Privacy Notice & Other Disclosures

Privacy Notice: Argent Trust Company (ATN), a Tennessee state trust company, is aware that our customers count on us to place the highest importance on the privacy of personal information and financial dealings with our companies. This information is necessary for us to provide the financial products and exceptional customer service to you. We are providing you with the following information regarding our privacy policy and our commitment to safeguard your personal information.

Confidentiality and Security: We recognize the need for privacy when dealing with personal financial information. We maintain physical, electronic and procedural safeguards that comply with federal standards to store and secure information about you from unauthorized access, alteration and destruction.

Federal law gives consumers the right to limit some, but not all, sharing.  Federal law also requires us to tell you how we collect, share and protect your personal information.  Please read this notice carefully to understand what we do.

Information We Collect: The types of nonpublic personal information we collect and share depend on the product or service you have with us.  This information may include but not be limited to:

  • Social Security Number
  • Account Balances
  • Transaction History
  • Checking Account Information
  • Wire Transfer Instructions

We may collect nonpublic personal information about you from the following sources:

  • Information we receive from you on account applications or other forms.
  • Information about your transactions with our affiliates, others, or us.

Following are some examples of how we may collect this information:

  • When you open an account
  • When you make deposits or withdrawals from your account
  • When you make a wire transfer
  • When you show your government-issued ID.

Information We May Share:

All financial institutions need to share customers’ personal information to run their everyday business.  In the section below, we list the reasons financial institutions can share their customers’ nonpublic personal information; the reasons we choose to share; and whether you can limit the sharing.

In order to effect, administer, or enforce a transaction requested or authorized by you, the customer, we may share customer information with third party service providers only in accordance with strict confidentiality. We will share information in accordance with applicable law. We do not disclose any nonpublic personal information about you to unaffiliated third parties for them to rent, sell, trade, or for their independent use.

Employee Access to Information: All employees must adhere to ATN’s policy on confidentiality. Employee access to customer information is authorized for business purposes only, and the degree of access is based on the sensitivity of the information and on an employee’s need to know in order to service the customer’s account or comply with legal requirements.

Inactive Customers and Closed Accounts: Should you ever decide to close your account(s) or become an inactive customer at ATN, we will continue to adhere to the privacy policies and practices as described in this notice.

Internet Privacy: Like most websites, ATN’s website gathers and maintains statistics about the number of visitors. However, visitors to our website are anonymous except where registration is required and cookies are used to improve your online experience. ATN does not rent, sell, trade, or otherwise disclose any personal information collected through our website. Any information you provide is for ATN’s use only.

E-Mail: Please do not provide any account or personal information such as Social Security numbers, account numbers, or account balances within your e-mail correspondence to us. We cannot use e-mail to execute transaction instructions, provide personal account information, or change account registration.

Your confidence in us is important and we want you to know that your personal and account information is safe. If you have any questions or concerns, please contact us.

Funds awaiting investment or distribution:  All cash or cash equivalents received for your account are generally invested or swept into a money market fund or other interest bearing investment during the normal course of business. Distributions are removed from the account and from investment and other interest bearing accounts on the business day that distributions are processed. Depending on the timing of the collection of funds received and distributed and the availability of those funds, interest or other income may be earned on funds held for investment, sweep or distribution. Such interest or other income may be paid to ATN. The possibility of the receipt of such interest or other income was a factor in determining the total fees charged to each account or trust.

Mutual Fund Fees:  From time to time, ATN may invest funds in mutual funds, bank deposits or other investments from which ATN may receive financial benefits. These benefits may include receipt of certain fees (such as 12b-1 fees) or other income for providing services to clients of these investments. These benefits may result from shareholder servicing, administrative, and accounting services, by example. The possibility of the receipt of these financial benefits was a factor in determining the total fees charged to each account or trust.

Potential conflict of interest disclosure:  From time to time, ATN may invest funds in deposits of Origin Bank and may receive financial benefits in the form of interest or other income from that bank as disclosed above. Origin Bank’s parent is a minority (less than 10%) stockholder of ATN’s parent and both entities have other mutual contractual relationships. The ownership interests and other relationships may create a conflict of interest. You may write your account officer to request that your account not be invested in Origin Bank deposits.

Please contact your account officer to request current prospectuses or if you have any questions regarding this disclosure.

Class Action Litigation:  ATN will participate in class action litigation only when deemed beneficial to the account by ATN. Should the account holder desire to participate in class action litigation not deemed beneficial by ATN, the account holder accepts full responsibility for gathering information required to participate and holds ATN harmless for any performance of the litigation.

Important Information About Procedures For Opening A New Account With Argent Trust Company

To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account.

