www.investors-trust.

com

Electronic Plan documents prepared for:

Liliana Judith Bonilla

Plan Number: T15W035686

513253
www.investors-trust.com
Dear Liliana Judith Bonilla

Welcome to Investors Trust!

Your subscription in the amount of $3,600.00 to ITA International Trust has been accepted by ITA
International Financial Services Corp., as Trustee of ITA International Trust, for and on behalf and with respect to
the relevant Subaccount and applied to purchase policy T15W035686 from ITA International Insurer.

Enclosed with this letter, you will find the following:

1. Confirmation of Acceptance
2. Confirmation of Policy Issuance
3. Data Pages
4. Policy Terms and Conditions
5. Trust Agreement
6. Subscription Agreement

You may also view the information of your plan online by visiting our website at www.investors-trust.com. Simply go
to the Account Access page and follow the registration instructions in order to create your user name and password.
Our Secure Account Access website offers you the freedom of monitoring your account at all times, request online
transactions, review and make online payment, as well as update your contact or payment information. Please con-
tact your introducer if you require additional help registering to our website.

We appreciate your business!

Sincerely,
Investors Trust
 Confirmation of Acceptance

Plan Number:
T15W035686
Plan Participants’ Name: Plan Participants’ Date of Birth:
Liliana Judith Bonilla 18/06/1970

Premium: Issue Date:

$3,600.00 Annual, for the Premium Payment Term 24/03/2021
Product: Effective Date:
SPX15-X - S&P 500 15 Year Plan USD - Series III 24/03/2021
Product Sequence:
Base

The undersigned hereby confirms that the Subscription Agreement with the Plan Number previously defined has been
accepted “in Puerto Rico” by:

ITA International Financial Services Corp., as Trustee of ITA International Trust, for and on behalf of and with respect
to the relevant Subaccount

268 Ave. Ponce de León, Suite 1406, Hato Rey, San Juan,
Puerto Rico, 00918

By:
Jose Luis Pérez Machargo / Director

Date: 24/03/2021
 Confirmation of Policy Issuance

Plan Number:
T15W035686
Plan Participants’ Name: Plan Participants’ Date of Birth:
Liliana Judith Bonilla 18/06/1970

Premium: Issue Date:

$3,600.00 Annual, for the Premium Payment Term 24/03/2021
Product: Effective Date:
SPX15-X - S&P 500 15 Year Plan USD - Series III 24/03/2021

Product Sequence:
Base

The undersigned hereby confirms that the Policy has been issued “in Puerto Rico” by:

ITA International Insurer

268 Ave. Ponce de León, Suite 1406, Hato Rey, San Juan, Puerto Rico, 00918

By:
Jose Luis Pérez Machargo / Director

Date: 24/03/2021

ITA INTERNATIONAL INSURER, ORGANIZED UNDER CHAPTER 61 OF THE PUERTO RICO INSURANCE CODE. NO COVERAGE ISSUED BY THIS
INSURER IS PROTECTED BY ANY GUARANTEE OR INSOLVENCY FUND IN PUERTO RICO.
 Data Pages
Policy Number:
T15W035686

Plan Participant

Full Name: Nationality:

Liliana Judith Bonilla Ecuador

Date of Birth:
Female 18/06/1970

E-mail Address: Occupation:

lbonilla.lbc@gmail.com Telecommunications - Salesman

Address:
Residential Address - Mz 808, Sol #20 Metropolis#1 Pb Pascuales, -, Guayaquil, Guayas 090505 Ecuador

ID Expiration
Date:
Government ID 1711317220 Ecuador 09/11/2016 09/11/2026

Tax ID 1711317220001 Ecuador

Phone Numbers:
Mobile +593 9 97101430

Generated on: 24/03/2021

Printed on: 24/03/2021
513253 1
 Data Pages
Policy Number:
T15W035686

First Insured

Insured Name: Nationality:

Liliana Judith Bonilla Ecuador

Gender: Date of Birth:

Female 18/06/1970

E-mail Address: Occupation:

lbonilla.lbc@gmail.com Telecommunications - Salesman

Address:
Residential Address - Mz 808, Sol #20 Metropolis#1 Pb Pascuales, -, Guayaquil, Guayas 090505 Ecuador

ID Type: ID Number: ID Issuing Country: ID Issue ID Expiration

Date: Date:
Government ID 1711317220 Ecuador 09/11/2016 09/11/2026

Tax ID 1711317220001 Ecuador

Phone Numbers:
Mobile +593 9 97101430

Generated on: 24/03/2021

Printed on: 24/03/2021
513253

2
 Data Pages
Policy Number:
T15W035686

Beneficiaries
Type: Full Name: Percentage: Relationship: Date of Birth: Identification Number:

Beneficiary Cesar Jimenez Andrade 100.00% Spouse 01/09/1967 Government ID

0910178300
Contingent Ana Belen Jimenez Bonilla 50.00% Child 11/12/1995 Government ID
Beneficiary 0930872825
Contingent Cesar Jimenez Bonilla 50.00% Child 21/10/1994 Government ID
Beneficiary 0931543193

Generated on: 24/03/2021

Printed on: 24/03/2021 3
513253
 Data Pages
Policy Number:
T15W035686

Investment Details
Original Premium: $3,600.00 Issue Date: 24/03/2021

Premium: $3,600.00 Annual, for the Full Premium Payment Term Effective Date: 24/03/2021

Currency: USD Processing Date: 1st day of each monthaversary

Product: SPX15-X - S&P 500 15 Year Plan USD - Series III

Product Sequence: Base

Status: Inforce

Full Premium Payment Term: 15 years.

Initial Period: 24.48 Months

Issuer
ITA International Insurer, the Insurance Company.

Service Office
ITA International Financial Services Corp.
268 Ave. Ponce de León, Suite 1406
Hato Rey, San Juan
Puerto Rico, 00918
Tel: +1 (305) 603-1400
info@investors-trust.com

Segregated Asset Plan

ITA Protected Cell refers to the Segregated Asset Plan where the Assets underlying this Policy are allocated.

Policyowner
ITA International Trust acting as Policyowner on behalf of the unique Subaccount established in relation to the Plan Participants.

Guaranteed Value
This Product provides a guaranteed return of 140% of the sum of all Premiums paid at the end of the Full Premium Payment Term.

This guarantee includes Loyalty Bonuses. The underlying principal protection is derived from structured notes provided by highly rated financial
institutions. The Policyowner is facing issuer/counterparty risk of these institutions. An insolvency of these institutions could lead to a partial
or total loss of the capital invested by the principal participant. The Issuer reserves the right to select other highly rated financial institutions as
providers of the underlying principal protection.

All Premium payments due must have been received within the Grace Period, with no Premium decreases or partial surrenders, for the
guarantee to take effect.

Loyalty Bonus
The Issuer hereby agrees that it will pay a Loyalty Bonus on the said Policy as follows:

7.5% of the Premiums for years 1 through 10, credited at the end of year 10
7.5% of the Premiums for years 11 through 15, credited at the end of year 15

All Premium payments due must have been received within the Grace Period, with no Premium decreases or partial surrenders, for the Loyalty
Bonus to take effect.

All other terms and conditions of the Policy to which this bonus applies remain in full force and effect.

Generated on: 24/03/2021

Printed on: 24/03/2021
SPX15-X
version 10/2020 4
 Death Benefit
In the event of the relevant death, the standard amount payable will be 101% of the Account Value.

Surrenders
Minimum Partial Surrender:
$0.00
Minimum Cash Surrender Value, which must remain in the Policy after a partial surrender:
$2,400.00
Surrenders are only made on the Valuation Date for the affected Investment Account.

Charges and Fees

Policy Fee:
Monthly: $10
For as long as the Investment Account(s) remain(s) invested, the Policy Fee will continue to apply.

Structure Fee:
0.125% of Account Value per month.
For as long as the Investment Account(s) remain(s) invested, the Structure Fee will continue to apply.
This fee may also be referred to as the "Asset Management Fee".

Administration Charge:
1.7% per annum of total Premiums due from outset to the relevant Policy anniversary until the completion of the Full Premium Payment Term.
In case of a Premium decrease, the Administration Charge will continue to be deducted based on the Original Premium.

Surrender Charge:
Equal to the remaining Administration Charges that would have been deducted had Premiums been continued for the balance of the Full
Premium Payment Term.

Document Delivery Fee:

Upon issuance of the Policy the electronic documents are made available for download on the secure account access website free of charge.
The delivery of printed documents will result in a $50 fee.

Custodian
Assets are custodied by ITA International Financial Services Corp. and held in Brown Brothers Harriman & Co. and Bank of America Merrill
Lynch for the Segregated Asset Plan. Investments held in custody are segregated from bank liabilities.

Allocation Guidelines
1. Allocations must be in US Dollars.
2. Allocations are only made on a Valuation Date for the affected Investment Account.
3. When the Issuer cannot allocate Premiums to the selected Investment Account because such funds become available at a time when the
selected Investment Account was not accepting investments, the funds will be placed in the Issuer's general account pending allocation
to the selected Investment Account.

Valuation Dates
Prices are updated daily.

Investment Account Allocations

100.00% SPX - S&P 500 Index

Index Participation
Accounts will be credited with 100% participation in the S&P 500. Guaranteed participation rate is 90%.

Generated on: 24/03/2021

Printed on: 24/03/2021
SPX15-X
version 10/2020 5
 PART I // POLICY TERMS
www.investors-trust.com

AND CONDITIONS

T15W035686 - Liliana Judith Bonilla

version 10/2020
 Table Of Contents
SECTION I – DEFINITIONS SECTION VII - DEATH BENEFIT PROVISIONS
5 A. Insured
SECTION II – GENERAL PROVISIONS 5 B. Beneficiary
1 A. Important Dates 5 C. Change of Beneficiary
1 a. Issue Date 5 D. Death Benefit
1 b. Effective Date 5 E. Death Benefit Amount
1 c. Business Day 5 F. Due Proof of Death
1 d. Valuation Date 5 G. Minor Beneficiary
1 e. Processing Date 5 H. Payment of Death Benefits
1 B. The Entire Policy 5 I. Continuation of the Policy
1 C. The Segregated Assets Plan 5 J. Limitations
1 D. Claims of Creditors 5 K. Limits on Rights
1 E. Age 5 L. General
1 F. Non-Participating
1 G. Currency SECTION VIII – POLICY LOANS
1 H. Information and Reports 5 A. Loan Request
2 I. Notices and Instructions 5 B. Loan Interest
2 J. Taxes 5 C. Loan Repayments
2 K. Governing Law 5 D. Disbursement of Loans
2 L. Arbitration 5 E. Limits on Rights
2 M. Termination 5 F. General
2 N. Reinstatement
2 O. Proof of Entitlement SECTION IX – SURRENDERS
2 P. Severability 5 A. Surrender Request
2 Q. Non-Waiver 5 B. Full Surrender
2 R. Discretion 5 C. Partial Surrender
2 S. Amendments 6 D. Payment of Surrenders
2 T. Construction 6 E. Restrictions and Penalties
2 U. Electronic Record or Electronic Signature 6 F. Limits on Rights
2 V. Official Language Disclosure 6 G. General
2 W. Compliance
2 X. Outsourcing SECTION X – CHARGES AND FEES
3 Y. Representations and Warranties / Indemnity 6 A. Charges and Fees
6 B. Policy Fee
SECTION III - OWNERSHIP 6 C. Administration Charge
3 A. General 6 D. Asset Management Fee
3 B. Assignment of the Policy 6 E. Structure Fee
3 C. Death of the Policyowner(s) 6 F. Transfer Fee
6 G. Surrender Charge
SECTION IV – PREMIUMS 6 H. Bid/Offer Spread
3 A. Regular Premium Policy 6 I. Disbursement Fee
3 a. Premium 6 J. Collection Fee
3 b. Allocation to Initial Account 6 K. Document Delivery Fee
3 c. Grace Period 6 L. Other Charges and Fees
3 d. Nonpayment of Premiums during Initial Period 6 M. Inflation
3 e. Nonpayment of Premiums after Initial Period
3 f. Decrease of regular Premiums
3 g. Settlement Options
3 B. Single Premium Policy
3 a. Premium
3 b. Allocation to Initial Account
3 c. Policy Lapse
3 d. Settlement Options
3 C. Riders and Excess Premiums
3 a. Regular Premium Rider
3 b. Single Premium Rider
3 c. Excess Premiums
3 d. Limitations
3 D. Premium Payments
3 E. Bonuses, Extra Allocations and Guarantees

SECTION V - POLICY’S ACCOUNTS AND VALUES

4 A. Accounts
4 a. Investment Account
4 b. Account
4 c. Initial Account
4 d. Accumulation Account
4 e. Loan Account
4 B. Values
4 a. Account Value
4 b. Initial Account Value
4 c. Accumulation Account Value
4 d. Cash Surrender Value
4 e. Net Cash Surrender Value
4 f. Investment Account Value
4 g. Net Asset Value or “NAV”
4 h. Death Benefit
4 i. Net Death Benefit
4 C. Suspension and Deferral

SECTION VI – CHOICE OF INVESTMENT ACCOUNTS

4 A. Ownership of Investment Accounts
4 B. Choice of Investment Accounts
4 C. Initial Allocation of Premiums
4 D. Change of Investment Account
4 E. Future Allocation of Premiums
4 F. Liability
4 G. Limits on Rights
4 H. Investment Risk
4 I. General

