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Customer Contact Center                                                              Your future. Made easier.

PO Box 9271
Des Moines, IA 50306-9271
Express Mail: 909 Locust Street, Des Moines, IA 50309-2899
Phone: 800-366-0066

This operations guide provides information and forms which apply to transfers and reallocations done on behalf
of a contract owner by an authorized third party, whether an investment advisor, broker or other authorized
party (referred to in this guide as “Advisor”). The guide contains the following:

   1. Basic Rules, Procedures and Instructions
   2. Third Party Investment Advisor Agreement and Written Procedures
   3. Investment Advisory Declaration
   4. Letter of Indemnity
   5. ING Policy Owner Service – Contact List

A. Definitions
   The following are the definitions that we will use in this section and in the attached agreements and forms.
  1. Third Party Investment Advisor: Any person or company who is authorized by one or more contract
     owners to transfer values among investment options of an annuity or liquidate units within an annuity as
     a third party.

  2. Third Party Investment Advisor Agreement: The contractual agreement between ING and the Third Party
     Investment Advisor. This document contains the rights, responsibilities and liabilities of each party. This
     agreement may be terminated by either party upon written notice.

  3. Investment Advisory Declaration: The authorization by the client authorizing the Company to comply with
     the Advisor’s transfer instructions and authorizing the Company to comply with the Advisor’s requests
     to make withdrawals from the contract to pay fees to the Advisor. When the Advisor acquires a new
     account, the Advisor is responsible for providing ING with the completed Investment Advisor Declaration.
     This form must be on file with ING before any transfers/reallocations will be accepted.

  4. Advisory Authorized Persons: These individuals are authorized by the client to make transfers under his or
     her contract on behalf of the Advisor firm. The client and Advisor may designate up to three individuals
     to make reallocations. The Advisor must provide Social Security Numbers for those designated individuals.
     The Advisor can change the authorized individuals by providing the changes in writing to the Company.

                                                                                               Order #130957 07/14/2008
B. Operating Procedures
  The following procedures must be followed by Advisors. Additional procedures are contained in the Third
  Party Investment Advisor Agreement and Written Procedures, which are included in this operations guide.
  We continually monitor third party and contract owner transfers/reallocations to ensure that our procedures
  are being followed and that the rights and interests of other contract owners are not being negatively
  impacted by the frequency or amount of such transfers. In the event that we become aware of violations of
  our procedures or that our procedures are not protecting our contract owners as intended, we may revise
  our procedures or limit or suspend a particular Advisor’s rights to make transfers or reallocations.

  1. In order to receive prices for a particular trading day, reallocation orders must be received by ING before
     the close of trading on the New York Stock Exchange, currently 4:00 p.m. Eastern Standard Time (EST).
     A call should be made as early in the day as possible alerting us of any large upcoming transfers.

  2. All reallocation orders from Advisors requesting block reallocations involving five or more annuity contracts
     must be sent to ING by fax. The reallocation fax number is 515-698-2033.

  3. Telephone transfers are limited to five per call. Our Customer Contact Center can be reached at 800-366-0066.

  4. All requests must be presented in one of two ways:
     a. Reallocate premium of each contract on a client list among the various Portfolios chosen in accordance
        with the specified percentages. Please note that total of the percentages must equal 100%. Any total
        which is greater than or less than 100% will be rejected; or
     b. Transfer specified percentages from the indicated Portfolio(s) to one or more other Portfolios, also
        stated as a percentage. Transfer “to” and transfer “from” percentages must equal 100%.
  5. The Advisor must provide to ING the following information:
     a. Advisor name, Tax ID number, address and contact person(s)
     b. Advisor phone and fax numbers
     c. Current client list including strategies. This list must be sorted by contract number.
  6. Transfer requests cannot be accepted during the Free Look period for contracts issued in states where
     we hold money in the Liquid Asset or Money Market Account during the free look period. Transfer
     instructions will be accepted upon the expiration of the Free Look Period.
C. Investment Advisor Strategy Lists
  Each Advisor is requested to provide ING with their complete Client list, which should be classified in lists by
  contracts with similar investment strategies. Each client list will be assigned a control number which ING will
  use to group or mass process all reallocations within that control number. A transaction confirmation will
  be sent to the contract owner, agent of record and the Advisor following each reallocation. The procedures
  for list transactions are:
  1. All changes, including deletions or additions, to a list must be submitted to ING by 12:00 p.m. EST in
     order for the change to be effective on the business day received. List changes must be communicated
     via email; our email address is
  2. Each strategy list must contain the following information for each contract:
     a. Contract number
     b. Contract owner name
     c. Investment strategy identifier (name and/or number)
  3. Instructions for list transactions should be submitted, detailing the strategy name and reallocation
     instructions. Reallocation instructions must reflect the strategy/list name and trade instructions. If the
     entire strategy list is provided with the reallocation, ING will not reconcile the list. Reallocations will be
     processed based on the current Advisor list on file.