What this means for you:  When you open an account or establish a trust, we will ask you for your name, address, date of birth (in the case of an individual), taxpayer identification number, and other information that will allow us to identify you. We may also ask to see your driver’s license or other identifying document in order to verify the information that you have provided to us. We are required by law to attempt to match the information provided by you against lists issued by various governmental agencies to confirm that you are not a known or suspected terrorist or in any way affiliated with a known or suspected terrorist group.

If you have any questions about this process, please discuss them with your account or trust officer or our internal anti-money laundering program coordinator. Thank you for your cooperation and understanding with this process.

Pricing

Pricing for securities traded on the exchange is provided by third party sources.  While sources used for pricing publicly traded securities are considered reliable, the prices displayed on your statement may be based on actual trades, bid/ask information or vendor evaluations.  As such, the prices displayed on your statement may or may not reflect actual trade prices you would receive in the current market.  It is possible prices for certain securities may vary widely at the time of trade execution in comparison to valuation prices displayed for statement purposes.    Securities not traded on an exchange are valued by a variety of sources, which may include issuer-provided or client-provided information.  ATN, including any of its affiliates, does not guarantee the accuracy, reliability, completeness or attainability of any pricing information provided by third party sources.

Objection To Disclosure of Beneficial Ownership

In an effort to permit direct communications between a company which issues securities and the shareholder who votes the securities, the Securities and Exchange Commission (SEC) has adopted a rule, referenced as 14b-1, “Shareholders Communication Act”.

For your protection, the Rule prohibits the requesting company from using your name and address for any purpose other than corporate communications.

ATN is authorized to refuse to disclose the Owner’s name, address, and security position(s) of current and/or future holdings that the Owner(s) may own from time to time pursuant to SEC Rule #14b-1.

Please contact your account officer to request current prospectuses or if you have any questions regarding this disclosure.

Argent Advisors Privacy Policy

 Argent Advisors, Inc., an SEC registered investment adviser, (“Argent”), maintains physical, electronic, and procedural safeguards that comply with federal standards to protect clients’ nonpublic personal information (“information”). Through this policy and its underlying procedures, Argent attempts to secure the confidentiality of customer records and information and protect against anticipated threats or hazards to the security or integrity of customer records and information.

It is the policy of Argent to restrict access to all current and former clients’ information (i.e., information and records pertaining to personal background, investment objectives, financial situation, tax information/returns, investment holdings, account numbers, account balances, etc.) to those employees and affiliated/nonaffiliated entities who need to know that information in order to provide products or services to the client. Argent may disclose the client’s information if Argent is: (1) previously authorized to disclose the information to individuals and/or entities not affiliated with Argent, including, but not limited to the client’s other professional advisors and/or service providers (i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser, account custodian, etc.); (2) required to do so by judicial or regulatory process; or (3) otherwise permitted to do so in accordance with the parameters of applicable federal and/or state privacy regulations. The disclosure of information contained in any document completed by the client for processing and/or transmittal by Argent in order to facilitate the commencement/continuation/termination of a business relationship between the client and a nonaffiliated third party service provider (i.e., broker-dealer, investment adviser, account custodian, insurance company, etc.), including information contained in any document completed and/or executed by the client for Argent (i.e., advisory agreement, client information form, etc.), shall be deemed as having been automatically authorized by the client with respect to the corresponding nonaffiliated third party service provider. Argent permits only authorized employees and affiliates who have signed a copy of Argent’s Privacy Policy to have access to client information. Employees violating Argent’s Privacy Policy will be subject to Argent’s disciplinary process. Additionally, whenever Argent hires other organizations to provide services to Argent’s clients, Argent will require them to sign confidentiality agreements and/or the Privacy Policy. Certain of Argent’s personnel are also in their individual capacities representatives and or employed by an unaffiliated broker dealer. Argent may provide information to that broker dealer in response to that broker dealer’s request for information pursuant to that broker dealer’s regulatory and or compliance requirements. To the extent that any Argent clients have a question or concern about this information sharing, please call the Argent office regarding a potential opt out from this sharing.

Should you have any questions regarding the above, please contact Vicki Tindall, at (318) 324-8000.

Email Disclosure

As a company policy, we do not accept any voice mail or email instructions. Any information you submit to us over the Internet is by definition insecure and could be observed by a third party while in transit. If you wish to submit personal financial information or other information you would like to keep private, it would be safer for you to send it to us in a more secure mode (mail, fax, overnight courier, etc.).

This communication, together with any attachments hereto or links contained herein, is intended for the use of the intended recipient(s) only and may contain information that is confidential or legally protected. If you are not the intended recipient, you are hereby notified that any review, disclosure, copying, dissemination, distribution or use of this communication is STRICTLY PROHIBITED. If you have received this communication in error, please notify the sender immediately by return e-mail message and delete all copies of the original communication, along with any attachments hereto or links herein, from your system.

Please contact us if there are any changes in your personal or financial situation that might require a change in your investment objectives or if you would like to request any changes in the services we provide to you. A current copy of our written disclosure statement is available upon request.