Protecting Your Privacy
Privacy policies and practices at Marshall & Ilsley Corporation (M&I)

M&I’s history began in 1847, and today, M&I ranks among the nation’s oldest and largest financial institutions. For more than 160 years, our commitment to our customers has remained unchanged. We will continue to help you build financial security by providing you with expert advice and a wide range of quality products and services. We will also continue to serve you with integrity and discretion at all times.

Keeping your information confidential and secure is an important part of our responsibility to you… and we take this responsibility very seriously. This notice describes our policies and practices that protect your information. We also provide you with options about how your information may be shared within M&I and with others as required or permitted by law -- including those who may work with us to better serve your needs.

Please read on to learn more about the ways in which we are working to protect your privacy. We recognize and value the trust you have placed in us, and as always, we will continue to serve you with integrity and respect in the years to come.

Background Note: The privacy policies and practices described here apply to the M&I affiliates identified below. These policies may be amended at any time. We will keep you informed of any applicable changes as required by law.

Some of the terms used in this notice include the following:

• “Affiliates” include companies related to M&I through common control or ownership. We refer to our affiliates as members of the M&I family.
• “Customer” refers to individuals who apply for or use products and services primarily for personal, family or household purposes that are provided through the M&I affiliates listed in this notice, or have done so in the past.
• “Nonaffiliated third parties” include third parties that are not members of our corporate family, but with whom we may have a special arrangement or joint marketing agreement.
• “Nonpublic personal information” refers to customer information available to M&I through the collection of information described in this notice.

1. We apply high standards of confidentiality and security in order to safeguard your nonpublic personal information.

Our employees access nonpublic personal information in relation to their job functions and the services they provide to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

On our Web site(s), we use a full range of Internet security measures such as data encryption, Secure Socket Layer technology, and multi-factor authentication. Please note, however, that when you use a link from our Web site(s) to a non-M&I site, M&I privacy policies and Internet security measures no longer apply.

2. By collecting and maintaining accurate nonpublic personal information, we learn more about your needs and are better able to provide superior customer service to you.

We collect and maintain nonpublic personal information in order to:

• Protect your accounts from unauthorized access or identity theft.
• Help ensure the security of your transactions with M&I, including online transactions.
• Service your accounts accurately and efficiently.
• Provide you with products and services designed to match your needs now and in the future.
• Introduce you to special offers and opportunities available through the M&I family and others.

The nonpublic personal information we collect may include:

• Information we receive from you on applications or other loan and account forms, such as your name, address, assets and income.
• Information about your transactions with us, our affiliates or others, and information to verify representations made by you, such as your account balance, payment history, parties to transactions, and credit usage.
• Information we receive from third parties, including credit bureaus, such as your creditworthiness, credit score and payment history.
• Information we obtain regarding your employment, credit or other relationships, such as your employment history.
• Information submitted by you for insurance applications or claims, such as medical information, that is used exclusively for the specific purposes you have authorized.

Collection of information on our Web site(s) may include data such as pages visited, downloads, other Web sites from which visitors arrive, and the types of operating systems and browsers used. We collect this information to personalize the information displayed and to enhance the performance of the site. M&I may also offer online planning tools, such as calculators, to help you evaluate your personal finances or decide whether an M&I product is right for you. Information obtained through online planning tools, or online payments and transfers, may be used in connection with the transaction you initiate.

3. Information sharing and marketing is limited. It is important to note that M&I does not sell or share your nonpublic information with companies outside of the M&I family so they can market their products to you.

Information sharing with affiliates: In our efforts to better serve your financial needs, we may share the nonpublic personal information we collect as described above with M&I affiliates. We want to be sure we understand your entire relationship with us when addressing your needs, providing you services, developing products and determining what products you may want to know about.

You may ask us not to share certain credit information with M&I affiliates including:

• Information we obtain from your application, such as your income, assets, or employer.
• Information we obtain from a consumer report, such as your credit score or credit history.
• Information we obtain to verify representations made by you, such as your creditors or assets.
• Information we obtain from another person regarding your employment, credit or other relationships, such as your employment history.

You have a choice as to whether or not you want this information shared among our affiliates. If you prefer that we not share this information within the M&I family, you may opt out. However, even if you have opted out, we may still share this information with certain M&I affiliates that perform technical or operational support services. These services include approving applications, preparing documents and account statements, and servicing your accounts. We also share information with M&I affiliates, where permitted by law, about your transactions and experiences with us (such as your account balances and transaction history), even if you have opted out.

