A suitable match. Producer guide to fixed annuity suitability. For agent use only. Not for public distribution.

Transcription

1 A suitable match Producer guide to fixed annuity suitability

2 We believe everyone is entitled to a secure financial future and we re committed to making that possible one person, one family and one institution at a time. We re here, each and every day, to help you and your clients envision the future, get organized and take the steps necessary to pursue financial success together. Purpose This guide will assist you in understanding and completing the Suitability Profile form that must accompany fixed annuity applications. In addition to the section by section instructions, we have provided an excerpt from the Suitability Regulation at the end of this document to assist you in understanding and explaining to your client why we request certain information. It s your responsibility Every recommendation you make must be suitable for your client. A decision to recommend an annuity should be based on a careful analysis of the information you gather from your client. This means that, before recommending the purchase or replacement of an annuity, you must first obtain a full and accurate picture of your client s individual needs, financial status and financial objectives. Annuities can be a valuable component of a diversified portfolio, but may not be right for everyone. You should disregard compensation, bonuses, and any other incentives when making a recommendation or suitability determination.

3 Please note: product specific training is required prior to solicitation. Voya makes available various webinars that provide additional information regarding product features and strategies. When making a suitability determination and reviewing the proposed annuity with your customer, please utilize the product disclosure (as applicable) to explain the contract terms and conditions, and ensure the customer understands the product being recommended. If your client does not understand the product you should not proceed with the recommendation until you have answered any questions the client has regarding the proposed annuity. You must complete and submit a Suitability Profile form with each annuity application. We may ask you to provide additional details as part of our suitability review. You should do a thorough examination of all of your client s sources of income and expenses to determine if your client can afford to purchase the annuity. You should determine whether the client has sufficient income and liquid assets to reasonably pay current and anticipated living expenses after purchasing the proposed annuity in the payout period as applicable, or without taking withdrawals or other distributions from the proposed annuity during its surrender period. While you cannot predict the future, your client should have enough income or liquid assets to provide a cushion for any expected or unexpected life changes. You should determine whether your client would have too much net worth in fixed annuities as a result of the proposed purchase, taking into consideration all annuities owned. Every client s situation is different. There is no such thing as a typical annuity customer. Note: Some firms have entered into a Suitability Addendum with Voya and have agreed to conduct the suitability review. If you are affiliated with any of those firms, you are required to follow that firm s suitability process in place of the Voya Suitability Profile. The DOL Fiduciary Rule This guide is intended as an overview of annuity suitability. You may have additional obligations if the proposed annuity is covered by the Department of Labor (DOL) Fiduciary Rule. Fiduciaries relying on Prohibited Transaction Exemptions must adhere to the Best Interest Standard as of June 9, Advice must be prudent and loyal; you must avoid misleading statements, and receive no more than reasonable compensation. Voya Financial insurance companies will not act as a fiduciary or Financial Institution. Although Voya cannot provide you with legal advice regarding your obligations under the DOL fiduciary rule, we do require you to take all necessary steps to comply with the rule. Tell us the story The Suitability Profile form allows you to tell us the story of your client and how the proposed annuity meets the client s financial goals and objectives; we understand that Suitability is not one size fits all. The Suitability Profile questions are designed to meet the requirements under the various state regulations. We need your assistance in telling the full story of how the proposed annuity best meets the needs and objectives of your clients. To that end, providing as much information as possible regarding how the proposed annuity aligns with your client s needs and objectives will assist us in our review. This symbol serves as a reminder to tell us the story. As you see items throughout this guide that include this symbol, feel free to provide a cover letter and/or use the Producer Acknowledgement section of the Suitability form to provide additional details. 1

