The Todd Organization
Disclosure Regarding Structure, Compensation, Product Selection and Role

The Todd Organization is a marketing name under which The Producer Group, LLC (“TPG”) operates. TPG is a firm comprised of independent sales agents (“Todd Producers”) across the United States who act as consultants that specialize in the design, implementation, administration, and financing of Non-Qualified Deferred Compensation and other Executive Benefit Plans (“NQ Plans”).

Each Todd Producer is also a licensed insurance agent of The Northwestern Mutual Life Insurance Company (“Northwestern Mutual”) and may also act as an appointed agent for certain other insurance companies. Additionally, each Todd Producer is a registered representative of Northwestern Mutual Investment Services, LLC (“NMIS”), a registered broker-dealer and member firm of the Financial Industry Regulatory Authority. Todd Producers offer and sell products from a number of third-party insurance companies and investment companies. Todd Producers, however, do not represent all insurance and investment companies nor do they necessarily offer to sell all products from each insurance and investment company that they represent.

When a Todd Producer interacts with a client, he or she is doing so as an executive benefit consultant of TPG when engaged in plan design and analysis; as a licensed insurance agent of Northwestern Mutual or appointed agent for other insurance companies when offering non-variable insurance products; and/or as a registered representative of NMIS when selling variable insurance or investment products. In such capacities, the Todd Producer is not acting in a fiduciary role with respect to any client.

Todd Producers do not provide, offer or receive compensation for legal, tax, accounting or investment advice. Todd Producers are compensated by commissions and fees. Commission and fee schedules vary by product, service, insurance and investment company. What and how a Todd Producer is compensated when a client purchases an insurance or investment product depends on the product and the insurance or investment company issuing the product. While the exact amount of compensation payable to a Todd Producer for any particular transaction may not be determinable until the arrangement is finalized, an estimate of such compensation can be provided to the client upon request.

Each Todd Producer is a party to a contract with The Newport Group, Inc. (“Newport”) under which Newport may provide certain analysis, design, marketing, and other support services (“Newport Services”) to a Todd Producer’s client. Newport will not necessarily provide Newport Services to each client of a Todd Producer. For any client receiving Newport Services which relate to a sale, the Todd Producer agrees to share with Newport a portion of any commissions derived from the sale of insurance or investment products to such client. Newport may also charge the client certain additional fees, not related to the purchase or sale of products, for the administration and/or servicing of NQ Plans.

Should there be any material change that affects the arrangements described herein, this disclosure statement will be amended accordingly. For additional information, please contact Mike Powers at powersm@toddorg.com.