Sponsor Guide to Understanding Fee Disclosure

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Elfrieda Beasley
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Sponsor Guide to Understanding Fee Disclosure The Department of Labor s regulation (covering plans subject to the Employee Retirement Income Security Act of 1974 (ERISA)) requires service providers,

1 Sponsor Guide to Understanding Fee Disclosure The Department of Labor s regulation (covering plans subject to the Employee Retirement Income Security Act of 1974 (ERISA)) requires service providers, including ING* to disclose direct and indirect fees and compensation for services that are expected to be at least $1,000, as well as any fiduciary or investment advisory role it might be assuming. Service providers must also generally report any changes to disclosure information to you, as the plan fiduciary, as soon as possible, but no later than 60 days after we are informed of or initiate the change. However, note that changes to investment related disclosures must be reported at least annually. ING provides this disclosure to you in two reports: the Investment Expenses and Indirect Compensation report and the Service Description and Direct Compensation report. The following is intended to help you understand the reports provided by ING. Please Note: The reports that ING provides to you do not supersede the terms of your program agreement with ING. In the event of a conflict between these reports and the contract or other program agreements or disclosure, the terms of the contract and/or other program agreements and disclosure will prevail. In addition, ING offers a variety of products to meet the needs of our clients, and the terminology used to describe fees in your contract may differ slightly from the terminology used in the fee disclosure reports (for example, Self Directed Brokerage Option vs. Self Directed Brokerage Account). Please be assured that the fees themselves have not changed. Guide to reading the Investment Expenses and Indirect Compensation report The chart on the next page shows the components of the investment expenses for the non-fixed interest funds available under your plan, as well as the revenue paid to ING from the funds in support of the recordkeeping and administrative services we provide in connection with your plan. It can include mutual fund operating expenses and contract charges, such as a mortality and expense charge or daily asset charge, if applicable. The revenue received by ING from the fund is paid by the fund itself or a related party (e.g., the fund s investment manager) and is not an additional expense above the fund fees. ING uses this revenue to maintain the investment, administrative and technological platforms and other supporting services used by your plan. Part of this revenue may also be used to compensate your adviser. Amounts shown will be based on charges in effect as of the date at the top of each page of the report and are subject to change. Indirect compensation generally refers to compensation that is paid from sources other than the plan or a plan sponsor. It includes compensation that service providers receive from fund companies and others providing services in connection with the plan. *ING refers to ING Life Insurance and Annuity Company, ING Institutional Plan Services and/or Reliastar Life Insurance Company. Your future. Made easier.

SAMPLE 1: COMPONENTS OF THE INVESTMENT EXPENSES This chart shows the components of the investment expenses for the non-fixed interest funds available under your plan, as well as the revenue paid to

2 SAMPLE 1: COMPONENTS OF THE INVESTMENT EXPENSES This chart shows the components of the investment expenses for the non-fixed interest funds available under your plan, as well as the revenue paid to ING from the funds in support of the recordkeeping and administrative services we provide in connection with your plan. Expenses Paid Recordkeeping Revenue to ING FUND EXPENSES TOTAL TOTAL Fund No. Fund Name (A) Management Fees (B) 12b-1 Fees (C) Other Expenses (D) Gross Fund Expenses (A+B+C) (E) Waivers and Adjustments (F) Net Fund Expense (D+E) Prospectus Date (G) Sub TA Expense Reimbursement (H) 12b-1 Fee (I) Service Fee (J) Total Revenue to ING (G+H+I) 0000 Fund name to go here 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% MM/DD/YYYY 0.00% 0.00% 0.00% 0.00% 0000 Fund name to go here 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% MM/DD/YYYY 0.00% 0.00% 0.00% 0.00% 0000 Fund name to go here 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% MM/DD/YYYY 0.00% 0.00% 0.00% 0.00% 0000 Fund name to go here - Fixed Investment Option N/A N/A N/A N/A N/A N/A N/A N/A N/A 0.00% 0.00% 2