T15W035686 - Liliana Judith Bonilla

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 SECTION I – DEFINITIONS
The following definitions shall apply to these Terms and Conditions:
Account – As defined in Section V of these Terms and Conditions.
Account Value – As defined in Section V of these Terms and Conditions.
Accumulation Account – As defined in Section V of these Terms and Conditions.
Accumulation Account Value – As defined in Section V of these Terms and Conditions.
Administration Charge – As defined in Section X of these Terms and Conditions.
Application – The questionnaire form to be completed prior to the issuance of the Policy by the
Company.
Assets – The assets to be made available for the Policyowner(s) to select and link to the Policy.
The Assets may include Funds, as well as other investments such as stocks, bonds, ETFs, and
structured notes.
Beneficiary – The person(s) or entity(ies) designated as such by the Policyowner.
Cash Surrender Value - As defined in Section V of these Terms and Conditions.
Charges – The charges imposed by the Company detailed herein and as identified on the Data
Pages.
Company – ITA International Insurer.
Data Pages – The schedule first issued with the Policy and any revised schedule issued due to any
modification of the terms of the Policy. The Data Pages set forth the details specific to the Policy.
Death Benefit – As defined in Section V of these Terms and Conditions.
Debt – Any outstanding Loan plus accrued Loan interest.
Electronic – relating to technology having electrical, digital, magnetic, wireless, optical,
electromagnetic or similar capabilities.
Electronic Record – a Record created, generated, sent, communicated, received or stored by
Electronic means.
Electronic Signature – an Electronic sound, symbol or process attached to or logically associated
with a Record and executed or adopted by a Person with the intent to sign the Record.
Fees – The fees deducted by the Company as identified on the Data Pages.
Full Premium Payment Term – The number of years selected by the Policyowner over which
Premiums for a Regular Premium Policy are to be paid as set forth in the Data Pages.
Fund – A Fund may be an external fund managed by a third-party asset manager or an internal fund
managed by the Company or an affiliate.
Grace Period – As defined in Section IV of these Terms and Conditions.
Information Processing System – an Electronic system for creating, generating, sending, receiving,
storing, displaying or processing information.
Initial Account – As defined in Section V of these Terms and Conditions.
Initial Account Value – As defined in Section V of these Terms and Conditions.
Initial Amount – The percentage of the initial Premium shown on the Data Pages which is used to
determine the portion of the Premium applied to any applicable Administration Charge.
Initial Period – The period of time shown (beginning on the Effective Date) on the Data Pages which
is used to determine which Premiums are used to pay for any applicable Administration Charge.
Insured – The individual(s) so named on the Data Pages upon whose death(s) the Company will
provide the Net Death Benefit to the Beneficiary(ies) according to the terms of this Policy.
Introducer – A Person authorized by the Company to engage in the introduction and distribution
of the Products.
Investment Account – As defined in Section V of these Terms and Conditions.
Jurisdiction – Puerto Rico.
Loan – An amount which is borrowed from the Company using this Policy as collateral.
Loan Request – As defined in Section VIII of these Terms and Conditions.
Minimum Cash Surrender Value – The minimum cash surrender value established by the Company
as identified on the Data Pages.
Minimum Partial Surrender – The minimum partial surrender established by the Company as
identified on the Data Pages.
Net Asset Value or “NAV” – As defined in Section V of these Terms and Conditions.
Net Cash Surrender Value – As defined in Section V of these Terms and Conditions.
Original Premium – The first Premium due as set forth in the Data Pages.
Paid Up – The status of a Policy under which no additional Premium payments are due.
Person – means a legal person, including, without limitation, any individual, corporation, estate,
partnership, joint venture, association, joint stock company, limited liability company, trust,
unincorporated association, protected cell company or protected cell thereof, segregated portfolio
company or segregated portfolio thereof, or government or any agency or political subdivision
thereof, or any other entity of whatever nature.
Policy – means the policy identified in the Data Pages.
Policyowner – The Person(s) identified on the Data Pages entitled to all the ownership rights under
this Policy. If Joint Policyowners are named, all references to Policyowner shall include the Joint
Policyowners. As applicable, the term Policyowner shall also include any Person(s) duly authorized
in writing to represent and/or act on behalf of the Person(s) entitled to the ownership rights under
this Policy.
Policy Term – The length of time of a Single Premium Policy as set forth in the Data Pages.
Policy Year – One year beginning from the Issue Date and from each Policy anniversary.
Premium – The premium paid/payable by the Policyowner or on behalf of the Policyowner for the
Policy.
Product – The insurance product selected by the Policyowner before the issuance of the Policy as
set forth in the Data Pages.
Record – Information that is inscribed on a tangible medium or that is stored in an Electronic or
other medium and is retrievable in perceivable form.
Regular Premium Policy – A Policy that requires regular Premium payments over time.
Segregated Assets Plan – As defined in Section II of these Terms and Conditions.
Signed – The term “signed” includes an Electronic Signature where such Electronic Signature is
T15W035686 - Liliana Judith Bonilla
1
version 10/2020
made available by the Company, as well as a wet signature.
Single Premium Policy – A Policy effected by a single Premium payment.
Surrender Charges – As defined in Section X of these Terms and Conditions.
Surrender Request – As defined in Section IX of these Terms and Conditions.
UBO – The Ultimate Beneficial Owner refers to the natural person(s) who ultimately own(s) or
control(s) a Person, other than an individual, and/or the natural person(s) on whose behalf a
transaction is being conducted.
Website – The Company’s secure account access website accessible to the Policyowner(s).
SECTION II – GENERAL PROVISIONS
A. Important Dates
a. Issue Date
The date that the Policy is issued by the Company.
b. Effective Date
The date when coverage under the Policy commences and the date used to determine the
Policy’s Account Values, Death Benefit and any Charges and Fees. The Effective Date may
differ from the Issue Date.
c. Business Day
A Business Day is any day (excluding Saturdays and Sundays) that banks are open for the
conduct of business in the Jurisdiction.
d. Valuation Date
A Business Day on which an Investment Account may be valued. If the Company is unable to
value or determine the value of an Investment Account on any particular Business Day, the
Valuation Date shall be the first Business Day thereafter when the value of such Investment
Account can be valued or determined. When only a portion of the Investment Accounts linked
to the Policy can be determined on any particular Business Day, the Company may, in its
discretion, process the transaction only with respect to that portion of the Policy. The remainder
of the transaction will be processed on the first Business Day thereafter when such value can
be determined. The Company may, in its discretion, use an estimated value to complete the
transaction. When a correct value is determined, an appropriate adjustment will be made to
reflect the correction from the estimated value to the correct value.
e. Processing Date
The day when Charges and Fees shall be deducted from the Policy. The Processing Date is
listed on the Data Pages.
B. The Entire Policy
The Policy is a contract between the Policyowner and the Company. The entire Policy consists of:
1. This Policy Terms and Conditions;
2. The Data Pages; and
3. Any riders or endorsements attached, or to be attached at any time in the future, to this
Policy.
This Policy may be changed or altered only by a Director, Vice President or Secretary of the
Company. A change or alteration must be made in writing. This Policy may be modified by the
Company without prior consent of the Policyowner in order to maintain compliance with applicable
laws of the Jurisdiction or laws of any other jurisdiction where such laws may have a bearing on
this Policy.
Upon issuance of the Policy, the Policy documents will be made available to the Policyowner for
download from the Website. If the Policyowner requests a printed copy of the Policy documents
from the Company, the Company may, in its sole discretion, accept or reject the request. Delivery
of a printed copy is subject to a Document Delivery Fee.
C. The Segregated Assets Plan
The Company has established one or more segregated assets plans, also referred to as Protected
Cells, in accordance with the laws of the Jurisdiction. With respect to the Policy, Premiums and
other Assets underlying this Policy are allocated to a Segregated Assets Plan separate from the
assets allocated to the Company’s general account or any other segregated assets plan. The
name of the Segregated Assets Plan from which the Policy has been issued shall be displayed on
the Data Pages. Assets allocated to the Segregated Assets Plan are not chargeable with liabilities
arising out of any other business the Company conducts. Any claim under the Policy shall be met
only from the assets of such Segregated Assets Plan and specifically no claim under the Policy
shall have recourse against any assets of the Company comprised in any other segregated assets
plan other than that named in the Data Pages or the general assets of the Company. The Assets of
the Segregated Assets Plan are the property of the Company.
D.Claims of Creditors
To the extent permitted by law, neither the Policy, nor any benefits claimed thereunder, shall be
subject to the claims of the creditors of any Policyowner.
E. Age
Issue Age: The Insured’s age on his or her last birthday as of the Effective Date.
Attained Age: The Insured’s Issue Age plus the number of full years elapsed since the Effective
Date.
F. Non-Participating
The Policy is non-participating and will not share in the Company’s profits or surplus earnings. The
Company will not pay dividends on the Policy.
G. Currency
Transactions between the Policyowner and the Company will be made in either Dollars of the United
States of America, Euros, or British Pounds Sterling in accordance with the selection detailed on
the Data Pages, or as otherwise agreed to in writing by the parties. If the currency of the Policy is
replaced by another currency, the currency of the Policy will become that other currency and the
Policy will continue. If the currency of the Policy is abandoned, the currency of the Policy shall, at
the discretion of the Company, be converted to a currency equivalent to the abandoned currency.
H. Information and Reports
The Company will make available to the Policyowner in its Website, information regarding the
Policy, including the Account Value, Premium payments, amount of Debt and any other information
as may be made available from time to time by the Company. At least once a year the Company
will make available for download from the Website a report including the annual basic information
of the Policy and its annual activity for the previous year. If requested in writing, the Company will
generate and make available for download by the Policyowner, no more than once per year, an
additional copy of the report.
It is the Policyowner’s responsibility to review the information on the Website regarding the Policy
to take such action as may be necessary relating to the Policy and/or the Policyowner’s relationship
with the Company.
Any requirement for the Company to communicate with or notify the Policyowner will be considered
fulfilled by the Company when such communication or notification is: (i) made available to the
Policyowner on the Website or (ii) sent either by mail or e-mail to at least one Policyowner. It is the
continuing responsibility of the Policyowner to ensure that his/her/its contact information provided
to the Company is current. If is the contact information is not kept current, the Company shall be
deemed to have satisfied any notice requirements if such notice (including any reports or other
communications) is delivered to the Policyowner’s last known mailing address or e-mail address,
by so doing, the Company will be deemed to have properly notified the Policyowner or other party
for whom the communication was intended.
I. Notices and Instructions
To be effective, all notices and instructions provided by the Policyowner must be in writing, signed
by the Policyowner and received by the Company. If a Policy has more than one Policyowner, then
the Company, in its sole discretion, shall decide which notices and instructions, to be effective,
must be signed by all Policyowners and which notices and instructions may be signed by any one
of the Policyowners.
Unless otherwise provided, all notices, requests, and elections will be effective when received
by the Company, complete with all necessary information and properly signed, certified or
acknowledged, as required.
The Company may request the Policyowner to confirm any instruction, but may act upon
instructions which the Company reasonably believes are valid. The Company reserves the right
not to act upon any instructions until it has received confirmation from the Policyowner, although
lack of any such confirmation will not invalidate any instructions the Company has already acted
upon. The Company shall not be required to act upon any instructions where it reasonably believes
such action may involve an act of fraud or a breach of law, rule or regulation.
The Company will not be held responsible for any loss, damage, fraud or misappropriation arising
as a result of any error or breakdown in transmission, misunderstandings, errors by the Company
or its employees, agents, contractors, directors regarding the identity of the person or persons
giving instructions by fax, electronic mail or other means. The Policyowner agrees to indemnify the
Company and hold it harmless against all losses, damages, liabilities, actions, proceedings, claims,
costs and expenses, including but not limited to, legal expenses arising from or in connection with
the Company acting or failing to act on instructions given by the Policyowner.
The Company may, in its sole discretion, make available alternative methods for the Policyowner
to provide instructions to the Company, including a Website to provide certain instructions or to
execute certain actions using an Information Processing System.
J. Taxes
Any taxes or duties paid to any governmental entity relating to the Policy will be deducted from
Premiums contributed towards the Policy or the Policy’s Account Value when incurred. The
Company may, in its sole discretion, determine when taxes or duties have resulted from the
issuance or existence of the Policy or receipt by the Company of Premiums. The Company may,
in its sole discretion, pay taxes or duties when due and deduct such amounts from Premiums
contributed towards the Policy or the Policy’s Account Value at a later date. Payment at an earlier
date does not waive any right the Company may have to deduct amounts at a later date.
K. Governing Law
The laws of the Jurisdiction will govern the Policy, except as otherwise stated or agreed to by the
Company and the Policyowner with respect to compliance with the laws of another applicable
jurisdiction. The Jurisdiction’s law may require the Company to report certain information about
the Policy and the Persons related to the Policy to the authorities in the Jurisdiction or other
jurisdictions.
L. Arbitration
All claims and disputes arising under or relating to this Policy are to be settled by binding arbitration
in the Jurisdiction or another location mutually agreeable to the parties. The arbitration shall be
conducted on a confidential basis pursuant to the Commercial Arbitration Rules of the American
Arbitration Association. Any decision or award as a result of any such arbitration proceeding shall
be in writing and shall include the assessment of costs, expenses, and reasonable attorneys' fees
to the prevailing party. Any such arbitration shall be conducted by an arbitrator experienced in
matters relating to insurance policies and insurance contracts issued through entities established
under the purview of Law Number 273 of September 25, 2012 pursuant to 7 Laws of Puerto
Rico Annotated section 3091(12) (7 L.P.R.A. §3091(12)) and shall include a written record of the
arbitration hearing. The parties reserve the right to object to any individual who shall be employed
by or affiliated with a competing organization or entity. An award of arbitration may be confirmed in
a court of competent jurisdiction.
M. Termination
The Company may, at its sole discretion, terminate the Policy when any of the following occurs:
1. The Policyowner fails to make any required Premium payment;
2. The Policyowner surrenders the Policy in full;
3. The Insured dies;
4. The total Debt equals or exceeds 90% of the Cash Surrender Value of the Policy and a
sufficient Premium payment or repayment of a Loan is not made within the Grace Period;
5. The Cash Surrender Value is insufficient to pay any applicable Charges and Fees, and a
sufficient Premium payment or repayment of a Loan is not made within the Grace Period;
6. The Policy lapses;
7. The Company in its discretion determines that the Policy, any Person associated therewith
or any monies received in connection therewith conflict or contravene any portion of these
Terms and Conditions or any applicable law or regulations; or
8. The Company in its discretion determines that there has been a material omission from, or
misstatement of fact on, or in connection with the Application for the Policy, including, but
not limited to, with respect to the existence or status of a medical condition or any treatment
received.
Upon the occurrence of one or more of the above termination events, and in compliance with these
Terms and Conditions, the Company’s liability under the Policy will cease, no further Premiums will
be accepted and no further benefits shall be paid with respect to the Policy.
N. Reinstatement
Unless surrendered in full, the Company may, at its sole discretion, reinstate the Policy and any
attached riders, within two (2) years after the date of termination and while the Insured is alive,
subject to the payment of past due Premiums and Charges and Fees.
O. Proof of Entitlement
Prior to any payment or acknowledgement or action by the Company, the Company must be
T15W035686 - Liliana Judith Bonilla
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version 10/2020
satisfied that the Person(s) making a claim or request has the right to do so. The Company requires
reasonable proof and the Policyowner may have to produce the Policy documents.
P. Severability
Each provision of the Policy, including these Terms and Conditions, shall be considered severable
and if, for any reason, any provision of the Policy is held to be invalid or unenforceable to any
extent, this will not affect the validity or enforceability of any other provision of the Policy. Upon
any such determination of invalidity, the Company may modify the Policy so as to give effect to
its original intent as closely as possible in order that the transactions contemplated hereby are
consummated, to the greatest extent possible, as originally intended.
Q. Non-Waiver
The failure of the Company to seek redress for default of or to insist upon the strict performance
of any covenant or condition of the Policy, including these Terms and Conditions, shall not prevent
a subsequent act, which would have originally constituted a default, from having the effect of an
original default.
R. Discretion
Whenever under or in connection with these Terms and Conditions, the Company is permitted or
required to make a decision (a) at its “sole discretion,” “sole and absolute discretion,” “full discretion”
or “discretion,” or under a similar grant of authority, such as “reserves the right,” the Company shall
be entitled to consider only such interests and factors as it desires, and may consider its own
interests, and shall have no duty or obligation to give any consideration to any interests of or
factors affecting the Company or the Policyowner, or (b) in its “good faith” or under another express
standard, the Company shall act under such express standard and shall not be subject to any other
or different standards that may be imposed by these Terms and Conditions or by law or any other
agreement contemplated herein.
S. Amendments
All rights granted to the Policyowner under the Policy are granted subject to the reservation of
the right to amend these Terms and Conditions as herein provided, except that no amendment
shall (a) affect the limitations on personal liability of a Policyowner without the express written
consent of such Person, or (b) affect the limitations on personal liability or any other rights, benefits,
protections, privileges, duties, or immunities of the Company without the express written consent of
such Person in its individual capacity. Subject to the foregoing, the provisions of these Terms and
Conditions (whether or not related to the rights of the Policyowner) may be amended at any time,
so long as such amendment does not materially adversely affect the rights of any Policyowner with
respect to which such amendment is or purports to be applicable (unless each such Policyowner
consents to such amendment in writing), and so long as such amendment is not in contravention
of applicable law and is evidenced by an instrument in writing signed by the Company. Subject to
the foregoing, to the fullest extent permitted by law, any such amendment shall be effective as of
any past or future time as provided in the instrument containing the terms of such amendment.
T. Construction
Whenever the singular number is used in these Terms and Conditions and when required by the
context, the same shall include the plural and vice versa, and the masculine gender shall include
the feminine and neuter genders and vice versa.
The headings of these Policy Terms and Conditions are for convenience purposes only and shall
not be used in interpreting the Policy. If any provision of these Policy Terms and Conditions conflicts
with the Product brochure or any other document, the provision of the Policy Terms and Conditions
shall control.
U. Electronic Record or Electronic Signature
For purposes of the Policy: (i) an Electronic Record or Electronic Signature is attributable to a
Person if it was the act of or on behalf of the Person, and such act may be shown in any manner,
