We have a strong commitment to adhere to the suitability guidelines set forth in the NAIC Suitability in Annuity Transactions Model Regulation and applicable state laws. We have developed guidelines and forms for you to use to ensure that every sale and replacement of an annuity product is suitable. We rely on your insight and personal knowledge of your client and their financial situation to identify facts and information that may not be obvious to the individual reviewing the forms or application. We expect you to know and understand our products and our suitability standards and apply this knowledge in your every day practice of soliciting our products.

You must have reasonable grounds for believing that the recommendation to purchase or replace an annuity is suitable for the client based on the information provided by the client.

Solicitation

• Make a reasonable effort to obtain your client’s suitability information and ensure the information is accurate.
• Do not solicit an individual who resides in a nursing home, has any form of cognitive impairment, or has been diagnosed with a terminal illness.
• Assess the various features of our annuities to make a reasonable determination if any product is suitable for your client based on the suitability information provided.
• Fully explain to your client the various features, risks, benefits and charges of the annuity and any rider(s) you are recommending.
• Fully document your rationale for recommending the purchase of the product and any rider(s) in your records as well as on the Annuity Suitability Questionnaire. Be specific.
• Review the applicable Buyer’s Guide, Product Disclosure, Rider Disclosure and Privacy Commitment Policy and any other disclosures required by law with your client throughout the application process.
• Accurately complete all required application forms, disclosures and supplemental materials.
• Ensure that both you and your client sign the signature pages of the Product Disclosure and Rider Disclosure and provide copies of each to Nassau with the completed application.
• Leave copies of the Buyer's Guide, Privacy Commitment and applicable disclosure documents with your client.

2020 Naic Suitability In Annuity Transactions Model Regulation

In Spring of 2020, the NAIC approved revisions to the Suitability in Annuity Transactions Model Regulation #275 requiring producers to use "reasonable diligence, care and skill" in making recommendations and to act in the "best interest" of consumers. In states which have adopted the new NAIC model regulation or similar regulations, all recommendations or sales must be in the best interest of the client. Under this new model regulation, in addition to existing suitability requirements:

• The client's interest must be prioritized.
• Recommendations and sales must effectively address the client's unique financial situation, insurance needs and financial objectives.
• Producers must meet specific "best interest" obligations regarding care, disclosure, conflict of interest and documentation.

The following is a summary of new producer responsibilities under the 2020 NAIC Suitability in Annuity Transactions model regulation:*

• Complete new training credits prior to any state deadline.
• Obtain a signed "Insurance Agent (Producer) Disclosure for Annuities" form at the time of recommendation or sale.
• Obtain additional signed forms if a consumer refuses to provide certain information or is making a purchasing decision against a producer's recommendation.**
• Avoid and disclose any material conflict of interest
• If requested by the client, disclose any cash and non-cash compensation in the form of a range or percentage.
• Communicate the basis or bases of any recommendation to the client and make a written record of any recommendation, the basis for the recommendation and any disclosures provided (including oral disclosures).

*This is only a summary. You are required to comply with all the regulations that are applicable in the state in which you are selling or recommending the purchase of an annuity.

**Nassau will not issue a contract if the Annuity Suitability Questionnaire is not completed or if the sale was not recommended by the producer.

Nassau position on sales of fixed indexed annuities to consumers age 81 and over

• Nassau recognizes that consumers in their 80s, or later stages of retirement are confronted with unique financial circumstances, needs and objectives. Age is one of many important considerations when exploring financial options for seniors and is a critical component of a comprehensive evaluation of financial objectives for your senior clients.
• Along with regulatory bodies, Nassau has a heightened sensitivity for consumers over age 80. Any applications received must meet additional suitability criteria. A pre-issue call out from a Suitability Analyst to the client is required for all Fixed Indexed Annuity cases. Please refer to Nassau’s Suitability FAQ by going to Start Suitability & Compliance on salesnet.nfg.com for more information regarding these types of sales.

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