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As the general partner of the Portfolio and the Fund, the GP oversees the investment activity of the Portfolio and the Fund. The GP manages the Portfolio and the Fund for the benefit of investors.

Does the structure change impact the withdrawal limitation? No, there is no impact to the status of the withdrawal limitation.

How will these changes benefit unitholders of the Separate Account?

How will these changes benefit unitholders of the Separate Account by Principal Life believes the changes may be favorable to unitholders of the Separate Account by potentially providing the following benefits:

• Greater diversification: A common investment principle is a group of assets has collectively lower risk than any individual asset. A larger investment portfolio can invest in more and different properties, which can lead to greater diversification, by property sector and geography.
• Higher quality properties: A larger pool of assets could invest in higher quality properties without compromising diversification by property sector and geography.
• Expanded transaction opportunity set: A larger pool of assets could participate in large portfolio transactions or large single asset transactions without compromising diversification.
• Cycle opportunity: At different times in economic and real estate cycles, better relative value can exist in the purchase of large assets versus small assets.
• Potential investment performance improvement: Over long time periods, larger properties have historically outperformed smaller properties and larger core real estate funds have historically outperformed smaller core real estate funds.¹
• Reduction in fixed costs: By creating a larger pool of assets, fixed costs paid to third parties, such as those for an audit or valuation services, will be spread over a larger number of investors.
• Investor diversification: Plan sponsors currently eligible to invest in the Separate Account are tax-favored retirement plans. Different investor types may exhibit different characteristics, including liquidity timing and frequency.

1Property performance: based on data from the NCREIF Property Index through June 30, 2020. Large and small fund performance: based on June 30, 2020 data from NFI-ODCE data contributing funds.

What are the Retained Assets? How were they selected and how will they be monitored? Initially, the Separate Account will transfer assets and liabilities, valued at no more than 95% of the Separate Account's holdings, to the Portfolio. Such assets will include most of the properties, cash and liabilities of the Separate Account. However, the Retained Assets in the Separate Account will consist of some of the properties it holds that have a value equaling approximately 7% of Separate Account holdings.

Principal Life retained an independent fiduciary that is a registered investment adviser with substantial expertise in real estate consulting and valuations to analyze the proposed Retained Assets portfolio. The independent fiduciary provided an opinion, a condensed version is available to you upon request on a non-reliance basis. To obtain a copy of the condensed opinion, please contact your Principal\circledR representative. The independent fiduciary concluded in their opinion that:

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