M209468PMIDisclosure and Custodial AgreementTraditional IRA Disclosure Statement1. INTRODUCTION — PAGE 2Purpose of this Disclosure Statement — page 2Who can open an IRA — page 2Revoking your IRA — page 22. THE ROLE OF MERRILL LYNCH — PAGE 23. ABOUT YOUR IRA AND SERVICESWE PROVIDE — PAGE 2Services for your IRA — page 24. DESIGNATING BENEFICIARIES — PAGE 3Types of beneficiaries — page 4Designating beneficiaries as primaryor contingent — page 4Changes in family status affectingdesignations — page 4Tax implications of making a designation — page 4Deductible and nondeductiblecontributions — page 14Penalty for contributions over theannual limit — page 14Tax-free distributions for nondeductiblecontributions — page 15Taxes on distributions — page 15Substantially Equal Periodic Payments toavoid penalty — page 15Penalty for failure to take minimumdistribution — page 1610. WORKSHEETS TO HELP YOU WITHCALCULATIONS — PAGE 16Calculating tax-free distributions — page 16Active participants: Calculating yourtax deduction — page 165. CONTRIBUTING TO YOUR IRA — PAGE 411. GLOSSARY — PAGE 17Transfers and rollovers from another IRA — page 5Annual contributions limits — page 712. IRS APPROVAL — PAGE 206. ADDITIONAL INFORMATION ABOUTYOUR ACCOUNT — PAGE 8Investing your IRA assets — page 8Prohibited investments and transactions — page 9Insurance and SIPC Protection — page 9Losing your IRA’s tax-deferred status — page 9Sweep arrangements for cash in your IRA — page 9Tax Communications we’ll send — page 107. DISTRIBUTIONS FROM YOUR IRA — PAGE 10Required minimum distributions — page 10Calculating your minimum distributions — page 10Taking your minimum distributions — page 11Distributions after your death — page 11Calculating distributions to beneficiaries — page 118. FEES AND EXPENSES — PAGE 12Custodial fees — page 12Account close-out fee — page 13Other fees and expenses — page 139. TAXES AND PENALTIES — PAGE 13Your responsibility to file tax returnsand other reports — page 13CUSTODIAL AGREEMENT — PAGE 21RETIREMENT ASSET SAVINGS PROGRAM — PAGE 35MERRILL LYNCH STATEMENT LINK SERVICE — PAGE 42The following pages contain the agreement anddisclosures governing your traditional IRA includingdisclosures required by federal law.This Disclosure Statement and Custodial Agreementhas not yet been updated for tax law changes includedin the Setting Every Community Up for RetirementEnhancement (SECURE) Act which became effective on1/1/2020. The SECURE Act changed the rules governingIRA contributions and the age at which you are requiredto start your Required Minimum Distributions (RMDs).SECURE Act changes to the law are not reflected inthis document. You should check with your tax advisorregarding your specific situation before making anydecisions concerning your IRA.Traditional Individual Retirement Account 1
Section 1: IntroductionPURPOSE OF THIS DISCLOSURE STATEMENTThis Disclosure Statement describes the rulesand benefits of your Traditional IndividualRetirement Account (IRA) as well as legal andfederal tax information you should know aboutit. In case there is a discrepancy betweenthis Disclosure Statement and your CustodialAgreement, the Custodial Agreement is theprimary document governing your IRA otherthan as provided in the second paragraph underSection 2: The role of Merrill Lynch in thisDisclosure Statement, which shall govern withrespect to our role as fiduciary.Section 2: The role ofMerrill LynchWe’ll follow your instructions for all purchases,sales, transfers, exchanges and other dispositionof assets. If we don’t receive instructions fromyou, we’ll hold assets uninvested and contactyou in writing at your last known address. If wecan’t locate you within two months, we mayinvest the cash proceeds in a money market fundor interest-bearing account, if you don’t have asweep arrangement for cash in your IRA. Suchinvestments in deposits of Bank of America, N.A.