokers and dealers, and the National Association of Insurance Commissions (NAIC) adopted a model “privacy” regulation (NAIC Model) and a model “safeguarding of information” regulation (which have been adopted in most states). The NAIC Models enforce various provisions of the GLBA for insurance companies.

Among other things, the NAIC Models require that a licensee give initial and annual notices to consumers regarding the licensee’s use of “non-public personal financial information” about consumers. An insurance agent does not need to provide the notices as long as an insurance company with which the agent is appointed gives the notices. The agent must enter into a contract with the insurance company that prohibits the agent from disclosing or using consumer nonpublic personal financial information unless the disclosure or use is in connection with the agent’s performance under the contract and as permitted by the regulation. Furthermore, the agent must implement a documented information security program to safeguard nonpublic personal information in his/her possession. This security program should include administrative, technical, and physical safeguards for the protection of customer information and be appropriate to the size and complexity of the agent’s business.

Nonpublic personal financial information is virtually any information—other than nonpublic personal health information—about a consumer that a licensee obtains. For example, nonpublic personal financial information includes a consumer’s gender, age, phone, and Social Security number, as well as information that more obviously seems “financial,” such as information about a consumer’s income or assets.

Protecting Health Information

The NAIC Model also prohibits insurance companies, agents, TPAs, etc., from disclosing “nonpublic personal health information” about a consumer to anyone, unless the consumer authorizes the disclosure or certain provisions of the regulation permit the disclosure.

Nonpublic personal health information is information created by or derived from a health care provider or consumer, and obtained by a licensee that relates to:

• The past, present, or future physical, mental, or behavioral health of an individual

• Health care provided to an individual

• Payment for health care provided to an individual

Additionally, the federal government protects consumers’ health information under the Health Insurance Portability and Accountability Act (HIPAA). HIPAA’s Privacy Rule became effective April 14, 2003. Under HIPAA, the Department of Health and Human Services (HHS) created guidelines to protect the confidentiality and security of Protected Health Information (PHI). HIPAA applies to medical providers and health plans but does not directly apply to life and annuity operations. The rules for “health plan” operations govern a range of subjects, including who may have access to medical information, how it may be obtained, and when it may be disclosed.

Do You Sell Health Plans?

The definition of “health plan” includes the following types of insurance coverage: specified disease, long-term care, hospitalization, major medical, as well as some riders that pay for medical costs, such as a long-term care rider. Agents

WFGUS10045C/12.18 18 of 41

who sell health plans are considered “Business Associates” under HIPAA because they collect and receive PHI regarding customers. Business Associates must comply with the HIPAA Privacy Rule.

If you sell health plans, HIPAA requires you to set up policies and procedures that limit unauthorized access to private information. This includes password-protecting computers, locking drawers and filing cabinets where PHI is stored, and ensuring that faxes, copies, and other papers containing PHI are expeditiously collected and distributed to appropriate individuals and are appropriately disposed of such as by secure shredding.

When meeting “face-to-face” with customers, HIPAA has no restrictions on the types of products you may discuss. Also, HIPAA’s marketing provisions expressly allow insurers and agents to inform customers of policy upgrades, and enhancements to health related products. However, HIPAA prohibits health plans and their agents from using PHI for cross-marketing purposes without an individual’s authorization. The information in the application for health plans is considered PHI and cannot be used to market other products. Please note that information that you did not create or receive in your capacity as an agent is not considered to be PHI. You are allowed to maintain a card file or computer list of customers. This information should be separate from any files that you might have that contain applications and other documents that have PHI.

The health plan must provide a HIPAA ‘Notice of Health Information practices” at the time of enrollment in the health plan and must remind policyholders that this notice is available at least once every three years. The notice explains policyholder rights and the health plan responsibilities under HIPAA.

Even if You Don’t Sell Health Plans

Even in situations where you are taking an application for life insurance or other lines that are not included in the definition of “health plan” under HIPAA, it is very likely that you will be required to get a special “HIPAA compliant” authorization signed by the applicant. This is because insurance companies often must request medical information from doctors, hospitals, and other health care providers. Those providers are subject to HIPAA and cannot provide requested medical information unless they are presented with a special HIPAA compliant authorization. Similar authorizations may need to be obtained at the time any claim is submitted.

Licensing and Appointment

Insurance agents are expected to fulfill certain legal, professional, and ethical duties for customers and the firms that agents represent. The company’s goal is to have agents who are properly qualified and adequately trained.

What’s Required

One of your most important responsibilities is to be legally and properly authorized to sell insurance products. Agent licensing serves two important functions:

• It authorizes you to sell certain products in certain jurisdictions.

• It protects the consumer by requiring you to obey the state’s insurance laws and complete a prescribed amount of insurance education.

Insurance agent licensing and appointments are governed by the insurance rules of each state. If you sell variable products, you must also be properly licensed for securities and be a registered representative of Transamerica Financial Advisors (TFA) to sell the product.

Have the Right Kind of Insurance License

States differ in how they categorize lines of business appearing on the agent license. For example, in some states, license authority for “individual life” may not cover variable life, group, credit, annuities, or health lines. If in doubt, check with your SMD.

Wait Until You Are Properly Authorized

Naturally, before acting as a licensed agent, you must wait until the official effective date of your license. This includes soliciting, advertising, taking applications, or collecting premiums. Many states also require you to become “appointed” with each insurance company you represent. State insurance department rules and procedures vary with respect to the date on which a submitted request for appointment becomes effective. Some states allow you to submit business while the

WFGUS10045C/12.18 19 of 41

appointment request is still pending, subject to certain conditions. You are not allowed to sell or solicit for the company until the company’s appointment of you has become effective with the State Insurance Department. Also, agents must make sure the company’s appointment covers the right lines of business. In order to remain with WFGIA, you must maintain an active insurance license and an appointment with at least one insurance company.

Be Licensed and Appointed in the Right State for Out-of-State Business

In most cases, an agent must be licensed in the state where the applicant or proposed policy owner resides. In some situations, an agent may solicit an application from an out-of-state individual or entity. Examples might include individuals with a seasonal residential address in the agent’s state or an out-of-state corporation or trust that has a bona fide location in the agent’s state.

To document the reason for any out-of-state sales exception, some insurance companies require that an applicant or owner complete a declaration form for any application made in a state other than the applicant’s/owner’s state of residence or business.

Be sure to check with any applicable insurer rules and requirements before conducting such business.

Just in Time Appointment Processing

“Just in Time” is a term used by providers, which means the provider will not appoint you with them until your first piece of business is received.

“Just in Time” Providers includes:

• VOYA

• Crump

• Pacific Life – “Just in Time” for all states except Florida, Kansas, Louisiana, Montana, Pennsylvania, Virginia and West Virginia

• Everest (IA American Amicable)

The “Just in Time” process is implemented after all Provider obligations have been met. (i.e. background investigation review, annuity training completed, etc.) If you submits business and there was a failure on any of the Provider requirements, the business is rejected.

Maintain and Renew Your License and Appointments to Continue Sales

Only conduct business with a current license and appointment. Your rights as an agent terminate when your license or appointment is revoked, terminated, lapsed, or not renewed.

Appointment and Background Checks

While formal background investigations may make the appointment process longer, they are an important step in the process. Many states have specific requirements regarding a background check and the Federal Insurance Protection Act of 1994 sets out specific acts that would preclude someone from acting as a licensed agent.

Answering questions in a full and honest manner is required. Failure to do so may jeopardize your status with WFGIA, violate state laws and may even be considered a felony under the Federal Insurance Fraud Protection Act of 1994.

After you have been licensed and appointed, if there is an event(s) that would change your answers to a background check, you should notify your SMD and WFGIA Compliance.

Errors & Omissions (E&O) Insurance

Agents engage in the business of providing services and products to customers. There may be situations in which errors, disputes or complaints may arise in regards to an Agents business activities. In order for an Agent to protect themselves from the potential financial impact of good faith errors or omissions, Agents are required to obtain E&O coverage.

All WFGIA agents (with the exception of agents with a New York resident address) are required to purchase E&O coverage through the WFGIA provided policy. Agents must ensure that they maintain their coverage by meeting the ongoing E&O payment schedule. Failure to comply will result in WFGIA taking action that may include termination.

WFGUS10045C/12.18 20 of 41

Agents with a New York resident address must maintain a current E&O policy with a $1,000,000 limit of liability, and must send a copy of the certificate to the WFGIA Licensing Department. You will be expected to keep your E&O coverage current and pay your E&O insurance coverage provider directly. You must provide proof of renewal of coverage on an on- going basis. Failure to provide proof of ongoing current coverage will result in WFGIA taking action that may include termination.

Even agents that do everything right may still receive a customer complaint. E&O is there to provide support, but it is also important to know policies & procedures, to follow good business practices & to maintain good customer notes.

Non-Licensed Staff

There are certain activities that require a license. You should be mindful of these requirements and not permit any non-licensed staff that you may have function in a capacity for which a license would otherwise be required. Specifically, you should not let an unlicensed person:

• Take applications for insurance

• Deliver insurance policies

• Discuss or explain the terms or features of a policy

• Conduct a seminar or meeting to solicit an interest in insurance or to generate leads, regardless of whether it’s intended for education or some other purpose

• Quote rates, present illustrations, or perform any other acts considered “solicitation” (varies by state)

Training and Education

Agents are expected to be adequately trained and educated throughout their careers. Training and education builds competency and allows you to help customers make informed buying decisions.

Titles with Seniors

Selling to seniors may require special care and diligence. Care should be exercised in using a professional designation or credential that implies an expertise in senior investments or retirement planning. When determining if a designation/credential implies special expertise in this area, carefully consider any word such as “senior,” “retirement,” or “elder,” when combined with words such as “certified,” “chartered,” “advisor,” “specialist,” “consultant,” “planner,” or like words. Be sure to present yourself and your credentials honestly.

Ethics and Compliance Training

Ethics and compliance training are two areas you cannot overlook. It is your responsibility to learn and understand the ethical principles, compliance laws and regulations, and the procedures an insurer may require.

Meeting and Training Standards

There are several ways you can meet insurance related ethical and compliance training standards. These include:

• Reviewing and understanding the materials set forth in this guide.

• Reviewing producer/agent guides that are published by insurance companies.

• Complete a formal insurance course or program in ethics. This may be required as part of your state’s licensing or continuing education requirements. If not, it is still good knowledge and training.

• Read, review and comply with any compliance bulletins, notices, and manuals.

• Know the insurance regulations of the states where you do business. Depending on the state and the type of business involved, these regulations and requirements might include: replacement, buyers’ guide and sales illustration requirements; special disclosure requirements (such as those used for sales to senior adults); licensing, continuing

WFGUS10045C/12.18 21 of 41

education, and claim and complaint-handling requirements; and underwriting requirements, such as delivering notices to customers concerning privacy rights, state guarantee funds, AIDS testing, credit report rights, or other matters

Product Training

Competent and professional agents are knowledgeable about the products and services they sell and must maintain a commitment to product training. While the degree and scope of training will vary by the markets you work in and the complexity of products you offer, there are a variety of sources you can draw upon. Keep in mind that knowing the product and pursuing product training is ultimately your responsibility.

Continuing Education

Most states require agents to continue their professional insurance education, usually annually. Insurance departments generally provide credit for approved courses, which enhance an agent’s professionalism, general product knowledge, and ethics. If you don’t comply with the continuing education laws, your state could suspend or lapse your insurance license.

Information Security

Customer Information Security Standards

Customer information refers to information about individuals who apply for or purchase a product or service. Confidential customer information includes, but is not limited to:

• Name, address, phone number and age

• Social security number or other identification number

• Account numbers

• Financial information, such as assets, debts and credit history

• Heath information including medical and prescriptions records

• Other personal information such as driving record

Agents must only disclose, access or use confidential information for business purposes. The information can only be shared on a “need to know” basis.

Physical Security Standards

Agents are required to follow these physical security standards:

• Customer information must not be left unattended in offices, conference rooms, fax machines or printers.

• Customer files, documents, or any other records/documents containing confidential information should be stored in locked file cabinets or desks when not in use, and in all cases, secured at the end of the business day.

• Visitors to an agency location should not be allowed to walk unescorted in areas where customer information is easily accessible.

• Destroy unneeded documents: Agents are required to either shred the document or dispose of them in secure bins located in their respective office. Under no circumstance is confidential information to be discarded in recycle or trash bins.

• Lock down agency location at the close of business.

• Complete all information security training administered by the firm.

• Report gaps: Agents are required to report any failures in physical safeguards (e.g., broken locks, inadequate secure zones, etc. to his /her SMD).

WFGUS10045C/12.18 22 of 41

Electronic Records Security Standards

Certain states, such as New York, require an agent to annually certify that they are in compliance with the NY Cybersecurity Requirements for Financial Services Companies or certify that they are exempt from such filing. Agents are required to be knowledgeable about, and comply with, all applicable state requirements related to the safeguarding of electronic information and cybersecurity requirements in the states in which they do business. At a minimum, Agents must follow the following electronic records security standards:

• PCs with access to customer information should not, as a general practice, be left unattended, or in the alternative, screen savers/sleep mode should incorporate password protection.

• Customer information should never be downloaded, maintained or saved to your PC.

• Password protections for access to PCs must be implemented. Agents should use passwords that are not easy-to-guess, avoid divulging passwords to other parties, and store passwords in a secure location.

• Encryption tools must be used when emailing confidential information to the customer.

Agent Security Standards

• Agents should limit access to customer information to only those agents/associates that require access to the information to either customer support, Operations or Compliance.

• Agents are prohibited from disclosing customer information over the phone or in response to an email unless they identified the person to whom they are communicating as the customer or fiduciary representative of the customer.

• Agents should only disclose information that is necessary. Generally that means only disclose information that is required to perform the business operation.

Reporting Data Breaches

WFGIA requires that its agents report any data breaches as they may cause damage to the firm, they may harm customers, and many states require customers be notified of data breaches that may expose them to identity theft and other risks. It is very important all potential data breaches be reported to agent’s SMD and Compliance immediately.

Trade Practices

Most states have adopted the Unfair Trade Practices Act to protect consumers against unfair or deceptive insurance marketing and claims practices. Certain agent or insurer practices are considered illegal and include the following activities:

Boycott, Coercion or Intimidation

Actions intended to create a monopoly or unreasonably restrain free trade in the business of insurance.

Defamation

A false, maliciously critical, or derogatory statement intended to injure a person engaged in the insurance business.

Discrimination

Allowing differences in rates, premiums, fees, or policy benefits between individuals of the same class or insurance risk based on place of residence, creed or national origin. Some states may also include gender, marital status, place of residency, or other factors in their definition(s).

False or Deceptive Advertising

Creating or using misleading or untrue material to solicit interest in insurance or in a product, company, or agents. This includes deliberate use or creation of false financial documents regarding the solvency of an insurer designed with the intent to deceive others.

WFGUS10045C/12.18 23 of 41

Illegal Premiums or Charges

Charging or collecting any premium or charge not specified in the insurance contract.

Insurance Churning

Replacing a customer’s insurance policy with a new policy from the same insurance company to earn a commission, rather than provide better coverage.

Misrepresentation in Insurance Applications

Making false or fraudulent statements or representations by an applicant, agent, or other person in or relating to an application for an insurance policy or an annuity contract. This would include encouraging or knowingly helping another person make such a representation or knowingly attest to it. Also keep in mind that a material misrepresentation in the application can void the policy contract and may result in commission chargebacks and loss of coverage.

Misrepresentation of an Insurance Policy

Oral or written statements, omissions, presentations, illustrations, estimates, or comparisons made or circulated by an agent, insurer, or other person that do not truly reflect the facts concerning the terms, benefits, rates, advantages, or conditions of any insurance policy or annuity contract.

Rebating

An illegal practice in most states. It involves the return of any portion of the agent’s commission to an insured or anything else of value given to an insured as an inducement to buy.

Twisting

Misrepresenting a policy or making incomplete comparisons of policies to induce a policy owner to change or replace an existing insurance policy with a policy from another life insurance company.

Borrowing from or Loaning Money to Customers

Agents are prohibited from borrowing money from or lending money to a customer or customer’s family member. This also includes depositing customer funds into your personal bank account(s).

Tie-Ins

Illegally requiring a person to buy another product or service to be eligible to buy insurance—or vice versa.

Examples of Inappropriate Actions

• “Bashing competitors” through disparaging remarks about other insurance companies, MGA’s, products, agents or producers

• Unfairly or incompletely compare companies, agents, producers, products, or insurance company ratings

• Misrepresent company ratings and financial statements

• Make untrue statements on an insurance application

Quick Reference Do’s and Don’ts

Do’s

• Use only illustrations and sales material provided or approved by WFGIA. All sales material must be reviewed and approved by the WFGIA Advertising Department prior to use.

