For U.S. producers only, for use only in the United States. Not for public use or distribution.

High Net Worth Foreign NationalUnderwriting OverviewUpdated 02/01/2016

1 Overview

2 Proposed Insured Qualifications

3 International Risk Reinsurance Pool Parameters

4 International Risk Parameters and Area Classes

OverviewThe Voya Life Companies (Voya) offer underwriting guidelines designed especially for the High Net Worth Foreign National (HNWFN) market. Our process includes dedicated international underwriters assigned to each case at the time of submission, plus reinsurance arrangements specifically put in place for Foreign National insureds.

Please note that no set of guidelines can accommodate every circumstance. Chief Underwriter signoff is required for acceptance of individual consideration and other unusual circumstances. However, these basic underwriting rules are currently in place for all of our HNWFN cases.

There are unique underwriting and regulatory considerations presented when issuing life insurance policies on individuals who spend a significant amount of time outside of the United States. This is especially true if the countries in question have poor economic conditions, lower standards of public health or political instability. In addition, the regulations of some countries may limit or prevent their residents or citizens from purchasing life insurance outside of their country of residence. Therefore, Voya may not be able to consider proposed insureds from all countries for coverage.

VOYA’S INTERNATIONAL UNDERWRITING GUIDELINES WILL BE REVISED ACCORDING TO WORLD CIRCUMSTANCES, WHICH MAY REQUIRE IMMEDIATE CHANGES WITHOUT NOTICE REGARDING TRAVEL OR RESIDENCE RATING APPROACHES AND/OR AREA CLASSES. RATING QUOTES FOR FOREIGN TRAVEL OR RESIDENCE ARE TO BE CONSIDERED TENTATIVE UNTIL ACTUAL POLICY APPROVAL.

Highlights and Guidelines: Ā Ages between 18-75 ( juvenile coverage is

not available).

Ā Proposed insured must have a U.S. connection.

Ā Minimum face amount of $1MM. Voya will not accept bundling of contracts to meet the $1MM requirement (e.g. two term policies of $750,000).

Please note: in the case of a cash value & term combo sale, if the term life insurance face amount is $1MM or more, the cash value policy face amount may be less than $1MM.

Ā Minimum net worth of $2MM USD equivalent required (not required for U.S. citizens or U.S. permanent residents by guidelines explained in this document).

Ā All Voya Life Companies’ fully underwritten cash value life insurance and term products are available.

Ā Medical Risks through Table 4 (200% or better).

Ā All underwriting requirements must be translated to English prior to submission to Voya. We will incur the costs for these medical records only on cash value products and only if translation is approved by Underwriting and if the case is approved.

Ā Domestic Age and Amount requirements will apply. In addition, Inspection Reports will be required at $3,000,001 and more.

Ā No politicians, public figures, missionaries, government leaders, journalists, judicial personnel, or politically exposed persons (PEPs).

Ā No aviation risks.

Ā Voya’s reinsurance treaty includes high auto bind coverage and jumbo limits.

Ā Riders ECV, Accelerated Death Benefit, Overloan Lapse Protection, and term riders on the primary insured (for Survivorship plans).

Ā No ratable avocation or occupation risks will be accepted for B, C, D & E areas.

For U.S. producers only, for use only in the United States. Not for public use or distribution. 1

Requirements for all HNWFN cases:

1. Financial Underwriting. Insured must have a net worth of at least $2,000,000. Voya reserves the right to request and review documentation establishing the net worth requirements. You should provide detailed information supporting the valuation of the assets used for this purpose. Third party verification or documents supporting the proposed valuation is recommended.

2. U.S. Connection. The insured/policy owner must own real estate, and/or have a family relationship, financial assets, or employment connection with the United States. Voya reserves the right in its sole discretion to determine whether an applicant qualifies for U.S. connection. The following are examples of U.S. connections:

a. Real Estate – Insured/Policy owner owns real estate in the U.S.

b. Family Relationships in U.S. – Insured/Policy owner has immediate family relatives residing in the United States (immediate family includes spouse, children, brothers or sisters).

c. Financial Assets – Insured/Policy owner has financial assets in the U.S. for a minimum of six months prior to application (example: brokerage account or bank account).

d. Employment – Insured/Policy owner works for a U.S. company or owns a business located in the U.S.

3. Solicitation and Servicing Agreement. Each policy owner will be required to sign a Solicitation and Services Agreement confirming that solicitation of the sale complied with Voya rules and acknowledging that servicing of the Policy will occur in the U.S.

4. Medical Examinations. All medical exams and labs must be completed by Voya approved vendors in the United States, or using an approved process for obtaining medical reports outside the U.S.