(BANA), Bank of America California, N.A. (BA-CA)or other Merrill Lynch affiliated bank will bear areasonable rate of interest as required under theexemption provided by Section 408(b)(4) of theEmployee Retirement Income Security Act of1974, as amended (“ERISA”), or Tax Code Section4975(d)(4).Notwithstanding anything to the contrary inthe Custodial Agreement, we acknowledgethat, effective February 1, 2022, Merrill Lynch isacting as a fiduciary under Title I of ERISA andSection 4975 of the Tax Code in its capacity asa broker-dealer when it provides investmentadvice and makes recommendations to youregarding securities or investment strategiesin your IRA. The Merrill Best Interest DisclosureStatement provides a description of servicesand information relating to our costs and fees,compensation earned and material conflicts ofinterest as required under these rules. At notime will we act as your tax or legal advisor.WHO CAN OPEN AN IRAYou can only open an IRA in an individualcapacity. It cannot be opened under jointownership or by non-individual entities.To make annual contributions to your IRA, youmust be under age 70½ at the end of the TaxYear and receive taxable compensation. Butthere are no age or compensation restrictionsto make contributions by rollover or directtransfer. See Section 5 for more information.REVOKING YOUR IRAYou can revoke your IRA and receive a completerefund of any contributions you’ve made tous by notifying us in writing within 14 daysfrom the date this Disclosure Statementwas mailed to you. If your revocation ispostmarked, certified or registered withinthis period, we’ll return your contributionswithout any deduction for sales commissions,administrative expenses, other fees orfluctuations in market value.To revoke your IRA, send your writtenrevocation to:Manager, Retirement Plan New AccountsMerrill Lynch, Pierce, Fenner & Smith Incorporated1400 American Blvd.NJ2-140-01-03Pennington, NJ 08534-4128Contact your advisor or Service Associate orcall 1.800.MERRILL (637.7455), if you have anyquestions about revoking your IRA.2 Traditional Individual Retirement AccountSection 3: About your IRA andservices we provideSERVICES FOR YOUR IRAYour IRA is being established for the solepurpose of providing you and your beneficiarieswith retirement benefits. An IRA providesyou with a way to save for retirementwithout paying taxes until you begin takingdistributions (or withdrawals). Your right to thebalance of your IRA, cannot be forfeited at any
time. As a non-bank custodian, we have beenapproved by the Internal Revenue Service (IRS)to administer your IRA, consistent with Section408(a) of the Tax Code.IRS Publications 590-A and 590-B (orreplacement publications) contains helpfulinformation about your IRA and related taxtopics. Visit irs.gov online or contact any IRSOffice to request a copy.Your advisor or Service Associate can offer youaccess to certain brokerage services and/or aMerrill Lynch investment advisory program.Statement LinkingYou can link multiple Merrill Lynch accounts,including those with different primary accountholders, and appoint one of those accountholders to receive a single monthly statementand a summary of account information for alllinked accounts. Individual account holdersremain responsible for checking individualstatements, reading notices and directingaccount activity. The assets of linked accountsare not commingled with other property,except as permitted by law in a common trustfund or a common investment fund.Linking some accounts may help you avoidcertain fees and deliver higher interest rates inthe Retirement Asset Savings Program. See theStatement Linking Service fact sheet for moreinformation in the Custodial Agreement.MyMerrill.comThe online service, MyMerrill.com, allows youto view your IRA balance, monitor transactions,transfer funds and set up alerts. MyMerrill.comalso provides industry-leading research byBank of America Merrill Lynch Global Researchto help inform your financial decisions. We candelete or modify any Merrill Lynch website andhave the right to terminate your enrollment inthe service at any time. Visit www.mymerrill.comor call (800) MERRILL to enroll.Online LinkingIf you enroll multiple accounts in MyMerrill.com,you can link them into a single MyMerrill.comaccount for a consolidated view and convenientonline access to all of your account information.Online Delivery of communicationsWhen you enroll in Online Delivery, you willreceive an email alert when your statementsor documents are available for viewing online.Your records can be accessed online, wherethey are protected by your password. We willnever email your statements or documents toyou, and we do not include any of your personalor account information in the email alerts.Providing access to these documentselectronically on MyMerrill.com will constitutegood and effective delivery, regardless ofwhether you actually access and review theinformation. We will deliver all communicationsto you electronically. Certain cases may requireus to send you paper copies as well. You mayrevoke your consent to Online Delivery andreceive paper copies of these