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OPTING OUT OF THE SETTLEMENT 14. Can I exclude myself from the Class? You can exclude yourself from the Class and the Settlement. By excluding yourself, you give up your Plan's right to receive money from the Settlement. By opting out, you preserve your right to bring your own lawsuit against ILIAC. 15. How do I exclude myself from the Class? To exclude yourself from the Class, an authorized representative of the plan must submit a written request for exclusion that includes (a) your name and the name of your plan, (b) your address, (c) your telephone number, and (d) a signed statement that states "Uwe hereby request that I/we be excluded from the class in the Healthcare Strategies, Inc., et al. v. ING Life Insurance & Annuity Co. litigation." Requests for exclusion must be mailed separately to the Settlement Administrator and Lead Counsel at the addresses listed below, and must be received by no later than September 3, 2014. Please note that you are receiving this notice because you are a fiduciary of your plan. Accordingly, you have legal obligations under ERISA to act in the interest of the plan and its participants/beneficiaries. You may wish to consult with Lead Counsel or your own legal counsel before deciding to opt out of the Settlement. The exclusion request should be addressed as follows: Lead Counsel: Shepherd, Finkelman, Miller & Shah, LLP 65 Main Street Chester, CT 06412 Attn: James E. Miller or Laurie Rubinow Settlement Administrator: Strategic Claims Services Attn: ING ERISA Settlement P.O. Box 230 600 N. Jackson Street, Suite 3 Media, PA 19063 OBJECTING TO THE SETTLEMENT 16. What does it mean to object? Objecting is simply telling the Court that you do not like something about the Settlement. Objecting will not have any bearing on your right to receive the benefits of the Settlement if it is approved by the Court. 17. What is the procedure for objecting to the Settlement? Any Class member who wants to object to the Settlement must file an objection in writing. Your objection must be received on or before September 3, 2014, and must list your name and the name of your plan, address, and telephone number and, if applicable, the name, address, and telephone number of your attorney. Your objection must be accompanied by any supporting papers or briefs you intend to submit in support of your objection. Objections must be filed with the Court and mailed to Lead Counsel and Counsel for ILIAC at the addresses listed below. You may also 4 125