Proposed Insured Status

A proposed insured gets classified as either:

1. a U.S. citizen or permanent resident,

2. a Foreign National residing in the U.S. without permanent resident qualifications, or

3. a Foreign National with foreign residence or long term foreign travel.

Generally, U.S. citizens and permanent residents will be considered under the domestic underwriting requirements. However, a U.S. citizen or permanent resident traveling outside the U.S. on a long term basis will be placed in the International Reinsurance Pool.

Proposed Insured Qualification

*Acceptable visas are typically E1-2, H1B, H4, K1-4, L1-2 and V1-3 – others may be considered on an individual basis.

Voya’s definition of a permanent resident is as follows.

Ā U.S. resident with an acceptable visa or 10 year Green Card with (1) intent to remain permanently on the U.S. and either (2a) 5 years continuous U.S. residence or (2b) multiple other evidences of permanence such as owning a home, marriage to a U.S. citizen, long term U.S. employment, etc.*

Voya’s definition of long term travel is as follows.

Ā Greater than 12 weeks to A+, A, & B class countries/jurisdictions

Ā Greater than 6 weeks to C class countries/jurisdictions

Voya’s definition of short term travel qualifies as follows.

Ā Up to 12 weeks/year in A+, A, & B class countries/jurisdictions

Ā Up to 6 weeks/year in C class countries/jurisdictions

U.S. Proposed Insured Residency & Travel Qualifications

2 For U.S. producers only, for use only in the United States. Not for public use or distribution.

International Risk Reinsurance Pool ParametersCash Value Life Insurance Products

Jurisdiction A+ A B C

Automatic Binding Limit* $25MM $25MM $15MM $ 5MMMinimum face $ 1MM $ 1MM $ 1MM $ 1MMBest class Super Preferred Preferred Preferred Standard + $2.00 flat extraJumbo limit $35MM $35MM $35MM $35MM*Includes Voya retained amount

Term Life Insurance Products

Jurisdiction A+ A B C

Automatic Binding Limit* $23MM $23MM $15MM $ 5MMMinimum face $ 1MM $ 1MM $ 1MM $ 1MMBest class Super Preferred Preferred Preferred Standard + $2.00 flat extraJumbo limit $35MM $35MM $35MM $35MM*Includes Voya retained amount

HNWFN Paramed Exam vendor: ExamOneUse preferred vendor ExamOne to order underwriting requirements for high net-worth Foreign National business.

When contacting ExamOne, please have the following paramedical services information available:

Ā applicant's name

Ā date of birth

Ā address

Ā Social Security Number (if applicant is from the U.S.)

Ā home and/or business phone number

Ā cell phone number

Ā email address (if available)

Ā policy amount

Ā insurance company

Ā underwriting requirements

For U.S. producers only, for use only in the United States. Not for public use or distribution. 3

International Risk Parameters and Area ClassesThe Voya Underwriting Guidelines allow policies to be offered to Foreign Nationals residing in a broad listing of foreign jurisdictions, as well as United States citizens traveling out of the country.

An individual’s underwriting classification will be impacted by the area class rating assigned to the individual’s country of residence (Foreign National applicants) or travel (Foreign National applicants and U.S. citizens and permanent residents). Area Classes range from a rating of A+ to E. Current ratings are included by country below. These ratings are updated from time to time and Voya may change a rating at any time in its sole discretion.

*Applicants residing in or traveling to countries listed on the TRAVEL.STATE.GOV travel alert and warning list may require facultative reinsurance.  Please contact underwriting for additional information on a case by case basis.

Non-U.S. Foreign Residence Guidelines

E Afghanistan

A Albania

B Algeria

A American Samoa

A Andorra

D Angola

A Anguilla

D Antarctica

A Antigua and Barbuda

A Argentina

B Armenia

A Aruba

A+ Australia

A+ Austria

B Azerbaijan

B Bahamas

A Bahrain

C Bangladesh

A Barbados

A Belarus (Beylorussia)