• Use the sales process to determine if a product is suitable and in the best interest for your customer’s needs and, for sales of fixed annuity contracts, provide the company required suitability forms with the application. The documented needs analysis in your customer’s file must include employment status, approximate annual income, source of income,

WFGUS10045C/12.18 24 of 41

estimated net worth, financial objectives, product time horizon, marginal federal income tax bracket, investment knowledge, existing investment account information, and risk tolerance.

• Accompany replacements with full disclosure to the customer of all important considerations including any surrender charges and the appropriate replacement form for the state-of-issue.

• Sell business only in states where you are properly licensed and appointed.

• Promptly deliver policy or contracts to the owner. You are not allowed to hold policies or contracts for safekeeping.

• Verify that all information on the application is correct. Applications should never be backdated or provide false or misleading information.

• Sign as a witness only if you are actually present at the signing process.

• Maintain complete customer files.

• Document and report customer complaints immediately to the WFGIA -Compliance Department.

• Educate yourself about state market conduct rules and regulations. Keep thorough continuing education records.

• Keep all customer Information confidential unless authorized by the customer to release.

• Protect customer confidentiality and security of personal information. Please remember that any email transmission which contains private customer Information (whether in the email itself or in an attachment) must be sent and received using an encrypted email process.

• Submit a full and complete illustration signed prior to, or the same date as, the application for life insurance.

• Provide and review comparative illustrations using accurate and similar assumptions before replacing existing life insurance coverage. While not required, we encourage you to provide an illustration for proposed annuities to include reviewing an illustration of the customer’s current contract and/or policy if a Replacement is involved.

• Immediately notify WFGIA Supervision and/or Compliance of all changes in your criminal history or of any involvement in a regulatory action.

• Complete all agent training and keep up to date on new product information provided by WFGIA.

• Cooperate fully with any investigation, audit, or inquiry being conducted by WFGIA.

• Keep all licenses and appointments up-to-date.

• Notify WFGIA if your insurance license or any professional license has been revoked, suspended, terminated, etc.

Don’ts

• Don’t churn! Churning is the practice where contract values in an existing contract are utilized to purchase another contract for the purpose of earning additional commissions, fees, or other compensation, without benefit to the Customer. It is prohibited.

• Don’t sign applications or forms from sales presentations made by other agents. The agent who signs the application should be the agent who made the sales presentation.

• Don’t sign or modify/alter any document on behalf of a customer or other person under any circumstances, even if you have authorization from the customer.

• Don’t make, modify, or discharge contracts, policies or accounts.

• Don’t extend the time for paying the premium or waive any of WFGIA’s or insurer’s rights or requirements.

• Don’t agree to accept extra premium for extra risks.

• Don’t advise a customer to access free withdrawal amounts for the purpose of purchasing another contract or using it as premium for an existing contract unless there is a clear economic benefit to the Customer.

• Don’t have a customer or another person sign a blank or incomplete document.

• Don’t market or sell a contract with a spend down strategy, including but not limited to Medicaid, Medi-CAL, Veteran’s Administration Benefits, or the like.

• Don’t endorse, deposit, cash, or otherwise negotiate any check drawn to WFGIA or any customer.

WFGUS10045C/12.18 25 of 41

• Don’t directly or indirectly give rebates. Don’t pay anything of value, directly or indirectly, to customers, agent, producer, or any other party to induce an individual or any legal entity to purchase a new contract or replace, withdraw funds, surrender, or in any other manner change an existing contract.

• Don’t be an Assignee, Owner, Beneficiary, Contingent Beneficiary, Power of Attorney, Trustee, or Contingent Trustee of any contract issued other than a contract on your life or the life of a member of your immediate family. Some states, such as Florida, may have even more strict guidelines that also prohibit the family of the agent from assuming these roles as well.

• Don’t represent WFGIA in any manner before any governmental or self-regulatory authorities, including, but not limited to, state Insurance Departments, state Securities Departments, FINRA, and the Securities Exchange Commission (SEC).

• Don’t modify or change the appearance of the contract, policy, account and/or company marketing materials.

• Don’t act as notary or signature guarantee on customers’ financial or nonfinancial transactions.

• Don’t maintain a joint financial account with a customer unless the Customer is a member of your immediate family.

• Don’t accept cash, money orders, credit card checks, traveler’s checks or starter checks with no printed account owner information.

• Don’t use personal funds to pay a customer’s premiums.

• Don’t discuss or attempt to requite or settle a complaint.

• Don’t allow customers to make checks payable to you, your corporation, agency, or office staff.

• Don’t use your personal or business address as the address for a customer or a customer’s contract.

• Don’t use white out to make corrections to an application or form. Complete a new form and obtain new signatures/dates.

• Don’t submit premiums whose source of funds is known to be loans of any kind, including but not limited to, mortgages, reverse mortgages, and margin loans.

• Don’t submit an application on a customer you suspect or know to have provided false or misleading information on the application unless you include a cover letter explaining your suspicions.

• Don’t engage with any customers known to be involved with activities that threaten public order or safety.

• Don’t accept gifts, cash or checks made payable to you from any wholesaler or product provider nor give a gift to a customer that has a value in excess of $100.00.

• Don’t use your WFG or TFA email account for personal business.

Business Practices

New York State Regulation 194 – Producer Compensation Transparency

Agents who have direct sales or solicitation of insurance products in New York are required to provide compensation disclosure as required by NY Regulation 194. Agents must provide the customer with the disclosures summarized below:

• Initial Disclosure: Agents are required to provide an initial disclosure, Reg. 194 Disclosure, to a customer who purchases an insurance product. The disclosure describes the role of the agent, the source of the agent’s compensation, factors that may cause the agent’s compensation to vary and that the purchaser my request additional information regarding the specific amount of compensation the agent will receive from the sale of the policy/contract. The customer is required to sign and date the disclosure, acknowledging receipt. The agent is responsible for maintaining a copy of the executed Reg. 194 Disclosure in his/her customer file.

• Disclosure Upon Request: If a customer requests additional information on the amount of compensation to be paid to the agent, you must disclose the amount of know compensation and make a reasonable estimate of unknown or contingent compensation. An agent may disclose the compensation as a stated dollar amount or as a percentage of one year of premium.

Agents are required to provide customers with the executed disclosures noted above, with a copy maintained in the respective customer file.

WFGUS10045C/12.18 26 of 41

Telemarketing

The Telephone Consumer Protection Act (TCPA) restricts telephone solicitations (i.e., telemarketing) and limits the use of automatic dialing systems, artificial or prerecorded voice messages, text messages, and advertising by fax. Non-compliance with the TCPA can result in penalties ranging from $500 to $1,500 per violation (the top end being reserved for knowing or willful violations).You are required to comply with all applicable telemarketing rules, including the Federal and State Do Not Call regulations. Agents may not place telephone calls to any telephone number that is maintained on the National Do Not Call registry. Specifically, agents are subject to these telemarketing requirements:

• Requirement to check the DNC Lists prior to making any telephone solicitation.

• Train Producers engaged in any aspect of telemarketing on the existence and use of a Do Not Call Policy and List

• Only make calls between the hours of 9am and 9pm local time

• Promptly identify the Producer’s name, company name and telephone number or address at which the Producer may be contacted

• Prohibition that a Producer block his/her caller ID

• Requirement to use a compliance-approved script

If a customer or prospect requests to be placed on the Company’s Do Not Call registry, the agent is required to submit the name and telephone number to the Company’s Do Not Call registry located on MyWFG.com. Agents should make every effort to enter this information into the Company’s registry with 48 hours. Waiting 30 days to enter the information may cause an agent to lose sight of the requirement resulting in the customer or prospective customer not being added to the registry.

Use of Prerecorded, Autodialed Call/Texts or Fax Machines for Marketing

Unless prior written consent is received from a customer or prospect, an agent may not market his/her services/products through the use of prerecorded, automatic calls/text, or fax messages. Prior written consent requires a written agreement that documents the telephone number that specifically authorizes telemarketing by prerecorded, automatic dialing/texting, or fax messages, and that is not required as a condition of purchase.

Copies of all executed written consents must be maintained by the agent.

Email Marketing

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, and gives recipients the right to have you stop emailing them. Similar to TCPA, failure to comply with this law subjects the company to monetary penalties of up to $40,000.

Prior to sending out any commercial email, the primary purpose of it needs to be determined as this will determine if the CAN-SPAM Act is applicable. An email can contain three different types of information:

• Commercial content: Advertises or promotes a commercial product or service, including content on a website operated for a commercial purpose.

• Transactional or relationship content: Facilitates an already agreed upon transaction or updates a customer about an ongoing transaction.

• Other content: Neither commercial nor transactional or relationship.

Any message that contains only commercial content must comply with the requirements of CAN-SPAM.

The key requirements of a CAN-SPAM program are as follows:

• Don’t use false or misleading header information: The “From,” “To,” “Reply-To,” and routing information, including the originating domain name and email address, must be accurate and identify the person or business who initiated the message.

• Don’t use deceptive subject lines. It must accurately reflect the content of the message.

• Identify the message as an ad.

• Inform recipients where you are located. The message must include a valid physical postal address.

• Inform recipients how to opt out receiving future emails. The message must contain a clear, conspicuous explanation of how the recipient can opt out receiving marketing emails in the future.

WFGUS10045C/12.18 27 of 41

Customer Funds

Forms of Payments

WFG prohibits the acceptance of cash or monetary instruments from customers. Acceptable forms of payment include:

• Customer personal check

• Bank/Cashier check

• Third party check (from a financial institution drawn on the account of an insurance company, broker/dealer, or mutual fund company)

• Unacceptable forms of payment include:

• Cash, travelers checks, money orders

• Checks drawn on non-US banks

• Agent’s personal check

• Starter checks

Policy Replacements

Overview

Agents should refrain from replacing or encouraging the replacement of existing policies and annuity contracts without first clearly, accurately, and fairly communicating to the customer information needed to determine whether replacing an existing policy or contract may or may not be appropriate. Comply with any state replacement regulation and follow these important requirements:

1. Obtain, study and keep a copy of your state’s regulations.

2. Accurately record the answers to the replacement questions on the policy application and the agent’s report.

3. Deliver any state or insurance company required Replacement Notice to the applicant at the time of application.

4. Comply with any other state regulations.

5. Make sure that you document the reasons justifying the replacement. Your documentation should include the customer’s reasons for the replacement and the advantages and disadvantages to the customer. The Society of Financial Service Professionals (www.financialpro.org) provides a fact-finding replacement questionnaire you can use with customers.

Life Insurance Replacement in New York

Every application for life insurance in New York requires that a “Definition of Replacement” form be completed.

The Definition of Replacement form asks if you will be lapsing, surrendering, canceling, reducing the face amount, changing policy to a paid-up insurance policy, assigning the policy as collateral, stopping premium payments, etc.

If you answer “yes” to any of the above, New York life insurance laws consider this to be a replacement under Regulation No. 60. Please visit (www.dfs.ny.gov) for details.

General Guidelines

If a customer is considering replacing an existing policy with another one, you can provide a valuable service by helping them evaluate whether a replacement is in their best interests. You should discuss and review the following factors with the customer to determine whether a replacement is appropriate:

Life Insurance

• Surrender charges, if any on the existing policy.

• Front-end loads or sales charges of the new policy.

WFGUS10045C/12.18 28 of 41

• Accessibility of policy values of the new policy. Be sure to disclose the availability of policy loans, the duration of the surrender charge period, amount of penalty and charges associated with partial withdrawals and surrenders, and any limits or conditions for waiving those penalties or charges.

• Effect of the new contestable and suicide periods of a new policy.

• Evidence of insurability: the new policy may be rated or declined.

• Cost and duration of premiums and fees for each policy.

• Comparison of cash value under the old and new policies.

• The costs and effect of borrowing from the existing policy, if contemplated.

• Tax treatment of the surrender or exchange or any outstanding policy loans.

• The advantage of modifying the existing policy, if possible, to meet customer’s objectives rather than buying a new policy.

• Financial ratings assigned to the new company if significantly different than the ratings of the old company.

Annuities

• Surrender charges, if any, on the existing annuity.

• Liquidity of the new annuity. Be sure to disclose the duration of the surrender charge period, amount of penalty and charges associated with partial withdrawals and surrenders, and any limits or conditions for waiving those penalties or charges.

• Tax treatment of the surrender or exchange.

• Cost and fees of each annuity.

• Guaranteed death benefits or riders.

• Financial ratings assigned to the new company if significantly different than the ratings of the old company.

Long Term Care Insurance

• Difference in the benefits and the limitations and exclusions between the policies.

• How important is it to the customer if the replacement results in the incontestability period are starting over under the new policy.

• Underwriting class under the new policy is or is not as favorable as it was under the old policy

• Possible tax consequences resulting from canceling the old policy and replacing it with the new one.

• Financial ratings assigned to the new company if significantly different than the ratings of the old company

Other Points to Remember Regarding Replacements

Use fact-finding tools to assist you in a complete and accurate comparison of policies. In the end, customers must make their own decisions regarding what they believe to be their best interests. However, a quick review of these issues and tools will allow you to assist the customer in making informed decisions concerning the advisability of replacement. If the customer decides to replace a policy, you should advise him or her to keep the old one in force until an underwriting decision is made on the new policy.

In addition, the appropriate replacement form for the state in which you are writing business must be used. One copy of this form is to be left with the applicant and one copy is to be returned to the insurance company with the completed new application.

In most states, completion of the replacement form will require you to certify that the replacing coverage materially improves the insured’s position. Indiscriminately replacing an insured’s coverage may subject you to fines and other penalties.

Regulations for Financed Sales

Financed sales are replacements funded by borrowing or withdrawing from an existing policy. Financed sales, “internal replacements,” and their related sales practices are closely monitored by insurers. Before recommending a financed sale, take special care to determine whether it is appropriate. Carefully document that the customer understands the costs of “financing” and the effect on the existing policy.

WFGUS10045C/12.18 29 of 41

Advertising

It is important that you communicate with your customers (and prospective customers) in a truthful and accurate manner regarding any products or services that you may be discussing, recommending, or otherwise “soliciting.” The words, actions, and presentation materials that you use help customers make informed buying decisions.

WFGIA requires agents to obtain marketing approval prior to using material(s) for advertising purposes unless it has been expressly marked as being pre-approved.

Guidelines for Creating Advertising Materials

At all times, advertising materials must be truthful and never mislead by fact, omission or implication, regardless of the medium used.

General Advertising Guidelines Include:

• Materials should be based on principles of fair dealing and good faith.

• Materials should be fair and balanced.

• Do not willfully omit material facts.

• Do not use false, exaggerated, unwarranted or promissory claims.

• Do not disparage any competitors, the products or business practices.

• Benefits provided by a rider should not be advertised with greater prominence than the products primary benefits.

• Do not provide tax or legal advice.

Life Advertisement Guidelines:

• Describe a life insurance policy clearly as life insurance and prominently describe the type of policy advertised.

• Describe life insurance payments as premiums, not deposits.

• If withdrawals are mentioned, describe them as “partial surrenders” and explain that they may be subject to surrender charges.

• If policy loans are mentioned, explain that interest will be charged on the policy loan and that it may reduce the death benefit of the policy.

• Do not imply that life insurance is an investment, savings plan or retirement plan.

• Index Universal Life / Index Annuity Guidelines:

• Clearly describe that it is a life insurance product and is designed to provide life insurance protection.

• Refer to the applicable index only as a factor that in part determines the interest to be credited at the end of the index period, and is not a vehicle for stock market participation.

• Clearly disclose that the insurance company is the entity backing the guarantees provided by the product.

• Emphasize that the insurance company credits interest, and not that the customer receives stock market gains or market growth.

• Clearly disclose that the product is not an investment (Index Universal Life).

• Clearly disclose that the participation rate and/or cap rate, and any other non-guaranteed components of the indexing formula may change at the insurance company’s discretion and may be different in the future

• Do not emphasize similarities to variable annuities, mutual funds or other investment vehicles.

• Do not place undue emphasis on the index.

WFGUS10045C/12.18 30 of 41

Instructions for Advertising Review

All advertising submissions should be sent to the WFG Advertising Department. The preferable method is to use the following email address: WFGAgent-TFARepAdvertising@Transamerica.com Whenever possible, please use the PDF file format.

Please take the following steps when submitting your advertising materials to WFG.

