2024 Annual Advertising Notification

National Life Group’s (“NLG” or the “Company”) approved advertising is an important tool for you to use to help your clients and prospects understand NLG, National Life Insurance Company (“NLIC”), Life Insurance Company of the Southwest (“LSW”), and the products and services available. NLG is committed to providing advertising that is clear, consistent, and accurately discloses relevant information. Whatever advertising medium you use, the Advertising Guidance Team (“AGT”) within Life & Annuity Compliance is here to help guide you in creating and utilizing content that meets these standards.

Advertising requirements are set by state and federal regulatory authorities to protect consumers and, because of this, are under constant scrutiny. State regulations vary, and it is important to know what is required in the state(s) in which you are licensed to do business.  At least once a year, NLG is required by the regulations to notify all individuals who may create and use their own advertisements (instead of using NLG approved materials) of the regulatory requirements and procedures for AGT approval prior to using those materials.  Non-compliance with NLG procedures or any applicable laws or regulations may result in disciplinary action up to, and including:

• Training or re-training.
• Additional monitoring of your sales.
• Adjustment of your commissions or other compensation.
• Issuance of a verbal or written disciplinary warning to you.
• Assessing a monetary fine.
• Termination of your contract appointment with NLG, up to and including, termination for cause.

What Requires Advertising Compliance Approval? 

 How you determine what requires pre-approval from NLG Life & Annuity Compliance begins with if you are securities registered or not.  From there, it will depend on if what you have created meets the definition of advertising.  The sections below will help guide your decisions.

Agents Not Securities Registered – ALL channels:

If you decide to create your own content, prior approval from Life & Annuity Compliance is needed for the following:

1. Advertising mentioning NLG companies, products, or information specific to us (i.e. our critical injury or Alzheimer’s accelerated benefit riders (“ABRs”), ratings, features, history, images, logos, etc.).
2. Advertising used to sell retirement products in one of our K-12 403(b)/457(b) plans, even if NLG is not mentioned.
3. Advertising in which the intent is to specifically create interest in NLG products and features, even if NLG is not mentioned, such as a brochure on indexed universal life insurance that is not branded with NLG, but you only intend to sell an NLG product.

Registered Representatives (“RRs”) and/or Investment Adviser Representatives (“IARs”) of Equity Services, Inc. (“ESI”):

Financial services marketing, communications, training, or recruiting pieces you create or personalize requires the AGT’s prior review and written approval, even if it does not mention NLG.

Note: Materials solely about fixed life insurance products that do not mention ESI, or materials that do not mention or discuss anything listed in the above three points, do not require the AGT’s prior review and approval, although you may submit these materials for the AGT’s confirmation.

RRs of Other Broker/Dealers:

If you are registered with another broker/dealer, you will need to verify their requirements.  Follow the requirements for the non-securities registered agents provided above for your marketing and communications for NLG products and services.

Definition of Advertising

The definition of “advertising” by insurance and securities regulators is broader than most people believe.  For insurance regulators, advertising is any material designed to create public interest in life insurance, annuities, or an insurer (i.e., NLIC or LSW or any affiliated company),  or in you as an agent/Registered Representative (“RR”)/Investment Adviser Representative (“IAR”), or any material designed to induce the public to purchase, increase, modify, reinstate, borrow on, surrender, replace, or retain a policy.

If you are securities registered, “retail communications” are defined as any written (including electronic) communication that is distributed or made available to more than 25 retail investors within any 30 calendar-day period.

Both definitions of advertising materials may include, but are not limited to the following:

Agents Not Securities Registered – ALL channels:

1. Printed and published material, audiovisual material, descriptive literature of an insurer or insurance producer used in direct mail, newspapers, magazines, radio and television scripts, telemarketing scripts, billboards and similar displays, and the internet or any other mass communication media such as social media sites and email.
2. Descriptive literature and sales aids of all kinds authored by the insurer, its insurance producers, or third parties, issued, distributed or used by the insurer or insurance producer; including but not limited to circulars, leaflets, booklets, web pages, depictions, illustrations and form letters.
3. Material used for the recruitment, training, and education of an insurer’s insurance producers which is designed to be used or is used to induce the public to purchase, increase, modify, reinstate, borrow on, surrender, replace, or retain a policy.
4. Prepared sales talks, presentations, and materials for use by insurance producers.

Registered Representatives (“RRs”) and/or Investment Adviser Representatives (“IARs”) of Equity Services, Inc. (“ESI”):

1. Prepared sales talks and presentations, including seminars and live webinars, including invitations and online registration pages associated with the presentations.
2. Videos and recorded webinars.
3. Social media, such as LinkedIn (profiles and Company pages), Facebook Business, X (formerly known as Twitter), Instagram Business, YouTube, etc.:
   1. Static profiles/pages.
   2. Interactive content on those profiles/pages, such as likes, comments, posts, shares, etc.
   3. Podcasts that will be posted on social media sites or websites.
4. Print ads and other printed or published materials, including form letters and direct mail.
5. Business cards, email signatures, and letterhead.
6. Websites, website listings, or online presences of any type for an agency, individual, or Doing Business As (“DBA”) entity.
7. Newspaper, radio, television, computer, audio recordings, signs, and billboard ads.
8. Descriptive literature, including brochures, circulars, and leaflets.
9. Agent training materials:
   1. Including training that will be used with agents to instruct them on the companies or products of NLG, ESI, or on the sale of such products.
10. Telephone solicitations and sales scripts.
11. Fact finders, illustrations, and proposals.
12. Newsletters, press releases, articles, and reprints.
13. Emails:
    1. For unsolicited sales or recruiting – Additional guidance is located on the Agent Portal of the NLG website.

