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Merrill

Merrill Edge® Self-Directed Investing


Client Relationship Agreement
Terms and Conditions 2. Overview of Merrill Edge Self-Directed Investing
Merrill Edge Self-Directed Investing is designed for U.S.-based investors
1. Introduction who wish to make their own investment choices in a Merrill Lynch, Pierce,
Fenner & Smith Incorporated brokerage account.
We have prepared the Merrill Edge® Self-Directed Investing Client Relationship
Agreement (hereinafter referred to as the “Merrill Edge Self-Directed CRA” or Neither Merrill, nor MESD, nor any Merrill or MESD representative, will provide
“this Agreement”) in order to help you understand your relationship with you with investment advice, including any recommendations, or offer any
Merrill Edge Self-Directed Investing. This Client Relationship Agreement opinion regarding the suitability of any security, order, transaction, or strategy
(“Agreement”), and the agreements for the various products and services in a Merrill Edge Self-Directed Investing Account, or monitor your investment
offered by Merrill Edge Self-Directed Investing, details the nature of the mutual or the appropriateness of your account or service level, or alert you to any
obligations for services you are about to use and those services you may recommended change to your investments, investment accounts, or services.
choose to use in the future. Neither Merrill nor MESD, nor any Merrill or MESD representative, will provide
any tax or legal advice.
Merrill Edge Self-Directed Investing (also referred to herein as “MESD”)
is the marketing name for certain brokerage services offered to clients No Merrill Research opinion, Independent Research opinion, the inclusion
on a self-directed basis through Merrill Lynch, Pierce, Fenner & Smith of a security on any list, or any information provided to you either on
Incorporated (“Merrill”). the Merrill Edge website or by mail or any other means constitutes a
recommendation to you to purchase, hold or sell any investment.
We have provided you with a copy of the Client Relationship Summary (“Form
CRS“) either online via the Online Account Opening process or as part of the By entering into this Agreement, you agree that any transactions executed
MESD application packet. through your Merrill Edge Self-Directed Investing Account, whether based on
information obtained from Merrill or elsewhere, will be solely your own decision
You should review the Form CRS to understand the scope of services that
and based on your own evaluation of your personal financial situation, needs,
we can provide you at Merrill and key information about our brokerage and
and investment objective(s).
investment advisory programs.
In addition to retaining the sole responsibility for investment decisions, you
Merrill offers its products, accounts and services through different service
understand and agree that you are responsible for knowing the rights and
models (e.g., self-directed or full-service). Based on the service model, the
terms of all securities in your account, specifically including valuable rights
same or similar products, accounts and services may vary in their prices or fees
that expire unless the holder takes action. This includes, but is not limited to,
charged to a client. The Summary of Programs and Services, as well as the
warrants, stock rights, convertible securities, bonds, and securities subject
Form CRS, outline these different programs and are included during the Online
to a tender or exchange offer. You understand and agree that Merrill accepts
Account Opening process or as part of the MESD Application Packet.
no obligation to notify you of any upcoming expiration or redemption dates, or,
Future account disclosures may be delivered to you via the internet, including except as required by applicable law or regulation, to take any action on your
as a message at the Secure Message Center. In certain cases, future account behalf without specific instructions from you. You also agree that all dividends
Disclosures may be delivered via statement message, statement insert or and interest payments credited to your account shall accumulate rather than
stand-alone letter. be paid to you upon receipt, but shall be subject to your withdrawal from time
When you agree to the terms of this Agreement, you are agreeing that its to time upon request for a check or other funds transfer.
terms will apply to all of your MESD accounts, transactions and services. Notwithstanding the foregoing, in its capacity as an investment adviser Merrill may
If you have any concerns about the services you receive under these terms and provide investment advice or recommend securities transactions or investment
conditions, please contact Merrill Edge Self-Directed Investing at 877.653.4732. strategies to you within certain investment advisory programs. To enroll in
such an investment advisory program, such as the Merrill Guided Investing
What to do if you have a problem Program, you may be required to establish and maintain a Merrill Edge Self-
We sincerely hope to service your account in such a manner that problems Directed Investing Account. Merrill acts as an investment adviser and not
will never occur. However, errors, misunderstandings or disputes can occur, a broker-dealer for the investment advisory services provided within these
and we want to resolve them promptly and fairly. investment advisory programs. To the extent that Merrill provides investment
Reviewing your confirmations and statements — Please review your advice or recommends any securities transactions or investment strategies
confirmations and account statements promptly and let us know if there is to you within any such investment advisory program, you understand and
any discrepancy in terms of transactions or deposits or withdrawals of either agree that Merrill does so in its capacity as an investment adviser and not as a
funds or securities. broker-dealer. You will be required to enter into a separate agreement with Merrill
and its affiliates to participate in an investment advisory program. Pursuant to
Whom to contact — If your concerns cannot be resolved or have not been
Section 5a of this Merrill Edge Self-Directed CRA, the terms governing any such
properly addressed, you may contact Merrill Compliance at 609.274.4040,
investment advisory program will control if there are any inconsistencies with
or in writing at P.O. Box 1520, Pennington, NJ 08534-1520.

