Phoenix Life Insurance CompanyInvestigative ConsumerReport AuthorizationIn compliance with provisions of federal and state law, this notice is to inform you that in connection with your requestto establish a relationship with Phoenix Life Insurance Company and any of its subsidiaries, an investigative consumerreport will be prepared. Typically, the report will contain information as to character, general reputation, personalcharacteristics, and mode of living; information which is obtained through an interview with you or an adult memberof your family, employees of business associates, financial sources, friends, neighbors, or others with whom you areacquainted. The information will consist, when applicable, of a confirmation of your identity, age, residence, maritalstatus, and past and present employment including occupational duties, financial information, driving record, sportsand recreational activities, health history, use of alcohol or drugs, if any, living conditions, and type of community.Upon written request, we will inform you of the address and telephone number of the investigative service to whomthe request was made. By contacting the office and providing proper identification, you may inspect or, for the properfee, receive a copy of such report.Specific authorization is hereby given to Phoenix Life Insurance Company and any of its subsidiaries to obtain aninvestigative consumer report on me, to contact any pertinent personal and business references and to verify myprevious employment and registration history. I release each person from any and all liability, of whatever nature, byreason of the furnishing of any of the above information. I specifically understand that this authorization, or a truephotocopy thereof, shall continue and may be used as long as I have a relationship with Phoenix LifeInsurance Company or their affiliates or subsidiaries, unless otherwise required by law. The undersignedapplicant hereby certifies that the applicant has received a copy of this notice and has read and understood itscontents.The investigative consumer report is prepared by:Business Information Group1105 Industrial HighwaySouthampton, PA 18966I further authorize Phoenix to obtain a Vector One report in connection with this contract application. Vector One is aservice that provides member insurance companies information about agent debit account balances. Phoenix maybecome a participant and subscriber to Vector One.I further authorize Phoenix or its duly authorized representatives to contact any organization or individual who hasknowledge of my employment history, credit history, financial status, or record of any criminal history to (a) obtain arecord of such history, status or activity and (b) hereby authorize the release of such information by such organizationor individual in connection with this application and (c) authorize Phoenix to release information about any debitbalance I may incur to Vector One, its successors, and/or any organization designated to replace Vector One. Theauthorization shall remain valid and effect during the term of any contract I may have with Phoenix.Applicant Name/Entity Name (Please print)Social Security Number/TINSignature of Applicant/Officer of EntityDateOL2448A5-12

Phoenix Life Insurance CompanyPO Box 8027Boston MA 02266-8027Application and Recommendation forContracting of Producers and CorporationsSection I - Demographic Information - Complete one form for each applicant (corporation, managing principal, and producer).Producer or Company NameProducer’s DOBSSN or TIN NumberDateProducer’s Home Address, City, State, ZIP CodeProducer’s Home Phone NumberBusiness Address, City, State, ZIP CodeBusiness Phone NumberFax NumberE-Mail AddressProducer’s Firm AffiliationSection II - Background Guidelines - Please ReviewOnce the Application and Recommendation for Contracting is received, a background investigation will be conducted on every producer and entityapplying for a producer agreement with Phoenix Life Insurance Company as required by state and federal law. You will not be eligible for a produceragreement with Phoenix if you do not meet our guidelines. You will need to resolve any outstanding items with the credit reporting agency or stateregulatory body prior to consideration. The guidelines are as follows:Financial Debt No credit report available Outstanding collection accounts, foreclosures, liens, or judgments exceeding 20,000, including commission chargebacks from an insurance company Pending or active bankruptcyCriminal Felony conviction (automatic decline) Misdemeanor convictions involving fraud, theft, or breach of trust (automatic decline) Other misdemeanor convictions within the last 10 years (reviewed case by case) Pending criminal chargesState Regulatory/FINRA State license revocation, suspension, fine, or sanction (reviewed case by case) Customer disputes, disciplinary and regulatory events resulting in fines, sanctions, or suspension (reviewed case by case)Other Background questions answers on the application do not match background report results “Yes” answers on the background questions and all explanations will be reviewedSection III - Your Background Information - COMPLETE THIS SECTION1. Have you ever had a state insurance license, state securities registration, or your FINRA registration denied, suspendedor revoked for any reason? