Full Circle Financial OSJ Retreat 2016

Agenda Home Office Updates DOL & Annuities 2016 Business Builders Conference/The Elite Summit

Leading Advice, Planning & Wealth Management Solution Positioning to Be an Industry Leader Delivering a Superior & Differentiated Value Proposition Leading Advice, Planning & Wealth Management Solution Improved Client Experience Knowledge & Expertise Trusted Products & Solutions Platform & Operational Expertise Talent, Planning Resources, Advisor-Centric Technology, Training, Engagement & Execution Are Essential Enablers 3 | For Internal Use Only

Leadership Team – Over 175 Years of Experience Chris Flint President and CEO 21 Years of Experience Libet Anderson Director of Advisory and Planning 24 Years of Experience Steve Youhn Chief Compliance Officer 22 Years of Experience Timothy Vardaman Managing Director of Operations 20 Years of Experience Blaine Miller Chief Supervision Officer 15 Years of Experience Rory Hartley Managing Director of Protective Securities 35 Years of Experience Darren Guerrera Chief Financial Officer Chris Shaw Chief Information Officer 4 | For Internal Use Only

DOL Decision – Existing Accounts Decision: ProEquities will use the Transition Period rules under the Best Interest Contract (BIC) Exemption While “Grandfathering” offers limited exemption from rule requirements on accounts open prior to 4/10/17, it does not cover compensation received from advice relating to subsequent investments after 4/10/17 To comply, ProEquities will send a “negative consent” letter to existing accounts informing them about the fiduciary rule and the firm’s plan to comply with BIC exemption 8 | For Internal Use Only

DOL Decision – Brokerage Activity Decision: ProEquities will operate under the Best Interest Contract (BIC) Exemption Compliance Requirements: Draft BIC Exemption contract and amendment Draft “Impartial Conduct Standards” (“ICS”) and create advisor ICS training and compliance program Review compensation practices to ensure investment recommendations will not result in the receipt of compensation that is in excess of “reasonable compensation” Evaluate universe of products to ensure compliance with ICS Create BIC Initial Disclosure Statement and forms for Transaction/Web disclosures List is not all-inclusive 9 | For Internal Use Only

DOL Decision – Brokerage Activity ? Level Comp BICE Rev Share BICE Lite Fee-Based FIA’s

DOL Decision – Brokerage Activity Fee Based VA’s Compensation Options Carrier adjusted B/D adjusted Fixed Index Annuities

DOL - Compliance Officer Decision: ProEquities will hire a Compliance Officer dedicated to DOL Compliance The BIC Exemption requires financial institutions to designate an employee to “address Material Conflicts of Interest and monitor Advisers‘ adherence to the Impartial Conduct Standards.” Recruiting for this position is in process. 11 | For Internal Use Only

DOL Project Roadmap 2016 2018 Q3 2016 Activity Resource Allocation Complete Implementation - Phase 1 Complete Implementation - Phase 2 Complete 4/10/2017 1/1/2018 DOL Compliance Strategy Complete Transition Period Begins Transition Period Ends 4/10/2017 Planning Complete 1/1/2018 62 days 2016 May Aug Oct 2017 May Aug Nov 2018 171 days Today 190 days Planning Phase 5/19/2016 – Q3 2016 Implementation Phase 1 Q3 2016 - 4/10/2017 Implementation Phase 2 4/11/2017 - 1/1/2018 12 | For Internal Use Only

Comments, Questions & Answers 24 | For Internal Use Only

2016 Business Builders October 24-26 in Charlotte, NC The Westin Charlotte Online registration opens September 12 Multiple tracks 20 | For Internal Use Only

The elite Summit April 26-30, 2017 Los Cabos, Mexico Exclusive, premier properties inside and outside the United States Smaller, more intimate settings Focus on relaxation, comradery, and optional activities Find qualification guidelines on Advisor Portal under Training and Education > Events and Conferences > The Elite Summit > The Elite Summit 2017 Qualification Rules April 26-30, 2017 Los Cabos, Mexico 21 | For Internal Use Only

Thank you, and we appreciate you!

Compliance & Supervision Licensing & Registration Branch Examinations Regulatory Exams Anti-Money Laundering New Business Submissions Marketing & Advertising Correspondence Transaction Review 14 | For Internal Use Only