including a showing of the efficacy of any security procedure applied to determine the Person to
which the Electronic Record or Electronic Signature was attributable; and (ii) an Electronic Record
is received by a Person only when: (A) it enters an Information Processing System that such
Person previously has designated in a writing to the sender for the purpose of receiving from such
sender Electronic Records of the type received and from which such Person is able to retrieve
the Electronic Record; (B) it is in a form capable of being processed by that system; and (C) a
responsible officer of such Person has actual knowledge of its receipt. Receipt of an Electronic
acknowledgment from an Information Processing System by itself does not establish that a Record
was received and does not establish that the content sent corresponds to the content received.
Reference in this document to “in writing” or “written” includes an Electronic Record.
V. Official Language Disclosure
The Company has designated English as the official language for all aspects of its relationships
and communications. All agreements, documents, notices, disclosures and other forms of
communications shall be written, interpreted and applied in English, whether delivered in hard copy
or electronic form. Notwithstanding the preparation or provision of any translation by the Company
or otherwise, the English language version of such document shall control for all purposes of
application, interpretation, or construction.
W. Compliance
Any notice, instruction or transaction (including all incoming or outgoing payments received or
executed by the Company) related to the Policy, as well as any Person related to the Policy
(including the UBO), must comply with the applicable laws, regulations or other requirements of
the Jurisdiction relating to anti-money laundering or the use of proceeds of crime; and any laws,
regulations or requirements of similar import; as well as the Company’s policies and procedures
relating to anti-money laundering, “know your customer” and others of similar import.
At all times while the Policy is in effect, the Company, if it deems, in its sole discretion, necessary
to do so, may, at any time, request additional information (including supporting documentation)
related to any notice, instruction or transaction (including all incoming or outgoing payments
executed or received by the Company) related to the Policy as well as any Person related to the
Policy (including the UBO).
The Company reserves the right to reject any notice, instruction or transaction that it deems, in
its discretion, to be non-compliant hereunder. Non-compliant transactions or Persons related in
any way to the Policy, may result in the termination or in the suspension of the Policy. In case of
suspension the Company will cease, reject or block certain activities or transactions related to
the Policy until such time when the Company determines the cause of the suspension has been
corrected.
X. Outsourcing
The Company reserves the right to engage service providers (the “Provider(s)”) to procure different
services required to support its business. These services may include but are not limited to the
following areas: accounting, audit, administration, operations, finance, information technology,
marketing and distribution. At any point in time a range of providers may be working for the
Company and the Company may from time to time engage new ones or disengage existing ones.
The Providers may be Persons affiliated with the Company or third parties with no affiliation with
the Company. Depending on the service to be provided by each Provider, they may require access
to sensitive information related to the Policy, the Policyowner, the Insured, the Beneficiaries or
any other information gathered by the Company according to these Terms and Conditions (the
“Information”). Any Information shared with any Provider will be treated as confidential by the
Provider and will be shared with the sole purpose of allowing the Provider to complete the assigned
task.
The Policyowner acknowledges and agrees that the Introducer(s) related to the Policy will, as
limited by the Company, in its sole discretion, be granted access to Information and will have
the ability to request additional information, transmit instructions and requests on behalf of the
Policyowner and execute certain actions in connection with the Policy.
The Policyowner agrees that the Company will not be held responsible for any loss or damage
arising from the sharing of Information hereunder.
Y. Representations and Warranties / Indemnity
The Policyowner is required to provide accurate information and valid representations and
warranties to the Company in connection with the Policy, howsoever provided, including the
Application, any additional forms and the contents of any personal or medical questionnaire
(together “Representations and Warranties”). Any inaccuracy of such information provided to
the Company as the issuer of the Policy and potentially to reinsurers thereof, may result in the
invalidity of the Policy and the loss of all Premiums paid in relation thereto. It is the Policyowner’s
responsibility to inform the Company of any change in any matter that forms the subject of any of
the Representations & Warranties.
The Policyowner agrees to indemnify and hold the Company harmless against all losses, damages,
liabilities, actions, proceedings, claims, costs and expenses including but not limited to legal
expenses on a full indemnity basis occasioned by any inaccuracy in any of the Representations
and Warranties or failure to advise the Company of any change in any matter that forms the subject
of any of the Representation and Warranties.
SECTION III - OWNERSHIP
A. General
The Policyowner(s) is/are the Person(s) that owns the Policy and named on the Data Pages,
unless changed, and has/have all the ownership interests and rights under the Policy. A Person
shall be issued a Policy and shall become bound by these Terms and Conditions, if such Person
(or a representative authorized in writing by such Person) executes and delivers (or takes action
that is deemed to constitute execution and delivery of) an Application that is accepted by the
Company. For all purposes of the Policy, any Electronic Signature by the Company, a Policyowner
or Introducer shall be deemed to constitute such Person’s acceptance and execution.
B. Assignment of the Policy
No entitlement under or interest in the Policy shall be transferred or assigned, in whole or in part,
except with the written approval of or on behalf of the Company. The ownership interest in the
Policy may be assigned from one Person to another by written request of the current Policyowner
to the Company. The change will take effect on the later of: (1) the date on which the request is
processed by the Company; or (2) the date requested by the Policyowner. The Policy may only be
assigned during the lifetime of the Insured. No assignment or other change to the Policy will be
binding on the Company unless it is written in a form acceptable to the Company, received by the
Company and approved by the Company. The transferee must be approved by the Company as a
Policyowner and must agree in writing to be bound by these Terms and Conditions. The Company
will not be liable for any payments made or actions the Company takes before the assignment is
accepted by the Company. The Company will not be responsible for the validity of an assignment.
Any transfer of a Policy, in whole or in part, other than in accordance with the foregoing, shall be
ineffective.
For purposes of this Section, an approval of or on behalf of the Policyowner (i) that is in the form of
an e-mail, that is sent by or on behalf of the Policyowner and is actually received by the Company
at an e-mail address of the Company previously provided by the Company to the Policyowner,
and of which a responsible officer of the Company has actual knowledge, or (ii) that is in the form
of an Electronic Record which the Company previously has consented in writing to receive, and
that is sent by or on behalf of the Policyowner and is actually received by the Company, shall be
deemed to be a written approval of or on behalf of the Policyowner delivered to the Company, and
an agreement of the transferee (iii) that is in the form of an e-mail, that is sent by the transferee
and is actually received by the Company at an e-mail address of the Company previously provided
by the Company to the transferee, and of which a responsible officer of the Company has actual
knowledge, or (iv) that is in the form of an Electronic Record which the Company previously has
consented in writing to receive from the transferee, and that is sent by the transferee and is actually
received by the Company, shall be deemed to be a written agreement of the transferee delivered
to the Company.
C. Death of the Policyowner(s)
If a Policy has more than one Policyowner and one of the Policyowners dies, the ownership of
the Policy shall automatically pass to the remaining Policyowner(s). Upon the death of the last
remaining Policyowner of a multi-owner Policy, the ownership of the Policy shall automatically
pass to the individual (or individuals) named as the Insured. Similarly, if a Policy has only one
Policyowner, upon the death of the Policyowner, the ownership of the Policy shall automatically
pass to the individual (or individuals) named as the Insured(s). If any individual named as Insured
is a minor at the time that the ownership of the Policy passes, the Company, in its discretion, may
either (i) hold the Policy for the benefit of the minor Insured until he/she reaches 18 years of age,
or (ii) assign ownership of the Policy to the lawful parent or legal guardian of the minor Insured.
Delivery and assignment of ownership of the Policy by the Company to such lawful parent or legal
guardian of a minor Insured shall serve to fully discharge any responsibilities that the Company
may have as the custodian of the Policy.
The Insured must notify the Company in writing of death of the Policyowner. Notices and instructions
provided by the Insured are governed by the same terms, conditions and requirements as those
applicable to the Policyowner.
SECTION IV – PREMIUMS
A. Regular Premium Policy
a. Premium
The Premium which the Policyowner has agreed to pay for the Full Premium Payment Term as
stated in the Data Pages. The Original Premium is due on or before the Issue Date. Premiums
shall be paid according to the schedule stated in the Data Pages. Changes in the Premium
payment schedule may be requested, provided that the request is at least thirty (30) days before
the date of the next scheduled payment. If approved, such change shall take effect on the next
date when the Premium is due.
b. Allocation to Initial Account
The Company allocates an amount equal to the amount of the total Premiums that would be
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payable during the Initial Period to the Initial Account. The Company in its sole discretion will
determine what amount is necessary to be maintained in the Initial Account.
c. Grace Period
Grace Period shall be defined as a period of 90 days for any payment required under the Policy,
after the Premium becomes past due.
d. Nonpayment of Premiums during Initial Period
During the Policy’s Initial Period, if Premiums are not paid timely (including any applicable Grace
Period), the Policy may, in the Company’s sole discretion, lapse.
e. Nonpayment of Premiums after Initial Period
After the Policy’s Initial Period, if Premiums are not paid timely (including any applicable Grace
Period), and subject to the Company’s discretion, the Policy may be deemed by the Company
to be Paid Up status. Additionally, as permitted by applicable law, surrenders (if available)
may be requested by the Policyowner, in accordance with the Policy’s Surrender set forth in
these Terms and Conditions. If the Policy is deemed to be in Paid Up status it will continue to
provide the benefits set out in the Policy, and Charges and Fees will continue to be deducted as
described herein. Premium payments may be recommenced, in the Company’s sole discretion,
upon request. If the Cash Surrender Value at any time is insufficient to meet the applicable
Charges and Fees, the Policy may lapse.
f. Decrease of regular Premiums
Premiums may not be reduced during the Initial Period. After the Policy’s Initial Period, the
Policyowner may request the Company to reduce the regular Premiums on a Regular Premium
Policy, subject to the minimum set by the Company. If the regular Premium is reduced, the
benefits described in the Policy will continue to be in force, and Charges and Fees will continue
to be deducted based on the Original Premium.
g. Settlement Options
Upon successful completion of the Full Premium Payment Term no further Premiums will be
required, and the Policy may be surrendered in part or in full without Surrender Charges. The
funds left may remain invested with the Company for a period of time as may be permitted by
the Company in its discretion. While the Policy remains in force, it will continue to be subject to
these Terms and Conditions, and Charges and Fees will continue to apply.
B. Single Premium Policy
a. Premium
The Premium agreed to as set forth in the Data Pages. The initial Premium is due on or before
the Issue Date.
b. Allocation to Initial Account
The Company allocates an amount equal to the Initial Amount portion of the initial Premium to
the Initial Account. The Company in its sole discretion will determine what amount is necessary
to be maintained in the Initial Account.
c. Policy Lapse
At the Company’s discretion, if the Cash Surrender Value is, at any time, insufficient to satisfy
the applicable Charges and Fees, the Policy may lapse.
d. Settlement Options
Upon the successful completion of the Policy Term, the Policy may be surrendered in part or
in full without Surrender Charges. The funds left may remain invested with the Company for a
period of time as may be permitted by the Company in its discretion. While the Policy remains
in force, it will continue to be subject to these Terms and Conditions, and Charges and Fees will
continue to apply.
C. Riders and Excess Premiums
a. Regular Premium Rider
A Policyowner may increase the amount of the regular Premiums to either a Regular Premium
Policy or Single Premium Policy provided the increase meets the minimum contribution amount
established by the Company for riders. The increase in the regular Premium will apply to all
Premium payments going forward. The rider increasing the Premium will have a new and
separate Initial Period and, for such purposes, will be treated as if it was a new Policy.
b. Single Premium Rider
A Policyowner may contribute at any time, upon acceptance by the Company, single Premium
contributions to either a Regular Premium Policy or Single Premium Policy; provided each
single Premium contribution meets the minimum contribution amount established by the
Company for riders. The rider for a single Premium contribution may have a new and separate
Initial Amount, will incur its own Charges and Fees and, for such purposes, will be treated as if
it was a new Policy.
c. Excess Premiums
A Policyowner may contribute additional Premiums to either a Regular Premium Policy or
Single Premium Policy at any time, upon acceptance by the Company, and provided any such
additional Premium meets the minimum contribution amount established by the Company for
excess Premiums. The Company shall charge a bid/offer spread, or a substitute charge or fee,
for any excess Premiums.
d. Limitations
Riders or excess Premiums may be subject to restrictions depending on the Product originally
selected in the base Policy and preexisting riders, if any. The Company reserves the right to
accept or reject any riders or excess Premiums.
D. Premium Payments
The Company will provide various methods for the Policyowner to pay the Premiums due and
Premiums must be paid using one of the permitted payment methods. The Company must
be notified in writing of any change in the payment method, with such notice specifying the
new payment method. The Company reserves the right to charge a fee for any change in the
payment method or payment schedule. Depending on the payment method and/or schedule
of Premium payments selected, the Company may, in its discretion, charge a Collection Fee.
Premium payments received in any currency other than the base currency of the Policy will be
subject to acceptance by the Company, in its sole discretion. If accepted, the Premium payment
will be converted to the base currency of the Policy to apply the payment to the Policy. The
currency conversion rate used by the Company for the Premium payment conversion will be the
rate applicable on the date the processing of the Premium payment by the Company takes place.
The Company shall have sole discretion with regard to acceptance of Premium payments.
E. Bonuses, Extra Allocations and Guarantees
Any bonuses, extra allocations or guarantees offered by the Company from time to time in
connection with the Policy shall be subject to any terms, conditions or requirements set by the
Company at the time the offer of bonuses, extra allocations or guarantees is made. Failure to meet
or satisfy any applicable term, condition or requirement relating to a bonus, extra allocation or
guarantees will render void any offer, including any benefits in connection therewith. The applicable
bonuses, extra allocations or guarantees (if any) are stated in the Data Pages. Additional applicable
bonuses, extra allocations or guarantees (if any) may also be found in the Application, illustration,
Company’s brochure and Product specifications.
SECTION V - POLICY’S ACCOUNTS AND VALUES
A. Accounts
a. Investment Account
An account or accounts established by the Company in order to determine the Account Value of
the Policy. Each Investment Account may include a different Fund or other Asset depending on
the Product of the Policy.
b. Account
The account established by the Company to calculate the total Account Value, including all
Premiums paid.
c. Initial Account
The account established by the Company in order to fund the Administration Charges due over
the duration of the Policy Term or Full Premium Payment Term.
d. Accumulation Account
For Regular Premium Policies, the account established by the Company to allocate all
Premiums due after the Initial Period of the Policy; and for Single Premium Policies, the excess
funds remaining from the initial Premium after the Initial Amount has been deducted.
e. Loan Account
The account established by the Company for purposes of calculating the portion of the Policy’s
Account Value, which is used to account for a Debt.
B. Values
a. Account Value
The Account Value of the Policy is the total of all values under the Policy. The Account Value
reflects Premiums paid, deductions of Charges and Fees, the investment history of the
Investment Accounts notionally linked to the Policy, bonuses, extra allocations or returns
guaranteed under the specific terms of the Policy (if any) and any withdrawals due to a partial
surrender.
b. Initial Account Value
The value of the Initial Account less Administration Charges deducted from the Policy.
c. Accumulation Account Value
The value of the Accumulation Account calculated after deduction of corresponding Charges
and Fees, the investment history of the Investment Accounts notionally linked to the Policy,
bonuses, extra allocations or returns guaranteed under the specific terms of the Policy (if any)
and any withdrawals due to a partial surrender.
d. Cash Surrender Value
The Policy’s Cash Surrender Value, also referred as the Surrender Value, equals the Account
Value less any Surrender Charges or other claims by the Company against the Policy, if any.
e. Net Cash Surrender Value
The Cash Surrender Value less any Debt and any applicable Charges and Fees.
f. Investment Account Value
Each Investment Account shall be valued on its relevant Valuation Date set by either the Fund
company, the market or the Company. Depending on the Investment Account this may be on a
daily, weekly, monthly or quarterly basis. For the purposes of the Policy, all Assets will be bought
and sold at their NAV.
Notwithstanding anything herein to the contrary, while the Suspension and Deferral provision is
in effect the Company reserves the right to estimate the value of an Investment Account using
either the last known price of the Asset, a value of zero or any other estimation based on internal
(the Company’s) or external (qualified third parties) analyses or forecasts of the Asset.
g. Net Asset Value or "NAV"
The market value of an Asset.
h. Death Benefit
The amount used to determine the proceeds payable upon the death of the Insured.
i. Net Death Benefit
The Death Benefit less any Debt, and less any applicable Charges and Fees.
C. Suspension and Deferral
The Company may, for a reasonable period of time, suspend the calculation of the Account Value
and/or Cash Surrender Value and/or defer any payment under the Policy such as a surrender or
Death Benefit or Investment Account transfer, in the following circumstances:
1. If there is a breakdown in any of the means normally employed in ascertaining the values of
an Investment Account; or
2. If for any reason the prices or values of an Investment Account cannot be reasonably
ascertained; or
3. If circumstances exist as a result of which it is not reasonably practicable to determine fairly
the value of an Investment Account; or
4. If the remittance of funds involved in the realization of, or in the payment for investments
or payment due under the Policy cannot be carried out without undue delay and at normal
rates of exchange.
Notice of the imposition and raising of any such suspension will be provided to the Policyowner
upon request from the Policyowner. Calculations and payments, which were due to have been
made, but were suspended or deferred, shall be made within thirty (30) days of the lifting of the
suspension or deferral. The Company reserves the right, in its discretion, to defer: (i) payment of
a surrender, (ii) payment of a Death Benefit, (iii) Investment Account transfers, or (iv) Premium
allocations, for as long as the aforementioned period of suspension is in place. The Company will
not have to pay interest for any delay in any payments under the Policy under any circumstances.
SECTION VI – CHOICE OF INVESTMENT ACCOUNTS
A. Ownership of Investment Accounts
The Company is the absolute legal and beneficial owner of all the investments in the Investment
Accounts which relate to the Policy. The Policyowner has no rights or entitlement to the underlying
Investment Accounts’ Assets, and therefore any action to be taken in relation to the Assets (i.e.
corporate actions) will be decided solely by the Company, in its sole discretion. The Investment
Accounts are notionally linked to the Policy solely for the purpose of calculating the benefits which
