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

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.

HERITAGE TRUST COMPANY PRIVACY POLICY

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.

Definitions:

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.

HERITAGE TRUST 2020 FORM 1099 REPORTING

Each year, we mail Forms 1099 to our clients which report dividends, interest, gains and losses, and other income earned in client account(s).

The law requires we must mail Forms 1099-DIV, 1099-INT, 1099-OID, and 1099-MISC to clients no later than January 31st, and Form 1099-B by February 15th. However, the deadline is March 15th if these 1099 forms include items from Widely Held Fixed Income Investment Trusts (WHFITs), because such investments may not have tax information available by the earlier deadline. Clients can expect to receive their combined Form 1099 for 2020 to vary from January 31st to March 15th.

It is important that our clients receive the most accurate 1099 Tax Form(s) possible where Dividends are accurately categorized for tax purposes. To accurately segregate “qualified” dividends on your Form 1099, we must be provided with information from the companies paying dividends, primarily mutual funds, and real estate investment trusts (WHFITs). In many cases the information needed to properly categorize dividend income will not be available till early February 2021. As a result, many clients will not receive Form 1099 by the IRS deadline of February 15, 2021. We have requested and received a mailing extension from the IRS which moves our mailing deadline to March 15, 2021. Your Form 1099 will be mailed no later than March 15, 2021.

Please contact your account administrator should you have any questions or concerns.

Tax Reporting Specific to Individual Retirement Accounts

2020 Form 5498:

The Fair Market Value of your IRA as of 12/31/2020 appears on your statement and will be reported to the Internal Revenue Service on Form 5498 on an annual basis. If you hold hard-to-value assets, it is probable that the market value will be different between your year-end statement and your Form 5498. IRAs with these types of assets are required, by IRS rules, to annually update market values. These updates generally happen after year-end statements are issued but before the Form 5498 is mailed. A Form 5498 will be mailed to you by May 31st if you have a reported transaction (contribution, rollover, Roth conversion, or re-characterization) to your IRA for 2020.

Your form 5498 will also be used to notify the IRS of any Required Minimum Distributions for the 2021 tax year. See Required Minimum Distributions (RMD) section for specific notice dates.

2020 Form 1099-R:

If reportable distributions were made from your IRA, your Form 1099-R will be mailed by January 31st.

Charitable contributions made from your Individual Retirement Accounts (paid directly to the charitable organization) will be reported as a normal distribution on your 1099-R. Please consult with your tax advisor for proper reporting on your individual income tax returns.

If your IRA distributions are sent to you directly (meaning they were not sent directly to another custodian or trustee as a direct transfer), then we are not able to determine the taxability of this distribution. Distributions will be reported in Box 1 – Gross Distributions, Box 2a – Taxable Amount, and Box 2b – Taxable Amount Not Determined in situations where we are not able to determine the taxability.

Required Minimum Distribution (RMD):

Your Required Minimum Distribution notice for 2021 will be mailed by January 31st if you:

  1. Reach age 72 in the prior calendar year and were born after June 30, 1949 or
  2. Reach age 70 ½ in the prior calendar year and were born before July 1, 1949.

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