4 Owner/joint owner information OWNER/JOINT OWNER INFORMATION Owner s name 1 : Current age: Anticipated retirement age: SSN/TIN: Are you actively employed? c Yes c No c Retired Joint owner s name: Current age: Anticipated retirement age: Are you actively employed? SSN/TIN: c Yes c No c Retired How long have you known the Producer? c Less than 1 year c 1 to 3 years c 3+ years For Trust Owned contracts - complete the form based on the Trust information as compared to the Annuitant or Grantor of the Trust. Note: Any death benefit is payable upon the death of the annuitant for Non-Natural Owned Annuity Contracts. Make sure to include each owner s name, current and anticipated retirement ages, SSN/TIN and whether the owner is actively employed. If the client is not actively employed and is not retired, please include additional information regarding the client s source of income. If the client is drawing unemployment benefits, please indicate the date those benefits will cease under question 3 in the Financial Status section. If the anticipated retirement age is less than the surrender charge period of the proposed annuity, please provide additional details regarding the impact of the change of income and/or possible change in expenses under question 3 in the Financial Status section. For non-natural owners, including trusts, please indicate N/A for current age and anticipated retirement age. Include a detailed explanation in the Producer Acknowledgement section of how the proposed annuity is in line with the objectives of the Trust and/or Non-Natural Owner and the relationship of the annuitant to the non-natural owner. You must indicate how long you ve known the client. Financial status FINANCIAL STATUS 1. The first year surrender charge for the Voya annuity applied for is (not applicable for SPIA)... %. 2. The surrender charge time period for the Voya annuity applied for is (not applicable for SPIA)... years. Questions 1 and 2 provide an opportunity for you to review important aspects of the proposed annuity with your client in relationship to the proceeding financial information, and help in determining the suitability of the proposed annuity. Note: This section is not applicable for single premium immediate annuity (SPIA) sales. Example disclosure form surrender charge information If you are unsure what the charges are or the number of years the surrender charge is in effect, you can find this information on the product disclosure form under Fees, Expenses & Other Charges. In the example shown to the right, the responses would be: Question 1 = 10% Question 2 = 10 years 2