• Complete and submit the WFG Agent/TFA Rep Advertising Submission Form to WFGAgent-TFARepAdvertising@Transamerica.com. You only have to remember one email address to submit your form and item for review: You will receive an automatic reply when you submit an item for review letting you know that your request has been received.

a. Each advertisement(s) must be submitted separately.

b. If statistics and quotes are referenced in the material, provide us with a copy of the source documentation so that the information can be verified.

c. If the advertising piece is in a foreign language, please provide a copy of the material in English as well. You are required to submit a certified attestation letter or email from a third party company that states that the English and the foreign language material states the same or very similar wording. The company that provides the attestation must provide translation as a service. Agents cannot provide the translation for the material(s).

• You will receive a final status email for your submission.

• Approvals for advertising material(s) expire in twelve (12) months, unless otherwise indicated.

• It is recommended that you save a copy of all approved advertising submissions to verify approval, if needed, and the tracking number.

Advertising Requiring Review

All advertisements and sales materials must be sent to WFG and/or WFGIA for review and approval prior to use. This includes materials related to products, recruiting, etc. In addition, all sales contests must also be submitted for review and approval prior to launch.

Approved Social Media Sites

The following is a list of approved social media websites:

• Facebook • LinkedIn • Monster • MySpace • Twitter • YouTube (Very Restrictive) • Instagram

Visit: https://www.mywfg.com/Media/Default/PDFs%202018/WFGUS10044%20Social%20Media%20Guidelines%207.pdf to view a copy of the Social Media Policies and Guidelines

Protecting the WFG Brand and the Use of the Transamerica Name, Image or Logo

Every associate throughout North America is responsible for maintaining the superb reputation of World Financial Group. Everything an associate does create an impression in the mind of the public, our consumers, and future potential Associates. World Financial Group is a Transamerica company. WFG agents/associates are independent contractors associated with WFG as either an associate or a licensed agent of World Financial Group Insurance Agency, Inc. Therefore, WFG agents/associates are only authorized to represent themselves as an associate with World Financial Group. This applies to both customer and recruiting communications. WFG agents/associates should never recruit or give the impression that they are recruiting to Transamerica.

WFGUS10045C/12.18 31 of 41

Use of Professional Designations

The use of improper and/or misleading professional designations and credentials is unlawful in some states, may violate FINRA rules and should be avoided. In all cases before using a professional designation or credential, you must have actually received or earned the designation/credential from an accredited university, college or professional society. The use of non-existent or self-conferred designations is prohibited, as are designations that imply a level of education, experience or training that you do not have.

Designations such as the CSA CIMC, ChFC, or others help demonstrate your commitment to customers and professional development. In addition, certain states have implemented regulations prohibiting the use of certain professional designations. You should verify that there is no state prohibition before considering a professional designation.

Here is a list of pre-approved designations:

• Chartered Financial Consultant (ChFC)

• Certified Senior Advisor (CSA)

• Certified Investment Management Consultant (CIMC)

• Certified Fund Specialist (CFS)

• Chartered Institute of Management Accountants (CIMA)

• Accredited Asset Management Specialist (AAMS)

• Master of Science in Financial Services (MSFS)

• Certification in Long-Term Care (CLTC)

• Certified Financial Educator (CFEd)

• Certified Public Accountant (CPA)

• Certified Retirement Counselor (CRC)

• Master of Business Administration (MBA)

• Doctor of Philosophy (PhD)

Sales Illustrations

Sales illustrations may be provided for certain types of products from insurance companies. Rules and guidelines will vary according to type of illustration (guaranteed, hypothetical, with or without loans, etc.) and the type of product being illustrated (term life, whole life, universal life, variable life, immediate or deferred annuity, fixed or variable annuity, etc.).

General Guidelines for Sales Illustrations

• When presenting a hypothetical illustration, inform the customer that the illustration is intended to show how the policy would work under different assumptions. It is improper to present a hypothetical illustration in such a way as to predict results or lead a customer to expect such results. Explain that the results cannot be predicted because the underlying non-guaranteed assumptions will vary over time.

• Never guarantee rates, values or projections in an illustration when they are based on non-guaranteed rates, non-guaranteed charges, or hypothetical performance or assumptions. Do not suggest or imply that they will, in fact, be achieved even though not guaranteed.

• Never alter, modify, mark on, or remove pages from illustrations.

• Use only insurance company approved illustrations. These include illustrations generated or provided by the insurance company at their home office, or generated by you through their software tool(s). If you generate the illustration, be sure to produce all the required parts of the program.

• It’s good practice to keep a copy of any presentation you present to the customer.

WFGUS10045C/12.18 32 of 41

Guidelines for Traditional Life Insurance

Most State Insurance Departments have adopted National Association of Insurance Commissioners (NAIC) Model Life Insurance Illustration Regulation, which applies to illustrations of traditional (non-variable) life insurance. Many companies apply the standards and procedures required by this Model Regulation nationally, even in states where it is not yet effective.

• The Regulation requires each insurance company to declare each product as either one to be sold with an illustration or one for which illustrations are forbidden. Make sure you follow each insurance company’s designations for each product that you sell.

• If you are offering a policy that is not to be illustrated, then any use of illustrations is strictly prohibited. You must not provide the customer with any depiction, advertisement, projection, or table that contains any non-guaranteed element. Ex. You must not present a customer with a projection or table of future non-guaranteed premium rates.

• If you are offering a policy an insurance company has declared must be illustrated, then you and the insurance company must comply with various requirements, including:

- The rates used in the illustration must meet strict actuarial standards and testing- At time of application, you must provide an illustration of the policy as applied for. The customer must sign the

illustration, and you must leave a copy with the customer, subject to certain conditions.- If the policy ultimately is issued other than as applied for, a new conforming illustration must be delivered with the policy.

Special requirements exist for annual policy reports and requests for in-force illustrations.

Guidelines for Sales Illustrations for Deferred Annuities

Fixed annuity illustrations can be based upon a non-guaranteed interest rate that shall not be greater than that currently being credited by the insurance company. The illustration must likewise set forth with equal prominence a comparable illustration based upon the policy’s minimum guaranteed interest rate. All illustrations containing a rate to be earned are required to reflect the deduction of all limitations and conditions, such as surrender charges and policy or administrative fees, which affect the rate of return. These limitations and conditions must also be disclosed prominently. Currently state rules and insurance company practices vary widely for sales illustrations of fixed annuities. Make sure you understand the rules and requirements of the insurance companies you do business with.

Insurance Fraud

Fraud and Deception

Fraud is deception deliberately practiced in order to secure unfair or unlawful gain. It costs insurers and consumers billions of dollars every year and is one of the most significant issues facing our industry. Because of this, the federal government and several states have enacted legislation designed to reduce insurance fraud. To aid in compliance with anti-fraud regulations, follow the guidelines listed below:

• Maintain appropriate licenses and appointments.

• Participate in periodic compliance training and continuing education.

• Promptly submit applications, premiums, claim forms, and policy changes to the appropriate office.

• Except where permitted by insurance company procedures, use original documents instead of faxes, email or photocopies.

• Instruct customers to make premium checks payable to the insurance company.

• Never give direct monetary or indirect “in-kind” rebates

• Avoid inaccuracies or misrepresentations when helping a customer complete an application or a claim form requesting benefits.

• Use only approved sales materials including illustrations.

• Respond in a timely manner to any requests received from the WFGIA Compliance or Supervisory Department and/or State Insurance Department with any investigation or inquiry regarding a customer complaint.

• Report suspected fraud by agents or customers to WFGIA.

• Document transactions where appropriate

WFGUS10045C/12.18 33 of 41

• Do not willfully hire, contract, employ, or appoint persons in the business of insurance without following the procedures, guidelines, and applicable background investigation requirement.

• Never impersonate another individual

• Never “fill in” for a colleague so they can avoid licensure in a state

Federal legislation includes the insurance fraud sections of the Violent Crime Control and Law Enforcement Act of 1994 (18 U.S. Code, Sections 1033 and 1034). Section 1033 of the Act makes insurance fraud a federal crime and specifically prohibits:

• Producers, agents, directors, employees, or officers of insurers who have been convicted of any criminal felony involving dishonesty or breach of trust from participating in the insurance business Acts of this nature involve “some element of deceit, untruthfulness or falsification” and include bribery, cheating, embezzlement, forgery, misrepresentation, perjury, and theft.

• An insurer from willfully hiring or contracting with a person convicted of a criminal felony involving dishonesty or breach of trust without written consent of an insurance regulator.

That Section classifies the following as federal criminal felonies:

• False financial reports to insurance regulators.

• Misappropriating from an insurance entity.

• False entries in financial books of an insurance entity.

• Obstruction of justice in a proceeding before any insurance regulator.

• Willfully permitting certain criminals to participate in the insurance business.

The statute requires that any person convicted of any criminal felony, as described above, obtain written consent from the State Insurance Commissioner before engaging or continuing to engage in the insurance business. Please note that this requirement does apply to persons already working in the insurance business.

The federal government is serious about enforcing anti-fraud regulations, and the penalties provided by section 1034 include:

• Up to 15 years in prison for each violation.

• Fines for each violation up to $50,000 or the amount of compensation received, whichever is greater.

• Injunction order(s) prohibiting a person from engaging in any illegal conduct.

Identifying Suspicious Activity

If you suspect criminal activity is occurring at or through WFGIA you should report it immediately to WFGIA Supervisory or Compliance Departments. To protect yourself and WFGIA, you should be alert to indicators that could provide circumstantial evidence that criminal activity is in the works and report those concerns to WFGIA Supervisory or Compliance Departments.

Potential Warning Signs of Fraud

It should be stressed that the presence of one or more of these indicators listed below does not mean that fraud has occurred, or will occur, but should be considered in determining if suspicious activity might be fraudulent in nature.

Life Insurance Fraud Indicators

• Policy’s effective date is close to date of death

• Deceased is not well-known by relatives and lived alone

• Policies requiring physical examinations are almost never used

• Numerous life insurance policies were purchased for deceased

• Different providers were used in securing coverage

• Coverage amount is not commensurate with the stated employment/income of the deceased

• Theft of premium or annuity payments

• Twisting

WFGUS10045C/12.18 34 of 41

• Churning

• Submission of unauthorized or fictitious policies

• Fraudulent misrepresentation

• Forging signatures on applications, amendments, and/or policy delivery receipts

• Theft of policy values

• Misrepresenting where application was signed

Application Fraud Indicators

• Unsolicited, new walk-in business not referred by existing policyholder

• Customer walks into agent’s office at noon or end of day when agent and staff may be rushed

• Customer neither works nor lives near the agent’s office

• Customer’s given address is inconsistent with stated employment/income

• Customer refuses to provide a telephone number

• Customer cannot provide driver’s license or other identification or has a temporary, recently issued, or out-of-state driver’s license

• Customer tries to pay premium in cash

• Customer suggests price is no object during application process

• Customer is unemployed or self-employed in transient occupation

• Customer asks in-depth questions regarding claims process

• Customer is unusually familiar with insurance terms or procedures

• Changes to the customer’s address, date of birth, tax ID number or health information are requested after the application has been submitted

• Third party conducts the transactions on behalf of customer for no apparent reason

• Application is not signed with agent present

Anti-Bribery & Corruption Policy

WFGIA’s policy requires agents to conduct all business in an honest and ethical manner. WFGIA takes a zero-tolerance approach to Bribery and Corruption and is committed to acting professionally, fairly and with integrity in all business dealings and relationships. If an agent suspects a member of WFGIA has violated an anti-corruption law or otherwise engaged in improper conduct in an effort to obtain business, s/he must immediately report such a suspected violation to the Supervision or Compliance Departments.

Bribery

Agents may not promise, offer, give or authorize, directly or indirectly, a bribe or anything of value to anyone, including any government official, employee, representative of a government (including state-owned enterprises and/or state-controlled entities), private (non-government) officials, or employees of any business (collectively, a “Third Party”) to attempt to improperly influence any act or decision to obtain or retain the business.

Gifts & Entertainment

Agents are not prohibited from giving or receiving gifts or entertainment to and from a Third Party so long as it is reasonable and not frequent to raise ethical concerns. However, agents are prohibited from accepting a gift/entertainment or giving a gift/entertainment to a Third Party in the following situations:

• It is made with the intention of influencing a Third Party to obtain or retain business, to gain a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favors or benefits.

WFGUS10045C/12.18 35 of 41

• It includes cash or a cash equivalent (such as gift certificates or vouchers).

• It is of an inappropriate type and value and given at an inappropriate time (e.g. during the sales process).

• It is given secretly and not openly.

Facilitation Payments & Kickbacks

Agents are also prohibited from making or accepting facilitation payments or kickbacks of any kind to a Third Party. It is not acceptable for an Agent to:

• Give, promise to give, or offer, a payment, gift or entertainment with the expectation that a business advantage will be received, or to reward a business advantage already given.

• Give, promise to give, or offer, a payment, gift or entertainment to a Third Party to ‘facilitate’ or expedite business.

• Accept payment from a Third Party that you know or suspect is offered with the expectation that it will obtain a business advantage for them.

• Accept a gift or entertainment from a Third Party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by the agent in return.

Anti-Money Laundering and the USA PATRIOT Act

Congress enacted the USA PATRIOT Act, which strengthened the anti-money laundering laws, particularly in the areas of enhanced due diligence for crimes by foreign nationals and foreign financial institutions. In addition, the U.S. Treasury Department has adopted anti-money laundering (AML) program regulations and regulations for required reporting of suspicious activity for insurance companies. The regulations apply to insurance companies that offer “covered products,” which include a permanent life insurance policy other than a group life insurance policy, any annuity contract other than group, and any other insurance product with features of cash value or investment, which includes variable universal life insurance and variable annuities.

Money Laundering and Terrorist Financing Defined

Money laundering is the illegal conversion of criminal proceeds into seemingly legitimate funds or the use of legitimate earnings for illegal activity. Financial institutions are required to monitor accounts under the Bank Secrecy Act, the Money laundering Control Act of 1986, and the USA PATRIOT Act.

Terrorist financing involves the use of money, which may be lawfully obtained, to fund illegal activities. Because the transactions often have a legitimate origin and can involve small amounts of money, terrorist financing can be more difficult to identify than money laundering activities.

Customer Identification Program (CIP) or “Know Your Customer”

AML regulations require that insurance companies obtain all relevant customer-related information necessary for an effective program. It is important that all customer information requested on the application or any supplemental form be obtained at the time of sale. NOTE: Agents who are also registered representatives should utilize TFA’s CIP procedures.

Red Flags

While it is impossible to list every potential situation that may be deemed suspicious, the activities can be generally thought of as falling into two categories—customer information and customer activity. You should be aware of suspicious activity and report this activity to the insurance company. Examples of suspicious activity include:

• The customer seems unusually concerned about providing, or seems reluctant to provide, personal financial information. The customer is reluctant to provide routine information about identity, source of funds, business activities, and bank references that you would expect the customer to provide.

• Payments are made via multiple cash equivalents (i.e. money orders or cashier’s checks).

WFGUS10045C/12.18 36 of 41

• The customer is from, or has accounts in, a country or territory identified as non-cooperative by the Financial Action Task Force, which is an international organization made up of several countries, including the United States, dedicated to combating international money laundering.

• The customer is introduced by an overseas agent, affiliate, or other company that’s based in a country known for drug trafficking, terrorism, or money laundering.

• The customer provides information that turns out to be false or suspicious—for example, the customer’s Social Security number or date of birth does not match that provided on other documents, the phone number provided by the customer is disconnected, or the business address is for a vacant building or an office space that seems inconsistent with the description of the business.

• The customer is concerned about currency reprinting or customer identification requirements.

• The customer withholds information necessary to complete required transaction reports

• The customer’s appearance or demeanor is suspiciously unusual, or the customer is excessively nervous.

• The customer doesn’t seem to care about returns on an investment, but instead focuses on restrictions relating to withdrawal or cancellation.

• The customer is named in news reports, or rumors circulate that the customer is engaged in illegal activities.

• The customer claims to be an agent (such as a lawyer or accountant) for someone else, but does not reveal the identity of the principal or permit you to speak to him or her.

Awareness Alert

The Financial Action Task Force (FATF) and the Financial Crimes Enforcement network (FinCEN) have advised financial institutions and their agents, producers, distributors, and employees to scrutinize and be aware of possible suspicious activity for accounts domiciled in countries identified by the FATF as non-cooperative.

The list of countries changes, but a current list can be obtained by visiting: www.fatf-gafi.org or www.fincen.gov.

AML and Know Your Customer

Verification of identification is a section under the USA PATRIOT Act and requires that producers, agents distributors, and employees to “know your customer.” At a minimum, be sure to request full identification of the customer, his/her business entities, and his/her source of funds. Also determine if product requests are in line with his/her business entities and his/her source of funds.

Willful Blindness

‘Willful blindness” is a violation of the AML regulations. This means it’s against the law for you to “look the other way” if you know of, or reasonably should have known of, red flags indicating suspicious activity. As an agent, you have a legal duty to “know your customer,” detect such suspicious activity and report it.