the Company has agreed to pay with respect to the Policy.
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B. Choice of Investment Accounts
The Investment Accounts linked to the Policy will vary according to the Product selected. As such,
the options available to the Policyowner will vary as follows:
(i) For products in which the Investment Accounts are mostly limited to Funds, the Policyowner
will be allowed to select the Funds from among a group of Funds determined solely by the
Company.
(ii) For products where the Investment Account is linked to the Standard & Poor's 500 Index, or
any other Index as may be made available by the Company from time to time, the Company
will manage the underlying investment portfolio and the Policyowner will have no power of
selection.
(iii) For products where the Investment Account is linked to a fixed income portfolio, or any other
preestablished portfolio as may be made available by the Company from time to time, the
Company will manage the underlying investment portfolio and the Policyowner will have no
power of selection.
The selection of Investment Accounts may change from time to time at the discretion of the
Company. The Company reserves the right to limit the number of Investment Accounts that may be
linked at any one time to the Policy.
If a Premium is received by the Company on a Valuation Date for the selected Investment Account,
the Company will allocate the appropriate amount of the selected Investment Account to the Policy
at that time. If the Company receives the Premium on a day other than a Valuation Date for the
selected Investment Account, the Company will allocate the appropriate amount of the selected
Investment Account to the Policy on the next Valuation Date for the selected Investment Account.
C. Initial Allocation of Premiums
The initial selection of Investment Accounts will be made by the Company. The Company will
allocate the first or initial Premium to the Investment Account indicated in the Data Pages.
D. Change of Investment Account
The initial allocation of Premiums will remain in effect until the Policyowner informs the Company,
in writing, of a new selection. Upon the Policyowner’s instructions to change the selection of
Investment Accounts linked to the Policy, the Company will cancel the appropriate amount of the
deselected Investment Account linked to the Policy and replace it with the new Investment Account
selected. The Company shall charge a Transfer Fee for changing Investment Accounts.
The Company reserves the right to exchange any Investment Account linked to the Policy for
any other Investment Account and the Company will notify the Policyowner in writing accordingly.
All transfers are subject to the following conditions:
1. Transfers will be effected on the Valuation Date following receipt by the Company of a
written transfer request containing all required information.
2. Any transfer direction must clearly specify: (a) the percentage or amount (as required by the
Company) that is to be transferred; and (b) the Investment Accounts that are to be affected.
3. The Company may from time to time set/change the minimum amount that can be
transferred and the minimum amount that must remain in an Investment Account.
E. Future Allocation of Premiums
While the Policy is in force, the Company will allocate future Premiums to the Investment Account
indicated in the Data Pages. The initial selection will remain in effect until the Policyowner informs
the Company, in writing, of a new selection of Investment Accounts to be used for future allocations
of Premiums to the Policy (the “Future Allocations”). Upon the Policyowner’s instructions to change
the Future Allocations, the Company will replace the existing Future Allocations and replace it with
the new Future Allocations. The Company may charge a fee for changing the Future Allocations.
The Company reserves the right to exchange any Investment Account to be used for Future
Allocations with any other Investment Account and the Company will notify the Policyowner in
writing accordingly.
All new selections of Future Allocations are subject to the following conditions:
1. Future Allocations will be effected following receipt by the Company of a written request to
change the Future Allocations containing all required information.
2. Any Future Allocations request must clearly specify the percentage of each Investment
Account included in the Future Allocations. The sum of the percentages allocated to each
of the Investment Accounts included in the Future Allocations must equal 100%.
3. The Company may from time to time set/change the minimum percentage that can be
allocated to each individual Investment Account in Future Allocations.
F. Liability
If the Policyowner elects to use the transfer privilege, neither the Company nor any of its affiliates
will be liable for transfers between Investment Accounts made in accordance with the Policyowner’s
instructions.
The Company will not be liable for any market fluctuation that might negatively affect the value of
an Investment Account, and therefore the value of the Account, that occurs: (a) during the period
of time between the receipt of the transfer request and the actual execution of the transfer by the
Company, and/or (b) after the transfer has been completed and the Investment Accounts are linked
to the Policy.
G. Limits on Rights
The Company reserves the right at any time and without prior notice to any party to terminate,
suspend, or modify the transfer privileges described above. Additionally, the Company may defer
the right of transfer for any period when the Suspension and Deferral provision is in effect or in the
event that the Asset becomes unavailable for purchase or sale by the Company.
H. Investment Risk
Each Policyowner acknowledges and accepts that the Policy is intended to be a medium/long-term
investment, and that there are various risks associated with the investments underlying the Policy,
including, but not limited to, credit risk, liquidity risk, market risk, interest rate risk, currency risk and
other investment related risks. The Company is not liable for any losses incurred as a consequence
of selecting an Investment Account and each Policyowner agrees not to bring any claim against the
Company, its affiliates, or any of their respective officers, directors or employees in respect of such
losses. Any choice of Investment Accounts is made entirely at each Policyowner’s own risk. Each
Policyowner should undertake such due diligence, or seek such independent advice as he/she/it
considers necessary prior to selecting an Investment Account. Each Policyowner is responsible to
ensure that he/she/it understands and accepts the risks associated with any Investment Account
selected in connection with the Policy.
I. General
The Company may from time to time establish any other reasonable guidelines or conditions
with respect to the choice or change of Investment Account linked to the Policy and/or Future
Allocations.
 SECTION VII - DEATH BENEFIT PROVISIONS
A. Insured
The Insured under the Policy is named in the Data Pages. If the Policy has only one Policyowner,
he or she will be the sole Insured of the Policy; and if the Policy has two Policyowners, then both of
them will be the Insured of the Policy.
If the Policyowner is a Person other than an individual, then an individual must be named as the
Insured by the Policyowner.
The Policyowner can name an individual other than the Policyowner as the Insured. This
appointment must be made in writing. The Company reserves the right to approve or reject any
Insured’s appointment at its sole discretion. Additional documentation regarding the Insured may
be required by the Company.
The Death Benefit will only be paid on the death of the Insured. If there is more than one Insured
named in the Data Pages, the Death Benefit will be paid on the death of the last surviving Insured
and only one Death Benefit shall be paid. Once the Death Benefit has been paid the Company will
not accept any further Premiums nor will it pay any further benefits and the Policy will terminate.
B. Beneficiary
If designated by the Policyowner, the Beneficiaries, both primary and contingent, of the Policy
are identified in the Data Pages. A Beneficiary is the person to whom the Company pays the
Death Benefit proceeds upon the death of the Insured. The Company shall pay the Death Benefit
proceeds to the primary Beneficiary. If the primary Beneficiary has died, the Death Benefit proceeds
shall be paid to any named contingent Beneficiary. If there are no surviving Beneficiaries, the
Company shall pay the Death Benefit proceeds to the estate of the Policyowner. One or more
persons may be named as primary Beneficiaries or contingent Beneficiaries. In such case, the
Company will assume the proceeds are to be paid to the surviving Beneficiaries as specified in
the Data Pages.
If there are surviving primary Beneficiaries at the time the proceeds are to be paid, payment of
such funds shall be made to the surviving primary Beneficiaries in proportion to the percentage
of entitlement allocated to such Primary Beneficiaries in the Data Pages (such that if there is only
one surviving Primary Beneficiary such surviving Primary Beneficiary shall receive all such funds).
If there are no surviving Primary Beneficiaries at the time the proceeds are to be paid, payment
of such funds shall be made to each Contingent Beneficiary in proportion to the percentage of
entitlements allocated to such Contingent Beneficiary in the Data Pages (such that if there is only
one surviving Contingent Beneficiary such surviving Contingent Beneficiary shall receive all such
funds). If there are no surviving Primary Beneficiaries or Contingent Beneficiaries, or none has
been designated, at the time the proceeds are to be paid, payment of such funds shall be made to
the estate of the Insured.
C. Change of Beneficiary
The Policyowner may change the primary or contingent Beneficiary(ies) by submitting a written
request to the Company in a form satisfactory to the Company, in its sole discretion. The change
will take effect as of the date such request is actually received by the Company. The Company
will not be liable for any payment made or action taken before the Company records the change.
D. Death Benefit
The Company shall pay the Death Benefit to the Beneficiary(ies) upon the following conditions
being satisfied:
1. due proof of death of the Insured;
2. due proof that the Beneficiary(ies) is/are legally entitled to the Death Benefit;
3. compliance with all duties and obligations in connection with the Policy; and
4. meeting any other reasonable conditions set out by the Company.
The Beneficiary(ies) must notify the Company in writing of any death claim. Notices and instructions
provided by the Beneficiary(ies) are governed by the same terms, conditions and requirements as
those applicable to the Policyowner.
E. Death Benefit Amount
The amount of the Death Benefit will be calculated as established in the Data Pages. The Death
Benefit shall be determined on the next Valuation Day after the conditions above have been fulfilled
to the satisfaction of the Company. The Death Benefit during a Grace Period is equal to the Death
Benefit in effect immediately prior to the start of the Grace Period less any overdue Charges and
Fees or Debt repayments.
F. Due Proof of Death
Due proof of death is required. Due proof of death is one of the following, received by the Company:
1. A certified copy of a death certificate.
2. A certified copy of a decree of a court of competent jurisdiction as to the finding of death.
3. Any other proof satisfactory to the Company.
G. Minor Beneficiary
Where a Beneficiary is a minor, the Company may either hold the Death Benefit for the benefit
of the Beneficiary until he/she reaches 18 years of age or pay the Death Benefit to the parent or
legal guardian of the Beneficiary. The receipt by such Person shall be a full and valid discharge
to the Company.
H. Payment of Death Benefits
The Death Benefit proceeds shall be paid within ninety (90) days of the Valuation Date for the
affected Investment Accounts after the Company has received proof of death of the Insured and all
other requirements are satisfied to process the Death Benefit.
The payee(s) must be the Beneficiary(ies), Beneficiary’s(ies’) parent or legal guardian or the estate
of the Insured, as may be applicable. The Company will pay the Death Benefit proceeds to each
authorized payee individually according to the payee’s payment instructions.
The Company will provide one or more methods for the payee to collect the proceeds and shall be
entitled to charge a Disbursement Fee for any outgoing payment.
In lieu of a lump sum payment due to the payee, the payee, at his or her election, may choose to
apply the Death Benefit proceeds towards the purchase of another Policy then being offered by
the Company.
I. Continuation of the Policy
At the time of the death of the Insured, the Beneficiary(ies) may choose to continue the Policy
instead of collecting the Death Benefit. Once due Proof of death has been provided and the
Beneficiary identity has been confirmed, and before the Death Benefit has been requested, the
Beneficiary(ies) may request in writing to the Company that the Policy be assigned to him and/or
her. The Policy shall only be transferred or assigned with the written approval of or on behalf of the
Company. The change will take effect on the later of: (1) the date on which the request is processed
by the Company; or (2) the date requested by the Beneficiary. No assignment or other change to
the Policy will be binding on the Company unless it is written in a form acceptable to the Company,
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received by the Company and approved by the Company. The transferee must be approved by the
Company as a Policyowner and must agree in writing to be bound by these Terms and Conditions.
The Company will not be liable for any payments made or actions the Company takes before the
assignment is accepted by the Company. The Company will not be responsible for the validity of an
assignment. Any transfer of a Policy, in whole or in part, other than in accordance with the foregoing
shall be ineffective.
J. Limitations
The Death Benefit shall not be payable when any of the following occurs:
1. All required Premiums are not paid within the Grace Period;
2. The Policy has completed the Policy Term or Full Premium Payment Term;
3. The Insured dies from an illness or physical conditions that pre-existed the Issue Date;
4. The Insured dies by suicide, while sane or insane, within two (2) years from the Issue Date;
or
5. The death of the Insured results from any injury or condition resulting directly or indirectly
from war, hostilities (declared or not), invasion, rebellion, revolution, civil war or active
participation in a riot, commotion or uprising.
Upon the occurrence of any of the above events, the Company’s liability will be limited to the Net
Cash Surrender Value of the Policy.
K. Limits on Rights
No payment of a Death Benefit shall be permitted if the Suspension and Deferral provision is in
effect.
L. General
Additional death claim guidelines may be set by the Company, from time to time.
SECTION VIII – POLICY LOANS
A. Loan Request
Subject to Section VIII.E below, while the Policy is in force and not in a Grace Period, the
Policyowner(s) may borrow against the Policy, and by doing so the Policyowner(s) will be assigning
the Policy to the Company as collateral. The Policyowner(s) must provide written notice of the
Policyowner’s intent to take a Loan in a form acceptable to the Company. The Company reserves
the right to reject any application for a Loan. The Loan is subject to terms and conditions offered
by the Company including a minimum or maximum amount that may be borrowed and a maximum
limit of Debt to Cash Surrender Value ratio.
B. Loan Interest
Interest on the Loan due to the Company will accrue daily at the rate set by the Company at the
time the Loan is approved. Interest on the Loan is due at the end of the period indicated in the terms
and conditions following the Loan. If interest on the Loan is not paid, an amount equal to the unpaid
interest shall become part of the outstanding Debt on the Policy and will accrue its own interest.
C. Loan Repayments
All or part of a Loan may be paid at any time and from time to time depending on the terms of the
Loan. The repayment terms of the Loan shall be provided by the Company upon approval of the
Loan. To repay a Loan in full, the Policyowner must pay a sufficient amount to cover the full Debt.
The Policyowner may also instruct the Company to surrender the Policy in part or in full to pay for
all or part of the Loan, including principal and/or outstanding interest.
Failure to repay any Loan or to pay interest shall not terminate the Policy unless the total Debt under
the Policy equals or exceeds 90% of the current Cash Surrender Value. Upon such termination, the
Company will pay to the Policyowner the amount, if any, of the Policy's Net Cash Surrender Value.
Nonetheless the Company reserves the right to execute a partial surrender of the Policy to pay
outstanding principal or interest due on the Loan in the event the maximum limit of Debt to Cash
Surrender Value ratio is exceeded.
D. Disbursement of Loans
The loan proceeds will be disbursed within ninety (90) days following the Company’s approval of
the Loan Request.
The Company will provide one or more methods for the payee to receive the loan amount and shall
be entitled to charge a Disbursement Fee for any outgoing disbursement.
E. Limits on Rights
The Policyowner is not entitled to a Loan. The Company reserves all of its rights to reject any
application for a Loan, at its discretion.
The Company may also defer the approval of a Loan during any period when the Suspension and
Deferral provision is in effect.
F. General
Additional loan guidelines may be set by the Company, from time to time.
SECTION IX – SURRENDERS
A. Surrender Request
At any time during the life of the Policy, the Policyowner may request a surrender under the Policy
by making a written request in a form satisfactory to the Company, in its sole discretion. A Surrender
Request is subject to the Policy having a positive Net Cash Surrender Value and the amount
requested not exceeding the Policy’s Net Cash Surrender Value.
B. Full Surrender
The Policyowner(s) will be paid the Policy’s Net Cash Surrender Value.
C. Partial Surrender
Payments with respect to any partial surrender, plus any money owing to the Company, will be
deducted from the Accumulation Account prorated from each Investment Account linked to the
Policy. The Policy’s Cash Surrender Value will also be decreased by the amount of any such
payment.
Each partial surrender must be for an amount that is not less than the Minimum Partial Surrender
amount. The Policy must also maintain a Minimum Cash Surrender Value. Both the Minimum
Partial Surrender and the Minimum Cash Surrender Value are established by the Company from
time to time and may be shown on the Data Pages.
Regularly scheduled partial surrenders may be established upon written request and subject to
agreement by the Company. Depending on the Product, the Policy may allow for partial surrenders
free of Surrender Charges, up to a set limit each Policy Year as established by the Company.
D. Payment of Surrenders
The Company will pay the Policyowner the amount of any surrender within ninety (90) days of
the Valuation Date for the affected Investment Accounts following the Company’s approval of the
Surrender Request.
The Company will provide one or more methods for the payee to collect the proceeds and shall be
entitled to charge a Disbursement Fee for any outgoing payment.
In lieu of a lump sum payment, the Policyowner, at his or her election, may elect in writing to apply
the proceeds payable under the Policy toward the purchase of another Policy then being offered
by the Company.
E. Restrictions and Penalties
Each Policy may, depending on the Product, have different restrictions and penalties with regard
to both Full and Partial Surrenders. Particular restrictions and penalties may include: liquidity
restriction, free partial surrenders limitations or restrictions, loss of guarantee, loss of bonuses,
among others. The applicable restrictions and penalties (if any) are stated in the Data Pages.
Additional applicable restrictions and penalties (if any) may also be found in the Application,
illustration, Company’s brochure and Product specifications.
F. Limits on Rights
No surrender shall be permitted if the Suspension and Deferral provision is in effect.
G. General
Additional surrender guidelines may be set by the Company, from time to time.
SECTION X – CHARGES AND FEES
A. Charges and Fees
The Company makes a number of Charges and applies a number of Fees against the Policy to
cover the cost of issuing and administering the Policy. The Company will make the appropriate
deductions for the Charges and Fees against the Policy on their respective Processing Dates.
Charges and Fees are shown for convenience purposes on the Data Pages, but the Company
reserves the right to change the amount of any Charges and Fees and will give the Policyowner at
least thirty (30) days notice in writing of any change in the amount or basis of calculation.
J. Collection Fee
Collection Fees are those expenses and/or charges relating to the processing or collection of
the Premium incurred by the Company, whether directly or through a third party, will be the sole
responsibility of the Policyowner(s) and shall be deducted from the relevant Premium payment at
the time of the payment.
K. Document Delivery Fee
The Document Delivery Fee is the fee charged by the Company to print and deliver the Policy
documents. This fee will only apply to a Policyowner’s request for a printed copy of the Policy
documents. The Document Delivery Fee will be deducted from the Policy by reducing the units in
the Accumulation Account.
During the Initial Period if the Accumulation Account Value is insufficient to cover the fee, the fee
may be deferred until such time when the Accumulation Account Value is sufficient as long as the
Policy remains in force. After the Initial Period if the Accumulation Account Value is insufficient to
cover the fee, the Policy may lapse.
L. Other Charges and Fees
Other charges and fees may be charged by the Company if the Company incurs any fees,
expenses or charges as a result of the payment of any benefits or receipt of any Premiums or as
a result of issuing and/or administering the Policy. Any such fees, expenses and/or charges will be
charged against the Policy. Any such other Charges or Fees will be deducted from the Policy as
incurred by reducing the Account.
M. Inflation
Any Charge or Fee identified in these Policy Terms and Conditions or elsewhere in the Policy may
be increased from time to time in line with any increase in the Consumer Price Index published by
the Government of the Jurisdiction or any appropriate replacement index.

