Service Agreement

• Date: 28 September 2004
• Parties: The Victory Portfolios ("Trust"), Hartford Life Insurance Co., Inc. ("Administrator")
• State: Ohio
• Section: Commercial Contracts

SERVICE AGREEMENT

This Agreement is entered into as of 9/28/2004 by and among The Victory Portfolios (the “Trust”), a Delaware statutory trust, on

behalf of those series identified on Schedule A to this Agreement individually and not jointly (such series being individual referred to herein as the

“Fund” and collectively as the “Funds”), and Hartford Life Insurance Co., Inc. (“Administrator”), a Connecticut corporation.

RECITALS

1. The Trust is registered as an open-end management investment company under the Investment Company Act of 1940, as amended

(hereinafter the “1940 Act”) and its shares are registered under the Securities Act of 1933, as amended (hereinafter the “1933 Act”); and

2. The Administrator issues certain group variable annuity contracts and group funding agreements (the “Contracts”) in connection with

retirement plans intended to meet the qualification requirements of Sections 401, 403(b) or 457 of the Internal Revenue Code of 1986, as amended

(the “Code”); and

3. Each Separate Account is a duly organized, validly existing segregated asset account, established by resolution of the Board of

Directors of the Administrator under the insurance laws of the State of Connecticut to set aside and invest assets attributable to the Contracts; and

4. To the extent permitted by applicable insurance laws and regulations, the Administrator intends to purchase shares of the Funds set

forth in Schedule A on behalf of each corresponding Separate Account set forth on such Schedule A to fund the Contracts and the Trust is

authorized to sell such shares to unit investment trusts such as the Separate Accounts at net asset value; and

5. Administrator provides administrative services comprised of, but not limited to, recordkeeping, reporting and processing services (the

“Administrative Services”) to certain retirement plans (the “Plans”). Administrative Services for each Plan include processing and transfer

arrangements for the investment and reinvestment of Plan assets in investment media specified by an investment adviser, sponsor or administrative

committee of the Plan (a “Plan Representative”) generally upon the direction of Plan beneficiaries (the “Participants”). The Administrative Services

are provided by Administrator under service agreements with various Plans; and

6. The Trust and Administrator desire to facilitate the purchase and redemption of shares of the Funds listed on Schedule A (the “Shares”)

on behalf of the Plans and their Participants through one or more accounts (not to exceed one per Plan) in each Fund (individually an “Account”

and collectively the “Accounts”), subject to the terms and conditions of this Agreement and the applicable Fund prospectus.