WFGIA Anti-Money Laundering Requirement

WFGIA agents are required to complete Anti-Money Launder Training (AML), annually. If you do not meet the annual requirement, you can be placed on an AML suspension and your commissions can be held. You can access some of WFG’s preferred education providers through the Continuing Education page on MyWFG.com.

WFGIA will accept any AML course offered through a third party education provider as long as they are approved for your resident state’s continuing education. However, if you use ExamFX or a provider other than Kaplan, A.D. Banker, or Success CE you are responsible for certifying your AML course through the Back Office Support System (BOSS).

If you are a Transamerica Financial Advisors (TFA) Representative, the TFA firm element AML course satisfies the WFGIA AML requirement. However, you must remember to certify your completed AML certificate through BOSS by clicking “AML Certification.” Simply locate your certificate in the TFA Training Center under the “Reports” tab, print it out and sign and date it and make sure to include your code number on it. Then you can scan it into your computer as a PDF and upload it to BOSS.

WFGUS10045C/12.18 37 of 41

Handling Complaints and Other Special Customer Communications

If you receive a customer complaint, you must inform your SMD, WFGIA Compliance Department and the insurance provider immediately (that same day). You should cooperate with the investigation and provide copies of any documents, explanations, or statements requested. You should never promise the customer a specific result and you should not argue with the customer. The insurance provider and WFGIA (where applicable) will investigate the complaint and respond to the customer.

Customers may contact you for a variety of reasons that could include: service requests, inquiries, questions, concerns, lack of understanding, or a serious grievance. It’s important to listen to customers carefully and provide prompt and effective service.

If you receive or become aware of an “insurance complaint,” you must give it special handling. Under the insurance laws of most states, a complaint is defined as written or verbal communication primarily expressing a grievance. The customer might send the complaint to you, to WFGIA, the insurance company, or file it directly with the State Insurance Department or other regulatory agency, or any combination of these. It might be sent or filed by the customer or by a representative or attorney for the customer. In any of these cases, if the communication is in writing and expresses primarily a grievance, it’s considered a complaint.

Lawsuits and Policy Claims

Lawsuits, threatened lawsuits, death claims, or claims for other policy benefits are not necessarily complaints. But, like complaints, they are serious communications that require your prompt handling. If you don’t handle them properly and promptly, they could lead to a complaint against you.

• Report lawsuits or threatened lawsuits immediately. Contact WFGIA on the same day and deliver a copy of any notice you’ve received.

• Once you become aware of a lawsuit or threatened lawsuit, do not comment on the case, its facts, or allegations to the customer, customer’s lawyer or representative, or any other third party—unless instructed otherwise. Above all, don’t argue with customers.

• If you are notified, even verbally, of a death claim or policy claim, get details and contact the insurance company claims department immediately with the pertinent information. It’s also good practice to advise the claimant to contact the insurance company claims department directly, as a backup.

• While you may assure the claimant that the insurance company will process the claim, never guarantee or imply that the claim will, in fact, be paid, or how much, or when. The final payment or determination of the claim will be communicated in writing by the insurance company.

• Assist in getting information or documents requested by the Claims Department when asked.

• Deliver the check promptly to the beneficiary if the insurance company sends the claim check to you.

Processing an insurance claim can be a complex process. For example, the claim could be delayed by a necessary investigation. There could also be questions regarding the proper beneficiary, or other factual or contractual issues. Depending on the type of policy and its status (e.g. outstanding policy loans), the insurance company will have to verify the exact amount of benefit payable. In rare instances, the policy may be contested by the insurance company for misrepresentation or the claim could be denied for fraud. In any event, the insurance company will communicate the final payment or determination of the claim writing.

Handling Customer Communications

Maintaining a good filing system can help avoid problems later on. Some good practices could include:

• A separate file for each customer. A complete customer file includes copies of all sales materials used, correspondence, fact finders, needs analysis, disclosure forms, illustrations, applications, etc.

• A master compliance files. This should include all sales materials approvals, records of audits, WFGIA insurance guide, bulletins or memos, and other relevant materials such as an insurance company agent guide.

WFGUS10045C/12.18 38 of 41

Supervision

WFGIA is committed to maintaining ethical market conduct and sales practices. Guides, such as this insurance guide are meant to provide guidance and suggestions for a variety of situations, but may not be able to address all possible situations that you as an agent may face in your day to day activities. Furthermore, there may be situations where an agent may require supervision, or may require some form of monitoring. If you function in the capacity of a supervisor it is your responsibility to understand any and all requirements of your role.

If WFGIA or an insurance company believes that an agent has failed to comply with policies, procedures, or established guidelines one or more of the following steps may be taken:

• Training or retraining may be initiated

• Agent’s sales may be monitored for a period of time

• Compensation may be appropriately adjusted (including moving to “as earned”)

• A verbal or written warning may be issued; And/or

• The agent’s contract and/or appointment with the insurance company may be suspended or terminated, and/or the agent’s affiliation with WFGIA may be suspended or terminated.

Code of Professional Conduct for Agents

WFGIA is committed to treating our customers fairly and ethically. That is why we have adopted this Code of Professional Conduct (Code) for our agents. WFGIA agents have a responsibility to treat customers and other agents fairly and ethically. Failure to adhere to these principles may result in disciplinary actions, up to and including termination.

Principles

WFGIA commits itself, and requires its agents to:

• Conduct business according to high standards of honesty and fairness and treat our customers and agents as we would expect to be treated

• Provide competent and customer-focused sales and service

• Compete fairly

• Provide advertising and sales material that is clear, honest and fair

• Handle customer complaints and disputes fairly and promptly

• Maintain a system of supervision and monitoring reasonably designed to demonstrate WFGIA’s commitment to and compliance with these principles

In addition, WFGIA has adopted the following policies specific to the company’s individually sold life insurance, annuity and long term care insurance (hereby referred to as “insurance products”). It is the policy of WFGIA, in the sale of its insurance products, to meet the needs of its customers.

WFGIA commits itself and requires agents to:

• Enter into life insurance transactions that assist customers in meeting their insurable needs and objectives.

• Provide recommendations to purchase individually sold annuities, life insurance or long term care that are suitable based upon relevant information obtained from customers.

• Maintain a process to comply with laws and regulations that are related to this Code in the marketing and sale of insurance products or related to the running of an insurance business

• Proactively seek to improve the life insurance industry’s practices for marketing and sales of insurance products.

• Adopt and support the concepts in this Code.

To disclose any violations of this Code so that WFGIA may take corrective action upon where deemed applicable.

WFGUS10045C/12.18 39 of 41

Use Qualified and Trained Agents

• Agents will be of good character and business repute and have the appropriate qualifications implemented by WFGIA.

• Agents will be licensed, appointed (where necessary), and meet other applicable state requirements required to solicit insurance products.

• Agents will be properly trained on how to comply with laws and regulations, WFGIA procedures, and with this code, as appropriate.

• Agents will be familiar with information that WFGIA makes available about WFGIA’s approved product(s) and the features and operations of the product(s). The information may be provided or made available through various methods, including: sales, marketing, or other descriptive product materials; manuals; training or training materials; software; websites or system based information; or other appropriate means.

• Agents shall participate in continuing education designed to provide current knowledge regarding products, industry issues, and emerging trends.

Compete Fairly

• Engage in fair and active competition in the marketing and sales of insurance products. WFGIA and its agents will: - Maintain compliance with the applicable state and federal laws fostering fair competition - Refrain from disparaging competitors

• Sales involving the replacement of an insurance product, agents will: - The agent shall provide customers with information they need to ascertain whether a replacement is appropriate,

including reasons why it may not be appropriate.

Sell Fairly and Use Clear and Accurate Sales Materials

• Advertising and sales material that is designed to lead to sales or solicitation of insurance products should be presented in a manner consistent with the needs of the customer. Such advertising and sales material will be based upon the principles of fair dealing and good faith and will have a sound basis in fact.

• Materials presented as part of the sale are clear and understandable in light of the complexity of the product being sold.

• Materials are not permitted to be used in the sale of insurance products unless they are reviewed and approved by WFGIA for compliance with this Code and with applicable laws and regulations related to advertising, unfair trade practices, sales illustrations, and other similar provisions.

• Only pre-approved Provider materials can be used.

• Appropriately handle and monitor complaints

• Customer complaints will be identified, evaluated and handles in compliance with applicable laws and regulations.

• Policies and procedures will be maintained, adhered to and designed to reasonably assure that customer complaint information gathered is analyzed, efforts are made to eliminate their root cause, and that it makes good faith efforts to resolve complaints and disputes.

Appropriately Handle and Monitor Complaints

• Customer complaints will be identified, evaluated and handles in compliance with applicable laws and regulations. Materials presented as part of the sale are clear and understandable in light of the complexity of the product being sold.

• Policies and procedures will be maintained, adhered to and designed to reasonably assure that customer complaint information gathered is analyzed, efforts are made to eliminate their root cause, and that it makes good faith efforts to resolve complaints and disputes.

WFGUS10045C/12.18 40 of 41

For internal use only. Not for public distribution.

©2019 World Financial Group Insurance Agency, Inc.

WFGUS10045C/1.19

WorldFinancialGroup.com

AGENT INSURANCE GUIDE ACKNOWLEDGMENT

©2018 World Financial Group Insurance Agency, Inc. WFGUS10042/5.18For internal use only.

World Financial Group Insurance Agency, Inc. and it’s subsidiaries (WFGIA) has developed the Agent Insurance Guide, as amended from time to time, which contains important information to ensure that WFGIA and its agents comply with all laws and regulations governing insurance sales practices. It is up to you to familiarize yourself with any and all rules that may apply to you as a licensed insurance agent conducting your business. WFGIA requires all agents to sign the following acknowledgment.

AcknowledgmentI understand and acknowledge that:

• I must familiarize myself with the material in the Agent Insurance Guide

• I am responsible for complying with the rules and requirements contained in the Guide

• The information described in the Guide is subject to change

• All changes will be communicated through official notices, and I understand that the revised information may supersede, modify or eliminate existing policies; I further understand that I am responsible for complying with such changes when communicated

• I have read and understand the content within the Guide

Agent’s Full Name Agent Code Number

Agent’s Signature Date

WFGUS10045A/12.18

Background Screening Disclosure FormFor Contracting Purposes

Please be advised that a consumer report may be obtained on you for employment purposes, which includes independent contractors under the Fair Credit Reporting Act (FCRA).

Consumer reports may be obtained at any time after the company receives your written authorization, including during the contracting process; and, during any subsequent period of your association with the company, where permitted by law.

Under the FCRA, consumer reports include any written, oral or other communication of information by a consumer reporting agency bearing on your credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living that is used or is expected to be used for contracting purposes. Consumer reports may include credit reports, criminal records and driving records, among other forms of information obtained from private and public record sources.

By signing below, I acknowledge that I have read the above.

Signature of Applicant: Date:

Print Full Name:

WFGUS10045A/12.18

State Disclosures

Please be advised that a consumer report and/or investigative consumer report may be obtained on you for employment purposes. The consumer reporting agency that may provide the company with your report is:

Business Information Group, Inc. P.O. Box 541 Southampton, PA 18966 Telephone: (800) 260-1680 www.bigreport.com

BIG’s privacy practices with respect to the preparation and processing of consumer reports and/or investigative consumer reports may be found at http://www.bigreport.com/privacy-policy/.

For Maine Applicants & ResidentsUpon request, you will be informed whether or not an investigative consumer report was requested, and if such a report was requested, the name and address of the consumer reporting agency furnishing the report. You may request and receive from us, within 5 business days of our receipt of your request, the name, address and telephone number of the nearest unit designated to handle inquiries for the consumer reporting agency issuing an investigative consumer report concerning you. You also have the right, under Maine law, to request and promptly receive from all such agencies copies of any reports.

For Massachusetts Applicants & ResidentsYou have the right, upon request, to know whether the company ordered an investigative consumer report about you. You also have the right to ask the consumer reporting agency for a copy of any such report. For Minnesota Applicants & ResidentsYou have the right in most circumstances to submit a written request to the consumer reporting agency for a complete and accurate disclosure of the nature and scope of any consumer report the company ordered about you. The consumer reporting agency must provide you with this disclosure within five (5) business days after its receipt of your request or the report was requested by the company, whichever date is later. If an investigative consumer report is obtained, such a report may include information obtained through personal interviews regarding your character, general reputation, personal characteristics, or mode of living.

For New Jersey Applicants & ResidentsYou have the right to submit a request to the consumer reporting agency for a copy of any investigative consumer report the company ordered about you.

For New York Applicants & ResidentsYou have the right, upon written request, to be informed of whether or not a consumer report and/or investigative consumer report was requested. If a consumer report is requested, you will be provided with the name and address of the consumer reporting agency furnishing the report.

For Washington Applicants & ResidentsIf we request an investigative consumer report, you have the right, upon written request made within a reasonable period of time, to receive from us a complete and accurate disclosure of the nature and scope of the investigation. You are entitled to this disclosure within five business days after the date your request is received or we ordered the report, whichever is later. You have the right to request from the consumer reporting agency a summary of your rights and remedies under state law.

WFGUS10045A/12.18

California, Minnesota, and Oklahoma Applicants & Residents:You have the right to receive a free copy of your background report. If you would like to receive a copy, please email CAMNOKBGReport@transamerica.com

CALIFORNIA DISCLOSURE DOCUMENT

The company may order an investigative consumer report on you in connection with your application, and if you are contracted, or if you already are contracted with the company, may order additional such reports on you for contracting purposes.

Such reports may contain information about your character, general reputation, personal characteristics, and mode of living. With respect to any investigative consumer report, the Company may investigate the information contained in your application and other background information about you, which may include information concerning your employment and earnings history, education, credit history, motor vehicle history, criminal history, military service, and professional credentials and licenses.

The consumer reporting agency (“CRA”), BUSINESS INFORMATION GROUP, INC., will prepare the investigative consumer report for the company. The CRA’s address is P.O. Box 541, Southampton, PA 18966 and can be reached at (800) 260-1680. The privacy policies for the CRA can be found at its website: http://www.bigreport.com/privacy-policy/.

SUMMARY OF RIGHTS UNDER CIVIL CODE SECTION 1786.22

a. An investigative consumer reporting agency shall supply files and information required under Section 1786.10 during normal business hours and on reasonable notice.

b. Files maintained on a consumer shall be made available for the consumer’s visual inspection, as follows:

c. The term “proper identification” as used in subdivision (b) shall mean that information generally deemed sufficient to identify a person. Such information includes documents such as a valid driver’s license, social security account number, military identification card, and credit cards. Only if the consumer is unable to reasonably identify himself or herself with the information described above, may an investigative consumer reporting agency require additional information concerning the consumer’s employment and personal or family history in order to verify his or her identity.

d. The investigative consumer reporting agency shall provide trained personnel to explain to the consumer any information furnished him or her pursuant to Section 1786.10.

e. The investigative consumer reporting agency shall provide a written explanation of any coded information contained in files maintained on a consumer. This written explanation shall be distributed whenever a file is provided to a consumer for visual inspection as required under Section 1786.22.

f. The consumer shall be permitted to be accompanied by one other person of his or her choosing, who shall furnish reasonable identification. An investigative consumer reporting agency may require the consumer to furnish a written statement granting permission to the consumer reporting agency to discuss the consumer’s file in such person’s presence.

1. In person, if he or she appears in person and furnishes proper identification. A copy of his or her file shall also be available to the consumer for a fee not to exceed the actual costs of duplication services provided.

2. By certified mail, if he or she makes a written request, with proper identification, for copies to be sent to a specified addressee. Investigative consumer reporting agencies complying with requests for certified mailings under this section shall not be liable for disclosures to third parties caused by mishandling of mail after such mailings leave the investigative consumer reporting agencies.

3. A summary of all information contained in files on a consumer and required to be provided by Section 1786.10 shall be provided by telephone, if the consumer has made a written request, with proper identification for telephone disclosure, and the toll charge, if any, for the telephone call is prepaid by or charged directly to the consumer.

State Disclosures

WFGUS10045A/12.18

Background Screening Authorization FormFor Contracting Purposes

Please be advised that we may also obtain an investigative consumer report including information as to your character, general reputation, personal characteristics, and mode of living. This information may be obtained by contacting and/or conducting personal interviews with your present and previous employers or references supplied by you. Please be advised that you have the right to request, in writing, within a reasonable time, that we make a complete and accurate disclosure of the nature and scope of the investigation requested.

Additional information concerning the Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq., is available at the Federal Trade Commission’s web site (http://www.ftc.gov). For more information, including information about additional rights, go to www.consumerfinance.gov/ or write to: Consumer Financial Protection Bureau, PO Box 4503, Iowa City, IA 52244.