                                                                                                 Order #130957 07/14/2008
D. Establishing Your Third Party Investment Advisor Relationship with ING
  In order to establish your Advisor relationship with respect to transactions under ING contracts, you must
  do the following:
  1. Complete and sign the Third Party Investment Advisor Agreement.
  2. Complete and sign the Advisory Authorized Persons Request.
  3. Provide a completed Investment Advisory Declaration signed by the contract owner.
  4. Complete and sign the Letter of Indemnity.
  5. Return the signed documents to ING, 909 Locust Street, Des Moines, IA 50309-2899. ING will countersign
     the agreement when the forms are accepted.

E. Fees
  The Investment Advisory Declaration authorizes the Company to comply with requests from the Advisor
  to make withdrawals from the contract value to pay the Advisor fees that are associated with reallocations
  made by the Advisor on behalf of the contract owner. Withdrawals will be made pro-rata from each
  investment option unless notified to process otherwise.

  1. Fee withdrawals are processed within 48 hours of receipt.
  2. The following tax reporting will apply to amounts withdrawn to pay the Advisor’s fees:

     a. Non-Qualified Contracts. All distributions from non-qualified annuities, including distributions to pay
        service fees that are attributable to gain in the contract, are reported as ordinary income to the contract
        owner and, therefore, may result in income tax liability to the contract owner. Distributions may be
        subject to a 10% penalty tax if they are made from an annuity whose Owner is under age 591/2. All
        contractual provisions, including but not limited to surrender penalties, penalty free withdrawals, and
        minimum withdrawal amounts, apply to all distributions from the contract.

     b. Qualified Contracts. Withdrawals to pay service fees will not be reported as distributions for qualified
        annuities. Such withdrawals will be subjected to all contractual provisions on withdrawals.

                                                                                              Order #130957 07/14/2008

This agreement sets forth the agreement between ING (the “Company”) and the Third Party Investment Advisor listed
on the Agreement (“Investment Advisor”), relating to the Investment Advisor’s authority to direct the investment
allocation of account value or cash value, as applicable, within the Company’s variable products (“Annuity”) and/or
liquidate limited amounts of units of such annuities on behalf of the company’s annuity owners who are also clients of
the Investment Advisor (“Clients”).
1. Liquidation or Transfer
  Any transfer amount investment option of an Annuity or liquidation of units of an Annuity shall be subject to
  the terms and conditions of the relevant Annuity contract, as well as the applicable prospectus and statement of
  additional information (“SIA”) then in effect.
2. Pricing
  Transfers or liquidation ordered by the Investment Advisor will be accepted only at the value calculated after receipt
  of the order, in good order, from the Investment Advisor; it shall be the responsibility of the Investment Advisor to
  transmit orders on a timely basis. No “as of” orders shall be permitted.
3. Compliance with the Written Procedures, Applicable Laws, Rules and Regulations.
  The Investment Advisor warrants, represents, and covenants that it and all its officers, agents, contractors and
  employees shall comply with (a) the written procedures (including those in the Annuity prospectus) relating to the
  Annuity, as amended from time to time, including restrictions on the availability of funds offered through an Annuity;
  (b) all applicable federal and state laws in conducting its and their activities, including, without limitation, federal and
  state securities and insurance laws, and; (c) all rules, regulations and interpretations by governmental and regulatory
  bodies and self-regulatory organizations having jurisdiction. The Company retains the right, in its sole discretion, to
  amend, modify or revise any of its written procedures at any time. The Company shall provide the Investment Advisor
  with copies of any such amendment, modification or revision a reasonable period of time prior to the expected
  effective date thereof.
4. ING Excessive Trading Policy
  The Company has adopted the “ING Excessive Trading Policy”, a copy of which can be provided upon request. ING
  Excessive Trading Policy may be amended from time to time by the Company in its sole discretion and with or without
  advance notice to the Advisor. The terms of the ING Excessive Trading Policy, as such policy may be amended from
  time to time, hereby are incorporated herein by reference. Violation of the ING Excessive Trading Policy may result
  in the “Electronic Trading Privileges”, as such term is defined under the ING Excessive Trading Policy, of individual
  contract owners being suspended or terminated and also may result in the suspension or termination of your ability to
  conduct business with the Company under the terrms of the Third Party Investment Advisor Agreement or otherwise.
  By entering into this Agreement with the Company, you hereby explicitly agree to abide by the terms of the ING
  Excessive Trading Policy.
5. Authority
  The Investment Advisor warrants, represents and covenants that it has full discretionary management authority to act
  on behalf of Annuity owners in the manner contemplated by the Agreement, and each time the Investment Advisor
  so acts it shall be deemed to have restated such warranty, representation and covenant. The Investment Advisor shall
  promptly notify the Company in writing in the event that is ceases to have such authority. Nothing in this Agreement
  continues or shall be deemed to be the appointment of the Investment Advisor or its agents or employees as an agent
  or employee of the Company, or any affiliate as defined in the Investment Advisor’s Act of 1940, as amended.
6. TELEFAX Exchanges
  As noted herein, certain portfolios may be subject to certain restrictions on block reallocations and transfers. The
  Investment Advisor may from time to time instruct the Company by Fax or in writing to effect transfer transactions
  for one or more Annuity owners either separately or concurrently. Such transactions shall be subject to all terms and
  conditions of the relevant Annuity’s contract, prospectus, and SAI in effect at the time of the transaction.