B. Policy Fee
The Policy Fee is a fee charged by the Company to maintain the Policy. The Policy Fee will be
deducted from the Policy as scheduled in the Data Pages by reducing the units in the Accumulation
Account.
During the Initial Period if the Accumulation Account Value is insufficient to cover the fee, the fee
may be deferred until such time when the Accumulation Account Value is sufficient, as long as the
Policy remains in force. After the Initial Period if the Accumulation Account Value is insufficient to
cover the fee, the Policy may lapse.

C. Administration Charge
The Administration Charge is the fee charged by the Company to administer the Policy. The
Administration Charge(s) will be deducted from the Policy as scheduled in the Data Pages by
reducing the units in the Initial Account. Units will be deducted at the acquisition cost at which units
were calculated in the Initial Period or Initial Amount.

D. Asset Management Fee

The Asset Management Fee is the fee charged by the Company to manage the Assets under the
Policy. The Asset Management Fee will be deducted from the Policy as scheduled in the Data
Pages by reducing the units in the Accumulation Account.
During the Initial Period if the Accumulation Account Value is insufficient to cover the fee, the fee
may be deferred until such time when the Accumulation Account Value is sufficient as long as the
Policy remains in force. After the Initial Period if the Accumulation Account Value is insufficient to
cover the fee, the Policy may lapse.

E. Structure Fee
The Structure Fee is the fee charged by the Company to maintain the structure related to the
Investment Accounts notionally linked to the Policy. The Structure Fee will be deducted from the
Policy as scheduled in the Data Pages by reducing the units in the Accumulation Account.
During the Initial Period if the Accumulation Account Value is insufficient to cover the fee, the fee
may be deferred until such time when the Accumulation Account Value sufficient as long as the
Policy remains in force. After the Initial Period if the Accumulation Account Value is insufficient to
cover the fee, the Policy may lapse.

F. Transfer Fee
The Transfer Fee is the fee charged by the Company in connection with transfers into and out of
the Investment Accounts that are notionally linked to the Policy. The Transfer Fee will be deducted
from the Investment Account from which the transfer is made. However, if the entire interest in an
Investment Account is being transferred, the Transfer Fee will be deducted from the amount that is
transferred. The Transfer Fee will be deducted from the Policy as scheduled in the Data Pages by
reducing the units in the Accumulation Account.
During the Initial Period if the Accumulation Account Value is insufficient to cover the fee, the fee
may be deferred until such time when the Accumulation Account Value is sufficient as long as the
Policy remains in force. After the Initial Period if the Accumulation Account Value is insufficient to
cover the fee, the Policy may lapse.

G. Surrender Charge
The Surrender Charge is the charge related to surrendering the Policy by the Policyowner or
termination of the Policy by the Company in accordance with these Terms and Conditions. The
Surrender Charge is equal to the remaining Administration Charges that would have been deducted
had Premiums been paid for the balance of the Full Premium Payment Term or Policy Term.
For Single Premium Policies without Administration Charges, the Surrender Charge is calculated
as a percentage of paid Premiums or the Account Value as scheduled in the Data Pages.

H. Bid/Offer Spread
The Company may at its discretion charge a bid/offer spread on any Premium payment on a
Regular Premium Policy or a Single Premium Policy. Any such spread shall be deducted from the
relevant Premium payment at the time of the payment as scheduled in the Data Pages.

I. Disbursement Fee
The Disbursement Fee is the fee charged by the Company to process a payment on any Policy.
The Disbursement Fee may vary depending on the payout method selected and will be deducted
from the Net Cash Surrender Value at the time of processing the payment or before the payment
is executed.