documents atany time, by contacting your advisor or ServiceAssociate, or making your selection online.Merrill Lynch investment advisory programYou may enroll in a Merrill Lynch investmentadvisory program and authorize a financialprofessional to make investment decisions andmanage your portfolio, based on criteria youdetermine. You will need to sign an additionalagreement to enroll. Fees for accounts enrolledin a Merrill Lynch investment advisory programare based on assets under management.Contact your advisor or Service Associate, if youhave any questions about fees.Section 4: DesignatingbeneficiariesYou can designate in writing a beneficiaryto receive the balance of your IRA upon yourdeath. If you make no designation, the balancewill be distributed to your surviving spouse,if you are married. If you do not have a survivingspouse, the balance will be distributed toyour estate.You can change your designation at any timeby notifying us in writing. The change will notbecome effective, until we receive notice andaccept the change in beneficiary.Traditional Individual Retirement Account 3
All beneficiary designations must be compatiblewith our administrative and operationalrequirements, which may change at any time.TYPES OF BENEFICIARIESA beneficiary can be an individual (e.g., anatural person with a birth date), estate,charity or trust. You can designate multiplebeneficiaries for your IRA. However, specialrules apply for Required Minimum Distribution(RMD) purposes following your death. Forexample, if you want to extend paymentsbeyond five years after your death, each ofyour designated beneficiaries should be anatural person or a “look through” trust. Also,if all your beneficiaries are natural persons, theoldest will be considered to be your designatedbeneficiary for RMD purposes (see Distributionsafter your death in Section 7) (US TreasuryRegulation 1.401(a)(9)-4).DESIGNATING BENEFICIARIES AS PRIMARYOR CONTINGENTYou can designate beneficiaries as primary orcontingent: Primary beneficiaries will be the first toreceive the balance of your IRA. Contingent beneficiaries will receive thebalance of your IRA, only if no primarybeneficiary survives you.CHANGES IN FAMILY STATUS AFFECTINGDESIGNATIONSReview your beneficiary designation periodicallyto make sure it reflects your intentions,especially when your family status changes(e.g., marriage, divorce, births, adoptions, deathof a beneficiary), or during the establishment ofestate-planning trusts.If you are married and designate your spouseas beneficiary but later divorce or annul yourmarriage, your designation will be void, unless: The decree of divorce or annulmentdesignates your spouse as beneficiary, You re-designate your spouse as beneficiary,or Such spouse is re-designated to receiveproceeds or benefits in trust for, on behalf of,or for the benefit of your child or dependent.4 Traditional Individual Retirement AccountTAX IMPLICATIONS OF MAKING ADESIGNATIONDesignating a beneficiary is not generallyconsidered to be a gift subject to federal gifttax, even if the designation is irrevocable, sincethe account owner typically retains the right todirect distributions. Consult your tax advisor,to better understand the tax implications ofbeneficiary designations.Section 5: Contributing toyour IRAYou can make contributions to your IRA in-cashor in-kind (for rollover contributions or transfersfrom another IRA or qualified retirement plan).In-cash contributions are those made bycheck, money order or electronic funds transfer.You can mail checks or money orders to:Merrill LynchP.O. Box 16001Newark, NJ 07199In-kind contributions are non-cash assetslike mutual funds and securities currently heldat another financial institution that transferinto your IRA without being liquidated. In-kindcontributions must be compatible with ouradministrative and operational requirements.Certain in-kind contributions (e.g., limitedpartnership interests) can typically only transferinto your IRA at specific intervals, such asannually or semi-annually.You’re responsible for determining theeligibility of your contributions. We won’tknowingly accept contributions made by youor for you that exceed annual limits for any TaxYear. We’ll return excess contributions to you, ifyou ask us to do so in writing. (See Penalty forcontributions over the annual limit in Section 9for more information.)Assets in your IRA won’t be commingledwith other property for any reason, except aspermitted by law in a common trust fund or acommon investment fund.