                                                                                                       Order #130957 07/14/2008
7. Indemnification
  The Investment Advisor shall indemnify the Company for any loss, expense, costs, liabilities, and damages or claims
  (including legal fees) but not limited to taxes, penalties, or interest arising out of (a) any violation of the warranties,
  representations or covenants set forth in paragraphs 3 or 4; (b) any unauthorized representations by it, its agents,
  employees or affiliates, or; (c) any transfer or partial surrender initiated by the Investment Advisor or its agents,
  employees or affiliates. The Investment Advisor shall be solely responsible for ensuring that any such fee is calculated
  and disclosed to the Annuity owner in a manner that is consistant with applicable law.
8. Annuity Owner Authorization to Deduct Investment Advisor’s Fees
  Each Annuity owner may authorize, in a written form acceptable to the Company, the payment of Investment
  Advisor’s fee by partial withdrawal from such Annuity owner’s Annuity. If a properly executed form is submitted to
  the Company, the Investment Advisor may from time to time submit to the Company and each such Annuity owner
  at the same time a bill, in a form satisfactory to the Company, showing the amount of the fee. The Investment
  Advisor shall be solely responsible for the calculation and accuracy of the amounts set forth in such instructions and
  the Company shall not have any obligation to verify the accuracy, frequency or reasonableness of any such calculation
  or amount.
  The Annuity owner shall receive from the Investment Advisor, a confirmation of each such redemption transaction,
  indicating the purpose thereof and, at least quarterly, a copy of a statement from the Company indicating all amounts
  redeemed from the Annuity owner’s account, including the amount of advisory fees paid directly to the Investment

9. Modification and Termination; Governing Law; Assignment

 None of the provisions of this Agreement may be amended, modified or terminated except in writing signed by both
 parties. The Agreement may be terminated by either party on thirty (30) days’ prior written notice. This Agreement
 shall be interpreted in accordance with the laws of the State of Delaware. The Investment Advisor may not assign any
 of its rights, duties or obligations without the prior written consent of the Company, and no waiver of any provision
 of the Agreement on any particular occasion shall be deemed a waiver of such provision on any subsequent occasion.
 This Agreement shall automatically terminate without notice upon occurrence on any of the following events; (a)
 when and if you fail to obtain renewal of necessary license in any jurisdiction, but only as to the jurisdiction; or (b)
 when and if you are disqualified as an investment advisor with the Securities and Exchange Commission, or; (c) for
 cause if you violate the terms of this Agreement or any of the policies or procedures of the Company, including, but
 not limited to, the ING Excessive Trading Policy.

 This Agreement has been signed by duly authorized officers of the Investment Advisor and the Company
 on the            day of                       , 20          .


Investment Advisor Name _____________________________________________________________________________
Print Name _________________________________________ Tax ID _________________________________________
Signature___________________________________________ Title __________________________________________
Address ____________________________________________________________________________________________
City _______________________________________________ State ______________ ZIP ________________________
Phone _____________________________________________ Fax Number ___________________________________

Signature __________________________________________________________________________________________
Name _________________________________________ Title________________________________________
Advisor Name ______________________________________________________________________________
Date ______________________________________________________________________________________

                                                                                                       Order #130957 07/14/2008

Third Party Advisor _____________________________       Tax ID # ___________________________________

______________________________________________          ___________________________________________
Authorized Person’s Name                                Social Security Number

______________________________________________          ___________________________________________
Authorized Person’s Name                                Social Security Number

______________________________________________          ___________________________________________
Authorized Person’s Name                                Social Security Number

______________________________________________          ___________________________________________
Authorized Person’s Name                                Social Security Number

______________________________________________          ___________________________________________
Authorized Person’s Name                                Social Security Number

______________________________________________          ___________________________________________
Authorized Person’s Name                                Social Security Number

Please accept the above list as authorized persons acting on behalf of                           (“Advisor”).
I/We agree to indemnify ING (“Company”), its investment advisors, transfer agents, and distributors from and
against any loss or claim in connection with instructions from these authorized persons.

