Privacy Statement

Privacy at a Glance

Wachovia Securities¹ is dedicated to protecting your privacy and providing you with the highest level of service. We want you to understand how we gather and may share client information at Wachovia Securities, the choices you have, and how we protect that information in everything we do.

You Have Choices

• You may direct us not to contact you for marketing purposes by:
• Telephone
• Direct mail
• E-mail.
• You may direct us not to allow Wachovia companies to share or use information about you in two ways
• Do not share, with other Wachovia companies, credit information about you that we receive from you or others; and
• Limit Wachovia companies from marketing their products and services to you based on credit or transaction information about you that they receive from other Wachovia companies (this option is available beginning October 1, 2008, and is fully described in the section below titled "Your Choice to Limit Use of Information for Marketing").

How to Reach Us to Exercise Your Choices

• Visit a Wachovia Financial Center or Wachovia Securities Office.
• Call us at 1-866-203-5722 to speak to a representative (Command Asset Program, IRA, Brokerage, and Insurance clients should call 1-877-358-1114).
• Complete our Consumer Privacy Preferences form.

How We Protect Client Information
 
Keeping financial information secure is our responsibility and our commitment to you.

• We protect client information through physical, electronic, contractual and procedural measures that comply with or exceed applicable laws and standards.
• We train our employees to protect client information and only authorize access for employees who we believe have a business need for that information. Employees are held accountable by Wachovia Corporation's Code of Conduct and Ethics to properly protect client information.
• We maintain policies and procedures that provide for the proper physical security of workspaces and records.
• We require contractors and other companies that provide services on our behalf to protect information, and we prohibit those companies from using it for any other purpose. We only provide them with information that we believe is necessary to fulfill their responsibilities or to provide a financial service to you.
• Protecting information about our clients online is an essential part of our service to you. For more information on our Internet Security and Privacy practices, please visit wachoviasec.com/gotoprivacy.

¹This Privacy Statement explains how we handle and protect information and replaces any Privacy Statements previously provided. The Privacy Statement applies only to consumers who are clients or former clients of Wachovia Securities and have established relationships with Wachovia Securities in the United States. Wachovia Securities is the trade name used by two separate, registered broker-dealers and nonbank affiliates of Wachovia Corporation providing certain retail securities brokerage services: Wachovia Securities, LLC, Member NYSE/SIPC, and Wachovia Securities Financial Network, LLC, Member FINRA/SIPC. The policies and practices described in this Privacy Statement are subject to change, but we will notify you if there are significant changes. This Privacy Statement is issued as of February 2008.

If you believe you are a victim of fraud or identity theft, please contact us at 1-888-647-3648 for assistance, which may include placing holds on your accounts.

The section above is a summary. It is important that you read the rest of this Privacy Statement for a more detailed explanation of our privacy practices.

Section Links:
 
How We Gather Client Information
 
Sharing Client Information Within Wachovia Corporation
 
Sharing Client Information Outside of Wachovia Corporation
 
How We Use Client Information
 
Your Privacy Choices at Wachovia
 
When Financial Advisors Leave Wachovia Securities
 
How to Protect Yourself
 
If You Believe You May Be a Victim of Fraud or Identity Theft
 
How to Limit Direct Marketing from Other Companies
 
Maintaining Accurate Information
 
If You Have Questions, Contact Us
 
Other Applicable Laws
 
Your Choice to Limit Use of Information for Marketing
 
  How We Gather Client Information

We gather information about you to help us better understand your financial needs and to provide you with more personalized and efficient service. For example, this information may prompt us to suggest overdraft protection for your checking account, or recommend an investment product.

The information we gather comes from a variety of sources, including:

• Information you provide to us (such as name, address and telephone number).
• Information about your transactions with Wachovia Securities(such as account balance and payment history).
• Information we receive from credit reporting agencies and other companies and agencies (such as your credit history).

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Sharing Client Information Within Wachovia Corporation
 
Wachovia Corporation includes several related companies. These companies operate in a variety of business lines, such as banking, credit cards, consumer loans, insurance, securities and others. We may share client information about you among the companies that make up Wachovia Corporation, including:

• Information based on your transactions with us (for example, information that we would collect about your loan amounts and deposits with us in order to offer you a rate based on total balances) and contact information (such as your name and address).
• Credit information received from you or others (such as information from your credit application or your employment or credit history) to evaluate your eligibility for various financial services (for example, a home equity loan at a special rate).

