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IN THE UNITED STATES DISTRICT COURT <br />FOR THE DISTRICT OF CONNECTICUT <br />If you are the current or former trustee, sponsor, fiduciary, or administrator of an <br />employee pension plan covered by the Employee Retirement Income Security Act <br />("ERISA") subject to Internal Revenue Code sections 401(a) or 401(k), and for which ING <br />Life Insurance & Annuity Co. ("ILIAC") either serves or has served as a service provider <br />at any time between February 23, 2005 to February 7, 2013, pursuant to the terms of a <br />group variable annuity contract or group funding agreement, your plan may benefit from <br />this class action settlement. <br />The case is called Healthcare Strategies, Inc., et al. v. ING Life Insurance & Annuity Co. <br />No. 3:11-cv-00282 (WGY)(D.Conn ). A Court authorized this notice. This is not a solicitation <br />from a lawyer. <br />This Notice advises you of a settlement (the "Settlement") of a lawsuit against ILIAC. In the <br />lawsuit, Plaintiffs, Healthcare Strategies, Inc. ("HSI"), as the Plan Administrator of the <br />Healthcare Strategies, Inc. 401(k) Plan and the Healthcare Strategies, Inc. CBU 401(k) Plan, and <br />The DeRosa Corporation ("TDC"), as the Plan Administrator of The DeRosa Corporation 401K <br />PS Plan, claimed that ILIAC breached its fiduciary duties under ERISA and engaged in <br />prohibited transactions through "revenue sharing" arrangements with mutual fund companies. <br />The Defendant, ILIAC, denies that it engaged in any improper conduct and maintains that <br />"revenue sharing" is a legal and appropriate form of compensation received for its services. You <br />should read this entire Notice carefully because your legal rights, and the rights of your plan(s) <br />and plan participants and beneficiaries, may be affected whether you act or not. <br />Your rights and options, and the deadline for you to object if you are opposed to the Settlement, <br />are explained in this Notice. <br />120 <br />