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Date Created: 12/20/15
ING quotEXCESSIVE TRADINGquot POLICY 1 ING actively monitors fund transfer 2 If ING determines that an individual The ING family of companies quotINGquot as providers of multi fund variable insurance and retirement products has adopted this Excessive Trading Policy to respond to the demands of the various fund families which make their funds available through our variable insurance and retirement products to restrict excessive fund trading activity and to ensure compliance with Section 22c2 of the Investment Company Act of 1940 as amended ING s current definition of Excessive Trading and our policy with respect to and reallocation activity within its variable insurance and retirement products to identify Excessive Trading ING currently defines Excessive Trading as a More than one purchase and sale of the same fund including money market funds within a 60 calendar day period hereinafter a purchase and sale of the same fund is referred to as a quotround tripquot This means two or more roundtrips involving the same fund within a 60 calendar day period would meet ING39s definition of Excessive Trading or b Six roundtrips within a twelve month period has made a purchase of a fund within 60 days of a prior round trip involving the same fund ING will send them a letter warning that another sale of that same fund within 60 days of the beginning of the prior round trip will be deemed to be Excessive Trading and result in a six month suspension of their ability to initiate fund transfers or reallocations through the Internet facsimile Voice Response Unit VRU telephone calls to the ING Customer Service Center or other electronic trading medium that ING may make available from time to time quotElectronic Trading Privilegesquot Likewise if ING determines that an individual has made five roundtrips within a twelve month period ING will send them a letter warning that another purchase and sale of that same fund within twelve months of the initial The following transactions are excluded when determining whether trading activity is excessive such trading activity is outlined below a Purchases or sales of shares related to non fund transfers for example new purchase payments withdrawals and loans b Transfers associated with scheduled dollar cost averaging scheduled rebalancing or scheduled asset allocation programs c Purchases and sales of fund shares in the amount of 5000 or less d Purchases and sales of funds that affirmatively permit shortterm trading in their fund shares and movement between such funds and a money market fund and e Transactions initiated by a member of the ING family of insurance companies purchase in the first roundtrip in the prior twelve month period will be deemed to be Excessive Trading and result in a six month suspension of their Electronic Trading Privileges According to the needs of the various business units a copy of the warning letters may also be sent as applicable to the persons or entity authorized to initiate fund transfers or reallocations the agentregistered representative or investment adviser for that individual A copy of the warning letters and details of the individual39s trading activity may also be sent to the fund whose shares were involved in the trading activity Your future Made easier ING quotEXCESSIVE TRADINGquot POLICY 3 If ING determines that an individual has used one or more of its products to engage in Excessive Trading ING will send a second letter to the individual This letter will state that the individual s Electronic Trading Privileges have been suspended for a period of six months Consequently all fund transfers or reallocations not just those which involve the fund whose shares were involved in the Excessive Trading activity will then have to be initiated by providing written instructions to ING via regular US mail During the six month suspension period electronic quotinquiry onlyquot privileges will be permitted where and when possible A copy of the letter restricting future transfer and reallocation activity to regular US mail and details of the individual39s trading activity may also be sent to the fund whose shares were involved in the Excessive Trading activity httpingus 4 Following the six month suspension period during which no additional Excessive Trading is identified Electronic Trading Privileges may again be restored ING will continue to monitor the fund transfer and reallocation activity and any future Excessive Trading will result in an indefinite suspension of the Electronic Trading Privileges Excessive Trading activity during the six month suspension period will also result in an indefinite suspension of the Electronic Trading Privileges ING reserves the right to limit fund trading or reallocation privileges with respect to any individual with or without prior notice if ING determines that the individual39s trading activity is disruptive regardless of whether the individual s trading activity falls within the definition of Excessive Trading set forth above Also ING s failure to send or an individual s failure to receive any warning letter or other notice contemplated under this Policy will not prevent ING from suspending that individual39s Electronic Trading Privileges or taking any other action provided for in this Policy 6 Each fund available through ING39s variable insurance and retirement products either by prospectus or stated policy has adopted or may adopt its own excessivefrequent trading policy ING reserves the right without prior notice to implement restrictions andor block future purchases of a fund by an individual who the fund has identified as violating its excessivefrequent trading policy All such restrictions andor blocking of future fund purchases will be done in accordance with the directions ING receives from the fund Insurance products annuities and funding agreements issued by ING Life Insurance and Annuity Company quotILIACquot One Orange Way Windsor CT 06095 which is solely responsible for meeting its obligations Plan administrative services provided by ILIAC or ING Institutional Plan Services LLC Securities distributed by or offered through ING Financial Advisers LLC member SIPC or other brokerdealers with which it has a selling agreement Annuities may also be issued by ReliaStar Life Insurance Company Minneapolis MN and ReliaStar Life Insurance Company of New York Woodbury NY Variable annuities issued by ReliaStar Life Insurance Company are distributed by ING Financial Advisers LLC Variable annuities issued by ReliaStar Life Insurance Company of New York are distributed by Directed Services LLC Only ING Life Insurance and Annuity Company and ReliaStar Life Insurance Company of New York are admitted and issue products in the state of New York All companies are members of the ING family of companies Products and services may vary by state and may not be available in all states 154907 3011051XP3 IOll ClllOll020lOll HTTPNGUS
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