You may tell us not to share credit information with other Wachovia companies.* For more information, on how to exercise this option, see the section below entitled Your Privacy Choices at Wachovia.

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Sharing Client Information Outside of Wachovia Corporation

We do not provide client information to companies outside of Wachovia Corporation, except as outlined below. You do not need to request this confidentiality - it is our standard practice.

We may provide all of the information we gather to:

• Companies that perform business operations for us (such as check printing).
• Companies that act on our behalf to market our services, or financial institutions with whom we have entered into a joint marketing agreement in order to provide you with valuable financial products and services.*
• Others as permitted or required by law (such as to protect against fraud or in response to a subpoena).

Our policies for sharing client information, both within and outside of Wachovia as described above, also apply to all of the information we have gathered about former clients of Wachovia.

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How We Use Client Information

The client information we gather helps us to better understand your financial needs and to provide you with superior service by offering the right services at the right time. We may use the information among Wachovia companies and other authorized entities, for the following purposes, among others:

• To protect your accounts from unauthorized access or fraud.
• To provide you with the products and services you requested.
• To service your accounts.
• To inform you about financial products and services that may be of interest to you.

 

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Your Privacy Choices at Wachovia

Because we recognize that you may wish to limit the ways in which we contact you for marketing purposes, we offer the following options. You can choose not to be contacted for marketing purposes by:

You also have choices about how information about you is shared or used within Wachovia. You may choose the following options:

If you are comfortable with the ways in which we contact you currently, there is no need to indicate your preferences. To discuss your options, inform us of a preference, or provide us with feedback, call us at 1-866-203-5722 (Command Asset Program, IRA, Brokerage, and Insurance Clients should call 1-877-358-1114), visit a Wachovia Financial Center or Wachovia Securities Office, or visit us on the web at wachoviasec.com/gotoprivacy.

Whatever your preferences, we will honor your wishes and respect your privacy. Your preferences will remain in effect until you tell us otherwise. You do not need to notify us if you have already indicated your preferences to us. If you contact us, we will assume your preferences apply to you only - unless you tell us that they also apply to other individuals listed on your accounts.

Please note that we are committed to providing you with superior service. We may contact you to resolve a problem or to service your accounts even if you have asked us not to contact you for marketing purposes. For example, if we notice unusual activity on your credit card, we may contact you to verify your purchases and confirm you authorized them. If you choose not to be contacted by direct mail for marketing purposes, you will continue to receive the marketing information that accompanies your usual account mailings and statements. our usual account mailings and statements. You may also be contacted by your Financial Advisor, Branch Manager, or Financial Center Relationship Manager.

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When Financial Advisors Leave Wachovia Securities.
 

Wachovia Securities recognizes that your relationship with your financial advisor is important. If your financial advisor's affiliation with Wachovia Securities ends and he or she joins a non-affiliated securities broker-dealer with which Wachovia Securities has entered into an agreement regarding the movement of financial advisors between firms, Wachovia Securities will permit the financial advisor to use certain client contact information to solicit clients to join the financial advisor's new firm. The client contact information that the financial advisor may use is limited to your name, address, email address, phone number and account title.

If your financial advisor is affiliated with Wachovia Securities Financial Network, LLC (WSFN) and the financial advisor's relationship with WSFN is terminated, your WSFN financial advisor will also be permitted to retain originals or copies of all client and account documentation for the purpose of continuing the relationship with you and servicing your account through the financial advisor's new firm. Wachovia Securities Financial Network, LLC will also retain your client and account documentation.

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How to Protect Yourself
 
At Wachovia, we're committed to client protection, which includes protecting personal information about you as well as providing you with ways to protect yourself. We recommend that you follow these security measures to protect and help prevent potential misuse of personal information about you:

• Protect and properly dispose of your account records.
• Do not share account information, passwords, user ID's, PINs, code words or other confidential information with others.
• Do not provide confidential information by telephone to unknown callers.
• Do not provide confidential information online unless you initiated the contact, know the party with whom you are dealing, and provide the information through a secure channel.
• When conducting business over the Internet, always use a secure browser, exit online applications as soon as you finish using them, and make sure you have virus protection and a firewall and update them regularly.
• Monitor your credit report for accuracy. By law, you are entitled to receive one free credit file disclosure every 12 months from each of the nationwide consumer credit reporting companies. To learn more or request a copy of your credit report, visit annualcreditreport.com or call 1-877-322-8228.
• For additional information, please visit wachoviasec.com/gotosecurity or call us at 1-888-647-3648

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If You Believe You May Be a Victim of Fraud or Identity Theft
 
Contact us at 1-888-647-3648 to place holds on your accounts, obtain a free copy of Wachovia's Client Fraud Assistance Package or for other assistance.

