PortfolioBuilder

Although ING DIRECT Investing carefully evaluates the portfolio recommendations generated by PortfolioBuilder based on customers' stated investing goals and risk tolerance, we make no representation regarding the likelihood or probability that any proposed investing plan will in fact achieve a particular investment goal. We are unable to predict or forecast market fluctuations or other uncertainties that may affect the value of any investment and is prohibited by law from making such predictions or projections. While PortfolioBuilder is designed to provide helpful investing guidance, as a self-directed investor, you must carefully consider the appropriateness of the proposed investments in light of your own personal financial circumstances, including cash flow needs, unusual tax circumstances, or other complex or subjective concerns. You are urged to use all available resources to educate yourself about investing in general, as well as the investments and the overall portfolio composition suggested by PortfolioBuilder. Additionally, market conditions and your personal financial circumstances may change - perhaps suddenly or maybe gradually over time. We do not undertake any updating of the "snap shot" guidance you receive from PortfolioBuilder. Monitoring and adjusting your ShareBuilder investing plan to suit changing circumstances is your responsibility, and it is recommended that you reassess any investing program on a regular basis to ensure that it remains consistent with your current financial resources and investment objectives.

Limitations of PortfolioBuilder: The portfolio recommendations generated by PortfolioBuilder consist entirely of exchange-traded funds (ETFs). In addition to the preceding link to ShareBuilder's ETF help topic, learn more about ETFs under the "Risks" section below. Unlike individual stocks, ETFs are not shares of a company, but rather are shares of a trust that holds baskets of different stocks. Based on historical performance of stock indices, we believe a portfolio comprised solely of ETFs can produce a reasonable investment return while limiting the portfolio's exposure to price fluctuations affecting individual stocks. ETFs do not, however, offer protection from price volatility in the event of market declines. We believe that a tradeoff in relying solely on ETFs as a strategy to achieve greater portfolio diversification at lower costs is the potential for lower returns in a strong market, compared to a portfolio with one or more well-chosen individual stocks. You must monitor the performance of your plan yourself and make any appropriate adjustments over time.

Risks: Although broad-based ETFs may prove to be less volatile than individual stocks, investing in ETFs still involves many of the same risks as investing in individual stocks. If the stock market declines, ETFs will decline in value too, and when you sell your ETF shares, they may be worth less than when you bought them. As with any investment in securities, ETFs focused on a particular sector of the economy will be subject to cyclical volatility and to specific positive and negative developments affecting that sector. Some ETFs may be particularly vulnerable to declines in the value of one or more individual stocks included within the ETF. Additionally, although the expenses charged by the companies that manage individual ETFs are generally lower than those charged by mutual fund managers, those expenses and market factors may cause individual ETFs to trade at values lower than the actual value of the underlying shares held in the ETF's trust. The trading price of ETFs could also decline in the event that market interest in ETFs declines or interest in particular ETFs declines. There are other risks associated with investments in ETFs that are described in the prospectuses offered for each ETF. We encourage you to click on the symbol for each individual ETF contained in your recommended portfolio in order to obtain and read its prospectus.

Methodology and Assumptions: PortfolioBuilder will first ask you to define your investing goal and respond to a number of questions designed to determine your investing risk profile. Next, PortfolioBuilder will ask you to determine your weekly or monthly investment amount. Based on these inputs, PortfolioBuilder recommends a portfolio of ETFs and the amount to be invested in each ETF. In general, these model portfolios represent blends of ETFs that balance risk and reward. PortfolioBuilder will select a portfolio with fewer ETF investments in response to a smaller investment amount in order to limit the impact of fees on overall returns, but the ETFs recommended in smaller model portfolios will tend to cover a broader market index to provide a measure of diversification. For larger investment amounts, PortfolioBuilder recommends a more diversified model portfolio that may include more targeted ETFs that focus on more narrowly defined stock or bond indices. ING DIRECT Investing and its technical research firm review the model portfolios approximately every quarter and make changes as it deems appropriate in response to market conditions. These changes only affect portfolio recommendations generated following subsequent uses of PortfolioBuilder, but do not affect existing investing plans or trigger automatic rebalancing.

Rates of Return Represent "Model Results" - The returns for the PortfolioBuilder portfolios do not represent results in an actual account(s) or actual trading strategies, but rather model calculations as described below. The modeled rates of return are just one factor to consider and should not form the sole basis for an investing decision or strategy. Past performance is not a guarantee of future results.

Each of the PortfolioBuilder portfolios is composed of several Exchange Traded Funds, or "ETFs". Each of the ETFs used in the portfolios mimics a commonly recognized market index, such as the "Dow Jones Industrial Average", the "S&P 500" index, the "Russell 2000 Midcap Index", etc. Each portfolio is designed by ShareBuilder Advisors, LLC to be appropriate for a specific risk tolerance range and stated periodic investment amount.

The rates of return for each portfolio are calculated using "total return" data for each of the underlying ETFs during the relevant period and taking into account the percentage allocation of each ETF within the portfolio. These returns are calculated at the end of each month using Bloomberg® Total Returns© . According to Bloomberg, Total Returns for each of the underlying ETFs are calculated, in part, as follows:

The total return earned over the holding period by reinvesting all realized dividends into the security. When the period is daily, dividends are reinvested on their ex-date. If there is no valid price on the ex-date, the dividends are reinvested on the first day with a valid price prior to the ex-date. When the period is non-daily, dividends are reinvested on the last day of the period that has a valid price.

Published return data for the portfolios is updated quarterly. Returns for quarterly, annual and year-to-date periods are calculated based on the monthly return data. Returns of one year or longer are annualized. In calculating the rates of return, we assume a single investment made at the beginning of the relevant period and does not take into account transaction fees or taxes.

ShareBuilder Advisors, LLC works with an outside consultant to review each of the portfolios quarterly to determine whether any adjustments to the ETF allocations within each portfolio are necessary based on the risk profile associated with the portfolio, market performance, and other factors. ShareBuilder does not update or rebalance customers’ existing portfolios following changes to the model portfolios, but the model portfolio rates of return calculations reflect such changes to the portfolios on the first of each month following changes to the portfolios.

Performance stated reflects any changes made to the model portfolios as of the date the change was made. Performance is not recalculated to reflect changes prior to the date they were actually made.

ETF Investors: You should carefully consider an exchange-traded fund’s investment objectives, risks, charges and expenses before investing. For this and other important information please review the fund’s prospectus, available from the fund sponsor or from our ETF prospectus page. Please read the prospectus carefully before investing. Learn more about the differences between mutual funds and ETFs.