Advisor (Print Name & Title)               Signature                                 Date

                                                                                            Order #130957 07/14/2008

Annuity (“Annuity”) Number _________________________________________________________________

Application date (If completed at time of application) ____________________________________________

Owner(s) __________________________________________________________________________________

Social Security/Tax I.D. # _______________________________________________________________________

Advisory Fees are to be made payable and sent to Investment Advisor (if applicable)
“Advisor” _____________________________________________________________________________________
Advisor Address ________________________________________________________________________________

City _____________________________________________ State ___________________ ZIP _________________

Strategy name/number: ______________________________________________________________________
Annuity Type:
 Non-Qualified      IRA       403(b)       401(k)      Simple IRA       457      Other Qualified

1. Transfer Authorization
I/We hereby authorize Company to comply with written, telephone, or faxed transfer instructions. The advisor
will provide a list of authorized persons who can provide these instructions. Advisor may make changes to the
list of authorized persons at the Advisor’s discretion.

2. Fee Payment Authorization
I/We hereby authorize the Company to comply with written requests by the Advisor to liquidate a given dollar
amount in the Annuity to pay Advisory Fees (“Fees”) under an agreement executed between Advisor and
Owner. Company has no responsibility or liability to determine that instructions received from the Advisor are
in compliance with such agreement. Unless directed otherwise by Owner or Advisor, Fees will be deducted
pro-rata from the funds in variable sub-accounts of the Annuity. I/We acknowledge and understand that
partial surrenders may incur surrender charges which will require Company to liquidate a larger percentage
or dollar amount than the amount required to pay the Fees. I/We expressly authorize Company to liquidate
such percentage or dollar amounts.

3. Statements
I/We authorize Company to release information including financial transactions, values and statements
regarding this contract to the Advisor.

                                                                                          Order #130957 07/14/2008
4. Disclaimer and Indemnification
Company does not make any representation or warranty, by accepting instruction or by executing an advisory
services agreement or otherwise, concerning the tax treatment of payment of Fees under the Internal
Revenue Code, as amended, or otherwise. Company has no responsibility or liability for any taxes, penalties,
and/or interest which may be assessed by the Internal Revenue Service or other administrative tribunal or
court arising out of this authorization. I/We hereby indemnify and hold Company harmless from and against
any and all claims, losses, liabilities or damages, costs or expenses, including but not limited to taxes, penalties
and/or interest (individually and collectively referred to as “Loss”) arising out of any Advisor initiated transfer
or partial surrender. Company is not responsible and has no liability for any Loss incurred by Owner(s) as a
result of the transactions contemplated by this authorization except in the event that Owner suffers any such
Loss as a result of the willful misconduct of Company, its employees or agents in processing transfer or partial
surrender requests made by Advisor.

This authorization will remain in full force and effect until revoked by me/us by a written notice received at
ING’s Customer Contact Center.

Owner Signature ____________________________________________ Date __________________________

Joint Owner Signature (if applicable) ___________________________ Date___________________________

                                                                                               Order #130957 07/14/2008


Enclosed please find a listing of clients’ annuities for which we have received Investment Advisory Declarations,
authorizing us to request withdrawals from contract value for fee redemption. You have a copy of this
agreement for each client, but we will provide access to the originals upon request.


I/we agree to indemnify ING, its investment advisors, transfer agents and distributors from and against any
loss or claim in connection with your compliance with instructions received pursuant to the Investment
Advisory Declaration authorization.

Advisor Name (Please print)

Authorized Signature                                                                    Date

                                                                                             Order #130957 07/14/2008

ING is dedicated to providing superior service to our clients. Listed are the names of the individuals on the
Policy Owner Service – Reallocation service team. Feel free to contact any individual listed for assistance.

Reallocation service team primary contacts:
Melissa Fedson 515-698-7340

Reallocation service team manager:
Scott Allard 515-698-7749

Advisory Fee primary contact:
Bill Goss 515-698-7812

Advisory Fee team lead:
Jamie Henrichs 515-698-7795

Advisory Fee manager:
Scott Allard 515-698-7749

Toll Free: Dial 800-369-3690. Extensions are the last four digits of the above phone numbers preceded by
the number 8. (Example: The extension for phone number 515-698-1234 is 81234.)

                                                                                          Order #130957 07/14/2008