Disclosure & Privacy Policies

Heritage Trust Company Disclosure Statement

Third-Party Service Providers: In order to effect, administer, or enforce a transaction requested or authorized by you, the customer, we may share your personal information with third-party service providers. 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 Heritage’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 the 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 Heritage, we will continue to adhere to the privacy policies and practices as described in this our Privacy Notice.

Internet Privacy: Like most websites, Heritage’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. Heritage does not rent, sell, trade, or otherwise disclose any personal information collected through our website. Any information you provide is for Heritage’s use only.

E-Mail: Please do not provide any account or personal information such as tax identification 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.

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 Heritage. The possibility of the receipt of such interest or other income was a factor in determining the total fees charged to your account.

Mutual Fund Fees: From time to time, Heritage may invest funds in mutual funds, bank deposits or other investments from which Heritage 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 your account.

Affiliated Entities: From time to time, Heritage 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, Origin Bancorp, Inc., is a minority (less than 10%) stockholder of Heritage’s parent, Argent Financial Group, Inc., 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: Heritage employs a third-party vendor for the processing for class actions. Class Action Settlements will be deposited from each successful claim, less processing fees.

Important Information About Procedures For Opening A New Account With Heritage 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, 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 officer or our internal anti-money laundering program coordinator. Thank you for your cooperation and understanding with this process.


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. heritage, 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.

Heritage 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.


Privacy Notice: Heritage Trust Company (dba Heritage Trust Company), an Oklahoma State-Chartered Trust Company, is aware that our customers count on us to place the highest importance on the privacy of their 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 your personal information. 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 personal information we collect and share depend on the product or service you have with us. This information can include:

Social Security Number
Account Balances
Transaction History
Checking and Savings Account Information
Wire Transfer Instructions
Assets and Investment Experience

We may collect personal information, for example, when you:

Open an account
Make deposits or withdrawals from your account
Provide account information or give us your contact information
Direct us to buy or sell securities

When you are no longer a customer, we continue to share your information as described in this notice.

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.


Affiliates: Companies related by common ownership or control. They can be financial or nonfinancial companies. Our affiliates include

Argent Trust Company of Tennessee, AmeriTrust Corporation, Argent Retirement Plan Advisors, LLC, Argent Advisors, LLC, Argent Fiduciary Consulting Services, LLC, Argent Insurance Services, LLC, Argent Mineral Management, LLC, Highland Capital Management, LLC, and Wynden Capital Management, LLC.

Non-Affiliates: Companies not related by common ownership or control. They can be financial and nonfinancial companies.

Heritage Trust Company does not share with non-affiliates so they can market to you.

Joint Marketing: A formal agreement between non-affiliated companies that together market financial or non-financial products or services to you.

Heritage Trust Company does not jointly market.

Notice To Consumers Who Are Residents Of California:

I. Your Rights: The California Consumer Privacy Act (“CCPA”) grants California residents (“Consumers”) or another person authorized to act on behalf of the consumer, the right to:

A. Know what personal information Heritage Trust Company, including its subsidiaries and affiliates, has collected about you during the prior twelve months;

B. Know where Heritage Trust Company sells your personal information, and if so, to whom;

C. Give or withhold consent for Heritage Trust Company to sell your personal information;

D. Request that Heritage Trust Company disclose to you:

1. The categories of personal information collected about you;
2. The categories of sources from which the personal information is collected;
3. The purpose for collecting the personal information;
4. The categories of third parties with whom Heritage Trust Company shares personal information; and
5. The specific pieces of personal information collected about you.

E. Request that Heritage Trust Company delete your personal information, to the extent possible; and

F. Receive non-discriminatory services and product pricing from Heritage Trust Company, regardless of whether you exercise your privacy rights under the CCPA.

II. What Information Is Covered? Personal information is defined under the CCPA to include any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with a particular consumer of household. Examples include social security numbers, account information, transaction histories, and other biometric data.

III. What Information Is Not Covered? Much of the personal information Heritage Trust Company collects is already regulated by federal and state laws, and therefore is exempt from the CCPA. For instance, the CCPA does not apply to personal information collected or disclosed in connection with financial products or services that are used primarily for personal, family, or household purposes. The CCPA also does not apply to personal information that reflects a communication or transaction between Heritage Trust Company and another company, partnership, sole proprietorship, non-profit, or government agency, so long as that communication or transaction involves due diligence about Heritage Trust Company or other business, or Heritage Trust Company is providing or receiving a product or service. The CCPA also currently does not afford access or deletion rights to you if your information was collected and used by Heritage Trust Company in the context of your role as a job applicant, employee, director, officer, medical staff member, or contractor.