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 PART II // ITA International Trust
Trust Agreement

T15W035686 - Liliana Judith Bonilla

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 DEED NUMBER ONE HUNDRED FOURTEEN (114)
TRUST AGREEMENT
In Guaynabo, Puerto Rico, this Nineteenth (19th day of December, Two Thousand Eighteen
(2018).
BEFORE ME
MANUEL E. SARMIENTO
Notary Public in and for the Commonwealth of Puerto Rico, with residence in Guaynabo,
Puerto Rico and offices at Metro Office Park, Street One (1), Lot Three (3), Metro Office Three
(3), Suite Four Hundred Two (402), Guaynabo, Puerto Rico.
APPEAR
AS PARTY OF THE ONLY PART: ITA International Financial Services Corp., a Corporation
organized and existing under and by virtue of the laws of Puerto Rico, with Tax Identification
Number sixty-six dash zero nine zero one five six two (66-0901562) and having its principal
place of business in Urb. Altamira, Perseo Street number five hundred sixteen (#516), San Juan,
Puerto Rico, acting by and represented herein by its resident agent, Jose Luis Perez Machargo,
of legal age, married to Patsy Janine Ramírez, property owner and resident of Guaynabo, Puerto
Rico, who warrants his official character and power to act on behalf of said Company through the
enclosed “Unanimous Written Consent of the Directors of ITA International Financial Services
Corp.” which is made to form a part of this Deed and who additionally binds himself to evidence
the same whenever and wherever necessary (hereinafter referred to as the “Settlor” and/or the
“Trustee” as the case might warrant).
I, the Notary, hereby certify that I know the appearing party and its representative, and through
their statements, as to their ages, civil status, occupations, residences and social security
numbers and through the attached resolutions their capacity to appear herein. They assure
me that they have, and in my judgment they do have, the necessary legal capacity to execute
this Deed.
WHEREAS, after obtaining a special permit from the Commissioner of Financial Institutions,
the Trustee will act as fiduciary; provided, that such fiduciary services shall not be offered to, nor
inure to the benefit of domestic persons, as such term is defined in Law Number Two Hundred
Seventy Three (273) of September Twenty Five (25), Two Thousand Twelve (2012) pursuant
to Seven Laws of Puerto Rico Annotated section Three Thousand Ninety One, enclosed
parenthesis Twelve (7 L.P.R.A. §3091(12)).
WHEREAS the Trust is established to provide a mechanism to enable the Trust to acquire
one or more Policies for the benefit of beneficiaries designated by the Plan Participants in the
Subscription Agreement, with monies received from the Plan Participants, and to carry out the
Plan as defined herein.
WHEREFORE, they freely state and covenant as follows:
I. DEFINITIONS
BENEFICIARY under this Trust shall mean a Plan Participant.
COMMISSIONER shall mean the Commissioner of Financial Institutions of Puerto Rico.
INSURANCE COMPANY means the insurer, selected by the Plan Participant in the
Subscription Agreement, to issue the Policy.
PLAN shall be defined as the means by which this Trust will allow approved individuals and
entities to enter into a subscription agreement with the Trust and the Trust will set up a unique
subaccount for each such individual or entity. The Trust will purchase, with monies received from
the Plan Participant, as defined herein, one or more Policies, as defined herein. At the Trustee’s
discretion, the Plan Participant may pay all amounts due with respect to insurance policies issued
directly to the issuer of such Policies and, additionally, receive therefrom; subject to the condition
that the Trust has knowledge of such transfers, payments and disbursements.
PLAN PARTICIPANT shall mean each party with whom the Trust enters into a Subscription
Agreement in accordance with the Plan.
POLICY OR POLICIES shall mean the insurance policy(ies) and/or insurance contract(s)
selected by the Plan Participants (from among those that are available to the Trust at that time)
and acquired by the Trust in accordance with the Plan and all Policies which may be transferred
to the Trust in compliance with all applicable laws of the Commonwealth of Puerto Rico.
POLICYOWNER shall mean the Trust acting as policyowner on behalf of the unique
subaccounts for the Policy(ies) issued. In case of insurance contracts, instead of life insurance
policies, the policyowner may be referred to as contract owner.
SUBACCOUNT shall mean each separate account established under the terms of this Trust
for the purchase of certain Policies with moneys received from each Plan Participant.
SUBSCRIPTION AGREEMENT shall mean the agreement entered or to be entered into
between each proposed Plan Participant and the Trust, dealing with the manner and provisions
of subscription into the Plan. Which Subscription Agreement shall be in the form that from time
to time the Trust shall choose to use, and any Subscription Agreement, or other form thereof of
similar purposes, which may be transferred to the Trust in compliance with all applicable laws of
the Commonwealth of Puerto Rico.
TRUST FUND shall mean all property that from time to time is deposited with the Trust and the
income derived therefrom; including all property placed from time to time in each of the separate
Subaccounts established pursuant to this Deed.
II. CONSTITUTION OF TRUST
Settlor hereby creates and establishes a trust (hereinafter referred to as the “Trust”) for the
purposes stated above. Settlor hereby transfers to the Trust which has been constituted herein
the sum of $100.00 which property constitutes the initial corpus of the Trust Fund.
The Trustee shall not be required to post a bond for the faithful execution of its duties as trustee
and may obtain such policies of errors and omissions as the trustee may deem fit and charge
the expenses related thereto to the Trust Fund. The Trustee hereby accepts to act as trustee in
accordance with the terms and conditions prescribed in this Deed.
III. NAME OF THE TRUST
The Trust hereby created shall be known and designated as ITA INTERNATIONAL TRUST.
IV. TRUST FUND
The corpus of the Trust Fund will also consist of any asset that the Trust may receive through
transfers of whichever manner, from the Settlor, a Plan Participant or by any other person or
entity in accordance with the Plan (in which case separate accounts must be maintained for each
so that the assets of one party shall not be commingled with that of another party); provided that
such additional assets transferred through whichever manner, to form a part of the Trust Fund, as
well as their disposition, shall be governed solely by the provisions of this Deed. The Trust shall
receive each asset paid or otherwise transferred to the Trust by the Settlor, the Plan Participant,
if applicable, or by any other person or entity in accordance with the Plan in a form acceptable to
the Trust as determined by the Trustee in its sole discretion.
The Trust shall receive, hold, manage and administer the Trust Fund for the exclusive purposes
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set forth above and in accordance with the provisions hereinafter prescribed.
V. THE BENEFICIARY
The Beneficiary/ies of this Trust shall be those Plan Participants entering into a Subscription
Agreement to the extent of their interest in their Subaccount(s) as established herein.
VI. TRUSTEE
A. POWERS AND DUTIES OF THE TRUSTEE.
ONE: The Trustee shall have the power to resolve any uncertainty as to the purposes or the
mode of execution of the Subaccounts created by or under this Trust.
The Trustee shall endeavor to carry out the Plan and shall act accordingly in dealing with the
property of the Trust.
Insofar as the Plan is unspecific as to the Trustee’s action and does not require the Trustee to
act as directed by another, or to delegate to another, the Trustee shall have discretion to act as it
deems fit, having regard to the letter and the spirit of the Plan.
The Trust, acting through the Trustee, shall enter into or be assigned a Subscription Agreement
with each Plan Participant. By completion of a Subscription Agreement, the Plan Participant will
apply to the Trust for participation in the Plan and the Trustee shall be free to accept or reject
such application at its sole discretion.
Whenever under or in connection with this Trust and the Subscription Agreement, the Trustee is
permitted or required to make a decision (a) at its “sole discretion,” “sole and absolute discretion,”
“full discretion” or “discretion,” or under a similar grant of authority, such as “reserves the right,”
the Trustee shall be entitled to consider only such interests and factors as it desires, and may
consider its own interests, and shall have no duty or obligation to give any consideration to any
interests of or factors affecting the Trust or the Plan Participants, or (b) in its “good faith” or under
another express standard, the Trustee shall act under such express standard and shall not be
subject to any other or different standards that may be imposed by the Subscription Agreement
or by law or any other agreement contemplated therein.
The Trustee shall hold the Trust Fund on the Subaccounts and, subject to the terms and
conditions contained herein, may at any moment accept such additional funds as may be paid
or transferred to them or otherwise placed under its control by any person to be held upon such
Subaccounts. Any assets placed in such Subaccounts shall be exempt, to the highest extent
permitted by applicable law, from any claims of creditors of Beneficiaries or Plan Participants.
The Settlor and the Trustee shall have the exclusive right to enforce any and all provisions of
the Trust, and in any action or proceeding affecting the Trust, the Settlor and the Trustee shall be
the only necessary parties and the only parties entitled to any notice of process.
The Trustee may enter into or receive assignment of a Subscription Agreement with a Plan
Participant.
The Trustee may purchase with monies received from or on behalf of the Plan Participant, one
or more Policies for the benefit of beneficiaries designated by the Plan Participants in such Policy.
The Trustee shall deliver, itself or through a third party, confirmation in writing of Plan
participation to each Plan Participant following the purchase of a Policy or Policies for that Plan
Participant.
The Trust shall administer the Plan and distribute or direct others to distribute the proceeds
of each Subaccount, in accordance with directions given to the Trust by each Plan Participant.
The Trustee, at its own discretion, may appoint an administrator (the “Administrator”) to execute
part or all the administration of the Trust following instructions given by the Trustee and under
direct supervision of the Trustee. Such appointment, if it exists, must be made in writing by the
Trustee and must include the powers, duties, responsibilities and limitations of the Administrator.
The Administrator’s appointment will not be considered part of this Deed.
The Trustee reserves the right to engage service providers (the “Provider(s)”) to procure
different services required to support the Trustee or the Administrator in the administration of the
Trust. These services may include but are not limited to the following areas: accounting, audit,
administration, operations, finance, information technology, marketing and distribution. At any
point in time a range of providers may working for the Trustee and the Trustee may from time
to time engage new ones or disengage existing ones. The providers may be affiliated with the
Company or they may be third parties with no affiliation with the Company.
Subject to the provisions of the preceding four (4) paragraphs, any amounts which are left as
surplus after full compliance with the requirements of carrying out the purposes of this Trust, and
in particular of operating the business scheme described in such preceding paragraphs above,
shall be invested by the Trust pending distribution, in the discretion of the Trustee, in a manner
deemed to be consistent with the objectives stated above.
The Trustee shall also be endowed with such additional powers as specifically provided for
in articles 21 through 25 and 27 of the Trust Law of Puerto Rico, Law 219 of August 31, 2012.
TWO: ACCOUNTS OF THE TRUSTEE.
The Trust shall, directly or through the services of a third party, maintain, in accordance with the
applicable laws of Puerto Rico, accurate records and prepare an annual report of all transactions
effected hereby. The report shall include a statement setting forth all receipts, investments,
disbursements and other transactions effected by or on behalf of the Trust during the reporting
period. All records hereunder shall be available at all reasonable times for inspection by any
person or persons designated by the Governing Board.
For accounting, reporting and any other related purposes the Trust shall operate on the basis
of the calendar year, ending on December thirty first (31) of each year.
The Trustee, through the Insurance Company, jointly or independently, shall make available to
each Plan Participant information regarding his/her/its Plan and his/her/its Policy. Any requirement
for the Trustee to communicate with or notify the Plan Participant(s) will be considered fulfilled by
the Trustee when such communication or notification is made available to the Plan Participant(s).
The Trustee, upon the request of the Commissioner, shall render a report to the Commissioner
on the financial conditions of the Trust, payments made, its investments and any other proper
matter requested thereof.
THREE: RESIGNATION OR REMOVAL OF THE TRUSTEE.
The Trustee may resign its duties by written notice thereof to the Settlor. Such resignation will
not take effect until thirty (30) days from the date thereof, unless prior thereto a successor shall
have been named.
The Settlor may remove the Trustee at any time upon thirty (30) days written notice to the
Trustee.
The Settlor shall appoint a successor upon the removal or resignation of said Trustee. All of the
provisions set forth herein with respect to the Trustee shall relate to each successor so appointed
with the same force and effect as if such successor had been originally named.
FOUR: INDEMNIFICATION OF THE TRUSTEE.
The Trustee shall be fully protected in relying upon resolutions of the Settlor with respect to
any instruction, direction or determination of such Settlor. The Trustee shall be fully protected
in acting upon any instrument, certificate or paper believed by it to be genuine and to be signed
or presented by the proper person or persons, and the Trustee shall be under no duty to make
any investigation or inquiry as to any statement contained in any such writing. The Trustee shall
accept the same as conclusive evidence of the truth and accuracy of the statements therein
contained.
The Trustee shall not be liable for the proper application of the Trust Fund if made in accordance
to the instructions of the Settlor.
The Trustee shall not be responsible for the adequacy of the Trust Fund to meet and discharge
any and all payments and liabilities of the Trust. All persons dealing with the Trust are released
from inquiry into the decision or authority of the Trustee and from seeing to the application of any
monies, securities or other property paid or delivered to the Trustee.
The Trustee, whether it continues to hold office or not, shall be entitled to indemnity from
the Trust Fund for any liability incurred in the administration of the Trust, including the cost
of defending any action or suit which may be brought against it in connection with such
administration, the cost of any settlement thereof and any liability incurred by reason of alleged
or actual act or failure to act in relation thereto, except such liability as may arise from its own
willful negligence or bad faith.
All expenses and costs of administering the Trust shall be paid by Settlor and/or Plan Participant
at the sole discretion of the Trustee. Such expenses shall include any expenses incidental to the
functioning of the Trust, including, but not limited to, fees of advisors, accountants, legal counsel
and other personnel, and any other costs of administering the Trust.
X. ACCEPTANCE
The appearing parties accept this Deed as drafted because it has been drawn up in accordance
with their instructions, stipulations, terms and conditions.
I, the Notary, do hereby certify that I have advised the appearing parties of the legal effects
of this deed.
I, the Notary, also certify that this document was read personally by each of the appearing
parties, who know and understand the English language and, I the Notary have reviewed and
explained this Deed, paragraph by paragraph to the appearing parties and they have found it
in accordance with their instructions, stipulations, terms and conditions, approve and ratify the
contents hereof and confirm the statements contained herein as the true and exact embodiment
of their agreements; and that thereupon the appearing parties affixed their initials on each and
every page and sign the original of this deed in one act, before me, the Notary.
To all of which, under my signature and seal, and after signing, sealing, marking and flourishing
the same according to law, I, the undersigned Notary, ATTEST.

VII. DURATION OF THE TRUST

This Trust shall terminate if it should ever be without assets.
This Trust shall be of indefinite duration but may be terminated and discontinued in the
absolute discretion of the Settlor.
Notice of such termination shall be given to the Trustee by an instrument in writing executed by
the Settlor, signed by its duly authorized officers, and declaring that the Trust hereby established
is terminated.
Upon receipt of such notice of termination, the Trustee shall liquidate any funds remaining
in the Trust Fund or any Policies remaining in any Subaccount and pay the proceeds of such
Policies to or for the benefit of the beneficiaries of any policy in accordance with the provisions of
the relevant Subscription Agreement.
The Trustee shall bear no liability whatsoever for acting in accordance with such written
directions.

VIII. ASSIGNMENT
No benefit, right or interest of any person hereunder shall be subject to anticipation, alienation,
sale, transfer, assignment, pledge, encumbrance or charge; nor to seizure, attachment or other
legal, equitable or other purposes; nor shall it be liable for, or subject to the debts, liabilities or
other obligations of such persons.