5 SUITABILITY PROFILE Voya Insurance and Annuity Company, Des Moines, IA ReliaStar Life Insurance Company, Minneapolis, MN - (Voya Retirement Index Select only) ReliaStar Life Insurance Company of New York, Woodbury, NY Voya Retirement Insurance and Annuity Company, Windsor, CT (the Company ) 3. Members Do you of anticipate the Voya any family of the of following companies changes during the surrender charge period (or the payout period for your immediate annuity) Fax: indicated for the Voya annuity? RESET FORM Mail: PO Box 1337, Des Moines, IA Customer If you Service: answer yes 909 to Locust any part Street, of question Des Moines, 3, please IA explain If possible estimate when you expect changes and the amount. Website: Voya.com Phone: Fixed Annuities a. Significant increase/decrease in living expenses (e.g. housing, medical care, assisted living costs)... c Yes c No SUITABILITY The purpose If yes, please of this PROFILE explain: profile is to help ensure that the product you are purchasing is appropriate based on your financial situation and longterm goals. Insurance Please and complete Annuity this Company, profile in Des its entirety Moines, and IA submit it with your application. Voya ReliaStar b. Significant increase/decrease income (e.g. retirement, lower pension amount, change in jobs)... c Yes c No OWNER/JOINT Life Insurance OWNER Company, INFORMATION Minneapolis, MN - (Voya Retirement Index Select only) ReliaStar If yes, Life please Insurance explain: Company of New York, Woodbury, NY Voya Retirement Insurance and Annuity Company, Windsor, CT Owner s c. Significant name 1 : increase/decrease in liquid assets (e.g. children s education, Current age: real estate transactions)... Anticipated retirement age: (the Company ) c Yes c No Members If yes, of please the Voya explain: family of companies Are you actively employed? Fax: SSN/TIN: c Yes c No c Retired Mail: d. PO Significant Box 1337, increase/decrease Des Moines, IA in net worth (e.g. bonuses/stock options, inheritance, settlements)... c Yes c No Customer Joint If owner s yes, Service: please name: 909 explain: Locust Street, Des Moines, IA Current age: Anticipated retirement age: Question Website: Voya.com 3 is to understand Phone: if the client will have any changes in living expenses, Fixed income, Annuities Are you actively employed? liquid assets or net worth The SSN/TIN: purpose during of the this profile surrender is to help charge ensure that period the product or payout are period purchasing as is applicable, appropriate c based that Yes on would c your No financial require c Retired situation the client and longterm goals. Please complete this profile in its entirety and submit it with your application. to access the How funds long within have you the known annuity. the Producer? c Less than 1 year c 1 to 3 years c 3+ years OWNER/JOINT OWNER INFORMATION For Trust Owned contracts - complete the form based the Trust information as compared to the Annuitant or Grantor of the Trust. Owner s If you need additional room for explanation, you may utilize back of page 3 and/or include an Note: Any name death 1 : benefit is payable upon the death of the annuitant for Non-Natural Current age: Owned Annuity Anticipated Contracts. retirement age: FINANCIAL additional STATUS sheet of paper that is signed by the client and producer. Are you actively employed? SSN/TIN: c Yes c No c Retired 1. The first year surrender charge for the Voya annuity applied for is (not applicable for SPIA)... %. 4. Joint Federal owner s income name: tax bracket: c 0% c 10% c 15% Current c 25% age: c 28% Anticipated c 33% retirement c age: 35% c % 2. The surrender charge time period for the Voya annuity applied for is (not applicable for SPIA)... years. Question 4: Provide the owner s federal income tax bracket. Are you actively employed? 3. SSN/TIN: Do you anticipate any of the following changes during the surrender charge period (or c the Yes payout c No period c for Retired your immediate annuity) indicated for the Voya annuity? How long If the have client you known has the a tax Producer? bracket c of Less 15% than or 1 less, year the c tax-deferral 1 to 3 years features c 3+ years of the proposed annuity will be of If you answer yes to any part of question 3, please explain. If possible estimate when you expect changes and the amount. For Trust limited Owned contracts benefit - complete to the the client. form based If the on client the Trust is information in a lower as compared tax bracket, to the Annuitant please or include Grantor of additional the Trust. details in the Note: a. Any Significant Producer death benefit increase/decrease Acknowledgement is payable upon in the living death expenses Section of the annuitant (e.g. of how housing, for Non-Natural the medical proposed Owned care, Annuity assisted annuity Contracts. living provides costs)... a benefit c Yes to the c client. No FINANCIAL If yes, please STATUS explain: b. Significant increase/decrease in income (e.g. retirement, lower pension amount, change in jobs)... c Yes c 1. The first year surrender charge for the Voya annuity applied for is (not applicable for SPIA)... No %. 5. The If PRIMARY yes, please financial explain: objective or intended use for purchasing this product is: 2. c The c. Significant Income surrender now charge time increase/decrease c period Guarantees for the Voya in liquid assets provided annuity applied (e.g. children s c Growth for is (not education, potential applicable for real estate c transactions)... Growth, SPIA)... followed by income c Yes c years. No 3. Do c If Tax-deferred you yes, anticipate please growth explain: any of the c following Pass on changes to beneficiaries during the surrender c Other charge period (or the payout period for your immediate annuity) d. Significant indicated increase/decrease for the Voya annuity? in net worth (e.g. bonuses/stock options, inheritance, settlements)... c Yes c No Question If If you yes, 5: answer please Select yes explain: to the any Primary part of question financial 3, please objective explain. If for possible recommending estimate when you the expect product changes to the and client. the amount. You may include additional information in the Producer Acknowledgment Section. 4. a. Federal Significant income increase/decrease tax bracket: c in 0% living expenses c 10% (e.g. c housing, 15% medical c 25% care, assisted c 28% living c costs) 33%... c 35% c Yes c c No % If yes, please explain: 5. The PRIMARY If the client financial has objective more than or intended one objective/intended use for purchasing this product use, please is: provide this information in the b. Significant c Income Producer increase/decrease now Acknowledgment in income c Guarantees section. (e.g. retirement, lower pension amount, change in jobs)... c Yes c No If yes, please explain: provided c Growth potential c Growth, followed by income c Tax-deferred growth c Pass on to beneficiaries c Other c. Significant increase/decrease in liquid assets (e.g. children s education, real estate transactions)... c Yes c No 6. How If yes, many please years explain: of investment/financial experience do you have? c None c Less than 1 year c 1-2 years c 3-5 years c 5+ years d. Significant increase/decrease in net worth (e.g. bonuses/stock options, inheritance, settlements)... c Yes c No 7. For If yes, SPIA please only, is explain: the annuity being purchased to fund the premium payments of a new life insurance policy?... c Yes c No Question 6: Indicate the client s investment/financial experience by checking the box next to the number of years 4. Federal 1 For non-individually of experience. income tax bracket: c 0% c 10% c 15% c 25% c 28% c 33% c 35% c % owned (including Trusts) contracts, see producer guide for instructions on completion of form. 5. Page The 1 of PRIMARY 4 - Incomplete financial without all objective pages. or intended use for purchasing RETURN TO VOYA this product is: Order # /09/2017 c Income If the now response is c None Guarantees or Less provided than 1 year, c please Growth include potential additional c Growth, details followed in the by income Producer c Tax-deferred Acknowledgement growth c Pass Section to to beneficiaries explain how c the Other proposed annuity was selected to meet your client s financial objectives. 6. How many years of investment/financial experience do you have? c None c Less than 1 year c 1-2 years c 3-5 years c 5+ years 7. For SPIA only, is the annuity being purchased to fund the premium payments of a new life insurance policy?... c Yes c No Financial status (continued) Question 7: Indicate if a SPIA purchase is being made to fund the premium payments to a new life insurance policy. 1 For non-individually owned (including Trusts) contracts, see producer guide for instructions on completion of form. Page 1 of 4 - Incomplete without all pages. RETURN TO VOYA Order # /09/2017 If the response is yes, please include additional details in the Producer Acknowledgement Section to explain how the proposed annuity was selected to meet your client s financial objectives. Please provide explanation as to how the customer anticipates paying for any potential increase in premiums, or payment of premiums beyond any Period Certain for the proposed SPIA product. 3