IV. Your Choices Under the CCPA, a consumer who is a resident of California has the right to request that Heritage Trust Company delete any personal information about the consumer which Heritage Trust Company has collected from the consumer. Heritage Trust Company is not required to comply with a consumer’s request to delete if it is necessary to maintain the consumer’s personal information in order to, for example:

1. Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of the ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer;

2. Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with Heritage Trust Company; or

3. Comply with a legal obligation, such as a regulatory requirement to retain information for a period of time.

Consumers who are residents of California may request that Heritage Trust Company disclose to the consumer the specific pieces of personal information that Heritage Trust Company has collected about the consumer and may request deletion of their personal information by calling the toll-free number 800-375-4646 or emailing compliance@argenttrust.com. However, as noted above, there are provisions of the California Consumer Privacy Act of 2018 that permit us to retain your personal information, in which case we may be unable to fulfill your request.

Currently, Hertiage Trust Company, its subsidiaries and affiliates, do not sell your personal information. If in the future, Heritage Trust Company, its subsidiaries and affiliates, seeks to sell the personal information of California residents, it will provide notice and the opportunity to opt-out. California residents Heritage Trust Company knows to be under the age of sixteen (16) would be opted out of the sale of their personal information.


Tax Guide For 2022

Mailing Schedule:
Heritage follows the Internal Revenue Service mailing deadlines for the delivery of tax data.  The below schedule will help you determine when your tax documents will be ready.  1099 tax form readiness is directly dependent upon the assets held within your account.

1099 Tax Information covered by forms:

Form Title
1099-B Proceeds from Broker and Barter Exchange Transactions
1099-INT Interest Income
1099-DIV Dividends and Distributions
1099-OID Original Issue Discount
1099-MISC Miscellaneous Income
1098 Mortgage Interest Statement

*Our annual policy is to apply for a 30-day extension with the IRS which allows us to receive information provided by security issuers and apply this information to your tax forms (1099-B, DIV, INT, & OID).   

January 31, 2023:
Form 1099 will mail for accounts who holds more simple assets that do not require reclassification of income or additional information to provide an accurate tax document.  Examples of these assets are stocks and bonds.  However, it is highly likely that most client’s 1099-DIOB Forms will have an initial mailing starting on February 15th.

Form 1098 & Form 1099-MISC will be mailed by this date.

February 15, 2023:
Form 1099 will mail for accounts holding certain mutual funds, Unit Investment Trust, REITs, and certain equities not released in the January 31 mailing, provided we have received final 2022 tax information from the security issuers.  Your account will be processed by the next deadline if you hold assets for which security issuers have not yet published final 2022 tax information.

February 28, 2023:
Form 1099 will mail for accounts where we received income reclassifications after the February 15th mailing deadline.  This typically impacts certain mutual funds and REITS.

March 15, 2023:
Form 1099s will mail for all remaining accounts regardless of whether security issuers have released income reclassification data.  If you hold Real Estate Investment Conduits (REMICS), Widely Held Fixed Investment Trusts (commonly referred to as WHFITS) including  UITs, royalty trusts, mortgage-back securities, commodity trusts, or complex securities that derive their values based on holding these types of assets, you can expect your tax data will process in the March 15th period.

Tax Worksheets for K-1 preparation:
Our tax worksheets will follow the above schedule based on the assets held by the respective trust and provided we have had adequate time to review the worksheet.

Tax Reporting for Retirement Accounts

Payer Information:
ATCTN LLC is the payer listed on IRS Form 1099-R where we are custodian.

1099-R Form:
If reportable distributions were made from your IRA or other retirement accounts, your tax forms will be mailed by January 31, 2023.

5498 Form:
We will submit to the IRS information that is covered by Form 5498 for all IRA accounts.  We will prepare and mail your Form 5498 by May 31, 2023.  Form 5498 will provide the IRS the fair market value of your account as of December 31, 2022.  This value may be different than that reported on your annual IRA statement if you hold hard-to-value assets.  It is important that you provide your account administrator with updated 2022 asset valuations if you have directed investments into non-marketable assets or hard-to-value assets within your IRA.  This will ensure that your account’s market value data is accurately reflected per IRS regulations.

2023 Required Minimum Distributions:
We will be furnishing IRA accountholders an RMD notice for tax year 2023 by January 31, 2023. This notice will be provided to any accountholder who attains age 72 in 2023 or is already 72 or older. The IRS recently released new life expectancy tables for RMD calculations. These revised tables will be used to calculate 2023 RMD notices.

Corrections to Tax Forms
The IRS requires corrected information be provided to clients where this information becomes available.  Updated income classifications are one reason for a corrected form to be mailed.  We will distribute the corrected forms as quickly as possible for you and your tax preparer to determine your course of action regarding the correction.

Taxpayer Identification Number:
Please check your name and TIN (Tax ID number) on the tax form received for accuracy.  If your legal name, your TIN, or your legal address are incorrect, please take immediate action by contacting your Relationship Manager or Administrator.  We will require a signed IRS Form W-9 (Request for Taxpayer Identification Number and Certification) to update our information and correct the tax form.  Mismatches in either your legal name or TIN can cause IRS filing and reporting issues.  To avoid these, please validate our information about you is correct.

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