ICBA FINANCIAL SERVICES CORPORATION and ICBA INSURANCE SERVICES,
Inc., (collectively “IBFS”), subsidiaries of the Independent Community Bankers of
America, is a service provider to your local community bank. We enable our member
banks to better serve their customers by offering access to investment opportunities
such as mutual funds, annuities, long-term health care, and other insurance products. We offer this service through a joint agreement between our firm and your bank. That
agreement requires that the confidentiality of your information must be maintained. We
want you to know that, as an IBFS customer, we believe that protecting your privacy is
extremely important. Your bank and we want to be sure that we maintain your
confidence and trust. ICBA Insurance Services, Inc., is the supplier of certain insurance
products while ICBA Financial Services Corporation supplies the investment products.
We collect nonpublic information from you on investment product applications and
related account documentation as well as from your continuing transaction records. We
may share this information about you with the bank that sponsors this program to help
the bank monitor the success of the program or to help the bank provide better service
for all its customers. We do not otherwise disclose any nonpublic personal information
about our customers or former customers to anyone, except as permitted by law. For
example, we may share information on your transactions if we are required to disclose it
by law, regulation, or court order. We restrict access to nonpublic information about you
to those employees who need to know that information in order to provide products or
services to you. We maintain physical, electronic, and procedural safeguards that
comply with federal standards to guard your nonpublic personal information. If you
decide to close your account(s) or become an inactive customer, we will adhere to the
privacy policies and practices as described in this notice.

The Independent Community Bankers of America (ICBA) provides this Web site as a benefit and service in furtherance of ICBA's nonprofit and tax exempt status. ICBA does not certify or guarantee the accuracy, completeness, efficacy or timeliness of information contained herein. ICBA does not exercise editorial control over materials and information posted by third parties onto this site or materials that are e-mailed by third parties to ICBA or to others. ICBA expressly disclaims liability for damages of any kind claimed by any person or organization arising, directly or indirectly, from the use of, or reliance upon, any information on this site or on third party postings. The ICBA site includes links to other Internet sites. These sites are independent from ICBA and ICBA does not endorse, approve, certify or control these sites and does not guarantee the accuracy, completeness, efficacy or timeliness of information contained therein. Reference on the ICBA site or on any external linked site to any specific commercial product, process or service does not constitute or imply endorsement or recommendation by ICBA. Users are solely responsible for product and service selections and vendors are solely responsible for the quality and value of their products and services, delivery, billing, warranty and service. ICBA expressly disclaims responsibility for damages of any kind claimed by any person or organization arising, directly or indirectly, from use, reference to or reliance upon any such product, process or service.

ICBA Financial Services Corporation (“the Firm”) has in place a business resumption
plan in the event that our current office is made unusable due to a natural or man-made
disaster. The Firm will remain operational in all instances, save and except for a
widespread disaster that would disrupt the entire financial systems in place throughout
the United States. Our plan calls us to be fully functional within 72 hours of the
occurrence.
We have in place alternative locations to conduct business and, as an introducing
broker/dealer that does not handle customer funds, our plan provides that we can assist
the customer by giving them the telephone numbers of the applicable fund, annuity, or
managed account company so that the customer may contact said firm or company
directly and originate a redemption or liquidation of the applicable account.
The Plan is subject to modification at any time. You can request any modification of the
above paragraph by writing the Firm at the address found in this document.

ICBA Financial Services Corporation and ICBA Insurance Services, Inc. have entered
into contracts with various mutual fund and insurance companies to provide investment
and insurance products to our customers. We are compensated for the sale of those
products pursuant to the contracts we enter. In the case of registered products such as
mutual funds, variable annuities, and variable life insurance, disclosure of that
compensation is made through a prospectus and a statement of additional information. The prospectus is given to the customer at the point of sale. The statement of additional
information is available to the customer upon request to the mutual fund or insurance
company.
In recent years, questions have been raised about revenue sharing agreements in
which brokerage or insurance firms require mutual fund or insurance companies to pay
additional compensation in return for recommending their products or placing such
products on a ‘preferred list’ for additional sales emphasis by their representatives. Our
companies do not do that.
