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United of Omaha Life Insurance Company Companion Life Insurance Company Responding to Your Fiduciary Concerns mutual of omaha retirement services Mutual of Omaha understands the complexities of being a plan fiduciary and appreciates that many plan sponsors and participants are not investment experts. We recognize that regardless of how you design your retirement plan and allocate responsibility for fiduciary actions, as the plan sponsor, you can never fully eliminate your fiduciary obligations. As a result, we designed a retirement plan solution to address your fiduciary concerns by offering services and support at the product, plan and participant levels. The following chart highlights the features of our product relating to some of your key fiduciary duties. Your Fiduciary Duty How The Mutual of Omaha Product Helps You Establish an investment policy for your plan. An investment policy allows you to document the investment objectives and performance guidelines for your plan. We provide a sample investment policy that incorporates many of the fundamental design features of our product, including professional investment portfolios, diversified investment offerings and funds with materially different risk/return characteristics. ERISA § 404(a)(1)(D). Choose a product that offers diversified investment options consistent with your investment policy. ERISA §§ 402(c)(3), 404(d)(1). Select service providers for your plan. ERISA § 404(a). 1 An Investment Manager Oversight Committee (IMOC) – comprised of respected investment and retirement services experts from Mutual of Omaha and supported by strategic investment consultant Callan Associates, Inc. – selects and monitors the investment managers and fund options in our product. Our investment managers are required to manage their particular funds to fulfill a specific investment style (e.g., large-cap growth, large-cap value, small cap, etc.). Your plan may appoint a fund’s investment manager as a plan fiduciary responsible for that portion of your plan’s assets, thus transferring a portion of your fiduciary responsibilities to the investment manager. 1 Our fully bundled solution includes a full complement of investment options suitable for a defined contribution plan, as well as all the plan administration and recordkeeping services needed to ensure your plan runs smoothly. Our TPA platform can be packaged, scaled and priced to fit any type of business or existing TPA model.  he plan’s appointment does not include mutual funds or insurer general account investments, which are not subject to ERISA’s T plan asset provisions. MUGC9172_1010 Select diversified investment options to provide to your retirement plan participants. ERISA §§ 404(a)(1)(C), 3(21). Provide information to plan participants regarding their investment options. ERISA § 404(c). Determine the default investment funds for participants that do not make investment elections or for automatic contributions. ERISA § 404(c)(5), 3(38); Labor Reg. § 2550.404c-5. Our retirement program offers the optional Mesirow Financial Fiduciary Partnership Program. Through this arrangement, Mesirow Financial Investment Management, Inc. can be appointed to serve as an investment advisor and co-fiduciary to your plan, undertaking specific responsibilities with respect to investment identification, selection and/or monitoring. As defined under ERISA Section 3(21), Mesirow is a fiduciary with respect to those plans that utilize Mesirow’s services, because it provides “investment advice for a fee” with respect to those plans. As a fiduciary to your plan, Mesirow Financial will perform and defend its duties and obligations in compliance with ERISA. We offer a variety of award-winning printed and electronic materials for use during enrollment and ongoing educational meetings. Participants can access additional investment information and planning calculators online, which are updated at least quarterly. To the extent participants direct how their contributions are invested, our product provides guidelines and disclosure statements relating to ERISA Section 404(c). This allows you to avoid fiduciary responsibility for investment losses in participants’ accounts as a result of their investment elections. Contributions can be invested in a Qualified Default Investment Alternative (QDIA), which relieves you from fiduciary responsibility for the performance of default investments. Our product offers two types of QDIA options: • Mutual GlidePathSM Portfolios – a series of target retirement date funds • Managed account services from Stadion Money Management, Inc., an independent registered investment advisory firm Stadion will serve as an ERISA fiduciary to your plan with respect to the assets it manages for your participants and, if you elect, for your employer-directed investments. As defined by ERISA § 3(38), Stadion is an investment manager with respect to any plan that uses the Stadion investment management service or that uses the Stadion funds for the plan’s QDIA. Stadion backs its QDIA with a written warranty, unlike other service providers who only agree to indemnify you if the plan fails to meet the requirements. Monitor your plan’s investment offerings and make any necessary changes in the investment policy or investment offerings. ERISA §§ 402(b), 404(a)(1); Labor Reg. § 2550.404a-1. Document your fiduciary actions and decisions. ERISA § 404, 405. With support from Callan Associates, the Investment Management Oversight Committee (IMOC) employs sophisticated monitoring processes to review each of our product’s investment offerings on an ongoing basis for performance and consistency with the stated objectives. As the plan fiduciary, you will receive regular reports detailing these investment reviews along with any investment manager changes the IMOC is planning to make in response to those managers no longer meeting our product’s investment criteria and/or their funds’ stated objectives. Based on ERISA sections 3(21) and 3(38), Callan is neither a fiduciary nor an investment manager with respect to the advisory services it provides to our 401(k) product. As your co-fiduciary, Mesirow Financial also provides quarterly investment monitoring reports for your plan’s investment options. Additionally, we conduct extensive annual reviews of your plan and develop comprehensive reports, which provide detailed results from the previous calendar year and offer additional information and guidance to help improve the overall health of your plan. FOCLpoint is an innovative, online database designed to help you manage your fiduciary documents in one secure location. Key paperwork is already populated in the database. You may add information as appropriate for your needs. Three Levels of Support Our tiered approach to fiduciary support includes services at the product, plan and participant levels. This structured support can help you meet your fiduciary responsibilities to provide prudent and diverse investments in your plan, while offering participants diversified investments and access to the educational materials and information they need to make sound investing decisions. For more detailed information on our product and the independent experts associated with it, please call your plan’s advisor or Mutual of Omaha representative. United of Omaha Life Insurance Company Omaha, NE 68175 Companion Life Insurance Company Hauppauge, NY 11788 (877) 401-SALE (7253) GetRetirementRight.com Availability of each feature varies by plan. Investment options are offered through a group variable annuity contract (Forms 902-GAQC-09 and 902-GAQC-09(OR) or 901GAQC-07 or 901-GAQC-07(OR)) underwritten by United of Omaha Life Insurance Company for contracts issued in all states except New York. United of Omaha is not licensed in New York. In New York, Companion Life Insurance Company, Hauppauge, NY 11788 underwrites the group variable annuity (Form 900-GAQC-07 (NY)). Each company accepts full responsibility for each of their respective contractual obligations under the contract but does not guarantee any contributions or investment returns except as provided in the Guaranteed Account and the Lifetime Guaranteed Income Account as provided under the contract. Neither United of Omaha, Companion Life Insurance, nor their representatives or affiliates offers investment advice in connection with the contract. Lifetime Guaranteed Income Account (Rider Forms 651-GAQR-10 or 651-GAQR-10(CT) or 651-GAQR-10(OR)) may not be available in all states and specific features may vary by state. The Lifetime Guaranteed Income Account is not available in Nevada or New York. MUGC9172_1010