SAMPLE 3: OTHER POTENTIAL SOURCES OF INDIRECT COMPENSATION This section of the report shows other potential

3 SAMPLE 2: FEES PAID TO ING If applicable to your plan, this section of the report shows revenue paid to ING by the funds on a per-participant basis and/or redemption fees that may apply to certain funds. SAMPLE 3: OTHER POTENTIAL SOURCES OF INDIRECT COMPENSATION This section of the report shows other potential sources of indirect compensation. Items such as Self Directed Brokerage Account will only appear on your report if your plan offers this option. 3

4 SAMPLE 4: APPENDIX OF COMMONLY USED TERMS This section of the report is an appendix of the terms commonly used in the Investment Expenses chart B.S (2/12) 4

Guide to reading the Service Description and Direct Compensation report In addition to investment-related compensation, a plan may pay direct fees to

Direct fees are hard dollar fees that are either paid directly by the plan sponsor or deducted from plan participant accounts and/or the plan

5 Guide to reading the Service Description and Direct Compensation report In addition to investment-related compensation, a plan may pay direct fees to ING in connection with the recordkeeping and other services ING provides. Direct fees are hard dollar fees that are either paid directly by the plan sponsor or deducted from plan participant accounts and/or the plan forfeiture account, in accordance with the terms of the plan, for recordkeeping or other administrative services. SAMPLE 5: RECORDKEEPING SERVICES This section of the report lists the standard recordkeeping services offered by ING. 5

SAMPLE 7: DIRECT FEES FOR OPTIONAL SERVICES This section of the report shows the direct fees for

6 SAMPLE 6: DIRECT FEES ASSOCIATED WITH STANDARD RECORDKEEPING SERVICES This section of the report shows the direct fees associated with the recordkeeping services provided to your plan. SAMPLE 7: DIRECT FEES FOR OPTIONAL SERVICES This section of the report shows the direct fees for optional services available under your plan. Only the services you have actually selected for your plan will appear. 6

7 SAMPLE 8: ADDITIONAL OPTIONAL SERVICES This section of the report shows additional optional services that may be a part of your plan. Only the services you have actually selected for your plan will appear. 7

8 ING IS COMMITTED TO HELPING YOU MANAGE YOUR PLAN Information available upon request ING and their predecessor companies have been providing recordkeeping and administrative services to defined contribution plans for more than 40 years. Our experience includes technology to help manage your plan, comprehensive support to help navigate today s regulatory landscape, dedicated resources to support your specific plan needs and communications to help educate, guide and motivate your participants to take full advantage of your plan s benefits. If you have any questions or need additional information about your disclosure obligations or the disclosures you will be receiving from ING, please contact your ING representative. IRS Circular 230 Disclosure To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this document is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code, or (ii) promoting, marketing, or recommending to another party any transaction or matter that is contained in this document. Neither ING nor its affiliated companies or representatives offer legal or tax advice. Please seek the advice of a tax attorney or tax advisor prior to making a tax-related decision. Any insurance products, annuities and funding agreements that you may have purchased are sold as securities and are issued by ING Life Insurance and Annuity Company, ("ILIAC"), One Orange Way, Windsor CT or ReliaStar Life Insurance Company, "ReliaStar", 20 Washington Avenue South, Minneapolis, MN Fixed annuities are issued by ILIAC or Reliastar. ILIAC or ReliaStar is solely responsible for meeting its obligations. Plan administrative services provided by ILIAC or ING Institutional Plan Services, LLC ("IIPS"). Neither ILIAC, ReliaStar nor IIPS engage in the sale or solicitation of securities. Securities are distributed by ING Financial Advisers, LLC (member SIPC), Directed Services, LLC (member SIPC) or other broker-dealers with which it has a selling agreement. All companies are members of the ING family of companies. All products or services may not be available in all states X.S ING North America Insurance Corporation CN

Fee Disclosure Q&A for Employers September 2014

Fee Disclosure Q&A for Employers September 2014 The Department of Labor (DOL) has issued two sets of final regulations requiring the disclosure of fees and expenses under plans governed by the Employee