Privacy Policy

Effective August 1, 2009

Today's marketing strategies have increased the amount of customer information collected and shared among businesses. Consumers rightfully are concerned about the impact this has on their privacy. We understand these concerns at Rabobank, N.A. (the Bank).

Your relationship with us is treated with great confidentiality. We view the security and confidentiality of Customer Information as a top priority throughout the Bank. We do not sell or share Customer Information with outside companies for purposes of independent telemarketing, direct mail or other marketing, or selling of any non-financial products or services to you.

The Bank maintains security standards and procedures designed to protect customer information. We will continue to test and update our technology to protect information about you.

This policy covers "Customer Information," which means nonpublic, personally identifiable information about a consumer or a consumer's current or former relationship with the Bank and its affiliates. This statement is provided in accordance with the federal and California state financial privacy laws.

We hope you will read all the details of the Bank's official position on privacy, below. At the very least, we want you to know that the Bank. uses the information that we have about you in a responsible manner to:

• Provide you with the services you have requested;
• Offer you other bank services;

This statement supersedes any previous privacy policies or statements issued by the Bank. If we change this statement, we will inform you.

TYPES OF INFORMATION WE COLLECT
We collect and use various types of information to respond to: your requests for financial services; service your existing accounts; save you time and money; and to gain a better understanding of your needs. And, we want to help you learn more about products and services that may be of interest to you.

Customer information we collect falls into the following types:

• Transaction and account experience information about you with our family of companies, such as your account balance, securities holdings and collateral, payment history, parties to transactions and credit card use or information about communications with you, such as requests for a loan history statement or a copy of a check and our response, or your response to a product offer. All of this is called "Experience Information." The types below are called "Non-Experience Information."
• Information you provide on applications and through other means, such as your income, monthly expenses, assets and debt;
• Information from credit bureaus (consumer reporting agencies), such as information regarding your credit worthiness or credit history;
• Information from other outside sources regarding their employment, credit or other relationship with you or substantiating representations made by you, such as your employment history, loan or line of credit balances or property insurance coverage;
• Because it is important to know what types of services may be most valuable to you, we also obtain household and demographic information about current and prospective customers from firms that provide this specialized marketing information.

USING THIS INFORMATION
Most of the information we collect is used for the purpose of helping us deliver the services you have requested, easily and efficiently. It may also permit us to design and offer specific products and services that we believe will be useful to you.

WHO HAS ACCESS TO THIS INFORMATION

Inside the Bank Family: Employees of the Bank and its affiliates are permitted access to the information they need to service your accounts and requests. We maintain strict internal policies against unauthorized use or disclosure of Customer Information. Further, we maintain physical, electronic and procedural safeguards that comply with federal standards to guard your information.
As permitted by law, "Experience Information" held by any Bank affiliate is available to other members of the Bank corporate family only for authorized purposes. "Non- Experience Information" is not shared with any Bank affiliate.

Marketing Associates and Non-Associated Marketers: We may disclose the following information to companies that perform marketing services on our behalf: Information we receive from you on applications or other forms, such as your name and address.

Service Providers: At times, we enter into arrangements with companies whose expertise is essential for our own services to function properly. We may share all five types of Customer Information with these companies to provide the products and services you have requested or already have with us. For example, we work with specialized firms to process credit and debit card transactions, generate account statements, process loan requests, service deposit and loan accounts, print checks, process data, and enable online banking for Bank customers. As permitted by law, we disclose to these service providers the Customer Information necessary to perform these functions and provide products and services to you, as well as a good customer experience. As with all our business partners, these companies are required, and contractually obligated, to safeguard your information and use it only to provide the services we have asked them to perform for you and us, or as allowed by law.

Credit Bureaus: In accordance with standard banking industry practice, and as allowed under federal and state law, the Bank routinely provides data about customer loan repayment and other transactions to credit bureaus (consumer reporting agencies). We will provide this information to other creditors or banks if you authorize it, or as necessary to complete a transaction you initiated.

Notify Us of Inaccurate Information We Report to Consumer Reporting Agencies. Please notify us if we report any inaccurate information about your account(s) to a consumer reporting agency. Your written notice describing the specific inaccuracy(ies) should be sent to us at the following address: Rabobank, N.A., P.O. Box 1845, El Centro, CA 92244-1845.

Courts and Government Entities: Certain federal and state statutes may require us to disclose information about you. For example, if you are involved in litigation with a third party, we may be ordered to provide information to the court or the other litigant. In these circumstances, only specific information required by law, subpoena, or court order will be disclosed.