By signing below, I hereby authorize the company to obtain a consumer report and/or an investigative consumer report on me, and further authorize all entities having information necessary to complete a consumer report and/or investigative consumer report on me to release such information to the company or any of its affiliates or carriers, including: present and former employers; personal references; criminal justice agencies; law enforcement and all other federal, state and local agencies; federal, state and local courts; the military; departments of motor vehicles and motor vehicle records agencies; schools and learning institutions; licensing agencies; and credit bureaus and credit reporting agencies.

By signing below, I acknowledge the information that can be disclosed to the consumer reporting agency, if and only as allowed by law, includes information concerning my employment and earnings history, education, credit history, motor vehicle history, criminal history, military service, and professional credentials and licenses.

By signing below, I acknowledge and agree that this Background Screening Authorization Form shall remain valid and in effect during the term of my contract and/or employment, subject to applicable laws, and authorize the company to obtain a consumer report and/or an investigative consumer report on me during the hiring process as well as at any time during the term of my employment and/or contract, where permitted by law.

Signature of Applicant: Date:

Print Full Name:

WFGUS10045A/12.18

Para información en español, visite www.consumerfinance.gov/learnmore o escribe al Consumer Financial Protection Bureau, 1700 G Street N.W., Washington, DC 20552.

A SUMMARY OF YOUR RIGHTS UNDER THE FAIR CREDIT REPORTING ACT

The federal Fair Credit Reporting Act (FCRA) promotes the accuracy, fairness, and privacy of information in the files of consumer reporting agencies. There are many types of consumer reporting agencies, including credit bureaus and specialty agencies (such as agencies that sell information about check writing histories, medical records, and rental history records). Here is a summary of your major rights under the FCRA. For more information, including information about additional rights, go to www.consumerfinance.gov/learnmore or write to: Consumer Financial Protection Bureau, 1700 G Street N.W., Washington, DC 20552.

• You must be told if information in your file has been used against you. Anyone who uses a credit report or another type of consumer report to deny your application for credit, insurance, or employment - or to take another adverse action against you - must tell you, and must give you the name, address, and phone number of the agency that provided the information.

• You have the right to know what is in your file. You may request and obtain all the information about you in the files of a consumer reporting agency (your “file disclosure”). You will be required to provide proper identification, which may include your Social Security number. In many cases, the disclosure will be free. You are entitled to a free file disclosure if:

• a person has taken adverse action against you because of information in your credit report;

• you are the victim of identity theft and place a fraud alert in your file;

• your file contains inaccurate information as a result of fraud;

• you are on public assistance;

• you are unemployed but expect to apply for employment within 60 days.

In addition, all consumers are entitled to one free disclosure every 12 months upon request from each nationwide credit bureau and from nationwide specialty consumer reporting agencies. See www.consumerfinance.gov/learnmore for additional information.

• You have the right to ask for a credit score. Credit scores are numerical summaries of your credit-worthiness based on information from credit bureaus. You may request a credit score from consumer reporting agencies that create scores or distribute scores used in residential real property loans, but you will have to pay for it. In some mortgage transactions, you will receive credit score information for free from the mortgage lender.

• You have the right to dispute incomplete or inaccurate information. If you identify information in your file that is incomplete or inaccurate, and report it to the consumer reporting agency, the agency must investigate unless your dispute is frivolous. See www.consumerfinance.gov/learnmore for an explanation of dispute procedures.

• Consumer reporting agencies must correct or delete inaccurate, incomplete, or unverifiable information. Inaccurate, incomplete or unverifiable information must be removed or corrected, usually within 30 days. However, a consumer reporting agency may continue to report information it has verified as accurate.

• Consumer reporting agencies may not report outdated negative information. In most cases, a consumer reporting agency may not report negative information that is more than seven years old, or bankruptcies that are more than 10 years old.

• Access to your file is limited. A consumer reporting agency may provide information about you only to people with a valid need – usually to consider an application with a creditor, insurer, employer, landlord, or other business. The FCRA specifies those with a valid need for access.

• You must give your consent for reports to be provided to employers. A consumer reporting agency may not give out information about you to your employer, or a potential employer, without your written consent given to the employer. Written consent generally is not required in the trucking industry. For more information, go to www.consumerfinance.gov/learnmore.

• You may limit “prescreened” offers of credit and insurance you get based on information in your credit report. Unsolicited “prescreened” offers for credit and insurance must include a toll-free phone number you can call if you choose to remove your name and address from the lists these offers are based on. You may opt out with the nationwide credit bureaus at 1-888-5-OPTOUT (1-888-567-8688).

WFGUS10045A/12.18

• You may seek damages from violators. If a consumer reporting agency, or in some cases a user of consumer reports or a furnisher of information to a consumer reporting agency violates the FCRA, you may be able to sue in state or federal court.

• Identity theft victims and active duty military personnel have additional rights. For more information, visit www.consumerfinance.gov/learnmore.

• States may enforce the FCRA, and many states have their own consumer reporting laws. In some cases, you may have more rights under state law. For more information, contact your state or local consumer protection agency or your state Attorney General. For information about your federal rights, contact:

TYPE OF BUSINESS CONTACT

1.

a. Banks, savings associations, and credit unions with total assets of over $10 billion and their affiliates

b. Such affiliates that are not banks, savings associations, or credit unions also should list, in addition to the CFPB:

a. Consumer Financial Protection Bureau 1700 G Street N.W. Washington, DC 20552

b. Federal Trade Commission: Consumer Response Center-FCRA Washington, DC 20580 (877) 382-4357

2. To the extent not included in item 1 above:

a. National banks, federal savings associations, and federal branches and federal agencies of foreign banks

b. State member banks, branches and agencies of foreign banks (other than federal branches, federal agencies, and Insured State Branches of Foreign Banks), commercial lending companies owned or controlled by foreign banks, and organizations operating under section 25 or 25A of the Federal Reserve Act

c. Nonmember Insured Banks, Insured State Branches of Foreign Banks, and insured state savings associations

d. Federal Credit Unions

a. Office of the Comptroller of the Currency Customer Assistance Group 1301 McKinney Street, Suite 3450 Houston, TX 77010-9050

b. Federal Reserve Consumer Help Center P.O. Box 1200 Minneapolis, MN 55480

c. FDIC Consumer Response Center 1100 Walnut Street, Box #11 Kansas City, MO 64106

d. National Credit Union Administration Office of Consumer Protection (OCP) Division of Consumer Compliance and Outreach (DCCO) 1775 Duke Street Alexandria, VA 22314

3. Air Carriers

Asst. General Counsel for Aviation Enforcement & Proceedings Aviation Consumer Protection DivisionDepartment of Transportation1200 New Jersey Avenue, S.E.Washington, DC 20423

4. Creditors Subject to the Surface Transportation Board

Office of Proceedings, Surface Transportation BoardDepartment of Transportation395 E Street, S.W.Washington, DC 20423

WFGUS10045A/12.18

TYPE OF BUSINESS CONTACT

5. Creditors Subject to the Packers and Stockyards Act, 1921 Nearest Packers and Stockyards Administration area supervisor

6. Small Business Investment Companies

Associate Deputy Administrator for Capital AccessUnited States Small Business Administration409 Third Street, S.W., 8th FloorWashington, DC 20549

7. Brokers and Dealers

Securities and Exchange Commission100 F Street, N.E.Washington, DC 20549

8. Federal Land Banks, Federal Land Bank Associations, Federal Intermediate Credit Banks, and Production Credit Associations

Farm Credit Administration1501 Farm Credit DriveMcLean, VA 22102-5090

9. Retailers, Finance Companies, and All Other Creditors Not Listed Above

FTC Regional Office for region in which the creditor operates or Federal Trade Commission: Consumer Response Center - FCRAWashington, DC 20580(877) 382-4357

Business Information Group, Inc.

A Vertical Screen® Company

Attn: Consumer Disclosure

P.O. Box 541, Southampton, PA 18966

Tollfree phone – 800-260-1680

WFGUS10045/01.19 1 of 17

Agent Agreement

This agent agreement (herein “Agreement”) is made and effective as of the date indicated on the signature page (the “Effective Date”) by and between World Financial Group Insurance Agency, Inc. and each undersigned agency (jointly and severally referred to herein as “WFG”), and each undersigned agency (jointly and severally referred to herein as “WFG”), and the undersigned individual (hereinafter referred to as the “Agent”). WFG and Agent are collectively referred to herein as “the Parties.”

WHEREAS, WFG is comprised of affiliated insurance agencies that market Products and Services approved for offer, referral or sale by WFG by retaining the services of independent insurance agents; and,

WHEREAS, properly licensed independent insurance agents may apply for appointment through WFG to market the Products and Services offered by one or more Product Providers as agents may choose; and,

WHEREAS, Agent is an independent contractor and not an employee of WFG, and this Agreement does not create an employment, agency or any other type of relationship between Agent and any of the Affiliated Companies,

NOW, THEREFORE, in consideration of the premises, mutual promises and covenants set forth in this Agreement, and other good and valuable consideration, including but not limited to WFG’s providing to Agent a platform through which Agent can, if Agent chooses, build Agent’s business and have access to Product Providers, financial services information, and Affiliated Companies, the receipt and sufficiency of which are hereby acknowledged by the Parties, and intending to be legally bound, the Parties hereby agree as follows:

1. Definitions

1.1 “Advance Commissions” - Any monies that may be paid by WFG to Agent for the sale of Products and Services through WFG as an advance against Agent’s commissions that are not yet Earned Commissions, as more specifically explained in the Commissions Policies.

1.2 “Affiliated Companies” - Includes all companies controlling, controlled by or under common control with WFG.

1.3 “Agent Guidelines” - Those guidelines, policies, practices and procedures, including, but not limited to, those set forth in the WFG field policies and procedures, Commissions Policies, guides, memoranda, bulletins or alerts as may be published, promulgated, or amended from time to time by WFG, which are fully incorporated by reference into this Agreement. Any changes shall be effective as of the date of general publication. Agent is expected to and acknowledges that Agent will (or has) read the Agent Guidelines and will keep current with all changes to them.

1.4 “Assistant” - Individual in the relationship of employee, independent contractor, or other position with Agent, as Agent may choose, separate from any direct relationship, if any, with WFG or one or more Affiliated Companies, for the purpose of assisting Agent with Agent’s business.

1.5 “Commissions Calculations” – Commissions are calculated pursuant to the terms of this Agreement and the Commissions Policies referred to herein. The Commissions Calculation includes any necessary adjustments, reconciliations, or off-sets made against any baseline unearned commission amount including, but not limited to, deductions for:

(a) License and other fees;

(b) Advance Commissions and Pending Commissions and expenses that Agent is required to refund to WFG because of Customer cancellations, rights of withdrawal, non-renewals, terminations, lapses or otherwise;

World Financial Group Insurance Agency

WFGUS10045/01.19 2 of 17

(c) Debit Balances of Agent’s Downline Agent(s) Roll Up;

(d) Indemnified Losses owed by Agent;

(e) other claims of WFG against Agent; and

(f) any and all money or value which may be erroneously paid, advanced, or credited by, or on behalf of, WFG or Affiliated Companies, to, or for the benefit of, Agent and any money owed by Agent to WFG or Affiliated Companies.

1.6 “Commissions Policies” - Policies and schedules created by WFG that govern how Agents’ commissions are calculated by WFG for the referral or sale of Products and Services, which policies are subject to change from time to time in the sole discretion of WFG and which policies are fully incorporated by reference into this Agreement.

1.7 “Compensation” - Remuneration paid, or caused to be paid, by WFG pursuant to this Agreement, Agent Guidelines and/or any selling agreements between WFG and Product Providers in the form of Earned Commissions, Referral fees, cash, Points, values of trips, rings, Visa cards, watches or any other form of compensation that WFG may provide from time to time, and as more specifically defined and explained in Section 3 of this Agreement.

1.8 “Confidential Information” - Any and all Personally Identifiable Information or confidential and proprietary records, data or information created by or on behalf of, or belonging to, WFG and now or hereafter acquired by, made known or disclosed to the Agent or any Assistant which has value to, and is not generally known by, competitors or potential competitors of WFG, and includes but is not limited to hierarchy lists and Personally Identifiable Information deemed to be confidential by applicable federal, state and/or commonwealth law and list(s) of WFG agents, including their identities and contact information. Confidential information does not include information which becomes generally available to the public other than as a result of disclosure by the Agent, any Assistant or any member of WFG’s network of contractually affiliated agents.

1.9 “Customer” - Any person or entity to whom any WFG agent solicits or attempts to solicit for Products and Services pursuant to the agent’s contractual relationship with WFG.

1.10 “Debit Balance” - The balance remaining from time to time after completing the Commissions Calculation under which Agent’s Advance Commissions and Pending Commissions exceed Agent’s Earned Commissions.

1.11 “Divestiture” – The ceasing of Agent’s entitlement to continuing Compensation from or through WFG.

1.12 “Downline Agent” - Any agent of WFG who is a member of Agent’s Hierarchy and who was: (a) recruited by Agent; (b) an agent recruited by any agent within Agent’s downward Hierarchy; or (c) transferred into Agent’s downward Hierarchy.

1.13 “Earned Commissions” – Has the meaning set out in Section 3.2.

1.14 “Georgia Courts” - The United States District Court for the Northern District of Georgia, and the Superior and State Courts of Fulton County, Georgia.

1.15 “Hierarchy” - The then current roster of agents reflected on WFG’s internal database(s) as part of Agent’s complete sales organization.

1.16 “Hierarchy Level” - The position obtained by an agent consistent with WFG’s Agent Guidelines criteria and in relation to other agents.

1.17 “Indemnified Losses” - Any and all liability, claims, demands, proceedings, obligations, assessments, losses, costs, damages, and expenses, of any nature whatsoever, contingent or otherwise, including, without limitation, any and all judgments, decrees, equitable relief, extraordinary relief, settlements, awards, E&O deductibles, attorney’s fees, court costs, punitive damage and arbitration costs including arbitrators’ fees against an Indemnified Party.

1.18 “Indemnified Party” - WFG, the Affiliated Companies and the respective officers, directors and employees of each such entity.

WFGUS10045/01.19 3 of 17

1.19 “Override Compensation” - Those monies that are paid to an agent from the referral or sale of Products and Services made by other WFG agents in accordance with Commissions Policies, commission schedules, rules and regulations issued by WFG from time to time.

1.20 “Pending Commissions” - Any monies that may be paid by WFG to Agent, including Advance Commissions and Override Commissions, for the sale of Products and Services through WFG which shall not become Earned Commissions until the Commissions Calculation is complete, as more specifically defined and explained in this Agreement and the Commissions Policies.

1.21 “Personally Identifiable Information” (“PII”) - An individual’s first name or initial and last name plus: (a) social security number; (b) driver’s license number or government-issued identification card number; (c) financial account, credit or debit card number with or without any required security code or personal identification number (PIN) that would permit access to a financial account; or (d) medical information.

1.22 “Points” - Value accumulated and used to achieve travel and other rewards provided by WFG to agents based on the amount of Commissions earned by agents.

1.23 “Product Providers” - One or more affiliated or unaffiliated companies with which WFG has established, or may from time to time establish, contractual relationships to refer, offer or sell Products and Services.

1.24 “Products and Services” - Those products and services of Product Providers that are approved by WFG for offer, referral or sale by agents as listed on the MyWFG.com internet site, and as may be updated by WFG from time to time with or without notice to agents.

1.25 “Referral” - The circumstance in which a WFG agent refers an individual to a Product Provider, but in which circumstance the agent does not actually offer a contract to sell or sell the Products and Services to the individual.

1.26 “Roll Up” - The transfer, with recourse, of the Debit Balance of a Downline Agent to that Downline Agent’s Upline Agents, as are more specifically set out in the Agent Guidelines.

1.27 “Trade Secret” - Any and all information, knowledge or data in any form whatsoever, tangible or intangible, which is considered a trade secret under applicable law.

1.28 “Upline Agent” - Any agent of WFG who is a member of Agent’s Hierarchy and who: (a) recruited Agent; (b) recruited the agent who recruited Agent; or (c) is in Agent’s upward Hierarchy.

1.29 “Vested” - The right of Agent to receive such Earned Commissions due based on insurance sales after termination of Agent’s contractual relationship with WFG, as permitted by law or the Agent Guidelines unless and until Divestiture occurs.

2. Agent’s Representations, Warranties and Obligations

Agent hereby understands, agrees, represents, warrants and acknowledges that:

2.1 Agent is of the legal age of majority in the state or commonwealth in which Agent resides on the date that Agent signs this Agreement and is otherwise competent to enter into this Agreement, and has the authority to enter into this Agreement and that, by virtue of entering into this Agreement and consummating the transactions contemplated hereby, or otherwise, Agent is not, and will not, be in breach of, violate, or interfere with, any other contract, agreement, business relationship or obligation which Agent has with any third party, company, agency, association, firm, person, corporation, or other entity.

