CLIENT PRIVACY

At Bessemer Trust we believe that it is essential to protect the privacy of client information. The nature and importance of our client relationships require the highest standards of confidentiality and discretion. Below is a summary of the non-public personal information that we may collect and maintain during the course of our relationship, our policy regarding the use of that information, and the measures we take to safeguard that information. We do not sell non-public personal information to anyone and only share it with others as described below.

Information We Collect
In the course of our business relationship, we obtain non-public personal information about clients, including:

  • Information we receive from you on applications, surveys, or other forms (such as your name, address, and social security number and information about your employment, income, assets, beneficiaries and investment objectives).
  • Information about your transactions with us, our affiliates or others (such as account activity, loan history, and transaction information from other banks and financial advisers with whom you work).
  • Information we might receive from outside agencies or other advisers or investment managers with whom you work.

Disclosure Policy
We do not disclose any non-public personal information about our clients or former clients to anyone, except as permitted by law to facilitate our services to our clients or as otherwise required by law. As allowed by law, we share information about current and former clients among our affiliates as necessary to help us service your account with us. We also provide non-public personal information to non-affiliated companies that require the information to provide specific services to client accounts.

Information Security
We have implemented procedures designed to restrict access to your non-public personal information to those employees who need it to perform their job responsibilities. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your non-public personal information.

This information is being provided in accordance with the provisions of Section V of the Gramm-Leach-Bliley Act and the regulations of the federal banking regulators issued thereunder.

INVESTMENTS ARE NOT FDIC INSURED OR GUARANTEED

Securities (including shares of mutual funds), alternative investments, and other investment products are not bank deposits and are not insured by the FDIC or any other agency of the United States, nor are they obligations of, or insured or guaranteed by, Bessemer Trust or any of its subsidiaries or affiliates. Securities (including shares of mutual funds) and other investments involve investment risks, including the possible loss of value.

NOTICE OF EXPIRATION OF THE TEMPORARY FULL FDIC INSURANCE COVERAGE FOR NONINTEREST-BEARING TRANSACTION ACCOUNTS

By operation of federal law, beginning January 1, 2013, funds deposited in a noninterest-bearing transaction account (including an Interest on Lawyer Trust Account) no longer will receive unlimited deposit insurance coverage by the Federal Deposit Insurance Corporation (FDIC). Beginning January 1, 2013, all of a depositor's accounts at an insured depository institution, including all noninterest-bearing transaction accounts, will be insured by the FDIC up to the standard maximum deposit insurance amount ($250,000), for each deposit insurance ownership category. For more information about FDIC insurance coverage of noninterest-bearing transaction accounts, visit: http://www.fdic.gov/deposit/deposits/unlimited/expiration.html.

PROHIBITION ON FUNDING OF UNLAWFUL INTERNET GAMBLING UNDER REGULATION GG

The Unlawful Internet Gambling Enforcement Act of 2006 (“the Act”) prohibits commercial clients (as defined in the Act) from conducting account transactions made in connection with unlawful Internet gambling (termed "Restricted Transactions" in the Act). Accordingly, Bessemer Trust prohibits the use of any Bessemer Trust account to engage in or process Restricted Transactions.

ELECTRONIC FUND TRANSFERS AND DISCLOSURES UNDER REGULATION E

You can request electronic fund transfers, such as direct deposits or withdrawals of funds and ACH transfers from personal accounts (each, a "Transfer") by contacting your Client Advisor. There are no charges for Transfers (although there is a $25 fee for wire transfers and a fee to enroll in Bessemer Trust's Centralized Bill Payment Service) and there are generally no limits on how often you can request a Transfer. In most cases you can request a Transfer of any amount up to the cash available in your account. To protect your account, however, Bessemer Trust will require increasing levels of verification depending on the size of the Transfer requested.

Statements and Your Rights Depending on your preferences, a quarterly or monthly statement will be mailed to you or your designee or made available to you via the client login at www.Bessemer.com. A statement will also be made available to you for every month in which you make a Transfer. We encourage you to review each statement promptly and carefully. If you see a problem with any Transfer, including Transfers that you do not recognize, please contact your Client Advisor immediately at the telephone number on your statement or at 212-708-9100. You can also contact us in writing at Bessemer Trust, 100 Woodbridge Center Drive, Woodbridge, New Jersey 07095, Attention: Client Administration Support. To ensure that the funds from any unauthorized Transfer can be returned to you, you have 60 days from the date of the first statement on which an unauthorized Transfer appeared to notify us of the problem (which time period may be extended if a good reason kept you from telling us).

When you contact us, please provide (i) your name and account number, (ii) the date and amount of the suspected error, and (iii) an explanation of why you believe there is an error or why you need more information. We will usually determine whether an error occurred within 14 days after hearing from you and we will correct any error promptly. In some circumstances, however, it may take up to 45 days for us to complete an investigation. If this extra time is required, we will credit your account within 14 days for the amount you think is in error so that you will have use of the funds during our investigation. We will tell you the results of our investigation within 3 business days after completing it. If we determine that there was no error, we will send you a written explanation, and we will provide supporting documentation upon your request.

Confidentiality Bessemer Trust will not disclose information about you or your Transfers except as permitted or required by law. For example, we will disclose such information to affiliated or unaffiliated service providers to facilitate the provision of our services to you, or to third parties in response to a subpoena or regulatory inquiry. For further information on Bessemer Trust's client privacy policies, please see above.

Right to Stop Transfers If you have told us in advance to make regular Transfers out of your account, you can stop any of these Transfers by calling the number on your statement or 212-708-9100 at least 3 business days or more before the Transfer is scheduled to be made, or by writing to us at Bessemer Trust, 100 Woodbridge Center Drive, Woodbridge, NJ 07095, Attention: Client Administration Support, in time for us to receive your request 3 business days or more before the payment is scheduled to be made. If you call, we may also require that you put your request in writing and send it to us within 14 days after your call. If you ask us to stop a Transfer 3 business days or more before the Transfer is scheduled, and we do not do so, we will be liable for your losses or damages.

Our Liability for Failure to Make Transfers If we do not complete a Transfer to or from your account on time or in the correct amount, we will be liable for your losses or damages. However, there are two exceptions: we will not be liable if (i) through no fault of ours, you do not have enough money in your account to make the Transfer, or (ii) circumstances beyond our control (such as fire, flood, or failure of a recipient's systems) prevent the Transfer, despite reasonable precautions that we have taken.

Direct Deposits If you would like to know whether a preauthorized transfer to your account has occurred, please call your Client Advisor at the telephone number on your statement or at 212-708-9100.

Business Days For purposes of these electronic fund transfer disclosures, Bessemer Trust's "business days" are any weekday except New Year's Day, Dr. Martin Luther King, Jr.'s Birthday, President's Day, Memorial Day, Independence Day, Labor Day, Thanksgiving Day and Christmas Day.