6 Financial status (continued) Monthly household income/expenses MONTHLY HOUSEHOLD 4 INCOME Salary/wages Social Security payments Pension/retirement Annuity payments 1 Interest/dividend income Other (e.g; Rental income, unemployment benefits, please explain) Total income: MONTHLY HOUSEHOLD 4 EXPENSES Rent/mortgage payment Utilities/transportation/food Debt repayment Health care/health insurance premiums Taxes 2 Other (e.g; Dependent support, charitable donations, please explain) 0.00 Total expenses: 0.00 Complete these sections to the best of your knowledge. Household information should include the financial information of the client and of the client s spouse/partner. Total income and total expenses are required for all clients. Trusts please complete the suitability information on the assets and liabilities of the Trust, not that of the Grantor, Trustee, or Annuitant. If the Trust has monthly income and/or expenses, please include those amounts. If there is no income (including interest and/or dividends), please state Non-Natural Owner If the proposed annuity will be owned by a corporation, provide the financial information of the legal entity. For Custodial accounts, provide information on the annuitant. For UGMA/UTMA, complete the financial information on the minor child. If any values are listed in the Other categories, utilize the space provided to explain those amounts. Important details as provided in the footers for this section: Annuity Payments under the Income section: Do not include income currently earned on money that will be used to purchase the annuity Do not include the value of assets used to purchase this annuity. Taxes under the Expenses section: Include property taxes, income taxes and FICA taxes (if self-employed) Please total the income and expenses columns correctly; it s helpful to use a calculator to do this. This is one of the areas where we frequently identify mathematical errors. Potential red flags for this section are listed below. You should fully review these with your client when determining if the proposed annuity is in your client s best interest. As stated earlier, we realize the suitability of the annuity is based on the totality of the information provided. Monthly income is 2,000 or less a month Negative disposable income Helpful hint: Use FastTrack to complete the application and suitability forms and the FastTrack system will complete the math for you! 4