IX. MISCELLANEOUS
Limited by the arbitration provisions of the Subscription Agreement between the Plan
Participant(s) and the Trust, the Trustee shall be liable to account for its administration in the
courts located in the Commonwealth of Puerto Rico. The Trustee may, at any time, initiate an
action or proceeding for the settlement of its accounts or for the determination of any question of
construction which may arise. The Trustee shall be further obligated to defend this Trust against
all suits, claims or attempts to question its validity and any expense related thereto shall be
charged and payable from the Trust Fund.
No part of the net earnings of the Trust Fund will inure to the benefit of or be distributed to any
member of the Trustee, the Settlor or any director, officer or other private person related to these
except that the Trust Fund shall be authorized and shall have sufficient powers to pay reasonable
compensation for services rendered and to make any other necessary payment or distribution
that is consistent with the purposes of this Trust. No substantial part of the activities of this Trust
shall consist of the dissemination of propaganda or otherwise attempting to influence legislation;
and the Trust shall not participate in or intervene in (including the publishing or distribution of
statements) any political campaign on behalf of any candidate for public office.
The Settlor, its successors and assigns, shall have the right at any time and from time to time
by an instrument in writing delivered to the Trustee, executed pursuant to its certified authorized
representative, in form similar to the execution of this trust agreement, to modify or amend this
agreement to conform it to new legislation that might affect this Trust, in whole or in part except
that the duties and responsibilities of the Trustee shall not be substantially increased without
its written consent, and further excepting that no amendment shall be made pursuant to which
any part of the Trust Fund may be used for or diverted to a purpose other than for those stated
herein. Any such amendment shall become effective upon delivery of the written instrument of
amendment to the Trustee, provided it does not increase the duties and responsibilities of the
Trustee, but if it does increase such duties and responsibilities it shall become effective upon the
endorsement of the Trustee of its written consent.
Separability of provisions. All the provisions of this Deed shall be interpreted separately, so
that if any provision of this Deed is held to be null or invalid under the laws of the Commonwealth
of Puerto Rico, said nullity, illegality or invalidity shall not affect the validity of the remaining
provisions of this Deed, and this Deed will be construed as if such null and invalid provisions had
never comprised a part hereof.
Title of sections. The titles used in all sections of this Deed are inserted for reference purposes
only, and in any manner these titles shall be used in the construction of these sections.
Grammatical interpretation. All words used in this deed will be construed to be of such gender
or number as the circumstances require; singular terms may include the plural and vice- versa,
unless the context clearly indicates the contrary.
Governing Law, Venue and Change of Jurisdiction. The law of the Commonwealth of Puerto
Rico shall govern the validity and interpretation of the provisions of this Deed; except as these
might be superseded by the laws of the United States.
Limited by the arbitration provisions of the Subscription Agreement between the Plan
Participant(s) and the Trust, the parties hereby irrevocably submit to the exclusive jurisdiction of
the Court of First Instance of Puerto Rico or the Federal District Court for the District of Puerto
Rico, over any dispute arising out of or relating to this Trust, and each party hereby irrevocably
agrees that all claims in respect of such dispute or any suit, action or proceeding related thereto
may be heard and determined in such courts.
Notwithstanding the above, Trustee shall have the power and discretion to decide, and in
its sole discretion declare, that this Trust shall take effect, be governed and be interpreted
exclusively in accordance with the law of some other jurisdiction (within or outside of the United
States of America), provided that such law would recognize the validity of this Trust and the
Beneficiary’s interest in this Trust.
Trustee may also direct that all or any part of the assets of the Trust be moved from one
jurisdiction to another and to change the situs of administration of the Trust from one jurisdiction
to another, if Trustee reasonably believes such change of governing law and/or change of sites
of administration shall inure to the benefit of the Beneficiary and/or create added security for the
Trust; provided that, notwithstanding the arbitration requirements of the Subscription Agreement,
any disputes relating to the performance of the obligations under this Deed shall be governed by
the laws of the Commonwealth of Puerto Rico.

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 PART III // ITA International Trust
Subscription Agreement