Special Types of Advertising

Social Media – RRs/IARs of ESI:

The following process applies if your business-related social media page is subject to compliance review:

• The only social media pages allowed for business purposes include LinkedIn (profile and Company), Facebook Business, Instagram Business, YouTube, and X.
• If you are planning to create a new page, please use our social media submission forms to submit the information you want to add to the profile for our review before publishing it. These submission forms can be found on the Agent Portal under Training>>Compliance>>Advertising/Social Media. Submit the social media submission form through AdTrax (or your agency, if they require you to do so), our online advertising submission and tracking system, found on the Agent Portal.
• For existing social media pages, submit the link to your page through AdTrax (or your agency, if they require you to do so).
• As required by securities regulations, after approval, you will be instructed to connect your business-related social media page to Hearsay, the Company’s monitoring and retention tool.

Social Media – Agents Not Securities Registered – ALL Channels & RRs with Other Broker/Dealers:

• As an agent who is not securities-registered, we do not need to approve your business-related social media page if you do not post NLG-created content (in other words, download or copy our content, or create new content mentioning NLG companies, then post it. Only affiliated agents with an NLG Compliance-approved business-related social media page are allowed to do this). If you are registered with another broker/dealer, you will need to verify their requirements.
• Sharing NLG-created content from our corporate social sites can be done without prior AGT review and approval of your business-related social media page, as long as you have not posted any content discussing NLG, our companies, products, or unique features, or your intention is not to sell retirement products in one of our K-12 403(b)/457(b) plans, even if NLG is not mentioned, or the intent is not to specifically create interest in NLG products and features, even if NLG is not mentioned. You can find content on our corporate social accounts and then click “share” on specific posts. Any caption or comment you include must be generic in nature.

Websites – RRs/IARs of ESI:

• RRs/IARs of ESI who would like a business-related website can choose between FMG and Broadridge, as Company-approved website providers.
• You can find information on both providers on the Agent Portal.
• Once you choose a provider and sign-up, new content and changes will come directly to AGT for prior approval through the website provider’s compliance tool. You do not need to submit anything else.

Websites – Agents Not Securities Registered – ALL Channels & RRs with Other Broker/Dealers:

• You may choose any website provider. If you are registered with another broker/dealer, you will need to verify their requirements.
• If there is no mention of NLG, its companies or products, or unique product features etc., then your website is not subject to the AGT’s review and prior approval.
• If you would like to add NLG content to your website, the entire website will need to be submitted to the AGT for review and approval prior to posting, through AdTrax.
• Once your site is reviewed and approved by AGT, you will be required to submit any additional changes to the site for AGT review and approval before the content can be published.

CoBrand OnDemand: 

Looking for a quick way to get your name on professional-looking marketing?  Check out NLG’s CoBrand OnDemand marketing system located on the Agent Portal.  This allows you to easily personalize flyers, ads, postcards, business cards, etc. for delivery to you in either print or email.  The pieces go straight to the AGT for review and prior approval – there is no need to create a separate submission. You will receive notification of the approval from both CoBrand and AdTrax.

For more information on the AGT’s review process, please refer to NLG’s Compliance Manual located on the Agent Portal.

For specific questions regarding what needs to be submitted, you may email AGT@nationallife.com or call (802) 229-3129.

How to Submit Advertising Material 

To submit materials for the AGT’s review, you must use AdTrax, our online advertising submission and tracking tool located on the Agent Portal. AdTrax training resources can be found on the Agent Portal, as well, under Training>>Compliance>>Advertising/Social Media.

Note (for affiliated agents): If your agency requires you to submit your advertising to them first, please do so and check with them before using AdTrax.

Tracking Control (TC) Numbers 

For most materials the AGT reviews, we assign a unique tracking control (“TC”) number to help identify the material and that it was approved.  An example would be TC1112345(1124)3.

The numbers in parentheses are the month and year the material was approved, and the final number represents how long the piece is approved for – 1 (one year) or 3 (three years). If there is no number at the end, it means the material is approved for a specific event date or single use. If you have any questions about material you submitted, please reach out to us – we are happy to help.

Resources Found on the Agent Portal Under Training > Compliance

• NLG Life & Annuity Compliance Manual 
• AdTrax link and training resources
• Guidelines for Creating Videos/Podcasts/Recordings
• List of Previously Approved and Unapproved Marketing Systems
• Social Media Policies and Resources:
  • Compliance and Advertising Policy on the use of Social Networking Sites for affiliated agents (not securities-registered) and RRs and IARs of ESI.
  • NLG’s Social Media Policy for independent agents (not securities-registered).
  • You can find links to our corporate social media sites on nationallife.com.

National Life Group® is a trade name of National Life Insurance Company, Montpelier, VT, Life Insurance Company of the Southwest, Addison, TX and their affiliates.  Each company of National Life Group is solely responsible for its own financial condition and contractual obligations.  Life Insurance Company of the Southwest is not an authorized insurer in New York and does not conduct insurance business in New York.

Equity Services, Inc., Member FINRA/SIPC, is a Broker/Dealer and Registered Investment Adviser affiliate of National Life Insurance Company. One National Life Drive, Montpelier, VT 05604.  (800) 344-7437.  In CO, MO, NH and WI, Equity Services, Inc. operates as Vermont Equity Services, Inc.