AIG Federal Savings Bank (“AIG Bank”) is committed to respecting your privacy. The following privacy policy outlines what nonpublic personal information we collect, how we protect nonpublic personal information, and how we share nonpublic personal information. This policy also advises you of your right to keep certain information from being shared with other companies within and outside the American International Group, Inc. (“AIG”) family.

1. The Type of Information We Collect
   
   We collect nonpublic personal information about you from the following sources:
   • Information we receive from you on applications or other forms in writing, verbally, or electronically, such as your name, address, and telephone number,
   • Information about your transactions with us, our affiliates, or nonaffiliated third parties, such as your account balances, payment history, and account activity,
   • Information we receive from a consumer reporting agency, such as your credit bureau reports and other information relating to your creditworthiness, and
   • Information we receive about you from other sources, such as your employer and other third parties.
   
   
2. How We Protect Information
   

   We take a number of steps to safeguard your information. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information. Access to nonpublic personal information about you is restricted to only those employees or servicers who need the information to provide products or services to you. We strive to keep our records of our information about you accurate and up-to-date. If you tell us of an error, we will update our records promptly.

   NOTICE OF YOUR OPPORTUNITY TO OPT OUT OF INFORMATION SHARING

3. What Information We May Share With Others

   We may share all of the information that we collect about you.

4. Who the Information May Be Shared With

   We may share the information we collect about you with companies within and outside of the AIG family of companies such as the following:

   • Companies within the AIG family include brokerage, consumer loan, retirement and insurance companies who may use this information to offer you financial products and services which may be of interest to you. Examples of these companies within the AIG family include:
            - Imperial A.I. Credit Companies
            - AIG American General
            - AIG Retirement
            - American General Financial Services
            - Chartis
            - Matrix Direct Insurance Services
            - National Union Fire Insurance Company of Pittsburgh
            - SagePoint Financial, Inc.
            - SunAmerica
            - Travel Guard
     
   • Additional affiliated companies which are controlled by AIG include:
            - Stowe Mountain
            - United Guaranty
     
   • Companies outside the AIG family who may receive this information include financial service providers, such as broker dealers, financial planners and insurance agents.

   We may also share nonpublic personal information about you with nonaffiliated third parties as required or permitted by law.

5. How You Can Opt Out of Having Your Information Shared

   You have three choices about how your information is shared. You may choose any, all, or none of the options. If you have already directed us not to share, you do not need to opt out again, unless you receive a separate notice indicating that your choice to limit marketing offers from our affiliates requires renewal. No action is required by you at this time if you wish to permit information sharing as described in this policy. If you would like to select one or more of the options listed below to limit information sharing please notify us of your opt out request by writing to us at AIGBank.com Privacy, P.O. Box 8733, Wilmington, DE 19899-8733, emailing us at AIGBank@aig.com, or by calling 1-877-238-5221.

   Option 1 Third Party Sharing: If you notify us not to, we will not share your nonpublic personal information, listed in Section I, with third party companies outside of the AIG family, except as required or permitted by law in certain circumstances, such as sharing information necessary to process and service your account.

   Option 2 Affiliate Sharing: If you notify us not to, we will not share with our member companies, information that you provide to us or that we obtain from third parties except as required or permitted by law. In any case, we may still share any information about our transactions or experiences with you to companies within the AIG family.

   Option 3 Affiliate Marketing: If you notify us not to, we will not share information about you with our member companies for the purposes of marketing their products and services to you, unless you have an account or business relationship with them. Your choice to limit these marketing offers will apply for five years from when you tell us your choice. After five years you will receive a renewal notice from us that will allow you to continue to limit the sharing of information about you for affiliate marketing purposes.

   For any accounts or loans that you hold jointly with another person, each person may separately opt out or joint account holders may opt out for each other. If only one joint account holder opts out, we may share information about the other joint account holders.

   AIG Bank will continue to adhere to its disclosed privacy practices for an account even if it becomes inactive or is closed. This policy updates and replaces any previous privacy notices from AIG Bank.

   For Nevada Residents only: Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington Street, Suite 3900, Las Vegas, NV 89101; Phone number: 702-486-3132; E-mail: BCINFO@ag.state.nv.us; Mail: AIG Federal Savings Bank, P.O. Box 8733, Wilmington, DE 19899-8733.

   For Vermont and California Residents only: The information-sharing practices described in this policy are in accordance with federal law. Vermont and California law places additional limits on sharing information about Vermont and California residents so long as you remain a resident of either Vermont or California.

   Vermont Residents: In accordance with Vermont law, AIG Bank will not share information we collect about Vermont residents with companies outside of the AIG family of companies except as permitted by law, such as with the consent of the customer, to service the customer’s accounts or to other financial institutions with which we have joint marketing agreements. AIG Bank will not share Application Information, Consumer Report Information and Information from Outside Sources about Vermont residents among the AIG family of companies except with the authorization or consent of the Vermont resident. AIG Bank will treat accounts with Vermont addresses as if you selected Options 1, 2 and 3.

   California Residents: In accordance with California law, AIG Bank will not share information we collect about California residents with companies outside of the AIG family of companies except as permitted by law, such as with the consent of the customer, to service the customer’s accounts, or to fulfill on rewards or benefits. We will limit sharing among our companies to the extent required by California law. AIG Bank will treat accounts with California addresses as if you selected Option 1.

6. Collection of Anonymous Information

   When you use our online products and services, we may use a service that collects data remotely by using “web beacons” or tags embedded in our site’s content. The data we collect includes which operating system and browser you use, how you navigate to and through our site, and how long you stay on our web pages. This information is anonymous and does not include your name, e-mail address, or any other contact information. We share this information with our corporate affiliates and with our third party vendor, Omniture, Inc. Omniture gives us reports of this aggregated, anonymous data, and we use the data to improve our site by responding to our users’ interests and providing information designed to be more relevant and useful to you. To learn more about Omniture’s privacy standards and use of web beacons, please visit http://www.omniture.com/company/acquisitions/visualsciences/privacy/policy.

If you have any questions regarding our privacy policy, please contact us at AIGBANK@aig.com. You can also reach us by phone at 1-877-238-5221, or by mail at AIGBank.com Privacy, P.O. Box 8733, Wilmington, DE 19899-8733.