Guiding Principle “We believe that giving participants access to institutionally priced alternatives for converting retirement savings into lifetime income is vital. Providing retirees a cost effective means to “pensionize” their hard-earned savings into a “paycheck for life” is necessary in order to meaningfully improve income sufficiency for millions of American retirees. Without such capabilities being widely accessible, the private retirement savings system has severe limits in terms of serving the public interest and meeting the retirement needs of an aging population.” Letter from Hueler Companies to DOL and Dep’t of Treasury, (May 3, 2010), available at http://www.dol.gov/ebsa/pdf/1210-AB33-670.pdf ©Hueler Companies 2019. All Rights Reserved.

What Does Rollover Behavior Tell Us? 11% of Rollover transactions went directly to insurers or a Top 10 Annuity distributor in the Independent Broker Dealer Channel An additional 10% of Rollover transactions went to a single independent Broker Dealer with significant Variable Annuity marketing efforts. The Variable Annuity product costs average 85bps to 200bps per year. Another 40% of Rollover transactions went to Broker Dealer/Mutual Fund firms with active annuity marketing efforts, particularly to pre-retiree and retiree populations ©Hueler Companies 2019. All Rights Reserved.

Institutional Delivery Model Conflict free: no “pay to play” Reduced distribution fees (“institutional pricing” with level fees) Fee disclosure Independent issuer selection criteria and on-going monitoring Standardized quotes- fee and feature leveled Meaningful competition IRA Rollover Retiree selects annuity form and income features Objective guidance and purchase guidelines ©Hueler Companies 2019. All Rights Reserved.