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Item 4 Advisory Business <br /> This brochure provides information about the business practices of NIA. NIA is an indirect subsidiary of <br /> Nationwide Financial Services, Inc. ("Nationwide Financial"). NIA is a registered investment adviser under the <br /> Investment Advisers Act of 1940. NIA's advisory representatives are registered as investment adviser <br /> representatives in accordance with the requirements of the state in which they operate. <br /> NIA's Background Information-- NIA was formed on May 12, 2006, as a limited liability company. On or about <br /> October 1, 2006, NIA assumed all advisory activities formerly performed by Nationwide Investment Services <br /> Corporation, a registered investment adviser and broker-dealer. This transfer of responsibilities did not result <br /> in a change in control or management of the advisory programs being offered at that time. <br /> NIA is wholly owned by Nationwide Life Insurance Company ("NLIC"), which is wholly owned by Nationwide <br /> Financial. Nationwide Financial is wholly owned by Nationwide Corporation, a holding company for entities <br /> affiliated with Nationwide Mutual Insurance Company. None of these Nationwide entities is publicly held. <br /> NIA's advisory services are provided through portfolio management, asset allocation models, managed <br /> accounts,and selection of other investment advisers for its programs described below. <br /> Nationwide Large Cap Growth Portfolio <br /> NIA is the investment adviser to the Nationwide Large Cap Growth Portfolio (the "LCG Portfolio"), an <br /> unregistered managed separate account sponsored by NLIC that is offered to employee benefit plans whose <br /> assets are not subject the Employee Retirement Income Security Act of 1974, as amended ("ERISA") or the <br /> Internal Revenue Code of 1986, as amended (the "Code"). NIA has hired sub-advisers to handle the day to day <br /> management of the LCG Portfolio's assets and delegates its investment discretion to the sub-advisers. NIA <br /> determines the allocation of LCG Portfolio assets among the sub-advisers and then oversees, evaluates, and <br /> monitors the services of each sub-adviser. NIA consults with the LCG Portfolio Board of Managers ("LCG <br /> Portfolio Board") and provides recommendations to the LCG Portfolio Board with respect to the overall <br /> investment strategy, including the allocation among sub-advisers and the selection and retention of sub- <br /> advisers,for the LCG Portfolio Board's approval, modification,or rejection. <br /> Point in Time Non-Discretionary Advice <br /> NIA provides non-discretionary, one-time (point in time) only, investment advice to participants (the "Clients") <br /> in certain public sector deferred compensation plans defined under Section 457 of the Code that are <br /> administered by an affiliated company, Nationwide Retirement Solutions, Inc ("NRS"). Clients seeking advice <br /> will enter into a non-discretionary investment advisory agreement with NIA and, often with the assistance of <br /> NIA's licensed investment advisory representatives, complete a Client Profile Questionnaire. The Client Profile <br /> Questionnaire is designed to help Clients identify their time horizon, risk tolerance, and investor profile. Based <br /> upon the Client's responses to the Client Profile Questionnaire, NIA recommends an asset allocation model, <br /> ranging from conservative to aggressive, and a corresponding portfolio of mutual funds. NIA constructs and <br /> maintains the asset allocation models and selects the mutual fund investment options from those available in <br /> the Client's retirement plan. NIA does not have discretionary authority over the Client's account and is not <br /> responsible for buying or selling any securities for the Client's account. The Client is solely responsible for <br /> implementing NIA's recommendations. NIA does not provide ongoing investment advice in connection with <br /> this service. Clients interested in seeking updated recommendations must enter into a new agreement with <br /> NIA and complete a new Client Profile Questionnaire. <br /> Advice Program for Plan Sponsors of Trustee Directed Retirement Plans <br /> NIA offers a discretionary investment advisory service (the "Advice Program") to plan sponsors of defined <br /> benefit plans and certain other trustee directed retirement plans that use a retirement program offered by an <br /> affiliated company, Nationwide Trust Company, FSB, a division of Nationwide Bank ("Nationwide Trust <br /> Company"). Under the Advice Program, the plan sponsor appoints NIA to allocate and reallocate the plan's <br /> 4 <br />