If this is an Inherited IRA, you can’t make anycontributions, and the early withdrawal penaltyand minimum distribution rules during yourlifetime don’t apply. See Distributions afteryour death, in Section 7 which applies.TRANSFERS AND ROLLOVERS FROMANOTHER IRAIf you already have another IRA or individualretirement annuity at Merrill Lynch or anotherfinancial institution, you can contribute assetsfrom those funds to your IRA in two ways—direct transfer or rollover. Tax implications differbetween methods, so discuss your optionswith your tax advisor. The rules explained inthis Disclosure Statement for rollovers andtransfers into your IRA generally apply to assetstransferred out of your IRA to another IRA aswell.If you want to contribute assets from a SIMPLERetirement Account (SRA) and keep thetax-deferred status of those assets, you musthave held your SRA for at least two years, or beexempt from the 25% penalty on prematureSRA distributions.A direct transfer moves assets from anotherIRA into your Merrill Lynch IRA withoutincurring taxes or penalties. To keep yourtax-deferred status, assets must be transferreddirectly between IRA custodians or trusteesyou cannot receive assets in your name.Transfers from Roth IRAs won’t be permitted,unless you recharacterize those assets.A rollover moves assets from anotherretirement account to your IRA with us. Youcan roll over any kind of distribution—cash,securities or other property, as long as it’scompatible with our systems. You can alsosell non-cash distributions and roll over theproceeds without paying capital gains tax.Assets must be rolled over into your IRA within60 days of the date you initially withdrew themfrom the transfer IRA or Employer RetirementPlan (ERP). Any portion of assets withdrawnbut not rolled over (including tax withholding)will be subject to tax. The IRS may waive the60-day requirement, if you demonstrate howthe delay in rolling over assets was beyond yourability to control (e.g., casualty or disaster).You can roll over distributions from: A Traditional IRA Your employer’s qualified retirement plan A section 457(b) eligible governmentaldeferred compensation plan 403(b) annuity plan Your deceased spouse’s IRA Your SRA, if you’ve participated for at leasttwo years Your deceased spouse’s qualified retirementplan (If you’re a nonspouse beneficiary, youcan only roll over these distributions into anInherited IRA you control.)Rollovers from another IRAYou can make only one tax-free rollover ofall or part of a distribution to or from yourTraditional IRA in a one-year period. The oneyear period begins on the date you receive theIRA distribution, not the date you roll it over.You can make only one rollover from an IRAto another (or the same) IRA in any 12-monthperiod, regardless of the number of IRAs youown. You can, however, continue to make asmany trustee-to-trustee transfers betweenIRAs as you want.Rollovers from a qualified retirement planYou can roll over assets from a qualifiedretirement plan.If you’re the non-spouse beneficiary of aqualified retirement plan participant, you canroll over such distributions to an Inherited IRAin the decedent’s name that you control.If you don’t directly roll over eligible rolloverdistributions from a qualified retirement planto an IRA or another qualified retirement plan,the amount will be subject to a mandatory20% federal income tax withholding, plus anyapplicable state or local withholding. To avoidthis withholding, you may want to directly rollover such distributions to your IRA. Ask youradvisor or Service Associate for the informationyou need to provide to your plan administrator.Traditional Individual Retirement Account 5
Ineligible rollovers from EmployerRetirement PlansWe won’t accept certain distributions fromyour ERP as rollover contributions to your IRA: Substantially equal periodic payments over aperiod of 10 years or longer or measured byyour life or life expectancy Required minimum distributions Distributions from a designated Roth IRAaccount Hardship distributions Certain corrective distributions Employee Stock Ownership Plan (ESOP)dividends Loans treated as deemed distributions Payments of certain automatic enrollmentcontributions requested to be withdrawnwithin 90 days of first contributions Cost of life insurance paid by the planRollovers from a defined benefitpension planYou can roll over a “restricted distribution” froma defined benefit pension plan. Your lump-sumdistribution may be considered restricted if theplan does not have assets exceeding 110% ofits accrued benefits and you’re one of its 25most highly paid participants.responsible for determining the eligibility ofyour conversion.Most rules for rollovers also apply toconversions, but there are a few exceptions,including: The conversion amount won’t be subjectto the 10% penalty for early withdrawals—except to the extent that any portion of theconversion was withheld for taxes. The one-year waiting period for rolloversdoesn’t apply to conversions. If your IRA assets were previouslyrecharacterized from a Roth IRA, you mustwait 30 days before reconverting them, andyou may not make two such conversions ofthe same assets in one year.Once converted, your assets will be subject torules governing Roth IRAs. For tax purposes, theapplicable amount distributed from your IRAin the conversion will be included in your grossincome for the year the conversion took place.(See the Calculating tax-free distributionsworksheet in Section 10 for more information.)Certain IRA distributions can’t be converted toRoth IRA: Required Minimum Distributions Distributions from an Inherited IRA, unless:— You’re the sole, spousal beneficiary, treatingIf you roll over a restricted distribution, youmay be required to: Repay a portion if the plan terminateswithout sufficient assets Provide security for a possible repayment,including pledging and assigning your IRA.We’ve designed your IRA to facilitate suchpledges and assignments in this limitedcircumstance. Your advisor or Service Associatecan provide your attorney with the informationnecessary to do so.Convert IRA contributions to Roth IRAcontributionsYou can move assets from an IRA to a Roth IRAby either direct transfer or rollover, and this iscalled a conversion. Conversions will generallybe treated as rollovers for tax purposes(except that the conversion is taxable). You’re6 Traditional Individual Retirement Accountthe IRA as your own, or— You’re a non-spouse beneficiary directlyrolling over assets from a qualifiedretirement planRecharacterize Roth IRA conversions asIRA contributionsYou can direct us or any custodian torecharacterize a Roth IRA conversion as long asyou do so before the tax-filing deadline for theyear you originally made the IRA contributions.When you request a recharacterization,your custodian will transfer your Roth IRAcontributions (plus earnings) to an IRA.The IRS may grant an extension forrecharacterizing invalid conversions ifyou provide sufficient evidence you actedreasonably and in good faith.
