Clark Securities, Inc. (“CSI”) is registered with the Securities and Exchange Commission as a broker-dealer and is a FINRA member firm engaged in recommending the purchase or sale of variable insurance contracts, variable annuities and mutual funds (“securities”) to informally fund various benefit and other corporate liabilities. CSI receives a commission and other forms of compensation, as described below, for any sale of securities. Each registered representative of CSI is also a licensed insurance agent associated with Clark Consulting, Inc. (“CCI”). CCI is a general agency authorized to sell, solicit and negotiate insurance and annuities in 48 states and Puerto Rico. Please note that CSI and CCI are not investment advisers. CCI does own Clark Investment Strategies, Inc., which is an investment adviser.

CSI and its registered representatives review and evaluate products of numerous insurance and mutual fund providers engaged in the employer-owned insurance marketplace. Based upon various factors, CSI contracts with certain providers who offer competitive products suitable for its clients. These factors include, but are not limited to, the financial strength of the provider, competitiveness of the provider’s product offerings, the financial incentives discussed below, systems compatibility to provide technical support for both the sale and servicing of employer-owned insurance contracts, and the provider’s ability to support CSI and its sales consultants through training, education and marketing materials.

Commission Payments

CSI and its registered representatives receive commissions and compensation from insurance companies for the sale of variable insurance or variable annuities, and from mutual funds for the sale of those mutual funds. CCI receives commissions and compensation from insurance companies for the sale of non-registered/fixed annuities and insurance products.

When CSI offers securities, including mutual funds, variable insurance products and annuities, it is acting as a non-exclusive agent for the mutual fund or the insurance company and, as such, will receive a commission payment. When CCI offers non-registered/fixed annuities and insurance products, it is acting as a non-exclusive agent for the insurance company and, as such, will receive a commission payment.

The amount of commission paid to CCI, CSI and CSI’s registered representatives depends on the product selected, the amount of premium received and the insurance company’s applicable commission rate. The commission rate varies depending on the particular product selected by the client and the specific company issuing the product. Renewal commission (sometimes referred to as “trails”) may also be paid on insurance products as long as the insurance remains in force. A portion of the commissions received from the sale of an insurance product is paid by CCI to the sales consultant involved in the sales transaction. In some cases, CCI or CSI may also make payments to a third party if such third party introduces a prospective client to CCI for the purchase of either a security offered by CSI or a non-registered product offered by CCI.

Distribution and Servicing Fees for Mutual Funds

CSI and its registered representatives may also receive distribution (Rule 12b-1 fees) and shareholder service fees from mutual funds. The fees are typically ongoing and based upon a percentage of the fund’s assets. The Rule 12b-1 fees and shareholder service fees are paid out of fund assets, are part of the fund’s expenses, and are required by law to be disclosed in the fund prospectus.

Marketing Allowances

In addition to the compensation arrangements described above, CSI receives marketing allowances from insurance companies that are used primarily to help pay the significant costs we incur in educating our registered representatives about the insurance products CSI offers, to assist CSI in developing new and innovative insurance

products, to service our clients who purchase these products, to offer client seminars, sales meetings and conferences, and in other marketing efforts. The marketing allowances received for these activities vary by insurance company, and are subject to change at any time. Any marketing allowances from an insurance company may be based on the amount of insurance or other financial products purchased through CSI.

Supplemental Compensation Arrangements

CSI or CCI also maintains supplemental compensation arrangements with the following insurance carriers: Transamerica Life Insurance Company and Life Investors Insurance Company of America (both affiliates of CSI and CCI), Great West Life & Annuity Insurance Company, ING America Equities, Inc, New York Life Insurance and Annuity Corporation and MassMutual Life Insurance Company. These arrangements generate revenue primarily with respect to existing blocks of business and, to a lesser extent, new blocks of business. Payments under these arrangements are typically based on the cash value or fair value of our existing in-force business with these carriers at specified dates of measurement, and, to a lesser extent, based on the value of new business generated. The payments may also include persistency incentives. These payments are not shared with our registered representatives. CSI or CCI uses part of the payments under these arrangements to help pay for the significant operating costs associated with its client administration systems.

Ownership

CSI and CCI are part of the AEGON group of companies, which includes Transamerica Life Insurance Company and Western Reserve Life Assurance Co. of Ohio.

Additional Information

Additional information related to the commission and other payments received by CSI or CCI may be available in the prospectuses or offering documents for the insurance product or in the mutual fund’s prospectus and Statement of Additional Information. You should consider the investment objective, risks, charges, and expenses related to the insurance product or mutual funds you select. For a current list of the providers with whom CSI or CCI maintains supplemental compensation arrangements and/or receives marketing allowances, please visit our website at www.clarkconsulting.com.

Insurance Products and Mutual Funds • Are NOT Deposits • Are NOT FDIC-Insured • Are NOT Insured By Any Federal Government Agency • Have NO Bank Guarantee • May Go Down In Value

(Effective date: June 9, 2008)