2.2 Agent has not engaged, and will not engage, in any business, practice or behavior or take any action which has resulted, or will result, in any violation of any restriction or covenant to which Agent is subject pursuant to any agreement.

2.3 Agent shall abide by the terms and conditions of this Agreement, including the Privacy Compliance Policies attached hereto as Exhibit A (which may be amended from time to time by WFG without the notice required in Section 7.3) and any

WFGUS10045/01.19 4 of 17

other contracts or agreement with WFG, and the WFG Agent Guidelines.

2.4 Agent shall comply with all applicable anti-money laundering laws, rules, regulations and government guidance, including any reporting, recordkeeping or compliance requirements. These include requirements to identify and report currency transactions and suspicious activity, to verify customer identity and to conduct customer due diligence. In addition to applicable laws, WFG and each Product Provider has implemented an anti-money laundering program which includes requirements for reporting suspicious activity and requires insurance agents to complete anti-money laundering training. Agent agrees to comply with WFG’s and each Product Provider’s anti-money laundering policies and reporting and training requirements.

2.5 Agent shall comply with all anti-corruption laws, and will not make any bribes or engage in any other unlawful or improper methods of remuneration to any person. Agent also agrees to immediately report to WFG any violations of the anti-corruption laws or suspicions that improper conduct was engaged in an effort to obtain business, and understands that WFG prohibits retaliation in any form against any Agent who has, in good faith, raised or reported such a violation or conduct.

2.6 It is understood that in agreeing to provide services as an agent under this Agreement, Agent shall be acting and shall act at all times as an independent contractor and not as an employee of WFG or its Affiliated Companies for any purpose whatsoever, including without limitation, for purposes relating to taxes, payments required by statute or any other withholdings or remittances to any governmental agency or authority. Neither this Agreement, the relationship created between the parties pursuant to this Agreement, nor any course of dealing between the parties is intended to create, or shall create an employment relationship, a joint venture, partnership or any similar relationship. Agent does not have authority to bind WFG in any contractual obligation outside of the authority described in this Agreement. Agent shall conduct and control Agent’s business activities, including but not limited to, schedule, work hours, customer prospects, office location, geographic area, Assistant and administrative support (if any), expenses, and business strategies and methods, subject to all applicable local, state, commonwealth and federal laws and regulations, this Agreement, and any other contract(s) between the Agent and WFG. So far as it is not inconsistent or in conflict with the terms of this Agreement, Agent is free to engage in any other remunerative contract, calling or occupation during the duration of this Agreement.

2.7 The Parties shall operate their respective businesses separately and independently of each other throughout the duration of this Agreement, subject to required insurance industry regulatory oversight from WFG.

2.8 None of the benefits, if any, that WFG provides to its employees, shall be available to Agent (or Agent’s employees or Assistants, if any). For the purpose of this Agreement, benefits means, without limitation, any employee benefit, pension, profit sharing, savings, retirement, deferred compensation, stock option, phantom stock, restricted stock, or stock purchase, insurance, health, dental, disability, employee welfare benefit, sick pay, workers’ compensation coverage, bonus, vacation pay, severance pay, and any other similar plans, programs and agreements, whether or not reduced to writing. Agent also agrees that, if applicable, it is the sole responsibility of Agent to purchase workers’ compensation insurance or file any required Notice of Designation as Independent Contractor or similar paperwork with the appropriate state or commonwealth agency.

2.9 The Agent shall procure and maintain all insurance coverage and permits of work of every nature and kind required by federal or state law (including, without limitation, applicable workers’ compensation coverage) and Agent shall have no recourse against WFG or its Affiliated Companies for any losses, damages, claims, costs, or expenses in relation to any occurrence connected with the services provided under this Agreement or the Agent’s delivery of the services. At WFG’s request, the Agent may be required to produce to WFG a clearance certificate or other documentation demonstrating that Agent has adequate workplace safety insurance compensation and other insurance coverage.

2.10 Agent shall have the right to select and engage Assistants to assist in the accomplishment of the work for which Agent engages in pursuant to this Agreement. Agent is solely responsible for paying all compensation owed to any Assistant and for paying, and/or withholding and remitting to the appropriate government agency(ies), any applicable taxes that might be owed with respect to such compensation. Agent shall be responsible for the activities of any such Assistants the same as if the activity was performed or conducted by Agent directly, including, but not limited to, any Assistant’s protection or use of Confidential Information.

WFGUS10045/01.19 5 of 17

2.11 Agent acknowledges that all Compensation owed to Agent as a result of business written or referred by Agent shall be paid to Agent by WFG, and that Product Providers have no obligation to Agent for Compensation on such business. All amounts earned in connection with the business written or referred by Agent while this Agreement is in effect shall be paid by Product Providers to WFG as long as the contracts or policies remain in force and subject to commission payments and WFG will pay Compensation to Agent in accordance with this Agreement.

2.12 The Compensation paid to Agent from the sale or referral of Products and Services is compensation for:

(a) the Agent’s sale or referral, or his/her Downline Agent’s sale or referral of Products and Services; and,

(b) the Agent’s agreement herein not to breach the terms of this Agreement.

2.13 While this Agreement is in force, Agent shall:

(a) have and maintain appropriate insurance licenses and appointments, as required, applicable to the business Agent conducts under this Agreement;

(b) not have any affiliation, other than as a customer, with a WFG Product Provider outside of his/her relationship with WFG for the sale of any new insurance business unless such affiliation is for receipt of vested or deferred commissions, earns, trails and/or renewals only, and such affiliation has been disclosed to WFG in writing;

(c) not be obligated to contract with WFG exclusively, and this Agreement does not give Agent exclusive rights in any area; and

(d) take reasonable actions to monitor and supervise the recruiting and selling activities of their Downline Agents and to ensure that their Downline Agents are following the terms of the Agent Guidelines.

2.14 Except as prohibited by law, during the period that Agent is an Agent of WFG and for a period of two (2) years following the termination of this Agreement for any reason, Agent shall not, either individually or in partnership or jointly or in conjunction with any other person or entity, as principal, agent, consultant, contractor, employer, employee or in any other manner, directly or indirectly, solicit, induce or entice away or in any other manner persuade or attempt to persuade any individual who is a current agent of WFG, or was an agent of WFG in the past six (6) months prior to the solicitation, inducement or enticement, and with whom the Agent had business contact with on behalf of WFG or its affiliated or related entities, to terminate or alter their agent relationship with WFG to join a competing organization. This non-recruitment restriction is limited and only applies with respect to any recruitment of an agent that resided in or engaged in business activities in the geographic area within fifty (50) miles of the location of the Agent’s office(s) during the eighteen (18 ) month period preceding the solicitation.

2.15 Agent shall not do anything that will damage the business, good name or reputation of WFG, Affiliated Companies and/or their respective officers, directors, and employees.

2.16 Agent shall not, in connection with any personal entity or activity, joint venture, partnership or corporation, appropriate or use WFG’s or Affiliated Companies’ service mark(s) or trademark(s), name(s) or any phrase, designation, or label, including the terms “WFG”, “WFG”, “World Financial Group”, “World Financial Group Insurance Agency”, “TFA”, “Transamerica”, “AEGON or other similar designations or derivatives whether separately, or in conjunction with any notation indicative of a business organization.

2.17 Agent shall comply with all of the terms and conditions of this Agreement and any other contract(s) with WFG, the Agent Guidelines and all policies, practices and procedures adopted by WFG that are mandated by law, regulation, administrative bulletin or FAQ, or binding industry requirement, specifically including insurance and data protection requirements. In addition, Agent shall take reasonable steps to ensure that any Assistant also complies with such Agreement, Agent Guidelines, and all other such policies, practices and procedures adopted by WFG while assisting with Agent’s duties governed by this Agreement.

2.18 Except as prohibited by law, the following terms shall apply: Agent shall promptly pay, including through offsets

WFGUS10045/01.19 6 of 17

against Pending Commissions, all expenses relating to this Agreement, including but not limited to indebtedness to WFG or Affiliated Companies. Agent shall also be obligated to repay WFG for the Debit Balances of any of Agent’s Downline Agents (Roll Up). Agent shall participate in, and pay monthly technology fees and insurance premiums related to, group plans for errors and omissions and fidelity insurance coverage, systems and technology provided by WFG according to the then current WFG policy. The Agent hereby acknowledges that any required fees and premiums relating to such coverage and services may be changed by WFG without prior notice. Agent hereby authorizes WFG to apply offsets against Agent’s Pending Commissions for payment of Agent’s expenses for errors and omissions insurance, systems and technology provided through WFG.

2.19 Agent shall be responsible for providing Agent’s own office, telephone, furniture, equipment, supplies, transportation, and such other facilities as Agent in his/her discretion, may deem necessary or appropriate, and Agent shall be solely responsible for all expenses incurred by Agent, including but not limited to training, travel, entertainment, office, signs, telephone, education, dues, subscriptions, insurance and/or securities licenses, business licenses, taxes, and Assistants, if any, and Assistants’ expenses, taxes, etc. Agent acknowledges that Agent shall receive no remuneration or reimbursement of any nature whatsoever for such expenses.

2.20 Agent shall be responsible for ensuring the accuracy of any records, calculations, or correspondence that Agent receives from WFG. If Agent identifies any error or inaccuracy in any such record, calculations, or correspondence, Agent shall notify WFG of such error or inaccuracy in writing within thirty (30) days of receipt of records, calculations, and correspondence. If Agent does not provide written notice to WFG within thirty (30) days of receipt of any records, calculations, or correspondence such record, calculation, or correspondence shall be deemed to be accurate and be binding upon Agent, and WFG shall be released from liability or responsibility for any and all matters contained therein. Notwithstanding the foregoing, if WFG identifies any error or inaccuracy in any record, calculation, or correspondence provided to Agent, it may correct such error or inaccuracy at any time.

2.21 Agent agrees that any and all “Personally Identifiable Information” or “PII” collected, accessed, stored, or transmitted by Agent or Agent’s Assistants (included in “Agent” in this Section 2.21 only), if any, on behalf of, or from WFG and/or Product Providers in connection with the performance of Agent’s services under this Agreement shall be used only as necessary to perform Agent services under this Agreement. Agent shall not collect, access, store, transmit or otherwise disclose PII for any other purpose, or to any person other than WFG, Product Providers, or the individual who is the subject of the PII unless specifically authorized in writing by WFG, Product Providers, or the individual who is the subject of the PII, or as otherwise permitted by law. Agent agrees to establish physical, electronic, and administrative procedures to protect the security and confidentiality of PII in accordance with the Agent Guidelines and privacy laws. This Section 2.21 survives the termination of this Agreement.

2.22 Agent shall comply with the terms, conditions and restrictions as conveyed through training, information made available from third-party providers and general industry standards with respect to the use of any WFG licensed computer software. Agent further agrees to comply with the terms of any license or other contractual agreement into which Agent is required to enter with any such third party software owner.

2.23 In connection with any payment or amount that WFG or the Product Providers may refund to any Customer, WFG shall deduct the amount of any previously received Compensation related to such transaction from any Pending Commissions due Agent, consistent with applicable law.

2.24 Agent shall repay all Debit Balances upon demand by WFG, and Agent expressly agrees to do so. Any Debit Balances not paid within thirty (30) days from the date of such demand shall bear interest from the end of such thirty (30) days at a rate equal to 11% per annum or at a rate equal to the maximum legal rate of interest provided by applicable law and such interest shall be added to the Debit Balance. Debit Balance will be offset against future Pending Commissions until fully recouped. If this Agreement is terminated in accordance with Section 4 by WFG or Agent for any reason, and Agent’s outstanding Debit Balance exceeds the amount of Pending Commissions owed, if any, as of termination, Agent must repay WFG the outstanding Debit Balance. WFG shall maintain the right to exercise any and all legal rights and remedies available to it to collect outstanding Debit Balances, including but not limited to, referring such Debit Balances to a collection agency and arbitration.

2.25 By entering into this Agreement with, or otherwise becoming an independent contractor of WFG, Agent expressly

WFGUS10045/01.19 7 of 17

consents to being contacted by WFG and its agents, representatives, and third party service providers via telephone, fax, email, mail, text message or other reasonable means, at any of Agent’s contact numbers, addresses, or email addresses, regardless of whether Agent is listed on any federal, state, commonwealth, provincial or other applicable “Do Not Call” list, with regards to the enforcement of any of the terms and conditions under this Agreement or for other purposes reasonably related to the relationship formed under this Agreement with WFG. This provision survives termination of this Agreement.

2.26 Agent shall cooperate fully and to provide assistance to WFG in the investigation and resolution of any complaints, claims, actions or proceedings that may be brought by or that may involve Agent or Agent’s hierarchy or WFG.

2.27 Agent shall not:

(a) take or perform any act or action, or make any representation purporting to create any obligation or liability on the part of WFG, its Affiliated Companies, or any of their respective officers, directors and employees, or bind WFG, its Affiliated Companies, or any of their respective officers, directors and employees to any other legal obligation including but not limited to, any contract or agreement with any third party except as otherwise authorized in this Agreement;

(b) collect cash or checks from Customers in payment for the purchase of Products and Services payable to any person other than a party designated by the appropriate Product Provider;

(c) (i) represent products or services that are not Products and Services under this Agreement as being approved by and offered for sale through WFG; (ii) sell, refer or offer to sell any products or service through WFG that is not a Product or Service under this Agreement; or (iii) make any misrepresentation to a Customer, in connection with a referral, or purchase of, or improperly induce any Customer to purchase Products and Services. Agent shall indemnify WFG and hold any Indemnified Party harmless, consistent with Section 6 of this Agreement, for Agent’s breach of this paragraph; and

(d) use, disseminate or reveal any Confidential Information or Trade Secrets of WFG which the Agent has or hereafter receives, including any document or information in any media or form comprising any hierarchy list, whether obtained from WFG or any other person, other than on behalf of, and as authorized by, WFG, during the term of this Agreement.

2.28 Upon termination or request, Agent shall return all WFG property, which Agent acknowledges includes all Customer and other files in the Agent’s possession.

3. Agent’s Compensation

3.1 Agent acknowledges and understands that Agent is compensated under this Agreement only from the sale or referral of the Products and Services offered through WFG by Agent or Agent’s Downline Agents. The Agent’s sole compensation under, and during the term of, this Agreement shall be that Compensation paid, or caused to be paid, by WFG pursuant to this Agreement, Agent Guidelines and/or any selling agreements between WFG and Product Providers. There is no guarantee that the Agent will be financially rewarded solely by virtue of becoming an Agent of WFG or by attempting to build his or her own business. Except as set forth in this Agreement and/or Agent Guidelines, Agent shall not receive any other compensation or benefit of any kind whatsoever, including but not limited to insurance benefits, workers’ compensation benefits, unemployment insurance benefits, disability income, paid sick leave, paid vacation, expense reimbursement or retirement benefits from WFG under this Agreement and/or Agent Guidelines.

3.2 Commission is not considered “earned” by Agent and due and payable by WFG under this Agreement (“Earned Commission”) unless and until:

(a) Agent has a valid license and active Agreement with WFG at the time of payout or otherwise “Vested”, as set forth in this Agreement;

(b) WFG has received payment from Product Providers on commissionable sales or Referrals;

(c) all requirements set forth in this Agreement are satisfied; and

(d) the Commissions Calculation is finalized.

WFGUS10045/01.19 8 of 17

The Commissions Calculation is not finalized until all calculations set forth herein and in the Commissions Policies are completed and any necessary adjustments and/or offsets are made as set forth in this Agreement and the Commissions Policies.

3.3 Subject to applicable law, any money, fees or Points owed by Agent to WFG, actual or contingent Debit Balance, and any money or Points which have been advanced or credited by or on behalf of WFG or the Product Providers, for the benefit of Agent, may be offset and deducted by WFG from any Pending Commission payment. Agent agrees and acknowledges that any obligation to repay Debit Balances or any other amounts including those owed to WFG and paid to and through, or offset against, Pending Commissions by WFG arises from a commercial transaction and is of a business nature.

3.4 Agent authorizes Affiliated Companies to pay directly to WFG any Pending Commissions or other Compensation which are otherwise payable to Agent by such Affiliate Companies in order to satisfy any obligation or liability of Agent to WFG, or to compensate WFG for any damages, losses, costs and expenses which WFG may sustain or be liable for by reason of any act or failure to act on the part of Agent. Agent authorizes WFG to pay directly to any Affiliated Companies any Pending Commissions or other Compensation which are otherwise payable to Agent by WFG in order to satisfy any obligation or liability of Agent to such Affiliated Companies or to compensate Affiliated Companies for any damages, losses, costs and expenses which Affiliated Companies may sustain or be liable for by reason of any act or failure to act on the part of Agent.

