Date: December 30, 2008

From: ING Life Product Development

Term Conversions and Life Settlements

Effective January 1, 2009, the ING Life Companies (ING) will add two new guidelines that affect commissions on term conversions to permanent policies that become life settlements.

In the past year, we have experienced a growing number of term policies being converted and then settled shortly thereafter. While life settlements may be suitable in certain situations, ING is concerned with having policies purchased with the intent of settling.

Conversions from Settled Term Policies

ING will not pay commission on permanent policies being converted from an ING Life Companies' term life insurance policy that has been settled.

Chargebacks on Settlements within Two Years of Conversion

ING will charge back all commissions paid on permanent policies that were converted from an ING Life Companies' term policy and settled within two years of the conversion date.

Ongoing Commitment to Quality

ING Life Companies' term products have conversion privileges that provide a competitive advantage to our customers needing protection over extended time periods. Taking these steps now will help ING continue to offer the most competitive life insurance product solutions to you and your customers.

For more information, contact your ING Life Companies' representative, access ING Pro through www.inglifeinsurance.com , or call ING Life Sales Support at 866-ING-SELL (866-464-7355).

For agent use only. Not for public distribution.

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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). Only ReliaStar Life Insurance Company of New York is admitted, and its products issued within the state of New York. All are members of the ING family of companies.

All guarantees are based on the financial strength and claims paying ability of the issuing insurance company, who is solely responsible for all obligations under its policies.