Affiliate marketing limits: You may limit M&I affiliates from marketing their products or services to you based on information that we share with them, such as your income, your account history, and your credit score. Your decision to opt out of marketing offers from M&I affiliates will not expire unless you tell us to change your choice. This limitation does not apply in certain circumstances, such as if you currently do business with one of our affiliates or if you ask to receive information or offers from them.

Information sharing with nonaffiliated third parties: We may share nonpublic personal information we collect as described above with nonaffiliated third parties, such as:

• Third parties that provide services necessary to effect, administer or enforce a transaction that you request or authorize.
• Credit bureaus or similar reporting agencies.
• Law enforcement officers and governmental agencies and courts as required by a subpoena, court order or law.
• Third parties that perform marketing or other services on our behalf.
• Other financial institutions with whom we have joint marketing agreements.
• Others to the extent permitted or required by law.

We may share your nonpublic personal information with the types of nonaffiliated third parties described directly above, even if you have opted out.

Information sharing in private-label credit card and affinity programs: You may receive M&I products or services, such as an M&I credit card, through a private-label credit card or affinity program sponsored by a nonaffiliated third party. As part of your participation in the program, the program sponsor may offer benefits to you, such as products or services offered by retail merchants as well as other M&I services. We may share nonpublic personal information collected as a result of your participation in a private-label credit card or affinity program with the program sponsor to assist the sponsor in making offers of other products or services to you, where permitted by law.

Other Applicable Laws. You may have other protections under applicable state laws, including, by way of example, those provided to residents of Vermont and California. To the extent these state laws apply, we will comply with them.

5. Additional information to help you.

Furnishing Negative Information. We may report information about your account to credit bureaus. Late payments, missed payments, or other defaults on your account may be reflected in your credit report.

Access to accounts. If you believe someone has accessed your accounts without authorization, or if someone has discovered your personal identification number (PIN), Personal Security Code, user name or password (“Codes”), please notify us at 1-888-464-5463 as soon as possible. Please assist us in this effort by protecting your Codes and account numbers. These numbers are for your personal use and should be kept confidential by you. Our employees and associates will never contact you for your Codes or other personal identification numbers.

Accuracy of customer information. We are committed to keeping your nonpublic personal information accurate. If you believe our records are outdated or incorrect, please contact M&I at M&I Direct, P.O. Box 622, Milwaukee, WI, 53201-0622. We will investigate the situation and make any necessary updates as soon as possible.

Web site(s). The information you request from our Web site(s) about your accounts can only be accessed with your Codes. It is your responsibility to keep your Codes confidential. Messages you send to us by e-mail are subject to viewing, alteration, and copying by potentially anyone on the Internet. We encourage you to send confidential correspondence through either the Postal Service or by using the telephone to speak directly to our employees.

Credit bureaus. If you would like to have your name removed from prescreened credit mailing lists obtained from the main consumer credit reporting agencies – TransUnion, Experian, Equifax, and Innovis – call 1- 888-5OPTOUT (888-567-8688).

This notice applies to the following M&I affiliates:

M&I Marshall & Ilsley Bank
Marshall & Ilsley Trust Company N.A.
M&I Investment Management Corp.
M&I Bank FSB
M&I Dealer Finance, Inc.
M&I Insurance Services, Inc.
Southwest Bank, an M&I Bank
M&I Financial Advisors, Inc.
M&I Insurance Company of Arizona, Inc.
North Star Trust Company
First Indiana Investor Services, Inc.

General M&I Home Lending Solutions Website Disclaimer
M&I Home Lending Solutions takes reasonable measures to ensure the quality of data and other information produced by M&I Home Lending Solutions that are available on this Web site. However, M&I Home Lending Solutions makes no warranty, express or implied, nor assumes any legal liability or responsibility for the accuracy, correctness, or completeness of any information that is available through this Web site nor represents that its use would not infringe on privately owned rights.

Disclaimer Regarding Non-M&I Home Lending Solutions Website Information
For convenience and informational purposes only, M&I Home Lending Solutions provides links to other Web sites. These sites may contain information that is copyrighted with restrictions on reuse. Permission to use copyrighted materials must be obtained from the original source and cannot be obtained from M&I Home Lending Solutions. M&I Home Lending Solutions is not responsible for the content of external Web sites linked to or referenced from the M&I Home Lending Solutions Web site.

M&I Home Lending Solutions neither endorses the information, content, presentation, or accuracy not makes any warranty, express or implied, regarding these external Web sites. Users should be aware that when they select link on the M&I Home Lending Solutions Web site to an external Web site, they are leaving the M&I Home Lending Solutions site.

Effective: June 2008