to tax or penalty in the year contributed. Theamount varies based on your age:You can recharacterize: Annual IRA and Roth IRA contributions Roth IRA conversions from IRAs and certainemployer retirement plansYou cannot recharacterize: Tax-free transfers or rollovers:— Between IRAs— Between Roth IRAsTo request a recharacterization, providecomplete and timely instructions to custodianson each end of the recharacterization. You thenmust report the recharacterization on yourfederal tax return as contributions made to thetransferee (or recipient) IRA or Roth IRA for theyear you made the original contributions.ANNUAL CONTRIBUTIONS LIMITSThe contributions limits described in thisDisclosure Statement apply to all your IRAs.For example, if you own two IRAs, yourcontributions limit doesn’t double. Your totalmust also include contributions made by youremployer on your behalf (except under SEP andSIMPLE plans).Until age 70½, you can contribute to yourIRA at any time during the Tax Year, and upuntil the tax-filing deadline (generally April15), not including extensions. Contributionswill be reported in the calendar year they aremade, unless you make contributions betweenJanuary 1 and the tax-filing deadline anddesignate in writing that it’s for the prior TaxYear. We’ll then report it to the IRS as such.After reaching the year you turn age 70½, youcan no longer contribute to your IRA.There is a limit to the amount you cancontribute each year that won’t be subjectUnder 50 5,50050 to 70½ 6,500If your annual compensation is less than theselimits, you can’t contribute more than 100%of your compensation. If your compensation,however, is less than your spouse’s and you filea joint tax return, you may add your spouse’scompensation in excess of contributions he orshe made to another IRA or Roth IRA to yourcompensation.The IRS will sometimes adjust the annual dollarlimit for cost-of-living increases (Tax Code219(b)(5)(D)). Any adjustment will be roundeddown to the next lower multiple of 500. Thiswill not apply to the 1,000 portion of theannual contributions limit for individuals age50 and over. The 2018 limits are reflected inthe above chart. See IRS Publication 590-A forthe current year limits. Employer contributions to SimplifiedEmployee Pension (SEP) IRAs and SRAs Contributions for which you’ve taken a taxdeductionA tax-free transfer or rollover between IRAsor Roth IRAs will not disqualify you fromrecharacterizing an annual or conversioncontributions.ANNUAL CONTRIBUTIONS LIMIT— From an ERP to an IRAAGEContributions over the annual limitYou can make certain contributions overthe annual limit without penalty, includingrepayments of: Qualified Reservist Distributions Plan distributions related to a federallydeclared disaster Plan distributions related to the Exxon ValdezlitigationVoluntary nondeductible contributions,“elective” contributions and salary deferralsmade under your employer’s retirement plando not reduce the amount you can contribute,but they may affect your tax deduction (seeSection 9) for IRA contributions.How IRA contributions affect Roth IRAcontributionsYour IRA contributions for a year will reducethe amount you can contribute to a Roth IRA inthe same year. However, your IRA contributionswon’t affect designated Roth IRA contributionsyou can make to your employer’s retirementTraditional Individual Retirement Account 7
Section 6: Additionalinformation about youraccountplan, 403(b) annuity program or government457(b) plan.Computing your annual contributions limitWhen computing your annual contributionslimit, your (and your spouse’s, if married)compensation includes taxable amounts youreceive, such as: Wages or salary Tips Professional fees Bonuses Commissions Taxable alimony or separate maintenancepayments (if divorced) Net income from a self-employmentbusiness, after deductions, for retirementplan contributions, and one-half of the selfemployment tax Non-taxable U.S. military service combat payand differential wage payments (Tax CodeSection 3401(h)(2))Your compensation cannot include amountsnot included in your gross income, such as: Deferred compensation Disability payments Social Security benefits Pensions Earnings and profits from investments orproperty (such as interest, rents or dividends) Foreign-earned income and housingallowancesYou can find your taxable compensation onyour Form W-2 or 1099. For Form W-2, deductany “non-qualified plans” distributions reportedin box 11 that were also included in box 1.If you were employed by the U.S. military, addin the non-taxable combat pay reportedon your Form W-2.8 