Merrill Lynch, Pierce, Fenner & Smith Incorporated (also referred to as “MLPF&S” or “Merrill”) makes available certain investment products sponsored, managed, distributed or provided
by companies that are affiliates of Bank of America Corporation (“BofA Corp.”). MLPF&S is a registered broker-dealer, registered investment adviser, Member SIPC and a wholly owned
subsidiary of BofA Corp.
Banking products are provided by Bank of America, N.A. and affiliated banks, Members FDIC and wholly owned subsidiaries of Bank of America Corporation.
Investment products:

Are Not FDIC Insured Are Not Bank Guaranteed May Lose Value

Page 1 | Merrill Edge Self-Directed Investing Client Relationship Agreement Code 422000PM-1123
the terms of this Merrill Edge Self-Directed CRA. If your account serves as the − Certain securities in your account may be loaned to Merrill or others to the
securities account for a Merrill investment advisory program, certain features extent not prohibited by applicable laws, rules or regulations.
of Merrill Edge Self-Directed Investing, such as the Margin Lending Program, • Limits may be placed on your ability to buy, sell, transfer and hold certain
check writing, and Visa cards, may not be available to you. If your account serves securities, like low-priced securities, as identified by Merrill.
as the securities account for a Merrill investment advisory program and if,
for any reason, you terminate from the investment advisory program without • If you’ve requested a Visa® Card, you agree that:
transferring the securities and assets out of your account, your account will be − Merrill is authorized to issue you the Visa® Card you requested for use with
a Merrill Edge Self-Directed Investing Account without any investment advisory eligible accounts, and you understand that Merrill or an affiliate may obtain
relationship. As such, and as explained more fully in the preceding paragraphs, a credit report due to your request.
neither Merrill, nor any Merrill representative, will provide any investment advice
or give any advice or offer any opinion regarding the suitability of any security, • If you’re establishing your relationship in a joint capacity, you agree that:
order or transaction in a Merrill Edge Self-Directed Investing Account. − Any joint accounts you open in the future held by the same owners will
Additionally, to the extent that you maintain other accounts or relationships have the same ownership designation you establish on this Agreement,
with Merrill or its affiliates under which you do receive investment advice or unless you notify us otherwise in writing.
management from us or our affiliate, you agree not to implement such advice If you are the custodian of an account opened under the Uniform Transfers to
in the account. Minors Act (UTMA) or the Uniform Gifts to Minors Act (UGMA) as adopted by
If you do not feel comfortable with self-directing your retirement assets or any jurisdiction, you agree to comply with all requirements of the applicable
would otherwise like to learn more about the benefits of our management UTMA or UGMA law, including but not limited to the requirements that you
and advisory services and programs for Retirement Investors, please contact (i) expend the UTMA or UGMA account assets only for the use and benefit of
Merrill Edge Self-Directed Investing at 877.653.4732. the minor named on the account (the “Minor”), and (ii) upon the earlier of the
Minor’s attainment of the applicable termination age or the Minor’s death,
transfer the UTMA or UGMA account assets to the Minor or to the Minor’s
3. Definitions
estate. Merrill shall not have any responsibility to make sure that you properly
For the purpose of this Agreement, “you” and “your” refers to each person who perform your duties as custodian.
has agreed to the terms in this Agreement. “Merrill,” “we,” “our” and “us” refer
You agree that once Merrill has reason to believe that the Minor has reached
to Merrill Lynch, Pierce, Fenner & Smith Incorporated, a registered broker-dealer
the termination age under applicable law, Merrill may, but is not obligated to,
and a wholly owned subsidiary of Bank of America Corporation. “Account” refers
take any or all of the following actions with respect to the UTMA or UGMA
to any securities account you open with Merrill.
account without further consent from you:
In the case of an entity, “you” and “your” refers to the entity, and by enrolling
• limit trading in the UTMA or UGMA account to liquidating orders;
the entity agrees that access to Merrill Edge Self-Directed Investing shall be
restricted to Authorized Representatives (as defined in the account agreement) • prohibit further deposits into the UTMA or UGMA account;
for such entity and that the entity will be liable for all acts or omissions of such • restrict withdrawals or transfers from the UTMA or UGMA account other
Authorized Representatives. than to the Minor;
For the purpose of this Agreement, Merrill Edge Self-Directed Investing
• communicate with the Minor or the Minor’s legal representative regarding
(“MESD”), which is made available through Merrill Lynch, Pierce, Fenner & Smith
the UTMA or UGMA account including, but not limited to, providing periodic
Incorporated (“MLPF&S”), refers to certain brokerage services offered to clients
account statements and tax statements to the Minor or Minor’s legal
on a self-directed basis through Merrill Lynch, Pierce, Fenner & Smith Incorporated
representative;
(“Merrill”) and which are the subject of this Agreement.
For purposes of the Margin Lending Program and Liens sections described • accept liquidating orders from the Minor; and
below, “securities and other properties” means, without limitation, money, • deliver the UTMA or UGMA account assets to the Minor.
securities, financial instruments and commodities of every kind and nature and
related contracts and options held in any of your accounts carried or maintained Attention Guardians and Conservators for Minors
by Merrill or any of its affiliates in which you may have an interest. If you are a fiduciary such as a guardian or conservator of an account opened
for a minor, you agree that you shall (i) expend the account assets only for the
use and benefit of the minor named on the account (the “Minor”), as directed
4. How the Merrill Edge CRA works
by the Court or as provided pursuant to applicable state law, and (ii) within a
This Agreement provides you with access to a range of accounts, Products and reasonable time after the Minor’s attainment of the age of majority or other
Services. When you agree to the terms of this Agreement, you’re agreeing that age specified by state law or court order, deliver the account assets to the
its terms will apply to all of your MESD accounts, transactions and services Minor, or as directed by court order. Merrill shall not have any responsibility
while you are an MESD client. to ensure that you properly perform your duties as fiduciary, but may request
In particular, you agree: copies of any applicable court orders.
• You will resolve any controversies with us through arbitration. You agree that once Merrill has reason to believe that the Minor has reached
• We have a lien on your non-retirement accounts and assets in those the age of majority or other age specified by state law or court order, Merrill
accounts for the payment of any obligation you have with us. may, but is not obligated to, take any or all of the following actions with respect
to the account without further consent from you:
• New York law governs your agreements and transactions, unless we
indicate otherwise. • limit trading in the account to liquidating orders;

