Consumer Privacy

The BB&T Corporate Family includes many types of financial services providers, such as banks, consumer finance companies, securities broker-dealers, insurance agencies, and mortgage companies. Over our long history as a financial services provider, we have placed the highest value on the information you share with us, and we are committed to protecting your privacy. This commitment forms the cornerstone of trust and confidence on which we hope to build long-lasting relationships with the clients we serve. With our goal of protecting your privacy in mind, we want to provide our Consumer Privacy Notice ("Notice") to you and reaffirm our commitment to safeguarding your information.

Consumer Privacy Notice

Our Consumer Privacy Notice tells you the kind of information we collect about you, with whom we share it, and how we protect it responsibly. The Notice applies to all consumer clients of Virginia Investment Counselors. You may receive a different privacy notice if you have other relationships with companies in the BB&T Corporate Family. The examples that you will find throughout this Notice are for purposes of illustration only and should not be considered a complete description of our information practices.

Categories of Information We May Collect

We may collect the following categories of information about you:

• Information we receive from you on applications or other forms, such as your name, address, social security number, assets and income
• Information about your investment transactions, such as your account balance or investment history
• Information collected from our Internet web sites, such as information you provide to us

Disclosure of Information To Third Parties

We do not disclose information about you to third parties, including affiliates, except as permitted or required by law. For example, we may disclose information to third parties such as your accountant at your request, or to government entities in response to subpoenas or other governmental information requests.

If you close your accounts or your relationship becomes inactive, we will continue to treat the information we have collected about you in accordance with this Notice.

Our Security Procedures

We maintain physical, electronic, and procedural safeguards that comply with federal guidelines to safeguard consumer information. Our employees are bound by our Code of Ethics and policies to access consumer information only for legitimate business purposes and to keep information about you confidential.

Revised: July 2007