7 Financial status (continued) Household net worth/liquid assets HOUSEHOLD 4 NET WORTH/LIQUID ASSETS - DO NOT INCLUDE: Primary residence, personal belongings/property (e.g; jewelry, furnishings, vehicles) Estimated premium of proposed annuity HOUSEHOLD 4 NET WORTH Annuities (excluding premium of proposed annuity) 3 CDs Checking/savings/money market Pension/401K Stocks/bonds/mutual funds (other securities) Other (e.g; Cash value of life insurance, real estate, please explain) HOUSEHOLD 4 LIQUID ASSETS Total: Instructions for Household Net Worth/Liquid Assets: List the total amount of your financial holdings for each category under Net Worth (left hand column). If any of the assets you list in Net Worth are in part or fully liquid (easily converted to cash without a penalty), list the dollar amount of the liquid portion under Liquid Assets (right hand column). There should be no items under Liquid Assets that are not also included in Net Worth. For Example: If you own 50,000 in annuities (excluding premium of the proposed annuity), and 5,000 of that is surrender charge free/liquid; list 50,000 in the Net Worth column, and 5,000 in the Liquid Assets column for annuities. For further instruction/examples on how to fill out this section, please refer to the producer s guide (143180). Complete these sections to the best of your client s knowledge. Household information should include the financial information of the client and of the client s spouse/partner. List client s financial holdings under Net Worth in the left hand column and then of those holdings list the amount that is liquid in the right hand column. There should be no items listed in Liquid Assets that are not also reflected under Net Worth. Here are two examples to help with filling out this section. Example 1: The client has 40,000 in annuities that they are not utilizing to purchase this annuity. However, only 20,000 is out of surrender, so to fill out this section, in the left hand column they will note 40,000 and then in the right hand column they will note 20,000. Example 2: The client has 50,000 in several CD s, but only one that is at maturity worth 10,000. In the left hand column it would state 50,000 and in the right hand column it would state 10,000. Detailed information is required for all ages. Liquid Assets refers to funds that can be converted to cash without financial penalty. For annuities, only include amounts that would not incur a surrender charge. As a general rule we encourage clients to have 3 to 6 months of expenses available in liquid assets. If your client does not have that amount available, please provide additional details regarding the limited liquid assets (e.g. tell us the story) and how the client would address unforeseen financial needs in the Producer Acknowledgement. Potential red flags for this section are listed below. You should fully review these with your client when determining if the proposed annuity is in your client s best interest. As stated earlier, we realize the suitability of the annuity is based on the totality of the information provided. Please include additional details in the Producer Acknowledgment section. Proposed annuity is greater than 50% of the client s net worth Total annuities exceeds 75% of client s net worth Please total the liquid assets and net worth columns correctly. It s helpful to use a calculator to do this. Helpful hint: Use FastTrack to complete the application and suitability forms and the FastTrack system will complete the math for you! 5

8 Financial status (continued) 8. What is your general risk tolerance? (check one) c c c c c Conservative Moderately Conservative Moderate Moderately Aggressive Aggressive 9. What is the source of this annuity s premium? (check all that apply) Question 8: Please check your client s general risk tolerance (only check one box). Potential red flag if Aggressive or Moderately Aggressive risk tolerance is selected and the client has a large portion of net worth held in annuities. Please tell us the story of how the proposed annuity aligns with your client s financial goals and objectives. The client may have an overall aggressive risk tolerance with the proposed annuity as a small portion of the client s financial assets to meet a specific goal. 9. What is the source of this annuity s premium? (check all that apply) c Life insurance c Certificates of deposit c Stocks/bonds/mutual funds c Reverse mortgage c Home equity loan c Savings/checking/money market c Death benefit proceeds from life insurance/annuity c Annuity c Employer Retirement Plan (401(k), 403(b), etc.) c Inheritance Question 9: Indicate all sources of premium for the proposed annuity. Please note: We do not allow financed purchases as such: Reverse Mortgage proceeds are not acceptable and would be declined Home Equity Loans are not acceptable and would be declined Potential red flags if a SPIA is being issued as a result of a deferred annuity replacement. You should review the annuitization payments available under the existing annuity and how they compare to the proposed SPIA payments to determine if the proposed SPIA better meets the client s income needs. 10. Do you now have or have you ever had a reverse mortgage?...c Yes c No Question 10: This question will be required for California, Minnesota, and Montana (as of January 1, 2018) applications under their Suitability Regulation. 11. Do you intend to apply for income based/means-tested government benefits, including but not limited to: Medicaid, MediCal, or Veteran s Aid and Attendance Benefits?...c Yes c No Question 11: This question is required for California customers under their Suitability Regulation. We encourage you to ask this of all customers. If the customer intends to apply for income based/means-tested benefits, we would encourage you to submit a letter from an independent estate planner or estate attorney regarding the consumer s annuity purchase as part of their estate planning. We will need additional information as to why someone who is looking to apply for means tested benefits is also looking to purchase an annuity. Sales made as part of a spend-down strategy will be declined. 12. Have you replaced or exchanged another annuity/life insurance policy within the past 5 years?...c Yes c No Question 12: Please answer this question based on any and all replacements the client has had in the past 5 years. Potential red flag if the client has had a replacement in the past 5 years. It is helpful to provide additional details regarding what has changed in the client s financial objectives that resulted in those replacements. If a client has had a replacement in the past 5 years you should also consider if they have incurred surrender charges and/or a loss of benefits with those replacements. 6

