NEA Member Benefits (“NEA MB”), in existence for over half a century, was established by the National Education Association (the “NEA”) to develop, implement, and administer voluntary benefit programs and services for NEA members. Our governing body includes a Board of Directors which oversees the corporation to ensure the quality and consistency of the programs. NEA MB has been in the business of marketing voluntary benefits, such as life insurance and credit cards, to members of the NEA since the mid 1960’s. NEA MB is a nonprofit membership corporation, and the NEA is its sole member. No dividends, royalties, profit, or licensing fees are returned to NEA, and NEA MB receives no dues dollars from the NEA. NEA members are teachers, education support professionals, professors, and students in the public schools and universities. NEA MB is a party to the NEA Retirement Program Service Agreement (the “Agreement”) between NEA MB and Security Benefit Corporation (“SB”). Pursuant to the Agreement, NEA MB provides administrative, marketing, and related services in connection with the NEA Retirement Program (the “Program”). The Program involves investments in variable annuity contracts and mutual funds underlying 403(b), 457, IRA, 401(k), and Health Reimbursement Account contracts. Through SB’s marketing and sales, the Program is available to NEA members and eligible employers (principally state and local school systems and districts and NEA-chartered state and local educational associations) as a means for such employers to provide their eligible employees and their retirees with retirement plan investment options. NEA MB began the Program in the early 1990’s with Nationwide Life Insurance Company (“Nationwide”). When Nationwide decided to exit the K-12

public school 403(b) market in 2000, NEA MB partnered with SB. NEA MB’s advisory services are impersonal. The services include: (1) making available monthly reports via NEA MB’s website about the performance of the investment options available through the Program using NEA MB developed criteria; (2) informing NEA members and employees of eligible employers about the existence of the Program through information on NEA MB’s website, social media, and the publication of ads in various NEA and state association publications; (3) making presentations from time to time to NEA members and employees of eligible employers concerning the Program; (4) through NEA MB’s representatives to the state associations, providing Program materials and other information about the Program to NEA members and employees of eligible employers; (5) maintaining articles, retirement and pension calculators, and a specified retirement report from Kiplinger’s Personal Finance magazine on NEA MB’s website; and (6) providing education via the website and face-to-face. NEA MB does not have clients who are retail investors, as NEA MB does not (i) provide personal investment advisory services or recommend specific investments to individuals, (ii) receive compensation for services from individuals, or (iii) have any contracts with individuals to provide advisory services. NEA MB’s “clients” (i.e., the persons who receive the benefit of the impersonal advisory services described above and referred to herein as “Program Participants”) are the NEA members and other employees of employers eligible for its services (i.e., public schools and universities, and referred to herein as “Eligible Employers”) that offer their employees the opportunity to participate in the Program’s investments.