Traditional Individual Retirement AccountINVESTING YOUR IRA ASSETSYour IRA can invest in a range of investmentproducts made available by us or our Affiliates,including: Merrill Lynch money market funds Securities traded on recognized exchanges or“over the counter” Mutual funds Government securities, such as treasury bills Annuity contracts 1-oz.Gold or Silver Eagle coins fromthe U.S. Mint Option strategiesAll investments must be compatible with ouradministrative and operational requirementsand procedures which may change fromtime to time. Ask your advisor or ServiceAssociate for more information about theserequirements.The investments you purchase for your IRAmay fluctuate in value and have varying rates ofreturn, so the future value of your IRA cannotbe guaranteed or projected.Careful consideration should be given to taxadvantaged investments held in your IRA: Tax exempt investments, such asmunicipal bonds, would become taxableas a distribution upon withdrawal from atraditional IRA, because IRA distributions aretaxable regardless of the tax-exempt status ofinvestments held in your account. Dividends and earnings on investments inforeign securities and foreign mutual fundsmay be subject to foreign tax withholding.The withholdings are often ineligible forthe U.S. foreign tax credit, if the underlyingsecurities are held in tax-exempt accounts,including IRAs. As a result, the effective yieldon foreign securities and foreign mutualfunds held in your IRA may be lower than the
effective yield of identical investments held ina nonretirement account. You may find it preferable to hold taxexempt or foreign investments in a taxableinvestment portfolio, if you have one, insteadof your IRA. Please consult your tax advisor ifyou have questions regarding tax advantagedinvestments and your specific tax situation.PROHIBITED INVESTMENTS ANDTRANSACTIONSYou’re prohibited from making certaininvestments, including: New issue offerings of equity and preferredsecurities where Merrill Lynch or an affiliateacts as the underwriter of the securities Investments bought on margin Commodities transactions (e.g., futurescontracts) Series E and EE U.S. Savings Bonds Investments in non-U.S. dollar-denominateddebt securities Foreign currency Shares of “restricted” stock and stock in mostS corporations Real estate Investments in life insurance contracts Other investments that we designate fromtime to time.Certain prohibited investments andtransactions result in certain taxconsequences and penaltiesProhibited transactions and investmentstreated as taxable distributions: Pledging your IRA as security for a loan Collectibles, including works of art, rugs,antiques, certain metals, gems, stamps, coins(other than those listed above), alcoholicbeverages and certain other tangible propertyProhibited transactions and investments thatcause your IRA to lose tax-deferred status: Pledging your IRA as security for a loan Borrowing from your IRA Buying property from your IRA Investing in life insurance contractsINSURANCE AND SIPC PROTECTIONThe securities and cash we hold in yourtraditional IRA(s) are protected by theSecurities Investor Protection Corporation(SIPC) for up to 500,000 per customer (asdefined by SIPC rules), including 250,000 incash. You may obtain further information aboutSIPC, including the SIPC brochure, via SIPC’swebsite at http://www.sipc.org.In addition, Merrill Lynch has obtained“excess SIPC” coverage from a Lloyd’s ofLondon syndicate. This policy provides furtherprotection for each customer (including up to 1.9 million for cash), subject to an aggregateloss limit of 1 billion for all customer claims.Neither SIPC protection nor the additional“excess SIPC” coverage applies to depositsmade through a bank deposit program(including deposits established through theRetirement Assets Savings Program (RASP)or to the other assets that are not securities.Each account held by a separate customer (asdefined by applicable law) is treated separatelyfor purposes of the above protection.SIPC and excess SIPC coverage does not protectagainst market losses. nor does it apply todeposits established through the RetirementAsset savings program (RASP). See theattached RASP Fact Sheet.LOSING YOUR IRA’S TAX-DEFERRED STATUSIf your IRA loses its tax-deferred status,your entire IRA balance (less nondeductiblecontributions) would be included in yourtaxable gross incom
Section 1: Introduction purpose oF This DisClosure sTATemenT  ﬔis Disclosure Statement describes the rules and beneﬁts of your Traditional Individual Retirement Account (IRA) as well as legal and