9 Financial status (continued) Replacements If the purchase of the Voya annuity is a replacement or exchange you must complete questions 12a through 12p. To expedite processing, please attach a Replacement Comparison or a copy of your most recent statement for each replaced life insurance policy or annuity contract. CONTRACT 1 CONTRACT 2 12a. Type of contract/policy being replaced... c Indexed Annuity c Fixed Annuity c Variable Annuity c Life Insurance 12b. Is this an internal exchange (coming from any company under the Voya family of companies)?... c Yes c No 12c. Is the contract/policy being replaced less than 5 years old?... c Yes c No 12d. If yes, was the contract/policy part of a prior replacement or exchange?... c Yes c No 12e. Is there a surrender charge?... c Yes c No 12f. What is the current accumulation value?... 12g. What is the current surrender value?... 12h. What is the surrender charge %?... 12i. What is the total amount being transferred?... 12j. What is the current death benefit on the contract/policy being replaced?... 12k. What is the current living benefit amount on the contract/policy being replaced? (If not applicable, list 0. Include riders and living benefits.)... 12l. What is the current interest rate and/or cap rate on contract/policy being replaced?... 12m. What is the Minimum Guaranteed Interest Rate MGIR on the contract/policy being replaced?... 12n. How many years of surrender charges remain on the contract being replaced?... 12o. What are the administrative/expense fees on contract/policy?... % % % c Indexed Annuity c Fixed Annuity c Variable Annuity c Life Insurance c Yes c No c Yes c No c Yes c No c Yes c No % % % 12p. Explain why the existing life insurance policy or annuity contract cannot meet your financial objectives. Contract 1 Contract 2 When your sale involves the replacement of an existing annuity or life insurance contract, we review to determine if the replacement is appropriate. Answer the questions in regards to each contract being replaced/exchanged; do not enter information about the proposed annuity in this section. Surrender charges are viewed within the context of the product being recommended. Questions 12a through 12p pertain to any replacement that will fund the proposed annuity. If the new annuity cannot be shown to provide an increased economic benefit and better meets the needs of the client compared to the existing contract/policy, then the sale is not suitable. Consideration should be given to the amount of any surrender charges on the existing contract/ policy and, depending on the client s age, they may not have sufficient time to regain those losses. For all replacements regardless of the client s age, additional details to support how the proposed annuity confers a substantial financial benefit to the client should be included in the Producer Acknowledgement section. You should review with the client advantages and disadvantages of the replacement, e.g. entering into a new surrender charge period. For annuity replacements funding a SPIA, you may include copies of annuitization quotes from the current product. 7

10 Financial status (continued) Additional information is required if you indicate that a bonus is offsetting any surrender charges on the existing contract. It is important for you to explain to your client that any bonus can be recaptured if the annuity is surrendered prematurely, and that bonus products may offer lower interest rates, participation rates, index caps, credit caps, and higher index spreads than non-bonus products. If there are more than two contracts being replaced, you will need to submit an additional page 3 of the form with the contract information filled in and signed by the client. While not required, we strongly encourage you to include the most recent statement for each contract, policy or account being replaced. Potential red flags include if the economic benefit to the customer is unclear given the surrender charges or if there is loss of other benefits, such as living or death benefits. Accessing your money ACCESSING YOUR MONEY 13. How do you anticipate taking withdrawals from this annuity? (check all that apply) c Required minimum distribution (IRA only) c Systematic withdrawals c Annuitize c Partial withdrawals c Enhanced withdrawal benefit c Lump sum c Immediate income c None anticipated 14. When do you anticipate taking your first withdrawal from this annuity? (choose one) c Less than 1 year c Between 1 and 5 years c Between 6 and 9 years c 10 or more years c None anticipated 15. By checking the box below (for SPIA only) Question 13: Check all that apply. Note: Annuitize also refers to the payments that begin upon the contract s Annuity Commencement Date. Question 14: Indicate when your client anticipates taking the first distribution/withdrawal from the proposed annuity. Potential red flags include if the time frame indicated in Question 14 does not align with the response for Question 13, it will create a red flag requiring additional details. 15. By checking the box below (for SPIA only) c I acknowledge that this annuity does not provide a surrender option and that I will only have access to the regular income stream provided by the SPIA. Question 15: This question is to ensure the customer understands that SPIAs do not have an underlying surrender value. 8

