Legal Disclosure

The North Dakota Department of Financial Institutions (DFI) exercises regulatory oversight responsibility for Bell Bank, a North Dakota chartered bank with full trust powers and with wealth management offices in North Dakota, Minnesota and Arizona. DFI conducts regular examinations of all business lines of Bell Bank, including examinations of the Wealth Management Division as part of the safety and soundness examinations and in connection with its fiduciary examinations.

Since Bell Bank is a member bank of the FDIC, the FDIC also conducts regular examinations of Bell Bank. Like DFI, the FDIC examines the Wealth Management Division both in connection with its annual safety and soundness examinations of Bell Bank and in connection with its fiduciary examinations.

Direct and Indirect Fees

Bell Bank periodically may review fee schedules and make adjustments according to the standard of reasonable compensation. Fee Schedules are available at the office providing your wealth management services.

Bell Bank collects and receives administrative and investment management fees up to 0.50% per annum on money market funds, including the FDIC Insured Sweep. Bell Bank’s and any third party providers’ fees generally are deducted from the gross interest earned on such funds before net earnings are posted to client accounts.

Bell Bank may purchase mutual funds in your account. The manager (or affiliates of the manager) of mutual funds held in your account may pay Bell Bank 12b-1, administrative or other servicing fees (collectively referred to as revenue share) based on assets invested in mutual funds.

Soft Dollar Receipts and Allocations: Commission Sharing Arrangements

Bell Bank strives to obtain favorable execution and prices on security trade orders with the brokerage industry. External brokerage fees are included in the cost basis of the securities and reflected in the net returns of the invested assets. Managed and non-managed/directed accounts incur these transaction costs which include trade execution, direct research and third party investment research including statistical or other investment related services referred to as soft dollars. Bell Bank uses soft dollars derived from securities transactions in both managed and non-managed/directed accounts to acquire research, software applications and other products and services as well as other information used in the investment management process and trade execution process for all accounts. The discretionary allocation of brokerage services is based upon our good faith determination that the commissions paid are fair and reasonable in relation to trade execution, research and investment services.

Release of Shareholder Information – Shareholder Communication Act

Under the federal Shareholder Communication Act, you have the right to direct Bell Bank to disclose or withhold your name, address and security holdings to companies requesting information about the holders of their respective securities. Companies who request this information about their stockholders are prohibited from using the information for any purpose other than corporate communications. In limited situations, such information may be obtained by persons other than the issuing company, such as a dissident or objecting shareholders.

Please contact Bell Bank if you wish to change your election on whether you do or do not want Bell Bank to disclose your name, address and holdings to requesting companies.

Foreign Tax Withholding & Reclamation

Domiciliary nations of foreign companies frequently assess and withhold taxes on the income and gains generated by such securities. Treaties between the United States and such countries frequently provide investors the opportunity to recover or reclaim all or a portion of such foreign tax withholdings.

Bell Bank does not provide foreign tax reclamation services to our clients as the out-of-pocket costs to our clients for these services in almost all instances would be greater than the amount of foreign tax actually recovered. Please consult with your tax advisor and ask your tax advisor whether you should engage a third party service to assist you in reclaiming foreign tax withholding.

Masking of Taxpayer Identification Numbers

As permitted by U.S. Treasury Regulations and as a measure we can take to protect our clients from identity theft, Bell Bank’s Wealth Management Division will exclude all but the last four numbers of individual Social Security Numbers or EINs on certain tax forms mailed to our clients. Please contact your wealth advisor if you have questions.

Investment Risk

There are inherent risks in the investment of securities. Some investment decisions will result in profits; others will result in losses. Bell Bank and its investment advisors cannot assure that a net profit will be obtained but only that we/they will exercise our/their judgment as a prudent fiduciary to investments in portfolios. The performance of the securities purchased are evaluated to determine whether the security position should be liquidated (even if the sale would be below the original purchase price), increased (even at prices higher than originally acquired) or maintained.

Investment products are not obligations of or guaranteed by Bell Bank, are not bank deposits, are not insured by the FDIC or any government agency and are subject to investment risks, including possible loss of the principal amount invested.

Investment Changes

Please remember to contact Bell Bank if there are any changes in your investment objectives. Also, please advise Bell Bank if you would like to impose, add or modify any reasonable restrictions to our investment management services. Copies of our current fee schedule and account agreement are available for your review upon request.

PRIVACY NOTICE

Federal law requires us to tell you how we collect, share and protect your personal information. Our privacy policy has not changed and you may review our policy and practices with respect to your personal information at https://www.bell.bank/privacy-policy/ or we will mail you a free copy upon request if you call us at 701-451-3000 or toll free at 1-800-709-5781.