Making Sure Information is Accurate: Keeping your account information accurate and up to date is very important. We provide you with access to your account information through various means, such as account statements, telephone banking and online banking. If you ever find that your account information is incomplete, inaccurate or not current, please call or write to us at the telephone number or address listed on your account statement, bank records, or other documentation. We will promptly update or correct any information we reasonably conclude to be erroneous. If you have questions, or feel that we have not handled information about you properly, you may always contact us and we will promptly investigate your inquiry or complaint.

INTERNET PRIVACY PRACTICES

Protecting Your Privacy Online: The Bank is concerned about your comfort level when it comes to Internet security and safety issues. We want you to know how we will handle the information we learn about you from your visit to our web site(s). This privacy statement applies to your visits to our web site(s), with some additional details below.

Information We Collect Online: The information we receive about you depends upon what you do when visiting our web site(s). We do not obtain personally identifying information about you when you visit our web site(s) unless you choose to provide such information.
We use the above information to collect and measure the number of visitors to the different sections of our web site(s), and to help us stay abreast of technical upgrades that can make our web site(s) more accessible and innovative for our visitors.

Online Banking Security: To protect your information, we maintain physical, electronic and procedural safeguards that comply with federal regulations. When you submit private data to us via our secure online banking channel, our internal security standards guard it in several ways. Encryption helps protect it from interception by a third party. The passwords and other safety features we have installed also help ensure that the information you provide us remains safe and secure. Never send us private data via regular e-mail as this is not secured by our procedural safeguards and could be intercepted by a third party outside the Bank.

Confidentiality: No one is permitted access to this information except employees and authorized outside service providers who provide services to you.
In addition, you should know about these online information management tools that may offer additional convenience:

"Cookies": A cookie is a piece of information that our web server stores on your computer's hard drive and retrieves later. We may use cookies to keep track of your preferences and to recognize return visitors. When you return to our website, your browser gives this data back to the server to improve your experience using the site. We also may place a "cookie" on your PC when you access our online banking services. These per-session cookies are for online banking functions and system security. When you close your online banking session, the per-session cookie is deleted. We do not use cookies to record information that will enable anyone to contact you via telephone, e-mail, or regular mail.

Consolidation Sites: Online aggregation, or "screen-scraping" services, are available to consumers at little or no cost from a number of other firms. Here's how they work:

• You give the service provider the passwords or other access keys to your various accounts at banks, brokerage houses and other institutions;
• The service provider then collects statement information from these institutions' web sites on your behalf, and aggregates all this information in a single online statement;
• Some services also allow you to initiate online payments or other transactions.

Please Use Caution When Using Consolidation Sites: Before you grant any company access to your account information, we recommend finding out how it will collect and safeguard your data. Consumer protections may vary depending on the nature and identity of the aggregator. In any event, if you allow third parties to access your personal information, the Bank and its subsidiaries can accept no responsibility for their actions or for any losses that may result.

WE RESPECT YOUR PRIVACY
As technology continues to advance, you can be sure the Bank will provide safeguards to keep your personal financial information confidential and secure. Your trust is important to us — and we are committed to protecting your privacy, whether you do business with us on the Internet, in person, via telephone or mail. Thank you for choosing us as your financial services provider.

CALIFORNIA ONLINE PRIVACY PROTECTION ACT (AB68)

Our web site does not currently collect any personally identifiable information above what is collected in writing when you sign-up for our eBanking service or when you submit a change to your personally identifiable information (address, phone number, etc.)

You may initiate changes directly via the online service. It is your sole responsibility to ensure that the contact information in your user profile is current and accurate. This includes, but is not limited to, name, address, and phone numbers and e-mail addresses. Changes can be made either within the application or by calling us at this toll-free number 707-227-9300. Any changes in your Payment Account should also be made in accordance with the procedures outlined within the application's Help files. All changes made are effective immediately for scheduled and future payments paid from the updated Payment Account information. The Service is not responsible for any payment processing errors or fees incurred if you do not provide accurate Payment Account or contact information.

USA PATRIOT Act Customer Identification Program

Important information about procedures for opening a new account.

To help the U.S. government fight the funding of terrorism and money laundering activities, U.S. federal law requires all financial institutions to obtain, verify and record information that identifies each person/entity that opens an account or conducts business with the Bank.

What this means for you: When you open an account, we are required to ask for your name, address, date of birth, and other information that will allow us to identify you. We may also ask to see your driver's license or other identifying documents. During this process, Rabobank, N.A. may verify your identity using commercially-available databases containing information from public records, other financial institutions and consumer reporting agencies.

WHERE TO FIND OUT MORE
If you have questions, concerns, or comments about our privacy practices, or the way your information is maintained and used, we would like to hear from you. Please visit your nearby branch, or write us at:

Rabobank, N. A.
Attn: Privacy Officer
P.O. Box 450 Salinas, CA 93902