LONGEVITY • INFRASTRUCTURE • KNOWLEDGE • INDEPENDENCE Overview of Private Placement Variable Annuity (PPVA) Investment Accounts Private Placement Variable Annuity STRUCTURE IDF IDF IDF IDF IDF IDF IDF TAX CHARACTERISTICS CLIENT INSURANCE-DEDICATED FUNDS ► Investment returns accumulate on a tax-deferred basis LR.C. Section 72 lb- Assets within a PPVA Investment Account may be reallocated without tax Rev. RuL81-225 and Rev. Rut 82-54 Ir. When withdrawals are taken from a PPVA Investment Account, deferred gains are subject to tax at ordinary income rates. There is a 10% excise tax on the gain element of withdrawals taken before age 59% I.R.C. Section 72 IP If a private foundation or public charity is designated as the beneficiary of a PPVA Investment Account, deferred gains become fully exempt from income and estate taxes at the death of the annuitant ► IRC Section 1035 permits tax•free exchanges from other annuities or life insurance policies to a PPVA Investment Account J.R.C. Section 1035 ATTRIBUTES ► NO limits on contributions IP• NO upfront loads or surrender charges it. NO restrictions on withdrawals KEY MARKET APPLICATIONS For Families: • Personal investments • Retirement income • Charitable Legacy planning • Restructuring retail variable annuities For Institutions: • USTI / Ea FIRPTA blocker PI- NO distributions required until age 95 or older IP' NOT subject to life insurance company credit risk ► NO K-ls • Regulating timing of fiduciary income • Pre-immigration planning • Non-grantor foreign trusts P.-rer, Nn, and On ftvel CONFIDENTIAL — PURSUANT TO FED. R. GRIM. P. 6(e) CONFIDENTIAL WINGED KEEL GROUe DB-SDNY-0102074 SDNY_GM_00248258 EFTA01447442