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No2. Have you ever been fined or censured by a federal or state regulatory agency? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No3. Do you have any outstanding collection accounts, liens or judgments against you, totaling 20,000 or more?. . . . . . . . . . . . . . . . . Yes No4. Do you currently have an active or pending bankruptcy petition (voluntary or involuntary)? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No5. Have you (or, if a corporation, a principal of this company) ever been charged with, convicted, pled guilty, or pledno lo contendre (no contest) to a felony? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No6. Have you (or, if a corporation, a principal of this company) ever been charged with, convicted, pled guilty, or pledno lo contendre (no contest) to a misdemeanor other than a minor traffic violation or DUI ? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes No7. Are you now the subject of any complaint, investigation or proceeding that could result in a “yes” answer to questions 1-6? . . . . . Yes No8. Do you have any outstanding debt(s) with any Distributor, Insurance Company, or Broker/Dealer? . . . . . . . . . . . . . . . . . . . . . . . . . Yes No9. Has a life insurance company ever terminated your appointment or contract to sell its products for any reason other thanlack of production? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Yes NoPlease explain any “Yes” answers to the background information questions in Section III. Give specific details including dates,circumstances, and outcome on a separate sheet of paper. Ensure that this sheet is signed, dated, and returned with the application. Alsoinclude copies of any relevant documentation, such as release of debt, satisfaction of judgment or approved payment plan.Section IV - Taxpayer AcknowledgementsUnder penalties of perjury, I certify that: (1) The number shown on this form is my correct taxpayer identification number (or I am waiting for a numberto be issued to me), and (2)I am not subject to backup withholding because: (a) I am exempt from backup withholding, or (b) I have not been notifiedby the Internal Revenue Service (IRS) that I am subject to backup withholding as a result of a failure to report all interest or dividends, or (c) the IRShas notified me that I am no longer subject to backup withholdingSection V - SignatureThe answers provided to the questions in Section III and the statements in Section IV above are true to the best of my knowledge. I will promptlynotify Phoenix Life Insurance Company if any of the above information changes. Failure to answer truthfully can result in immediate termination.Name - Please PrintFB17SignatureDate Signed6-12

Phoenix Life Insurance CompanyPHL Variable Insurance CompanyBroker AgreementThis BROKER AGREEMENT (“Agreement”) is made and entered into as of the execution dateset forth below by and between PHOENIX LIFE INSURANCE COMPANY (“PLIC”), an insurancecompany organized and existing under the laws of the State of New York and PHL VARIABLEINSURANCE COMPANY (“PHLVIC”), an insurance company organized and existing under thelaws of the State of Connecticut, and the person or entity below designated as the Broker(“Broker”) conducting business through the person or entity designated on the compensationschedule designated as the Supervising General Agent (“SGA”).Recitals. WHEREAS, PLIC and PHLVIC (collectively, “Phoenix”) are insurance companies thatmay market, sell and administer life insurance, health insurance and annuity products;WHEREAS, Broker sells insurance products through, the “Supervising General Agent (“SGA”),and may personally sell insurance products, and perform various functions in connection withthe sale of insurance products through the SGA; WHEREAS, Broker wishes to sell certainPhoenix insurance and annuity products (“Phoenix Products”), and Phoenix wishes to authorizeBroker to offer and sell Phoenix Products and perform the functions with respect to the PhoenixProducts set forth in this Agreement. NOW THEREFORE, in consideration of the mutualcovenants and agreements set forth herein, the parties hereto agree as follows:Definitions. The following terms, when used in this Agreement, shall have the meanings setforth in this Article. Other terms may be defined throughout this Agreement. Definitions shall bedeemed to refer to the singular or plural, as the context requires.