Updated 12/14/04

Primary Financial Company LLC ("Primary Financial") is one of the nation's largest providers of certificate of deposit services and it is committed to providing competitive and innovative products and services for the success of credit unions. In fulfilling its mission, Primary Financial has access to nonpublic personal information about its customers. Primary Financial values the protection of personal information and its use in a confidential manner, consistent with the requirements of its customers.

Primary Financial takes every reasonable precaution to protect the accuracy and integrity of nonpublic information. Primary Financial restricts access to nonpublic information to employees with a specific business purpose for use of the information. Primary Financial has established security procedures and security levels controlling employee access, as well as physical and electronic safeguards, which comply with existing regulations and which conform with standard industry practices to safeguard information.

Information is the cornerstone of Primary Financial’s ability to provide superior service and its most important asset is its customers' trust. Keeping customer information secure, and using it only as the law will permit, is a top priority for Primary Financial.

Primary Financial's policy is to satisfy all laws and regulations concerning the use and disclosure of nonpublic personal information about its corporate customers and their customers, and its corporate co-agents and their customer credit unions and their members, including the Securities and Exchange Commission Privacy Regulation, 17 C.F.R. Part 248 (the "SEC Privacy Regulation"). Under the SEC Privacy Regulation and other similar regulations, Primary Financial is limited in the manner it may use or disclose the nonpublic personal information it receives about the customers of its corporate customers and members of its customer credit unions. Primary Financial pledges to abide by these limitations.

Primary Financial collects nonpublic personal information about its natural person customers from the following sources: information received on application forms or other forms; and information about the customer’s transactions with Primary Financial, its affiliates, or others.

Primary Financial does not disclose any nonpublic personal information about customers and former customers to anyone, except as permitted by law. Primary Financial may disclose all of the information it collects as described above to companies that perform marketing services on its behalf or to other financial institutions with whom it has joint marketing agreements.

Primary Financial restricts access to nonpublic personal information about its natural person customers to those employees who need to know that information to provide products or services. Primary Financial maintains physical, electronic, and procedural safeguards that comply with federal regulations to guard the nonpublic personal information of its natural person customers.