January 2014 1 - cri4.com

1 Foresters Equity Services Inc. Compliance Contact information Submission Fax Number: (858) 244-4984. Questions Number (858) 550-4844 ext. 4869. Definition of Communications with the Public "communications with the public" consist of: Advertisements Sales literature Correspondence Institutional sales material Public appearances Independently prepared reprints Advertising or sales literature may include and is not limited to: Brochures and Illustrations Circulars, Newsletters or Flyers Statement Inserts Office Signage Group Email Prospecting or Direct-Mail communications Newspaper Articles and Advertisements Telemarketing Scripts Form Letters Audiovisual communications (audiotapes, videotapes, slides, overheads, etc.). Seminar materials, including materials of general interest, intended to educate attendees about basic financial concepts and generic financial and insurance products Sales Presentation materials (general and non-product specific) used to develop interest in financial planning concepts or insurance products.

2 Business Listings Reprints of third party articles or reports Business cards, letterhead, email signatures Radio or TV commercials and shows Internet, websites, and all other forms of electronic media, including chat rooms, bulletin boards and instant messaging Sales scripts (face-to-face, visual, audio or email). Software Illustrations Advertising Review Procedures Foresters Equity Services Representatives should use the Advertising Review Form as the first page of their submission. This form is located in the Forms section on the website. A hardcopy of all advertisements and sales literature must be submitted to Advertising Compliance for approval prior to use. Verbal approvals will not be given. When submitting material for review, representatives should complete the Advertising Review Form . A. separate copy of the form is required for each individual item. Official review is sent to the representatives and branch managers via email January 2014 1. Email responses from the analyst and attached documents must be printed and retained in the branch Advertising File.

3 Examiners will audit the Advertising File during branch inspections Seminar Submission Process: Seminar invitations or announcements must be submitted with the presentation If using a presentation that has not been previously approved, complete one Advertising Review Form for the presentation and the invitation and fax both items together under the one form. Fax one slide per page with the accompanying speaker's notes on each page. Include FINRA letter if applicable. Review of seminar invitations and announcements cannot be completed unless the presentation has been received or previously approved. Below are the status options that the Advertising Compliance Analyst may assign to representatives submissions: Approved The material is approved as is and may be used. Contingent Approval The material has been approved, provided changes are made exactly as indicated. It is not necessary to resubmit for final approval, unless the changes are different from the Analyst's comments.

4 Individual is pending registration Use of this material is permitted only upon written clearance from Registration is given on behalf of Foresters Equity Services Inc. Books and Records Representatives must retain their communications with the public, including pre-approved communications and those sent electronically, in their branch advertising file for six years from date of last use. These documents are subject to review by Compliance Branch Audit staff. The Branch Advertising File must include all of the following: Copy of the communication as it was reviewed by Foresters Equity Services The Advertising Review form, which includes the Analyst name, date approved and status . List of all recipients (not applicable to advertisements, see definition within this chapter). List of all attendees (applicable to group events and seminars) Additional copies may be retained in individual customer files, if preferred. FINRA Filing and FINRA Review Communications that include direct or indirect reference to registered investment products require filing with FINRA.

5 Registered investment products include: Mutual funds, variable annuities, variable life Insurance, In addition many communications regarding 529 plans require filing. FINRA's advertising regulation department will review the communications and provide comments based on FINRA rules and regulations. All FINRA revisions, if any, must be made, and the communications must be resubmitted to Advertising Compliance for final approval. Foresters Equity Services will file all applicable communications with FINRA on behalf of the representative. The filing fees are debited directly from the representatives commissions. FINRA charges $125 for the first 10 pages of material or the first 10 minutes of all videotapes or audiotapes and $10 for each additional page or minute. FINRA does have an expedited filing procedure that costs $600 for the first 10 pages or minutes and $25 for each additional page or minute. Communications that have been filed as expedited will be returned in three to five business days.