T15W035686 - Liliana Judith Bonilla

version 11/2019
 Subscription Agreement
This Subscription Agreement by and between ITA International Financial Services Corp., a Corporation
organized and existing under and by virtue of the laws of Puerto Rico and having its principal place
of business at 268 Ave. Ponce de Leon, Suite 1406, Hato Rey, San Juan, Puerto Rico, 00918, and ITA
International Trust (respectively the "Trustee" and the "Trust") and the Plan Participant(s) whose
signature(s) is/are affixed at the end hereof.
DECLARATION by the Plan Participants to the Trustee:
Each Plan Participant jointly and severally:
(1) represents that the information provided by the Plan Participant(s) in this Subscription Agreement
is accurate and complete;
(2) acknowledges receipt of a copy of the Deed of Trust dated December 19, 2018 (the "Deed of Trust")
has been provided to the Plan Participants;
(3) desires and hereby requests the Trustee to constitute a Subaccount (as defined herein);
(4) directs the Trustee to invest funds contributed by the Plan Participant(s) in a Policy issued by the
Insurance Company, as defined below allocated to the Subaccount;
(5) represents and acknowledges that each Plan Participant has read carefully this Subscription
Agreement, the Deed of Trust and the Terms and Conditions of the Policy to be acquired by the Trust
from the Insurance Company;
(6) represents, acknowledges, and agrees that each Plan Participant has full responsibility for
information entered and the selections made in this Subscription Agreement associated with the
Subaccount;
(7) represents and acknowledges that each Plan Participant has been informed and is aware of the
Product, as defined below, specifications including but not limited to the functioning of the Product,
its features, requirements and limitations as established by the Insurance Company;
(8) represents and acknowledges that each Plan Participant has been informed and is aware of the
Insurance Company to be the issuer of the Policy (as defined herein) and its corresponding jurisdiction;
(9) represents and warrants that he/she/it is not:
a. a citizen or resident of the United States of America;
b. a corporation or other entity deemed situated in the United States of America under the tax laws
and Regulations (as defined in the Declaration of Trust) of the United States of America; or
c. physically present in the United States of America for a number of days in a taxable year which
would result in he/she/it being taxable as a resident alien under the "substantial presence" test of
Section 7701(b) of the United States Internal Revenue Code of 1986, as amended; or
d. a domestic person of the Commonwealth of Puerto Rico; defined as a natural person resident
in the Commonwealth of Puerto Rico or a person incorporated or organized under the laws of
the Commonwealth of Puerto Rico or whose principal place of business is located in the
Commonwealth of Puerto Rico or the Government or any political subdivision or agency of the
Commonwealth of Puerto Rico.
(10) Each Plan Participant hereby represents, warrants, and agrees that:
i. he/she/it is aware that any failure to comply with the foregoing may result in material adverse tax
consequences and that neither the Trust nor the Trustee nor the Insurance Company shall have
any liability therefor; and
ii. he/she/it will immediately advise the Trustee should there be any failure to comply with the
foregoing;
(11) represents, acknowledges and agrees that no Plan Participant has or will contribute to the Trust any
proceeds obtained from unlawful activities (as is defined in the Money Laundering Control Act of 1986
issued by the Congress of the United States of America);
(12) represents, acknowledges, and agrees that all funds must be sent directly to the Trustee, or to the
entity designated by the Trustee to receive such payments on the Trustee’s behalf and that any funds
given to any intermediary will be at the sole risk of the Plan Participants.
WHEREAS
The Settlor and the Trustee have established the Trust under the Law of Trusts of Puerto Rico, Law
Number 219 of August 31, 2012, as amended;
A separate subaccount shall be constituted under the Trust herein (the "Subaccount");
Under the terms of the Trust, using one or more Subaccounts the Trustee shall purchase one or more
Policies, as defined below, from the Insurance Company, as defined below, with monies received from
Plan Participants (the "Plan");
The Trustee shall direct the Insurance Company to set up the Policies using the information entered and
the selections made by the Plan Participants in this Subscription Agreement;
The Trustee shall administer the Plan in accordance with the terms of the Trust and this Subscription
Agreement and the selections shall be set as forth by the Plan Participants in this Subscription
Agreement.
NOW IT IS HEREBY AGREED AS FOLLOWS
1. DEFINITIONS
In addition to terms otherwise defined herein, where the context so admits the following expression shall
have the following respective meanings:
"Beneficiary/ies" means the Persons designated as such in the Nomination of Beneficiaries Section of
this Subscription Agreement.
“Deed of Trust” means Public Deed number one hundred fourteen (114), executed in Guaynabo, Puerto
Rico on December 19, 2018 before Notary Public Manuel E. Sarmiento.
“Electronic” relates to technology having electrical, digital, magnetic, wireless, optical, electromagnetic
or similar capabilities.
“Electronic Record” means a Record created, generated, sent, communicated, received or stored by
Electronic means.
“Electronic Signature” means an Electronic sound, symbol or process attached to or logically associated
with a Record and executed or adopted by a Person with the intent to sign the Record.
“Information Processing System” means an Electronic system for creating, generating, sending,
receiving, storing, displaying or processing information;
"Insurance Company" means the insurer, selected by the Plan Participant from the list of insurers made
available by the Trustee, in its sole discretion, to issue the Policy.
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"Insured" means the natural person(s) whose life is insured under each Policy.
“Person” means a legal person, including, without limitation, any individual, corporation, estate,
partnership, joint venture, association, joint stock company, limited liability company, trust,
unincorporated association, protected cell company or protected cell thereof, segregated portfolio
company or segregated portfolio thereof, or government or any agency or political subdivision thereof, or
any other entity of whatever nature.
“Plan” shall have the meaning ascribed to it in the Deed of Trust.
“Plan Participant(s)” shall have the meaning ascribed to it in the Deed of Trust.
“Policy(ies)” shall have the meaning ascribed to it in the Deed of Trust.
“Policyowner” shall have the meaning ascribed to it in the Deed of Trust.
“Product” means the insurance product, selected by the Plan Participant from the list of insurance
products made available by the Insurance Company to the Trust as approved by the Trustee, in its sole
discretion, to be used in the Policy.
“Signed” includes an Electronic Signature where such Electronic Signature is made available by the
Trustee, as well as a wet signature.
“Trust” means the trust established pursuant to the Deed of Trust, currently known as the ITA
International Trust.
“Trustee” means the trustee or trustees from time to time holding such office under the purview of the
Deed of Trust.
“UBO” means the Ultimate Beneficial Ownership and refers to the natural person(s) who ultimately
own(s) or control(s) a Person, other than an individual, and/or the natural person(s) on whose behalf a
transaction is being conducted.
OTHER INTERPRETATION
(a) the singular shall include the plural and vice versa;
(b) the masculine gender shall include the feminine gender and vice versa;
(c) the neuter gender shall include the masculine and feminine and vice versa;
(d) headings shall not be construed as part of this document;
(e) this Subscription Agreement shall be construed in tandem with the provisions of the Deed of Trust
but to the extent that any provisions hereof are inconsistent therewith, the terms of the Deed of Trust
shall prevail;
(f) capitalized terms used but not otherwise defined in this Subscription Agreement have the meanings
assigned thereto in the Deed of Trust.
2. FRAUDULENT DISPOSITIONS
Each Plan Participant warrants that no transfer of money or other property by them to the Trustee will
at the time made constitute a fraudulent disposition under applicable law, i.e. that each such transfer
has not been made at an undervalue and has not been made with an intention to defraud a creditor of
the Plan Participants.
3. THE TRUST INSTRUMENT
Each Plan Participant agrees that it shall be subject to and bound by all provisions of the Deed of Trust
and this Subscription Agreement.
Without limiting the generality of the foregoing, each Plan Participant acknowledges and agrees: that
funds contributed by the Plan Participants will be credited to a Subaccount and used to purchase one
or more Policies; that the making of such contribution constitutes each Plan Participant’s agreement to
the terms of the Deed of Trust and this Subscription Agreement and such Plan Participant’s agreement
to be bound thereby.
4. PURCHASE OF THE POLICY(IES)
With funds received from the Plan Participants, the Trustee shall purchase one or more Policies and
shall continue to pay the premiums due thereon so long as funds contributed by the Plan Participants
are available in the Subaccount.
5. PAYMENTS TO THE TRUST
The Plan Participants have opted for a method of payment to the Trustee (or to the entity designated by
the Trustee to receive such payments on the Trustee’s behalf), as shown in this Subscription Agreement,
and such method may be changed by the Plan Participants, if agreed to by the Trustee, after written
notice requesting a change has been given by the Plan Participants to the Trustee.
The Trustee may also direct the Plan Participant(s) to send the premium payments of a Policy allocated
to the Subaccount established in relation to the Plan Participants directly to the Insurance Company.
6. DEFAULT IN CONTRIBUTION PAYMENTS
If the Plan Participants fail to make the necessary scheduled contribution, the Trustee shall not be under
any obligation to make any payment on any Policy if funds are not available within the Subaccount for
such purpose.
7. CLAIMS OF CREDITORS
To the extent permitted by law and the Deed of Trust, the Subaccount shall not be subject to the claims
of the creditors of the Plan Participants.
8. THE INSURED OF A POLICY
If the Plan has only one Plan Participant, he or she will be the sole Insured of the Policy; and if the Plan
has two Plan Participants, then both of them will be the Insured of the Policy.
If the Plan Participant is a Person other than an individual, then an individual must be named as the
Insured of the Policy in the Subscription Agreement.
The Plan Participants can name an individual other than themselves as the Insured. This appointment
must be made in writing. The Insurance Company reserves the right to approve or reject any Insured’s
appointment at its sole discretion. Additional documentation regarding the Insured may be required by
the Insurance Company.
9. THE BENEFICIARIES OF A POLICY
Subject to the provisions established herein, the Primary and Contingent Beneficiaries listed in the
Nomination of Beneficiaries section of this Subscription Agreement will be appointed as Beneficiaries of
the Policy allocated to the Subaccount established in relation to the Plan Participants and are subject
to compliance with applicable law (including laws and regulations directed at the prevention of money
laundering) at any time, and from time to time. Subject to all applicable laws and regulations and with
the sole discretionary consent of the Trustee and the Insurance Company, upon receipt by the Trustee of
a written notice signed by the Plan Participants, Beneficiaries may be deleted or added or the order or
proportion of their potential benefit may be altered in whatever manner.
10. DEATH OF THE PLAN PARTICIPANT(S)
If a Plan has more than one Plan Participant and one of the Plan Participants dies, the ownership of the
Plan shall automatically pass to the remaining Plan Participants. Upon the death of the last remaining
Plan Participant of a multi-owner Plan, the ownership of the Plan shall automatically pass to the
individual (or individuals) named as the Insured. Similarly, if a Plan has only one Plan Participant, upon
the death of the Plan Participant, the ownership of the Plan shall automatically pass to the individual
(or individuals) named as the Insured. If any individual named as Insured is a minor at the time that
the Plan Participant passes, the Trustee, in its discretion, may either (i) hold the Plan for the benefit of
the minor Insured until he/she reaches 18 years of age, or (ii) assign ownership of the Plan to the lawful
parent or guardian of the minor Insured. Delivery of the Plan by the Trustee to such lawful parent or
guardian of a minor Insured shall serve to fully discharge any responsibilities that the Trustee may have
as the custodian of the Plan.
11. REVOCATION
The Plan Participants may give notice of revocation of that portion of the Trust as constituted by the
Subaccount to the Trustee at any time, in which case the Trustee will surrender in full to the Insurance
Company each Policy allocated to the Subaccount established in relation to the Plan Participants. The
Subaccount shall be revoked if it should ever be without funds or in force or paid up Policies. If a
Policy under a revoked Subaccount regains its in force or paid up status, the Trustee may reinstate the
Subaccount for the benefit of the Plan Participant.
12. DISTRIBUTIONS
During the lifetime of the Insured, the Trustee shall ensure that payments are made to the Plan
Participants in respect of proceeds received from the Insurance Company upon a full or partial surrender
request of the Policy, in accordance with the Policy’s Term and Conditions.
The Trustee may instruct the Insurance Company to distribute the net proceeds directly to the Plan
Participants.
The payment, and timing of payments to the Plan Participants following a revocation, will depend upon
the redemption value of each, the receipt of funds in respect thereof from the Insurance Company and
compliance with applicable law.
In lieu of a lump sum payment due to the Plan Participants, as applicable, each Plan Participant, at his
or her election, may choose to collect the proceeds or to apply them towards the establishment of a new
Plan. The Trustee shall ensure that the Insurance Company makes the payments to the Beneficiaries
in respect of proceeds generated upon the death of the Insured under a Policy, in accordance with the
Policy’s Terms and Conditions.
13. ASSIGNMENT
No entitlement under or interest in the Plan shall be transferred or assigned, in whole or in part, except
with the written approval of the Trustee. The interests of a Plan Participant may be assigned from one
Person to another by written request of the current Plan Participant(s) to the Trustee.
The Plan Participants’ interests may only be assigned during the lifetime of the Insured, unless at the
time of the death of the Insured, the Beneficiary may choose to continue the Plan instead of collecting
the Death Benefit. Once due Proof of Death has been provided and the Beneficiary’s identity has been
confirmed, but before the Death Benefit has been requested to the Insurance Company, the Beneficiary
may request in writing to the Trustee that the Plan be transferred/assigned to him and/or her. The Plan
shall only be transferred or assigned upon the written approval of the Trustee.
No assignment or other change to the Plan will be binding on the Trust or otherwise effective unless it
is written in a form acceptable to the Trustee, received by the Trustee and approved by the Trustee. The
proposed assignees/transferees must be approved as a Plan Participant by the Trustee and must agree
in writing to be bound by this agreement. Neither the Trustee nor the Insurance Company will be liable
to any proposed assignee/transferee for any reason whatsoever prior to the time that the assignment
is approved by the Trustee. The Trustee shall have the right to assume that any requested assignment
submitted hereunder is a valid request submitted by the Plan Participant(s). Any assignment or transfer
hereunder, in whole or in part, other than in accordance with the foregoing shall be ineffective.
14. DELEGATION
The Trust, as Policyowner, through the Trustee authorizes the Plan Participant(s) to provide instructions
regarding a Policy allocated to the Subaccount established in relation to the Plan Participant directly
to the Insurance Company. Such instructions will be considered by the Insurance Company as coming
from the Policyowner.
At the same time, the Trust may also authorize the Insurance Company to communicate directly with
the Plan Participant(s) regarding a Policy allocated to the Subaccount established in relation to the
Plan Participant(s).
This authorization may be revoked at any time at the sole discretion of the Trustee.
15. INFORMATION AND REPORTS
Both the Trustee and the Insurance Company, jointly or independently, shall make available to each
Plan Participant information regarding the Plan and the Policy allocated to the Subaccount established
in relation to the Plan Participant(s) in the Trustee’s or the Insurance Company’s secure account access
website. It will be each Plan Participant’s responsibility to access the secure account access website
to review information related to the Plan and the Policy and other matters that relate to the Plan
Participant(s) in connection with the Trust and the Insurance Company and to take any necessary action.
Any requirement for the Trustee to communicate with or notify the Plan Participant(s) will be considered
fulfilled by the Trustee when such communication or notification is: (i) made available to the Plan
Participant(s) on the secure account access website or (ii) sent either by mail or e-mail to at least one
Plan Participant. It is the responsibility of the Plan Participant(s) to maintain all contact information
current with the Trustee. In the absence of any notification from a Plan Participant relating to changes in
the contact information, the Trustee shall deliver any notices, reports or other form of communication to
the mailing address or e-mail address of record, at the discretion of the Trustee.
16. CONFIRMATION OF REPRESENTATIONS AND WARRANTIES / INDEMNITY
Each Plan Participant hereby confirms the accuracy of all information and the validity of all
representations and warranties provided to the Trustee in connection with the Plan and for the Policy,
howsoever provided, including the terms of this Subscription Agreement, any additional forms and the
contents of any personal or medical questionnaire (together "Representations & Warranties"). Each Plan
Participant acknowledges that certain of such information will be provided to the Insurance Company as
the issuer of the Policy and potentially to reinsurers thereof, and that any inaccuracy therein may result
in the invalidity of such Policy and the loss of all funds contributed or paid in relation thereto. Each Plan
Participant hereby undertakes to inform the Trustee of any change in any matter that forms the subject
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of any of the Representations & Warranties.
Each Plan Participant hereby undertakes to indemnify, defend, and hold harmless the Trustee against
any loss or damage (including, without limitation, attorney’s fees) occasioned by any inaccuracy in any of
the Representations & Warranties or failure to advise the Trustee of any change in any matter that forms
the subject of any of the Representation & Warranties.
17. NOTICES AND INSTRUCTIONS
To be effective, all notices and instructions provided by the Plan Participants must be in writing, signed
by the Plan Participant and received by the Trustee. If a Plan has more than one Plan Participant, then
the Trustee, in its own discretion, shall establish which notices and instructions must be signed by all
Plan Participants and which notices and instructions must be signed by any one Plan Participant.
Unless otherwise provided, all notices, requests, and elections will be effective when received by the
Trustee, complete with all necessary information and properly signed, certified or acknowledged, as
required.
The Trustee may request the Plan Participants to confirm any instruction, but may act upon instructions
which the Trustee reasonably believes are valid. The Trustee reserves the right not to act upon any
instructions until the required confirmation from the Plan Participant(s) has been received, although lack
of any such confirmation will not invalidate any instructions already acted upon. The Trustee shall not be
required to act upon any instructions where the Trustee reasonably believes such action may involve an
act of fraud or a breach of law, rule or regulation.
The Trustee will not be held responsible for any loss, damage, fraud or misappropriation arising as a result
of any error or breakdown in transmission, misunderstandings, errors by the Trustee or its employees,
agents, contractors, directors regarding the identity of the person or persons giving instructions by fax,
electronic mail or other means. Each Plan Participant agrees to indemnify and hold the Trustee harmless
against all losses, damages, liabilities, actions, proceedings, claims, costs and expenses including but
not limited to legal expenses on a full indemnity basis arising from or in connection with the Trustee
acting or failing to act on instructions given by the Plan Participants.
The Trustee may, in its sole discretion, make available alternative methods for the Plan Participant(s)
to provide instructions to the Trustee, including a secure account access website to provide certain
instructions or to execute certain actions using an Information Processing System.
18. FEES AND EXPENSES
The Trustee and Insurance Company shall charge its fees and expenses as provided in the Deed of Trust
and Policy.
19. VERIFICATION OF IDENTIFICATION AND SOURCE OF FUNDS
As part of the Trust’s responsibility for the prevention of money laundering, and in regard to other
matters, the Trustee will require detailed verification of each Plan Participant and Payor’s (if other than
the Plan Participant(s)) identity and the source of the subscription funds, and Beneficiary’s identity.
The Trustee, in its own discretion, may deem it necessary to require additional documentation in relation
to each Plan Participant, the Payor (if other than the Plan Participant(s)) and each Beneficiary at any
point in time while the Plan is not revoked.
Failure to provide the required information/documentation may result in the Trustee’s revocation of that
portion of the Trust as constituted by the Subaccount established in relation to the Plan Participant(s).
20. INDEMNITY AND PROTECTIONS
The Trustee and other indemnified parties (each as such and in its individual capacity) are provided with
comprehensive indemnity and other protections in the Deed of Trust as described in the Deed of Trust.
21. OUTSOURCING
The Trustee reserves the right to engage service providers (the “Provider(s)”) as described in the Deed
of Trust. Depending on the service to be provided by each Provider, they may require access to sensitive
information related to the Plan, the Policy, the Plan Participant(s), the Insured, the Beneficiaries or any
other information gather by the Trustee according to the Subscription Agreement and the Deed of Trust
(the “Information”). Any information shared with any Provider will be treated as confidential by the
Provider and will be shared for the sole purpose of allowing the Provider to complete the assigned task.
The Plan Participant(s) agrees that the Trustee will not be held responsible for any loss or damage arising
from the sharing of Information hereunder.
22. GOVERNING LAW
This agreement is created under and shall be governed by and construed and enforced in accordance
with the laws of the Commonwealth of Puerto Rico (without regard to conflict of laws principles), which
may require the Trustee to report certain information about the Plan and the Persons related to the Plan
to the authorities in Puerto Rico or other jurisdictions.
23. ARBITRATION
All claims and disputes arising under or relating to this Subscription Agreement are to be settled by
binding arbitration in the Commonwealth of Puerto Rico or another location mutually agreeable to
the parties. The arbitration shall be conducted on a confidential basis pursuant to the Commercial
Arbitration Rules of the American Arbitration Association. Any decision or award as a result of any
such arbitration proceeding shall be in writing and shall include the assessment of costs, expenses,
and reasonable attorneys' fees to the prevailing party. Any such arbitration shall be conducted by an
arbitrator experienced in matters relating to trusts, insurance policies and insurance contracts issued
through entities established under the purview of Law Number 273 of September 25, 2012 pursuant to 7
Laws of Puerto Rico Annotated section 3091(12) (7 L.P.R.A. §3091(12)) and shall include a written record
of the arbitration hearing. The parties reserve the right to object to any individual who shall be employed
by or affiliated with a competing organization or entity. An award of arbitration may be confirmed in a
court of competent jurisdiction.
24. TAXES
Any taxes or duties paid to any governmental entity relating to the Subaccount will be deducted from the
contributions towards the Plan. The Trustee may, in its sole discretion, determine when taxes or duties
have resulted from the set up or existence of the Subaccount or receipt by the Trust of contributions.
The Trustee may, in its sole discretion, pay taxes or duties when due and deduct such amounts from
contributions towards the Plan at a later date. Payment at an earlier date does not waive any right the
Trust may have to deduct amounts at a later date.
25. COMPLIANCE
Any notice, instruction or transaction, including all incoming or outgoing payments received or executed
by the Trustee related to the Plan, as well as any related Person (including the UBO), must comply with
the applicable laws, regulations or other requirements of Puerto Rico relating to anti-money laundering
or the proceeds of crime or any laws, regulations or requirements of similar import; as well as Trustee’s
policies and procedures relating to anti-money laundering, “know your customer” and others of similar
import.
While the Subaccount has not been revoked, if considered necessary by the Trustee, it may, at its own
discretion and from time to time, request additional information (including supporting documentation)
related to any notice, instruction or transaction (including all incoming or outgoing payments executed or
received by the Trust) related to the Plan as well as any related Person (including the UBO).
The Trustee reserves the right, to reject any notice, instruction or transaction that it may consider non-
compliant. Non-compliant transactions or Persons related to the Plan in any way, may result in the
revocation or suspension of the Subaccount. In case of suspension the Trustee will cease, reject or block
certain activities or transactions related to the Subaccount until such time when the Trustee determines
the cause of the suspension has been corrected.
26. SEVERABILITY
Each provision of this Subscription Agreement shall be considered severable and if, for any reason,
any provision is held to be invalid or unenforceable to any extent, this will not affect the validity or
enforceability of any other provision of the Subscription Agreement. Upon any such determination of
invalidity, the Trustee may modify the Subscription Agreement so as to effect its original intent as closely
as possible in order that the transactions contemplated hereby are consummated, to the greatest extent
possible, as originally intended.
27. DISCRETION
Whenever under or in connection with these Subscription Agreement, the Trustee is permitted or required
to make a decision (a) at its “sole discretion,” “sole and absolute discretion,” “full discretion” or
“discretion,” or under a similar grant of authority, such as “reserves the right,” the Trustee shall be
entitled to consider only such interests and factors as it desires, and may consider its own interests,
and shall have no duty or obligation to give any consideration to any interests of or factors affecting the
Trust or the Plan Participants, or (b) in its “good faith” or under another express standard, the Trustee
shall act under such express standard and shall not be subject to any other or different standards that
may be imposed by this Subscription Agreement or by law or any other agreement contemplated herein.
28. ELECTRONIC RECORD OR ELECTRONIC SIGNATURE
For purposes of this Subscription Agreement: (i) an Electronic Record or Electronic Signature is
attributable to a Person if it was the act of or on behalf of the Person, and such act may be shown
in any manner, including a showing of the efficacy of any Security Procedure applied to determine the
Person to which the Electronic Record or Electronic Signature was attributable; and (ii) an Electronic
Record is received by a Person only when: (A) it enters an Information Processing System that such
Person previously has designated in writing to the sender for the purpose of receiving from such sender
Electronic Records of the type received and from which such Person is able to retrieve the Electronic
Record; (B) it is in a form capable of being processed by that system; and (C) a responsible officer of such
Person has actual knowledge of its receipt. Receipt of an Electronic acknowledgment from an Information
Processing System by itself does not establish that a Record was received and does not establish that the
content sent corresponds to the content received.
Reference in this document to “in writing” or “written” includes an Electronic Record.
29. OFFICIAL LANGUAGE DISCLOSURE
The Trustee has designated English as the official language for all aspects of its relationships and
communications. All agreements, documents, notices, disclosures and other forms of communications
shall be written, interpreted and applied in English, whether delivered in hard copy or electronic form.
Notwithstanding the preparation or provision of any translation by the Trustee or otherwise, the English
language version of such document shall control for all purposes of application, interpretation, or
construction.
30. EXECUTION BY PLAN PARTICIPANT(S)
This Subscription Agreement must be executed by the Plan Participant(s) and delivered to the Trustee as
follows: (i) signed with a wet signature and delivered by courier to an address indicated by the Trustee;
(ii) signed with a wet signature, digitally scanned and uploaded to an Information Processing System
indicated by the Trustee; or (iii) signed with an Electronic Signature and delivered using an Information
Processing System designated by the Trustee.
31. SUBJECT TO ACCEPTANCE
This Subscription Agreement is subject to acceptance by the Trustee and will not be effective unless and
until accepted by the Trustee.

IN WITNESS WHEREOF THIS SUBSCRIPTION AGREEMENT HAS BEEN EXECUTED AND DELIVERED by each
Plan Participant as of the date this Subscription Agreement is submitted.

T15W035686 - Liliana Judith Bonilla

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version 11/2019