A+ Belgium

C Belize

D Benin

A+ Bermuda

B Bhutan

C Bolivia

A Bosnia and Herzegovina

C Botswana

B Brazil

A+ British Virgin Islands

A Brunei

A Bulgaria

D Burkina Faso

D Burma/Myanmar

D Burundi

C Cambodia

D Cameroon

A+ Canada

A Canary Islands

B Cape Verde

A Cayman Islands

E Central African Republic

E Chad

A Chile

B China

B Colombia

C Comoros

D Congo

D Congo, Democratic Republic of

A Cook Islands

A Costa Rica

A Croatia

D Cuba

A Curacao

A Cyprus

A Czech Republic

A+ Denmark

D Djibouti

A Dominica

B Dominican Republic

C East Timor

B Ecuador

C Egypt

C El Salvador

D Equatorial Guinea

D Eritrea

A Estonia

D Ethiopia

A Falkland Islands

B Federated States of Micronesia

B Fiji

A+ Finland

A+ France

B French Guiana

A French Polynesia

D Gabon

D Gambia

D Gaza

B Georgia

A+ Germany

D Ghana

A Greece

A Greenland

A Grenada

A Guadeloupe

C Guatemala

D Guinea

D Guinea BissauC Guyana

D Haiti

C Honduras

A+ Hong Kong

A Hungary

A+ Iceland

B India - Delhi & Mumbai only

C India - except Delhi & Mumbai

B Indonesia

A+ Super PreferredA B PreferredC Standard plus $2.00 flat extra

D E Individual consideration. No auto binding available. Coverage for some D & E jurisdictions may be available on a facultative reinsurance basis.

4 For U.S. producers only, for use only in the United States. Not for public use or distribution.

D Iran

E Iraq

A+ Ireland

A Israel

A+ Italy

D Ivory Coast/Cote d'Ivoire

B Jamaica

A+ Japan

A Jordan

B Kazakhstan

D Kenya

C Kiribati

E Korea, North

A Korea, South

A Kosovo

A Kuwait

C Krygyzstan

C Laos

A Latvia

B Lebanon

D Lesotho

D Liberia

E Libya

A+ Liechtenstein

A Lithuania

A Luxembourg

A Macau

A Macedonia

D Madagascar

D Malawi

A Malaysia

B Maldives

E Mali

A Malta

A Marshall Islands

A Martinique

D Mauritania

A Mauritius

B Mexico

B Moldova

A+ Monaco

B Mongolia

A Montenegro

A Montserrat

B Morocco

D Mozambique

C Namibia

C Nauru

C Nepal

A Netherlands Antilles

A+ Netherlands

A New Caledonia

A+ New Zealand

C Nicaragua

E Niger

E Nigeria

B Niue

A Northern Marianas Islands

A+ Norway

A Oman

C Pakistan

A Palau

A Panama

C Papua New Guinea

B Paraguay

B Peru

C Philippines

A Poland

A+ Portugal

A Qatar

A Romania

B Russian Federation

D Rwanda

A Saint Kitts and Nevis

A Saint Lucia

A Saint Vincent and the Grenadines

B Samoa

A San Marino

C Sao Tome and Principe

B Saudi Arabia

D Senegal

A Serbia

B Seychelles

D Sierra Leone

A+ Singapore

A Saint Maarten

A Slovakia

A Slovenia

B Solomon Islands

E Somalia

C South Africa

E South Sudan

A+ Spain

B Sri Lanka

E Sudan

B Suriname

D Swaziland

A+ Sweden

A+ Switzerland

E Syria

A+ Taiwan

C Tajikistan

D Tanzania

B Thailand

D Togo

B Tonga

B Trinidad and Tobago

B Tunisia

B Turkey

C Turkmenistan

A Turks and Caicos

C Tuvalu

D Uganda

B Ukraine

A United Arab Emirates

A+ United Kingdom

A Uruguay

A+ U.S. Virgin Islands

B Uzbekistan

C Vanuatu

A+ Vatican City

C Venezuela

B Vietnam

C West Bank

D Western Sahara

E Yemen

D Zambia

D Zimbabwe

Please note: Canadian citizens residing in the U.S. are not covered under the HNWFN program. Please refer to Voya’s Distributor Underwriting Reference Guide (154947) and Underwriting Requirements guide (113151) Guide.

A+ Super PreferredA B PreferredC Standard plus $2.00 flat extra

D E Individual consideration. No auto binding available. Coverage for some D & E jurisdictions may be available on a facultative reinsurance basis.

For U.S. producers only, for use only in the United States. Not for public use or distribution. 5

Life insurance products are issued by ReliaStar Life Insurance Company (Minneapolis, MN), ReliaStar Life Insurance Company of New York (Woodbury, NY) and Security Life of Denver Insurance Company (Denver, CO). Within the state of New York, only ReliaStar Life Insurance Company of New York is admitted, and its products issued. All are members of the Voya® family of companies. All death benefit guarantees are based on the financial strength and claims paying ability of the issuing company, which is solely responsible for obligations under its own policies.

For U.S. producers only, for use only in the United States. Not for public use or distribution. ©2016 Voya Services Company. All rights reserved. CN1228-20675-0118

We understand that the HNWFN world is a complex market. We’re here to help. Please contact your local sales team or underwriter with any questions.

169507 02/01/2016

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