11 Owner acknowledgement OWNER ACKNOWLEDGEMENT By signing below, I understand that, if applicable to the annuity I purchased, I may incur a charge by taking money out of the annuity If I purchased a SPIA, I understand that I will only have access to the regular income stream provided by the SPIA. I acknowledge tha I reviewed the product-specific disclosure (if applicable) with my Producer. I understand the costs and features of the annuity I am purchasing. To the best of my knowledge the information I provided is true and complete and no required fields have been lef blank. I understand that I should consult my tax advisor regarding tax implications of the purchase of an annuity or the exchange of an existing Employer Retirement Plan, Annuity or Life insurance policy. Owner s signature: Joint owner s signature: The client must read the disclosures, and sign and date the form. If there is a Joint Owner, have them also sign and date the form. Important: Do not have the client sign blank forms. Date: Date: Producer basis of recommendation and acknowledgement PRODUCER ACKNOWLEDGEMENT By signing below, I acknowledge that I have completed the product specific training and that I believe the annuity for which the owner(s) is applying is suitable, based on the information provided. I have provided all known details at this time. I have verified the identity of the owner(s) and believe that the identity information provided to me is true and accurate. Additionally, I acknowledge that the Company is not a fiduciary, or acting as a Financial Institution. I further acknowledge that I am compliant with the DOL fiduciary rule, as applicable, including the Impartial Conduct Standards. Producer s signature: Date: Producer number: Very important: As a reminder, you have an obligation to ensure that your recommendations are in the best interest of the consumer based on the information the client provides to you and the products you offer. Your compensation should not factor into which product you are recommending to your client. You must indicate the basis for your recommendation of the proposed annuity. If additional space is needed, send in an additional letter or use the back of the form. This is your opportunity to tell us the whole story of why this annuity is the best fit for this client. Sign and date the form and any additional pages. It is a best practice to provide a copy of the fully completed Suitability Profile to your client. Note: Florida requires that a copy of the completed Annuity Suitability Questionnaire be provided to the client no later than the date of contract delivery. 9

12 Suitability regulation excerpts Suitability information. Suitability information means information that is reasonably appropriate to determine the suitability of a recommendation, including but not limited to the following: (1) age; (2) annual income; (3) financial situation and needs, including the financial resources used for the funding of the annuity; (4) financial experience; (5) financial objectives; (6) intended use of the annuity; (7) financial time horizon; (8) existing assets, including investment and life insurance holdings; (9) liquidity needs; (10) liquid net worth; (11) risk tolerance; and (12) tax status In recommending to a consumer the purchase of an annuity or the exchange of an annuity that results in another insurance transaction or series of insurance transactions, the insurance producer, or the insurer where no producer is involved, shall have reasonable grounds for believing that the recommendation is suitable for the consumer on the basis of the facts disclosed by the consumer as to his or her investments and other insurance products, and as to his or her financial situation and needs, including the consumer s suitability information, and that there is a reasonable basis to believe all of the following: (1) The consumer would benefit from certain features of the annuity, such as tax-deferred growth, annuitization or death or living benefit; (2) The particular annuity as a whole, the underlying subaccounts to which funds are allocated at the time of purchase or exchange of the annuity, and riders and similar product enhancements, if any, are suitable (and in the case of an exchange or replacement, the transaction as a whole is suitable) for the particular consumer based on his or her suitability information; and (3) In the case of an exchange or replacement of an annuity, the exchange or replacement is suitable including taking into consideration whether: (i) The consumer will incur a surrender charge, be subject to the commencement of a new surrender period, lose existing benefits (such as death, living or other contractual benefits), or be subject to increased fees, investment advisory fees or charges for riders and similar product enhancements; (ii) The consumer would benefit from product enhancements and improvements; and (iii) The consumer has had another annuity exchange or replacement and, in particular, an exchange or replacement within the preceding 36 months. Voya Financial offers a variety of fixed annuities. If you have any questions about the features of our fixed annuities, our sales support team is here to help. Call the Voya Sales Desk at Annuities are issued by Voya Insurance and Annuity Company (Des Moines, IA), a member of the Voya family of companies. Fixed index annuities are insurance contracts that, depending on the contract, may offer a guaranteed annual interest rate and earnings potential that is linked to participation in the increase, if any, of an index or benchmark. Neither Voya nor its affiliated companies or representatives offer legal or tax advice. Clients should seek the advice of a tax attorney or tax advisor prior to making a tax-related insurance/investment decision Voya Services Company. All rights reserved. CN D /17/2017 Voya.com