Mutual Fund Revenue-Sharing Arrangements

ShareBuilder receives revenue sharing payments from mutual fund families and their distributor, based on the amount of these funds sold by ShareBuilder and/or held through ShareBuilder by its customers. These revenue sharing payments are in addition to the sales charges, 12b-1 fees and other fees and expenses paid by customers or the funds and disclosed in the fund's prospectus fee table. Revenue sharing payments give ShareBuilder a financial incentive to sell certain mutual funds, and therefore create a conflict of interest that you should consider in making your investment decisions regarding such funds.

Additionally, ShareBuilder’s clearing firm, Pershing, may receive servicing fees from funds that participate in its no-transaction fee mutual fund program, in lieu of clearing transaction charges assessed to ShareBuilder. ShareBuilder shares with Pershing in such fees for providing shareholder services. These fees may be considered revenue sharing and are a significant source of revenue for Pershing and ShareBuilder. These fees are paid in accordance with an asset-based formula.

You understand that ShareBuilder Securities Corporation is an indirect subsidiary of ING DIRECT and affiliate of ING Funds. You understand that, as to all of the shares of funds offered by ShareBuilder from ING Funds, ShareBuilder receives compensation for the services they provide to ING Funds, which compensation, in part, is based on the size of the assets in the ING mutual fund. Other affiliates of ShareBuilder may be compensated for providing services to ING Funds.

The amount of compensation that ShareBuilder receives varies depending on the mutual fund purchased and the particular share class purchased, as mutual funds (and share classes) are priced differently. For additional information and potential conflicts of interest arising from such activities and other activities of ShareBuilder affiliates, see the fund prospectus and corresponding statement of additional information for each fund. You should carefully review these materials and consult with your financial advisor if you have any questions.