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Compensation Paid to Harbor Financial Services by Mutual Fund Companies, Direct Participation Programs and Insurance Companies

Harbor Financial distributes mutual funds, Direct Participation Programs and may receive additional compensation from them in the form of sales and asset-based education and marketing support payments. The additional compensation is not paid directly from the assets of your variable annuity. Additionally, no portion of the payments received by Harbor Financial are paid to or shared directly with your financial advisor or his or her respective branch office. The payments are paid directly from the companies to Harbor Financial and are not deducted from the separate accounts that hold the investment assets.

Education and Marketing Support Payments

Harbor Financial provides a variety of marketing and other sales support services to mutual fund companies, direct participation programs and insurance companies (including annuities). These services include, but are not limited to:

· providing detailed product information to financial advisors

· assisting insurance companies with strategic planning and sales support

· providing presentation opportunities during professional development workshops

· study groups, and other Harbor Financial events and conferences

· distribution support for sales literature and other promotional materials relating to their products

The marketing service and support fees come in a variety of forms, including payments which are sometimes referred to as “revenue sharing” fees and 12b-1 fees. This compensation may not be disclosed in detail in a variable annuity’s prospectus or contract language. At Harbor Financial, these fees do not provide placement on any preferred or recommended product lists. The companies Harbor Financial has received payment from includes Symetra, Hartford, AXA, Metlife, CNL, Crump, Shurwest, UFC and Raymond James. These fees can be as high as $15,000 per year and also include some type of asset based pay up to .05% per year on assets under management.

General Promotional Activities

Marketing representatives of insurance companies or their affiliated distributors, who are often referred to as “wholesalers,” work with Harbor Financial advisors and their branch office managers to promote their annuity products. Consistent with applicable laws and regulations, these insurance companies and their wholesalers may pay for or provide training and education programs for Harbor Financial advisors and their existing and prospective clients. Insurance companies may also pay for due diligence meetings, conferences, relationship building events, occasional recreational activities, and/or provide promotional items that are intended to result in the promotion and sale of their products. This could cause our financial advisors to focus on, and recommend to clients, the specific products issued by these insurance companies.

Specific Insurance Company Wholesale Disclosure

Harbor Financial Services operates as a wholesaler through a division called HFS Distributors. HFS Distributors markets and educates the Symetra insurance products to Harbor Financial representatives and other broker dealer representatives. Harbor Financial Services receives additional compensation when one of Symetra’s products is sold when using Harbors wholesaling agreement. Although no representatives of Harbor Financial Services receives this additional compensation, this could pose a conflict of interest when comparing similar products.

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