3.5 Except as otherwise provided in this Agreement, and subject to the terms of this Section, if and when Agent qualifies for, and attains, certain Hierarchy Level designations established by WFG from time to time pursuant to the Agent Guidelines and any other policies, practices and procedures adopted by WFG, Agent shall become Vested and entitled to continue receiving Earned Commissions after termination from WFG, subject to all applicable laws and regulations, including but not limited to, the rules of any regulatory or self-regulatory organizations with jurisdiction over WFG. If Agent becomes Vested, then, in the event that this Agreement terminates due to Agent’s death, WFG shall pay the Commissions to Agent’s estate or, Agent’s beneficiary as designated in writing by Agent’s estate representative at time of death. Agent shall, upon becoming Vested, be Vested only to the extent that WFG actually receives payment(s) from Product Providers, the commissions are Earned Commissions as set forth herein, and Agent can legally receive such amounts. In the event that Agent, at the time of termination of this Agreement, has not qualified and attained the sales position designation(s) established by WFG as a condition to becoming Vested, Agent shall have no right to any Advance Commissions, Pending Commissions, Earned Commissions, or other Compensation of any kind from WFG after termination.

3.6 Notwithstanding anything in this Agreement to the contrary, if Agent is Vested but Agent’s termination from WFG is a “For Cause Termination” in accordance with Section 4.3(b), Divestiture may occur in WFG’s sole discretion and Agent forfeits any right to receive Earned Commissions post-termination, unless such Divestiture is prohibited by applicable law. Additionally, even if Agent’s termination from WFG is not a “For Cause Termination” in accordance with Sections 4.2 or 4.3(a), should Agent subsequently violate or fail to comply with any promise, obligation, covenant, warranty or representation contained in this Agreement or any Agent Guidelines or other policies, practices and procedures adopted by WFG which survive the termination of this Agreement, such violation or failure could result in Divestiture, as described in this Section, unless such Divestiture is prohibited by applicable law.

3.7 As an independent contractor, Agent shall be responsible for paying any and all federal, state, commonwealth, city or other taxes and related amounts that may become payable with respect to any Compensation Agent may receive under the terms of this Agreement including without limitation, to Federal Insurance Contributions Act (“FICA”), the Social Security Act, the Federal Unemployment Tax Act (“FUTA”), federal income tax withholding requirements, State Personal Income Tax Withholding (“PIT”), State Unemployment taxes (“UI”), State Disability Insurance (“SDI”), and all other federal, state, commonwealth, city and local laws, rules and regulations. Agent shall be treated as an independent contractor with respect to WFG. Agent represents that Agent will file all required tax returns, tax declarations, and tax schedules. Agent acknowledges and agrees that WFG will not withhold any taxes from Compensation it pays Agent, except as is otherwise required by law. WFG will report all Compensation paid to Agent via the applicable tax form(s) and Agent acknowledges and agrees that WFG shall issue such form(s) to Agent that includes Compensation paid by WFG.

4. Term and Termination

4.1 This Agreement shall take effect on the Effective Date and shall remain in force until terminated in accordance with this

WFGUS10045/01.19 9 of 17

Section 4.

4.2 This Agreement may be terminated by either Party at any time and for any reason upon thirty (30) days written notice

4.3 This Agreement shall terminate immediately without advance notice, pay in lieu of notice, damages or compensation of any kind:

(a) on the death of Agent; or

(b) where WFG determines in its sole discretion that it has cause for termination with the possibility of divestiture (“For Cause Termination”), which shall include the occurrence of any of the following events:

(i) Agent’s insurance license is terminated for any reason;

(ii) Agent is indicted with or subject to trial for any crime;

(iii) Disciplinary action is taken against Agent by any state, commonwealth, provincial or federal regulatory agency or body with jurisdiction over Agent, WFG, Affiliated Companies and/or Product Providers;

(iv) Agent becomes temporarily or permanently enjoined, censured, suspended, disciplined or otherwise prohibited from:

(1) acting as an Agent of WFG, Affiliated Companies or Product Providers;

(2) conducting his/her business or performing any of his/her services under this Agreement; or,

(3) acting in any capacity in the insurance or financial services business that WFG considers, in its sole discretion, relevant to Agent’s performance of Agent’s duties under this Agreement;

(v) Termination for any reason of Agent’s agreement(s) by any Product Provider or Affiliated Companies, and Agent expressly acknowledges and agrees that WFG may rely on Product Providers’ or Affiliated Companies’ determinations and representations regarding the reason(s) for the termination of Agent;

(vi) Agent’s misappropriation or commingling of Customer payments or funds for any Products and Services;

(vii) Agent engages in a fraudulent act;

(viii) Agent misrepresents the characteristics or benefits of any of the Products and Services;

(ix) Agent violates any law, rule or regulation that governs the conduct of any part of Agent’s business;

(x) Agent breaches any provision of, or fails to perform or observe any obligation under, this Agreement or any other agreement that the Agent may have, now or hereafter, with WFG, including without limitation failing to repay Debit Balances or comply with any other monetary obligation owed by Agent to WFG in a timely manner;

(xi) Agent engages in any activity which, in the sole opinion of WFG, may adversely affect the good name and reputation of WFG or Affiliated Companies;

(xii) Agent engages in any activity which, in the sole opinion of WFG, may be detrimental of the business interests of WFG or Affiliated Companies;

(xiii) Agent’s fails to comply with a material aspect of the Agent Guidelines as determined by WFG;

(xiv) Agent is determined to have made any false or incorrect statement(s) in an application to a regulatory authority or WFG;

WFGUS10045/01.19 10 of 17

(xv) Failure to meet and maintain the background criteria set by WFG and/or the Product Providers; or

4.4 At WFG’s discretion to enforce its Agent Guidelines, instead of immediately terminating this Agreement, WFG may impose suspension of Agent’s benefits and rights and privileges, including suspension of rights to solicit for purchase or sale, or solicit Customers for, Products and Services and suspension and loss of Compensation, and may impose other disciplinary action, including the assessing of fines, without liability to Agent for loss or otherwise. Suspension or disciplinary action shall not in any way preclude or diminish WFG’s right to terminate this Agreement at any time.

4.5 In the event of termination of this Agreement by either party, WFG shall be entitled to notify the Product Providers and any regulatory body of such termination as required by applicable law. Agent acknowledges and agrees that WFG shall not have any liability for any loss, damage or otherwise resulting from termination by the Product Providers based on such notice.

4.6 Upon the termination of this Agreement, all Compensation due Agent as of the effective date of termination shall be paid to Agent in accordance with WFG’s then current Agent Guidelines. Other than Earned Commissions to which Agent may be entitled if Agent is Vested, no further Compensation shall be payable to Agent after termination. Divestiture in a “For Cause Termination” is at the discretion of WFG.

4.7 The terms and provisions of any paragraphs or sections of this Agreement which expressly state, or by their terms require, that they survive termination of this Agreement, shall so survive the termination of this Agreement.

5. Mutual Arbitration Agreement

5.1 Any dispute, controversy, claim or cause of action between the Parties arising out of or related to this Agreement or any breach or termination of this Agreement, including the provision of services by Agent to WFG, that otherwise could be brought in a federal, state, or local court or agency under applicable federal, state, or local laws shall be submitted to and decided by binding arbitration pursuant to the terms and conditions of this Mutual Arbitration Agreement and in accordance with the Federal Arbitration Act, except as provided below. Arbitration shall be administered exclusively by JAMS and shall be conducted according to the rules, regulations, and requirements established by JAMS for arbitration actions pertaining to comparable claims and in accordance with any applicable law. Any arbitral award determination shall be final and binding upon the Parties. This Mutual Arbitration Agreement survives after the termination of the Agreement.

(a) Exceptions. This Mutual Arbitration Agreement shall not apply to:

(i) Claims that any provision of this Section is unenforceable, unconscionable, void or voidable, which shall be determined by a court of competent jurisdiction;

(ii) Requests for temporary or preliminary injunctive relief sought to protect the intellectual property rights of either party or to prevent material, imminent harm to Customers;

(iii) Actions seeking monetary relief of less than $25,000.00;

(iv) Claims for worker’s compensation or unemployment insurance benefits;

(v) Litigation between Agent and WFG, any Affiliated Companies, that is pending in a state or federal court as of the date of Agent’s execution of this Agreement;

(vi) Claims brought by administrative agencies or under private attorney general actions; and

(vii) Any claim that may not be arbitrated as provided by applicable law.

(b) Government Action. Nothing in the Agreement shall be interpreted to mean that Agent is precluded from filing a complaint of alleged violation of law or regulation to any governmental agency or legislative body, or to participate, cooperate or testify in any action, investigation or proceeding relating to an investigation of alleged violation of law by such governmental agency or legislative body. However, any issue, claim or dispute between the Parties that survives

WFGUS10045/01.19 11 of 17

such governmental action, investigation or proceeding shall be resolved exclusively under this Mutual Arbitration Agreement.

(c) Class Action Waiver. Arbitrations shall proceed only on an individual basis. The Parties waive the right to assert, participate in, or receive money or any other relief from any class, collective, or representative proceeding. Each party shall only submit their own individual claims against the other and will not seek to represent the interests of any other person. No arbitrator shall have jurisdiction or authority to compel any class or collective claim, to consolidate different arbitration proceedings, or to join any other party to an arbitration between the Parties.

(d) Applicable Rules. Arbitrations under this provision shall generally follow the rules set forth in the JAMS Comprehensive Arbitration Rules and Procedures; however, the Parties agree to the following provisions:

(i) Each party is entitled to representation by attorney(s) of their choice.

(ii) The Parties shall select the Arbitrator in accordance with the rules, regulations, and requirements established by JAMS for arbitration actions pertaining to comparable claims, unless the Parties otherwise agree in writing to select an Arbitrator of their own mutual choosing.

(iii) The Parties shall each be responsible for equal amounts of the arbitrator’s fees and expenses. Each party shall pay its own costs and attorneys’ fees, if any, subject to Section 5.1(d)(ii).

(iv) The arbitrator shall award to the prevailing party, if any, costs and attorneys’ fees reasonably incurred by the prevailing party in connection with the arbitration. If a party prevails on some but not all of the claims and counterclaims, the arbitrator may award the prevailing party an appropriate percentage of the costs and attorneys’ fees reasonably incurred by the prevailing party in connection with the arbitration.

(v) The arbitrator has no authority to award punitive damages and each party hereby waives any right to seek or recover punitive damages with respect to any dispute resolved by arbitration.

(vi) The Parties shall maintain the confidential nature of the arbitration proceeding and the award, if any, except as necessary to prepare for or conduct the arbitration hearing on the merits, or to prosecute or defend judicial actions permitted under this Mutual Arbitration Agreement and applicable JAMS rules, or unless otherwise required by law or judicial decision.

(vii) Notwithstanding this Section, if the Agent brings an action that necessitates a finding of whether or not the Agent is a common-law employee, the arbitrator shall make a preliminary designation of the Agent’s employment status for the sole purpose of determining which rules will apply to the arbitration proceedings. For purposes of making this designation, the Parties agree to apply the JAMS Expedited Procedures. If such designation is that of employee, the arbitration shall proceed under the JAMS Employment Arbitration Rules and Procedures and, in the event of any conflict between the JAMS Employment Arbitration Rules and Procedures and any provision of this Mutual Arbitration Agreement, the JAMS Employment Arbitration Rules and Procedures shall control and supersede the conflicting provision of this Mutual Arbitration Agreement. This provision in no way implies or infers that Agent is anything other than an independent contractor and WFG does not waive any defenses it has to a claim of employment status by the Agent.

(e) Severability. If it is adjudged that any portion of this Mutual Arbitration Agreement is unenforceable, in whole or in part, then the unenforceable provision shall be severed from this Mutual Arbitration Agreement and any enforceable remaining provisions of this Mutual Arbitration Agreement shall remain in full force and effect and any covered claims or disputes between the Parties shall be heard in arbitration thereunder. If a counter-claim is brought in response to a claim that is an exception to this Mutual Arbitration Agreement, such counter-claim is subject to arbitration unless it is also subject to an exception.

(f) Notice. If either party initiates arbitration, the initiating party must notify the other party in writing via certified mail, return receipt requested, or hand delivery within the applicable statute of limitations period. This demand for arbitration must include (a) the name and address of the party seeking arbitration, (b) a statement of the legal and factual basis of

WFGUS10045/01.19 12 of 17

the claim, and (c) a description of the remedy sought. Any demand for arbitration by Agent must be delivered to World Financial Group Insurance Agency, Inc., Attn: President, 11315 Johns Creek Parkway, Johns Creek, Georgia 30097, with a separately delivered copy to General Counsel, Legal Department, 6400 C Street SW, Cedar Rapids, Iowa 52499.

(g) Location. Unless otherwise agreed to by the Parties in writing, arbitration shall take place in Atlanta, Georgia.

(h) Binding Arbitration. The Arbitrator shall render a final and binding award based solely on the evidence presented, and the applicable law, and the provisions contained herein. The award shall be rendered promptly and, unless otherwise agreed by the parties, no later than sixty calendar days from the close of the arbitration hearing. The award shall be in writing and signed and dated by the Arbitrator and shall contain express findings of fact and the rationale for the award, including any conclusions of law and discussions of binding or persuasive authorities. Except as may be permitted or required by law, neither a party nor an Arbitrator may disclose the existence, content, or results of any arbitration hereunder without the prior written consent of all parties. A court of competent jurisdiction shall have the authority to enter a judgment upon the award made pursuant to the arbitration.

(i) Full and Complete Agreement. This Mutual Arbitration Agreement is the full and complete agreement between the Parties relating to the resolution of any covered dispute, controversy, claim or cause of action between them in arbitration. Any prior agreements, representations, or other statements regarding such matters covered by this Mutual Arbitration Agreement are hereby null and void and shall be superseded by this Mutual Arbitration Agreement.

6. Agent’s Promise to Indemnify and Assign

6.1 Agent agrees to defend, indemnify and hold harmless any Indemnified Party with respect to any demand or claim related in any way to any failure to declare, collect, remit and/or pay on a timely basis all required taxes and related amounts.

6.2 Agent further agrees to indemnify and hold any Indemnified Party harmless, from and against, any and all Indemnified Losses (the “Claims”) incurred, sustained, suffered, or assessed against the Indemnified Party because of, arising out of, or as a result of, any act(s) or omission(s) of Agent, Agent’s Assistants, if any, or any of Agent’s Downline Agents, including but not limited to a breach of this Agreement, or any breach of contract(s) with the Product Providers, including but not limited to a misrepresentation involving whether Agent is authorized to act on behalf of an Indemnified Party or Product Providers or a misrepresentation involving the offer, referral or sale of Products and Services. In defending or otherwise addressing any such Claims, the Indemnified Party shall be entitled to use counsel of its own choosing and determine the validity of the Claims. The Indemnified Party shall not be required to notify the Agent of the existence or the progress of the defense of any such Claims as condition precedent to requiring payment by the Agent of the Indemnified Losses.

6.3 To secure the Agent’s promise of indemnification and the Agent’s obligation to repay any outstanding Debit Balance owed to WFG, Agent hereby assigns and grants to the appropriate Indemnified Party(ies) a continuing security interest in all Pending Commissions payable to Agent from WFG to the extent necessary to satisfy any Indemnified Losses or Debit Balance obligation of Agent. Agent agrees to execute such additional instruments or documents as may be necessary from time to time to perfect such security interest. This assignment is given to WFG to secure the Agent’s obligations as set forth in this Agreement. Agent expressly authorizes WFG to withhold Pending Commissions in connection with any indemnity obligation of the Agent owing to WFG.

7. Miscellaneous

7.1 WFG shall have the right to amend this Agreement at any time by giving written notice in compliance with Section 7.3(c), effective upon a minimum of 45 days advanced notice.

7.2 WFG may, from time to time, with or without notice, increase or decrease the rates and amounts of Commissions of agents, including Agent; provided, however, that any such changes may only be applied prospectively, and any such changes may affect only Commissions paid on any new business or subsequent payments on existing business.