6 When preparing advertising and sales literature, it is important for Representatives to allow enough time for all the necessary steps of the approval process. Doing Business As Names / DBAs Compliance Approval of DBAs Foresters Equity Services representatives may wish to brand their business under a name other than Foresters Equity Services Inc. This company name is called a doing business as name or DBA. Certain states may restrict representatives' use of DBA names or require additional disclosure. January 2014 2. Titles Foresters Equity Services Financial Representative Titles Below is a list of appropriate Foresters Equity Services titles based on registration. These titles are only appropriate for use as Foresters Equities Services titles, and not doing business as (DBA) titles. If you use a DBA name and wish to use one of the registration based titles listed below, you must make it clear that the title is held with Foresters Equity Services Inc, not the DBA.

7 For example, if you have a DBA and wish to use Registered Representative as your title, it must say Foresters Equity Services Inc. Registered Representative . or Registered Representative, Foresters Equity Services Inc. Non-Registered Associates must include a title to clarify their role. The following titles may be used Administrative Associate/Assistant Operations Manager Marketing Associate Sales Associate/Assistant Client Services Associate/Assistant Registered Associates must include a title to clarify their role and to make it clear that they do not offer securities or financial advice. Registered Associates may use any of the above titles; or Registered Administrative Associate/Assistant*. Registered Sales Associate/Assistant*. Series 6 and Series 7 registered representatives who are not registered as administrative associates, may use any of the above titled or: Registered Representative*. Account Executive Investment Consultant**. Investment Planner**.

8 Investment Representative Investment Executive Financial Representative Financial Consultant**. Wealth Consultant**. Wealth Planner**. Wealth Manager**. Series 65 or 66 registered representatives who are also registered as Investment Advisor Representatives (IARs) with Foresters Equity Services may use any of the above titles or: Investment Advisor Representative*. Financial Planner*. Financial Advisor*. Wealth Advisor Series 24 registered representatives Registered Principal*. *These titles are based on registrations held with Foresters Equity Services Inc. It must be clear that the title is held through Foresters Equity Services Inc. This can be done by placing Foresters Equity Services' in front of the title. **The state of Washington requires that the registered representative is registered as an Investment Advisor Representative to use this title. January 2014 3. Stationery Requirements Stationery includes, but is not limited to the following: Letterhead Half sheets / Note Pads Business Cards / Digital Business Cards Email Signatures Envelopes (including Return Envelopes).

9 Fax Cover Sheets Note Cards Shipping labels Labels Masthead Stationery must contain the following: Applicable broker-dealer disclosure as indicated in the Registered office location Telephone number of registered office location Two-Sided Business Cards Place the address and contact information on the back of the card along with the broker dealer disclosure. Logo, name and title can remain on the front side of the card. Place the broker-dealer disclosure on the front of the card and move nonessential information such as website address, fax number, etc. to the back. Broker-Dealer Disclosure Representatives using Foresters Equity Services The broker-dealer disclosure must include, "Member FINRA/SIPC" Representatives using a DBA. The broker-dealer disclosure must include, "Securities offered through Foresters Equity Services Inc., Member FINRA/SIPC". Professional Designations FINRA Rule 2210 prohibits member firms and associates from referencing nonexistent or self-conferred degrees or designations; or referencing legitimate degrees or designations in a misleading manner.

10 The FINRA website provides context to designations, however it does not imply that FINRA endorses or approves the listed designations. (See | Investor information | Professional Designations). Novelty Items Although novelty items (such as pens, mouse pads, mugs, etc.) appear simple, the review of such items can pose some unique challenges. There are many types of novelty items, therefore the requirements may vary based on size, content and intended use. Generally, the use of a DBA or DBA logo on novelty items such as pens and pencils would not necessitate the inclusion of the broker-dealer disclosure. On many larger novelty items such as mugs and mouse pads, reps may wish to include a laundry list of the products and/or services they offer and/or their phone number. The inclusion of such information would trigger the need to add the broker-dealer disclosure. Requirements may be based on the size of the item. Arkansas Representatives The State of Arkansas requires that all insurance licensed representatives provide their insurance license number on business cards and other communications that promote insurance products, including variable annuities.