Common use of RESPONSIBILITY FOR SECURITIES ACTIVITIES Clause in Contracts

RESPONSIBILITY FOR SECURITIES ACTIVITIES. CUNA Brokerage shall assume full responsibility for the securities activities of all persons engaged directly or indirectly in the distribution operations for CMIS's variable annuity products, including but not limited to training, supervision, and control as contemplated under appropriate provisions of the 1934 Act and regulations thereunder and by the rules of FINRA. All persons directly or indirectly involved in such variable annuity securities activities shall be registered representatives or registered principals of CUNA Brokerage as appropriate to their activities. Also, each registered representative selling the product and at least one registered principal shall be properly licensed as an insurance agent of CMIS. Further, CUNA Brokerage represents and warrants that during the term of this Agreement, it will maintain and implement (a) policies and procedures designed to comply with all applicable rules of FINRA, including but not limited to rules relating to suitability of variable annuity recommendations, (b) a training program for its registered representatives designed to ensure that such persons gather information concerning a customer's financial status, tax status, investment objective and other relevant information prior to recommending the purchase or exchange of a variable annuity contract, and (c) a reasonable system of sales supervision designed to achieve compliance with the rules of FINRA. CUNA Brokerage agrees to provide a report to CMIS upon request, certifying that CUNA Brokerage is in compliance with items (a) through (c) above. Each such report shall be certified by a senior manager of CUNA Brokerage who has responsibility for items (a) through (c). CUNA Brokerage understands and acknowledges that CMIS may conduct an inspection and/or audit of CUNA Brokerage on a periodic basis to ensure compliance with items (a) through (c) above, and CUNA Brokerage agrees to make reasonable accommodation to CMIS to enable CMIS to inspect documents directly related to the sale and suitability of any CMIS variable annuity product, which documents CUNA Brokerage shall be responsible for maintaining.

RESPONSIBILITY FOR SECURITIES ACTIVITIES. CUNA Brokerage shall assume full responsibility for the securities activities of all persons engaged directly or indirectly in the distribution operations for CMIS's variable annuity universal life products, including but not limited to training, supervision, and control as contemplated under appropriate provisions of the 1934 Act and regulations thereunder and by the rules of FINRA. All persons directly or indirectly involved in such variable annuity universal life securities activities shall be registered representatives or registered principals of CUNA Brokerage as appropriate to their activities. Also, each registered representative selling the product and at least one registered principal shall be properly licensed as an insurance agent of CMIS. Further, CUNA Brokerage represents and warrants that during the term of this Agreement, it will maintain and implement (a) policies and procedures designed to comply with all applicable rules of FINRA, including but not limited to rules relating to suitability of variable annuity universal life recommendations, (b) a training program for its registered representatives designed to ensure that such persons gather information concerning a customer's financial status, tax status, investment objective and other relevant information prior to recommending the purchase or exchange of a variable annuity universal life contract, and (c) a reasonable system of sales supervision designed to achieve compliance with the rules of FINRA. CUNA Brokerage agrees to provide a report to CMIS upon request, certifying that CUNA Brokerage is in compliance with items (a) through (c) above. Each such report shall be certified by a senior manager of CUNA Brokerage who has responsibility for items (a) through (c). CUNA Brokerage understands and acknowledges that CMIS may conduct an inspection and/or audit of CUNA Brokerage on a periodic basis to ensure compliance with items (a) through (c) above, and CUNA Brokerage agrees to make reasonable accommodation to CMIS to enable CMIS to inspect documents directly related to the sale and suitability of any CMIS variable annuity universal life product, which documents CUNA Brokerage shall be responsible for maintaining.

RESPONSIBILITY FOR SECURITIES ACTIVITIES. CUNA Brokerage CBSI shall assume full responsibility for the securities activities of all persons engaged directly or indirectly in the distribution operations for CMIS's variable annuity productsthe Registered Annuity Products, including but not limited to training, supervision, and control as contemplated under appropriate provisions of the 1934 Act and regulations thereunder and by the rules of FINRA. All persons directly or indirectly involved in such variable annuity securities activities relating to the Registered Annuity Products shall be registered representatives or registered principals of CUNA Brokerage CBSI as appropriate to their activities. Also, each registered representative selling the product Registered Annuity Products and at least one registered principal shall be properly licensed as an insurance agent of CMISMLIC. Further, CUNA Brokerage CBSI represents and warrants that during the term of this Agreement, it will maintain and implement (a) policies and procedures designed to comply with all applicable rules of FINRA, including but not limited to rules relating to suitability of variable annuity recommendations, (b) a training program for its registered representatives designed to ensure that such persons gather information concerning a customer's financial status, tax status, investment objective and other relevant information prior to recommending the purchase or exchange of a variable an annuity contract, and (c) a reasonable system of sales supervision designed to achieve compliance with the rules of FINRA. CUNA Brokerage CBSI agrees to provide a report to CMIS MLIC upon request, certifying that CUNA Brokerage CBSI is in compliance with items (a) through (c) above. Each such report shall be certified by a senior manager of CUNA Brokerage CBSI who has responsibility for items (a) through (c). CUNA Brokerage CBSI understands and acknowledges that CMIS MLIC may conduct an inspection and/or audit of CUNA Brokerage CBSI on a periodic basis to ensure compliance with items (a) through (c) above, and CUNA Brokerage CBSI agrees to make reasonable accommodation to CMIS MLIC to enable CMIS MLIC to inspect documents directly related to the sale and suitability of any CMIS variable annuity productRegistered Annuity Product, which documents CUNA Brokerage CBSI shall be responsible for maintaining.