(1) “Applicable Law” means anylaw (including common law), order, ordinance, writ, statute, treaty, rule or regulation of a federal,state or local domestic, foreign or supranational governmental, regulatory or self-regulatoryauthority, agency, court, tribunal, commission or other governmental, regulatory or self-regulatoryentity and includes, but is not limited to, state insurance laws and regulations, the Gramm-LeachBliley Act and other federal and state consumer privacy laws and regulations, and the HealthInsurance Portability and Accountability Act of 1996 (“HIPAA”) and related federal regulations.(2) “Broker” means any Independent Producer or entity transacting business through the SGA.(3) “Business Day” means any day other than a Saturday, Sunday, federal legal holiday or otherholiday, as determined by Phoenix. (4) “Customer Information” means information in electronic,paper or any other form that Broker or its Representatives obtained, had access to or created inconnection with its obligations under this Agreement regarding individuals who applied for orpurchased Phoenix Products. Customer Information includes Nonpublic Personal Information,as defined below, and Protected Health Information, as defined below. Customer Informationmay also include, but is not limited to, information such as the individual’s name, address,telephone number, social security number, as well as the fact that the individual has applied for,is insured under, or had purchased a Phoenix product. Customer Information does not, however,include information that is (a) generally available in the public domain and is derived or receivedfrom such public sources by Broker (b) received, obtained, developed or created by the Brokerindependently from the performance of its obligations under this Agreement; (c) disclosed to theBroker by a third party, provided such disclosure was made to Broker without any violation of anindependent obligation of confidentiality or Applicable Law of which the Broker is aware. (5)“Marks” has the meaning ascribed to such term in the paragraph named “Trademarks”. (6)“Phoenix Products” means the Phoenix insurance products identified in the CompensationSchedule(s). (7) “Nonpublic Personal Information” means financial or health related informationby which a financial institution’s consumers and customers are individually identifiable, includingbut not limited to nonpublic personal information as defined by Title V of the Gramm-Leach-BlileyAct and regulations adopted pursuant to that Act. (8) “Parties” means Broker, SGA and Phoenix.(9) “Protected Health Information” or “PHI” refers to information related to individuals who haveapplied for, have purchased or are insured under Phoenix Products that are considered to behealth plans subject to HIPPA, such as Phoenix’s long-term care insurance policies and riders,for the purposes of this Agreement and, consistent with regulations issued pursuant to HIPAA.PHI is defined as individually identifiable information that is transmitted or maintained in anymedium and related to: the past, present or future physical or mental health or condition of anindividual; the provision of health care to an individual; or future payment for the provision ofhealth care to the individual. This definition of PHI includes demographic information about theindividual, including, but not limited to, names, geographic subdivisions smaller than a state(including but not limited to street addresses and ZIP codes); all elements of dates (except year)for dates directly related to an individual, including but not limited to birth date; telephone numbers;fax numbers; electronic mail (E-mail) addresses; Social Security numbers; medical recordnumbers; health plan beneficiary numbers; account numbers; certificate/license numbers; vehicleidentifiers and serial numbers, including license plate numbers; device identifiers and serialnumbers; Web Universal Resource Locators (URL’s); Internet Protocol (IP) address numbers;biometric identifiers; including finger and voice prints; full face photographic images and anycomparable images; and any other unique identifying number, characteristic, or code. (10)“Representative” means any officer, director, employee, affiliate, subsidiary, sub-producer, agentof a Party, and additionally, the Broker.OBLIGATIONS OF BROKERLicensing. Broker shall offer Phoenix Products only in those states where it has valid licenses(to the extent licensing is required) at the time of solicitation and sale, has completed legallyrequired educational requirements, if any, and is otherwise in good standing with each stateagency that regulates the sale of the Phoenix Products. Broker shall take reasonable steps toensure that Broker offers Phoenix Products only in each jurisdiction where Broker has all