7.3 All notices or demands hereunder shall be sent addressed as follows:

WFGUS10045/01.19 13 of 17

(a) if to WFG, to the attention of President, World Financial Group Insurance Agency, Inc. at WFG’s then principal home office address, with a separately delivered copy to General Counsel, Legal Department, 6400 C Street SW, Cedar Rapids, Iowa 52499 sent by certified mail, return receipt requested, postage and certified fees prepaid, or by overnight courier service;

(b) if to an officer, director or employee of WFG, then addressed to that person c/o World Financial Group Insurance Agency, Inc., at WFG’s then principal home office address, with a separately delivered copy to General Counsel, Legal Department, 6400 C Street SW, Cedar Rapids, Iowa 52499 sent by certified mail, return receipt requested, postage and certified fees prepaid, or by overnight courier services; and,

(c) if to the Agent, addressed to him/her at such Agent’s home address or email address as reflected on WFG’s business records sent by electronic email or overnight courier service. Agent shall immediately notify WFG of any change in the Agent’s home and/or email address.

7.4 This Agreement is not a franchise agreement and does not create a franchise relationship between WFG and Agent. If any provision of this Agreement is deemed to create a franchise between the parties, then those provisions shall be deemed void and unenforceable and shall not impact the validity of any other provision(s) of this Agreement.

7.5 The failure or delay by any Party to insist upon strict performance of the terms and conditions of this Agreement shall not be deemed a waiver of any subsequent breach or default in the terms hereof. Any waiver must be in writing and signed by the Party granting the waiver. Any waiver granted by WFG must be signed by an officer of WFG.

7.6 Titles and headings of sections and subsections of this Agreement are for convenience and are not intended to encompass all of the provisions therein or to interpret such provisions.

7.7 If any part, section, clause, paragraph, term or provision of this Agreement shall be found to be void or unenforceable, such finding shall have no effect upon any other part, section, clause, paragraph, term or provision of this Agreement.

7.8 Agent may not assign any rights or obligations or delegate any services under this Agreement except as expressly provided herein, as expressly provided in the Agent Guidelines, or as otherwise authorized in writing by WFG prior to such assignment or delegation. WFG may assign any or all of its rights and obligations under this Agreement to any of the Affiliated Companies or other party; and Agent hereby consents and agrees to such assignment. Agent further agrees that, after any such assignment, WFG shall be released from all obligations and liabilities so assigned.

7.9 This Agreement (including all Exhibits) constitutes the entire agreement and understanding between the Parties hereto, unless another agreement is executed by the Parties simultaneously with or subsequent to this Agreement which makes specific reference to this Agreement and expressly supplements or modifies this Agreement. No attempted amendment of this Agreement shall be binding upon WFG unless agreed to in writing by an officer of WFG.

7.10 While certain business activities of the Agent may occur outside of Georgia, the Parties acknowledge that significant aspects of performance of this Agreement will occur in the State of Georgia, and that the provisions of this Agreement will be governed and construed under the laws of the State of Georgia. If conflict or choice of law rules would result in the application of the law of another jurisdiction, each Party waives such rules and agrees that the substantive law of Georgia shall nonetheless govern. Agent and WFG, without waiving their rights or relieving them of their obligations to arbitrate claims set forth in the Arbitration provision and herein confirming that the Parties Mutual Arbitration Agreement is governed by the FAA, expressly consent to the jurisdiction and venue of the Georgia Courts with respect to any such dispute or litigation.

7.11 In the interest of maintaining the safety and security of WFG’s customers, employees and property, Agent agrees that WFG shall have the right to run such credit, employment and other financial and background investigations on the Agent at any time as WFG deems useful, whether such investigation is conducted by WFG or by an outside service or third party. The Agent shall provide any necessary consents to such investigations, and consents to the disclosure by any person or entity to WFG or its designee, of any financial, background and employment information conducted by WFG or by an outside service or third party. Agent further consents to the disclosure by WFG of such information to any Product Provider to which Agent desires to get appointed.

WFGUS10045/01.19 14 of 17

7.12 As a condition to becoming an Agent of WFG, the Agent is not required to purchase any of the Products and Services and is not required to pay WFG or the Product Providers any consideration for not purchasing a Product or Service. Further, in order to purchase any Products and Services, the Agent is not required to be affiliated with WFG, Affiliated Companies or the Product Providers.

7.13 Agent irrevocably consents to and forever authorizes the use by WFG or anyone authorized by WFG, its legal representatives or assigns, the absolute and unqualified right to use all photographs in which the Agent has appeared for WFG and reproductions thereof, in which the Agent has been included in whole or part, made through any media without inspection or approval of the finished product or use to which it may be applied, in any manner WFG may desire, factually or fictionally, including the right to make adaptations of said material of every and any kind and character. For such purpose, WFG may obtain copyright in all countries on such use by WFG of such material in any form and upon any and all adaptations thereof to renew such copyrights. The Agent releases and discharges WFG, Affiliated Companies, their assigns, agents, or licensees from any and all claims and demands that the Agent may have, which arise out of or in connection with the use of such photographs or reproductions, including but not limited to, any and all claims of libel, slander, and invasion of privacy.

 By signing this Agreement, I hereby revoke and terminate any Associate Membership Agreement that I previously signed with World Financial Group, Inc., World Marketing Alliance, Inc. or any other predecessor to World Marketing Alliance, Inc. which is still in effect and agree that all such language is superseded by the language herein.

Agent:

Agent Name

By:Agent’s Signature

Dated:

World Financial Group Insurance Agency, Inc.World Financial Group Insurance Agency of Hawaii, Inc.World Financial Group Insurance Agency of Massachusetts, Inc.WFG Insurance Agency of Puerto Rico, Inc.

By: Thomas Dempsey President

WFGUS10045/01.19 15 of 17

EXHIBIT A

PRIVACY COMPLIANCE POLICIES

A. Privacy and Confidentiality Generally

(i) Except to the extent directly required to perform your services under this Agreement, you shall hold in strictest confidence and not disclose to any Person or use, at any time, whether during or after the termination of this Agreement, any information that we disclose or make available to you that is confidential or proprietary (“Information”). Without limiting your obligations under the previous sentence, you shall apply at least the same standard of care to protect the confidentiality of the Information as you use to protect your own confidential information. Upon termination of this Agreement, you shall return or securely destroy all Information without retaining any copies and shall provide us with your written and signed certification to that effect. All Information is our sole and exclusive property.

(ii) If you are requested to disclose Information pursuant to a subpoena or lawful order, unless prohibited by law, you shall notify us within 10 days of such request. In any event prior to responding, unless expressly prohibited by law, you shall (A) advise us of the terms of and circumstances relating to such request, (B) consult with us on the advisability of attempting to resist or narrow such request, and (C) if disclosure of Information is required, furnish only such Information you are legally obligated to disclose and cooperate with us to obtain assurance that the disclosed Information will be held in confidence. You also shall comply with our privacy and security rules that we have provided to you in writing.

B. Compliance with GLBA – You shall comply with the privacy requirements of the Gramm-Leach-Bliley Act and its rules and regulations as any of the same may be amended or superseded from time to time (“GLBA”). Compliance with GLBA includes the following:

(i) You may use or disclose Nonpublic Personal Financial Information only to perform your services under this Agreement, as specifically provided in Section E(iii) below, or as required by law. “Nonpublic Personal Financial Information” means personally identifiable financial information and includes any list, description, or other grouping of consumers (and publicly available information pertaining to them) that is derived using any nonpublic personal information; provided, however, that the above definition shall be superseded and replaced to the extent that the definition of Nonpublic Personal Financial Information under Title V of Public Law 106-102, Section 509, subsection (4), as the same may be amended or superseded from time to time, differs from this definition.

(ii) You shall maintain appropriate administrative, physical and technical safeguards to prevent prohibited uses or disclosures of Nonpublic Personal Financial Information.

(iii) You shall require that your directors, officers, and employees who have access to Nonpublic Personal Financial Information agree in writing to the same restrictions and conditions that apply to you.

C. Compliance with HIPAA – You shall comply with the privacy and security requirements of HIPAA. Compliance with HIPAA includes the following:

(i) You may use or disclose Protected Health Information only to perform your services under this Agreement, for the proper management and administration of your business (other than for cross-marketing and/or cross-selling of other policies or products, which are prohibited except to the extent specifically provided in Section E(iii) below), to carry out your legal responsibilities, or otherwise as required by law. “Protected Health Information” has the same meaning as the term “protected health information” in 45 C.F.R. §164.501 (as the same may be amended or superseded from time to time), limited to information that you create or that you receive from us or on our behalf, and includes information that relates to the past, present, or future physical or mental health or condition of a Policyholder, to the provision of health care to a Policyholder, or to the past, present, or future payment for the provision of health care to a Policyholder, and that identifies the Policyholder or for which there is a reasonable basis to believe that the information can be used to identify the Policyholder, in each case regardless of whether the Policyholder is living or deceased. By way of illustration only, the following information shall constitute Protected Health Information with respect to a Policyholder: (A) name, (B) street address, city, county, precinct, and zip code, (C) dates directly related to the Policyholder, including birth date,

WFGUS10045/01.19 16 of 17

admission date, discharge date, and date of death, (D) telephone numbers, fax numbers, and electronic mail addresses, (E) social security number, (F) medical record numbers, (G) health plan beneficiary numbers, (H) account numbers, (I) certificate/license numbers, (J) vehicle identifiers and serial numbers, including license plate numbers, and (K) any other unique identifying numbers, characteristics, or codes.

(ii) You may not use or disclose Protected Health Information in any manner that would constitute a violation of 45 C.F.R. Parts 160 and 164 if we used or disclosed the information in the same manner.

(iii) You shall comply with our request to accommodate a Policyholder’s access to his or her Protected Health Information as provided by 45 C.F.R. §164.524.

(iv) You shall comply with our request to amend Protected Health Information in accordance with a Policyholder’s request as provided by 45 C.F.R. § 164.526.

(v) You shall keep a record of disclosures of or access to Protected Health Information that must be provided under HIPAA to an individual to whom the Protected Health Information relates. You shall comply with any request that we make to provide us with information pertaining to such disclosures or access in such format as we reasonably may request. Such provided information shall include the content as required under HIPAA.

(vi) You shall make your internal practices, books, and records relating to uses and disclosures of Protected Health Information available to us (or to our designee) and to the Secretary of the U.S. Department of Health and Human Services (the “Secretary”), or to the Secretary’s designee, for the purpose of confirming your compliance and/or our compliance with 45 C.F.R. Parts 160 and 164.

(vii) Upon termination of this Agreement, if feasible, you shall return or destroy all Protected Health Information without retaining any copies and shall provide us with your written and signed certification to that effect. If such return or destruction is not feasible, you shall limit all further uses and disclosures to those purposes that make such return or destruction of the Protected Health Information not feasible.

(viii) You shall maintain appropriate administrative, physical and technical safeguards to prevent prohibited uses or disclosures, and to protect the confidentiality, integrity and availability, of any Protected Health Information that you create, receive, maintain or transmit. Such safeguards shall include development, implementation, and maintenance of a comprehensive written information security program compliant with applicable laws and designed to (A) protect the integrity and confidentiality of Protected Health Information, (B) protect against anticipated threats or hazards to the security, confidentiality and/or integrity of Protected Health Information, (C) protect against any unauthorized disclosure or use of Protected Health Information, (D) address computer and network security, (E) address physical security, and (F) provide for the secure disposal and destruction of Protected Health Information.

(ix) You shall ensure that any subcontractors (as defined in 45 C.F.R. § 160.101) that create, receive, maintain, or transmit Protected Health Information on your behalf agree to the same restrictions and conditions that apply to you with respect to such information. You agree to enter into appropriate written agreements outlining these obligations and to obtain satisfactory assurances (as that term is contemplated in HIPAA) of such compliance by all subcontractors. To the extent you make disclosures under 45 C.F.R. § 164.504(e)(4), you will obtain reasonable assurances that PHI will be held in confidence and will not be used or disclosed outside of the intended purpose.

(x) You shall require that your directors, officers, and employees who have access to Protected Health Information agree to the same restrictions and conditions that apply to you with respect to such information.

D. Compliance with HITECH Act

(i) You agree and acknowledge that you are directly subject to HIPAA as amended by the HITECH Act, including, without limitation, Sections 164.308, 164.310, 164.312 and 164.316 thereof, including its provisions relating to security and privacy of Protected Health Information as well as its enforcement and penalty provisions. You agree that you will comply with all applicable security and privacy provisions of HIPAA as amended by the HITECH Act and as it may be amended from time to time.

WFGUS10045/01.19 17 of 17

(ii) In the event either party learns of a pattern of activity or practice of the other party that constitutes a material breach or violation of its obligations relating to Protected Health Information under the Agreement, the non-breaching party will take reasonable steps to cure the breach or end the violation. If such steps are unsuccessful, the non-breaching party will terminate the Agreement, if feasible, or if termination is not feasible, report the problem to the Secretary. We reserve the right, in our sole discretion, to terminate this Agreement immediately upon notice in the event of any such material breach or security incident.

(iii) You acknowledge and agree to adhere to any limitations on the disclosure and/or sale of Protected Health Information as required under 45 C.F.R. § 164.508(d) and/or under HIPAA.

E. Additional Provisions Relating to Confidentiality Generally, GLBA, and HIPAA

(i) In response to an unsolicited direct Policyholder, Certificateholder, or Consumer inquiry, you may disclose Nonpublic Personal Financial Information and Protected Health Information directly to, and may discuss such information directly with, the Policyholder, Certificateholder, or Consumer to whom such information pertains, provided that such disclosure would not violate HIPAA if we made it.

(ii) We acknowledge that you may have relationships with affinity groups and associations and that, as a result, you may receive information (“Group Member Information”) relating to their members (each a “Group Member”) that constitutes Nonpublic Personal Financial Information and/or Protected Health Information. You and we agree that a Group Member’s Group Member Information shall constitute Nonpublic Personal Financial Information and/or Protected Health Information only from and after the time that a Group Member applies for a Policy.

(iii) You may use Information, Nonpublic Personal Financial Information and/or Protected Health Information for cross-marketing and/or cross-selling of other policies or products to the extent, but only to the extent, that the Policyholder to whom such information pertains has authorized you specifically in a writing that complies with HIPAA to do so and such marketing and selling is conducted in adherence with the restrictions on marketing and sale of PHI as provided under HIPAA.

(iv) Any ambiguity in this Agreement shall be resolved in favor of a meaning that permits compliance with GLBA and HIPAA.

(v) You shall notify us in writing without unreasonable delay and in any event within three (3) business days after becoming aware of a violation of Sections B, D, or E of this Agreement, or of the occurrence of a “security incident,” as defined in 45 C.F.R. §164.304. You agree to cooperate fully with us in any security-incident investigation or resolution and agree that no notifications or communications to any individual(s), media outlets, state or federal regulatory authorities, or other third parties regarding the incident shall be made without in each instance our specific prior written consent.

(vi) You shall comply with all applicable state and local laws and regulations enacted to protect the privacy of individual personal information.

(vii) We can further amend this Amendment to Agreement without your consent to reflect (i) future amendments of GLBA or HIPAA, or (ii) court orders interpreting the application of GLBA or HIPAA, or (iii) a material change in our business practices, but any such amendment shall be enforceable against you only after we have notified you.

(viii) Covered Entity shall notify you of any limitation(s) in its notice of privacy practices of Covered Entity in accordance with 45 CFR § 164.520, to the extent that such limitation may affect your use or disclosure of PHI.

(ix) Covered Entity shall notify you of any changes in, or revocation of, permission by an individual to use or disclose PHI, to the extent that such changes may affect your use or disclosure of PHI.

(x) Covered Entity shall notify you of any restriction to the use or disclosure of PHI that Covered Entity has agreed to in accordance with 45 CFR § 164.522, to the extent that such restriction may affect your use or disclosure of PHI.

PLEASE TYPE OR PRINT LEGIBLY As payment for fees and charges, WFG accepts debit and/or credit cards (Master Card, VISA, Discover, and

American Express). Please complete the form below and attach it to the front of the Agent Agreement. Your credit card will be charged the amount indicated below.

ALL ACKNOWLEDGEMENT/APPLICATION FEES ARE NON-REFUNDABLE AND NON-TRANSFERABLE.

ASSOCIATE/AGENT INFORMATION

Agent’s Name

Address

City State Zip Code

Telephone Fax

Email Address

CREDIT CARD INFORMATION

Agent Agreement: $125

Please check one: Master Card VISA Discover American Express Expiration Date:

Credit Card #: Verification Code:

Cardholder’s Name as it appears on card:

Cardholder’s Signature:

The undersigned credit/debit cardholder authorizes World Financial Group Insurance Agency, Inc. to bill or charge the above credit/debit card. The undersigned acknowledges and agrees that the fees paid herein are non-refundable and non-transferable. The undersigned agrees to the terms and conditions of this credit card payment agreement. Payment will not be accepted without cardholder’s signature.

Agent Signature: Date:

Fax this completed credit card payment form to: 770-248-3300

Credit Card Agreement

©2018 World Financial Group, Inc. WFGUS10045B2/12.18