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How to Limit Direct Marketing from Other Companies
 
To reduce the marketing materials you receive from companies other than Wachovia:
 

1. Contact the Credit Reporting Industry's pre-screening opt out number (1-888-567-8688 or visit optoutprescreen.com). This should remove your name from credit reporting industry databases used for making pre-approved credit solicitations.
2. Add your telephone number to the National Do Not Call Registry. You may either call 1-888-382-1222 or register online at donotcall.gov. While this will stop many calls, you may still receive calls from businesses where you are a client.

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Maintaining Accurate Information
 

It is important to keep information about your accounts accurate and up to date. If you ever believe that our records contain inaccurate or incomplete information about you, please let us know immediately by contacting us at 800-WACHOVIA (800-922-4684). We are committed to resolving any inaccuracies as quickly as possible.

Credit Reporting Agencies
If you believe we have reported inaccurate information about your account to any credit reporting agency, please let us know in writing. Be sure to include your complete name, current address, Social Security Number, telephone number, account number, type of account, specific item of dispute and the reason you believe the information is wrong. Send your notice to: Wachovia Bank, N.A., P.O. Box 3117, Winston-Salem, NC 27102. We will investigate your concern and correct any inaccuracies we find. We will inform you of any actions we take.

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If You Have Questions, Contact Us
 

We welcome the opportunity to answer any questions you may have about this statement or the safeguarding and confidentiality of information about our clients. Please visit our web site at wachoviasec.com/gotoprivacy, visit a Wachovia Financial Center or Wachovia Securities Office, or call us at 1-866-203-5722 (Command Asset Program, IRA, Brokerage, and Insurance clients should call 1-877-358-1114) to speak to a representative.

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*Other Applicable Laws
 
The practices described above are in accordance with federal law. You may have other protections under applicable state laws, such as those in Vermont, California and Nevada. To the extent these state laws apply, we will comply with them when we share information about you. For example, Vermont law places additional limits on sharing information about Vermont residents. As long as he or she remains residents of Vermont, we will not share information we collect about Vermont residents to companies outside of Wachovia, except:

• To companies that perform marketing or other services on our behalf;
• Contact information (like name and address), and transaction information (such as your payment history) to other financial institutions with which we have joint marketing agreements;
• With the authorization or consent of the Vermont resident; or
• As permitted or required by law.

We also will not share within Wachovia companies credit information about a Vermont resident received by another Wachovia company except with the authorization or consent of the Vermont resident.

Do Not Call Policy: This Privacy Statement constitutes Wachovia's Do Not Call Policy under the Telephone Consumer Protection Act for all consumers.

For Nevada residents: At any time, you may request to be placed on Wachovia's internal do not call list by following the instructions in the Your Privacy Choices at Wachovia section above. Nevada law also requires that we provide you with the following contact information:

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Your Choice to Limit Use of Information for Marketing
 
Wachovia Securities¹ is providing this notice.

You may limit Wachovia companies, such as the Wachovia banking, insurance and securities affiliates, Evergreen companies, American Mortgage Network, Inc. doing business as Vertice, GE Capital Administrative Services, Inc., GE Capital Management Corp., GE Capital Warranty Corp., Heritage Indemnity Company, Heritage Mechanical Breakdown Corp., J.L. Kaplan Associates, LLC, Metropolitan West Capital Management, LLC, Tattersall Advisory Group, Inc., Westlake Group Ltd., and Westlake Insurance Company, Ltd., from marketing their products or services to you based on credit or transaction information about you that they receive from other Wachovia companies. This information includes your account balance, payment history, and your credit history.

Your choice to limit such marketing offers from Wachovia companies will apply until you tell us to change your choice.

If you have already made a choice to limit such marketing offers from Wachovia companies, you do not need to act again.

To limit such marketing offers, contact us:

• By telephone: 1-866-203-5722 (Command Asset Program, IRA, Brokerage and Insurance clients should call 1-877-358-1114);
• On the Web: wachovia.com/privacy; or
• Visit a Wachovia Financial Center or Wachovia Securities Branch Office.

However, when you choose this option to limit the use of this information by other Wachovia companies to market their products and services to you, your choice does not apply to any Wachovia company that has an existing business relationship with you or where the use is otherwise permitted by law, including the use of information made available to that Wachovia company prior to October 1, 2008.
 

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