requiredOL4588licenses at the time of solicitation and sale, has completed legally required educationalrequirements, if any, and is otherwise in good standing with each state agency that regulates thesale of the Phoenix Products.Phoenix Materials. To the extent that Broker uses brochures, other promotional materials andliterature, and training material in connection with marketing or servicing Phoenix Products, orthat mention Phoenix, its products or services in any way (“Phoenix Materials”), such materialsshall only be used with the prior written approval of Phoenix. Similarly, Broker shall not use anyinformation related to Phoenix or Phoenix Products on any Website without the prior writtenconsent of Phoenix. Any requests for written approval of materials for use by Broker shall besubmitted in writing by the SGA to Phoenix.Disclosure of Relationship with Phoenix and Disclosure of Compensation. If and asrequired by Applicable Law, Broker must disclose in writing to each applicant for a PhoenixProduct, Broker’s relationship with Phoenix and the compensation, and anything of value, Brokerreceives from Phoenix for the services performed under this or any other Agreement. Phoenixreserves the right to disclose to its purchasers of Phoenix Products, and potential purchasers ofPhoenix products, details regarding compensation, and anything of value, it, and any Phoenixaffiliate, may pay to Broker, or any of their respective affiliates, under this Agreement and anyother agreement.Suitability. Broker shall insure that each sale of Phoenix Products covered by this Agreementwhich is proposed or made directly by the Broker is appropriate for and suitable to the needs ofthe insured and the person or entity to whom Broker made the sale, at the time the sale is made,and suitable in accordance with Applicable Law governing suitability of insurance products. Priorto presentation of an application for a Phoenix Product to an individual, Broker shall deliver tothe applicant any and all notices or other written documents required, either by Applicable Lawor by Phoenix, for delivery at or prior to the time of application, including, without limitation, anylegally and Phoenix required suitability forms and any legally-required shoppers' or buyers' guide.The knowledge of or consent to the sale by the insured or the person or entity to which the Brokermade the sale is not evidence of suitability.Replacement. Broker shall not engage in the systematic replacement of any insurance products,including the replacement of Phoenix Products. Consistent with Applicable Law, Broker shallmake necessary inquiries to each applicant for a Phoenix Product as to any insurance alreadyin effect for the applicant and, upon determination that a prospective sale involves the replacementof existing coverage, Broker shall furnish the applicant with and effect proper execution andretention of any replacement notices and information as required by Applicable Law.Marketing and Underwriting. Broker shall comply with all marketing and underwriting guidelinesof Phoenix applicable to the Phoenix Products. Broker acknowledges, that Phoenix will makeall underwriting decisions with respect to Phoenix Products.Transmission of Applications and Purchase Payments. Broker shall transmit promptly toPhoenix (and in no event later than five (5) Business Days of receipt by the Broker), all applicationsand any applicable initial purchase payments or premiums for Phoenix Products. Broker shallnot collect any payments other than initial purchase payments or premiums. Broker shall onlycollect payments in a form as directed by Phoenix.Premium Discounts and Rebating. Broker shall not discount premiums, except with the priorwritten approval from Phoenix, or engage in rebating in connection with the sale of a PhoenixProduct.Contract Delivery. Broker shall deliver newly issued contract to the contract owner in accordancewith Phoenix’s published guidelines. Broker shall have each contract owner and insured sign adelivery receipt (Policy Acceptance Form) consistent with Phoenix’s requirements.Ethical/Professional Behavior; Compliance. In the conduct of its business and in theperformance of its obligations under this Agreement, Broker shall comply with all Applicable Lawsand polices and procedures established by Phoenix, as may be amended from time to time andcommunicated to the SGA.Policyholder Complaint Handling. Upon receipt of any written or oral complaint from apolicyholder, Broker will immediately advise the SGA and Phoenix of the complaint. Broker agreesto fully cooperate with Phoenix in its investigation of the matter. This cooperation shall include,but not be limited to, responding to any requests for information, providing any needed statementsand supplying copies of files on the matter that is the subject of the complaint. Broker has noauthority to settle or resolve the comp