• Merrill has the right to amend this Agreement at any time with advance • prohibit further deposits into the account;
notice in writing. Any amendments will be effective on the date specified in • restrict withdrawals or transfers from the account other than to the Minor;
the notice.
• seek clarification and/or direction from the appointing court at your expense
• Merrill may in its sole discretion and without notice to you, to the extent or the Minor’s expense;
permissible under applicable law and other governing documents applicable
to your account, decline, cancel or reverse your orders or instructions, or • communicate with the Minor or the Minor’s legal representative regarding
place trading, disbursement and other restrictions on any of your accounts. the account including, but not limited to, providing periodic account
statements and tax statements to the Minor or Minor’s legal representative;
• If you’re enrolled in the Margin Lending Program, you agree and
understand that: • accept liquidating orders from the Minor; or
− You may borrow money from Merrill secured by a pledge of your eligible • deliver the account assets to the Minor.
securities and other property in your account.
− You will be charged interest on debit balances at a rate permitted by the
laws of the state of New York.

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Further, if the Minor dies prior to attaining the age of majority, you agree to For example, if you enroll in the Merrill Edge® Self-Directed Investing Cash
deliver the account assets as set forth pursuant to applicable state law or as Management Account® (CMA® account) financial service, the disclosures and
directed pursuant to court order. account agreement for that service are incorporated in this Agreement. We will
The specific provisions on these topics are set forth in detail below. If you provide those documents to you when you enroll.
trade and hold non-U.S. issued securities, you agree and acknowledge that: The terms governing a specific account or service will control if there are any
• Merrill or its affiliates may be required to disclose customer names and other inconsistencies with the terms of this Merrill Edge CRA. If you are establishing
identifying information, including but not limited to Social Security number a joint account with this Agreement, you must designate how the account is to
or tax identification number, to regulators (including taxing authorities) and/ be held by the owners of the account.
or issuers to comply with local law and/or customs and practice. For example, Eligible joint account designations include:
we may be required to provide personal information in order to meet local • JTWROS — Joint Tenancy With Right of Survivorship;
regulations that require the submission of investor names to the local stock
exchange, or an issuer may request residence and taxpayer identification • TIC — Joint Tenancy Without Right of Survivorship, also known as Tenants
information in order to obtain favorable tax treatment, such as lower in Common;
withholding rates, for shareholders. • ATBE — As Tenants by Entirety (for married persons, only in states where
• For clients who trade and hold shares of Italian companies whose equity applicable);
securities are traded in any regulated market: • COMMPROP — Community Property for married persons, only in states
− If you hold shares of Italian companies whose equity securities are where applicable;
traded in any regulated market, you hereby represent that you only hold • CPWROS - Community Property With Right of Survivorship for married
“Non-Qualified Equity Investments” (Partecipazioni Non Qualificate). persons, only in states where applicable;
You agree, and acknowledge that it is your responsibility, to immediately
inform Merrill if this representation is inaccurate or untrue or if it becomes • WI MAR PROP — Wisconsin Marital Property, for married residents of
inaccurate or untrue. Wisconsin only; and
• WI SURV MAR PROP — Wisconsin Survivorship Marital Property, for married
a) Read and understand English
residents of Wisconsin only.
You acknowledge that (i) you can read and fully understand English; (ii) that
written documents, agreements, and information (collectively referred to You hereby agree that, unless you notify us otherwise in writing, all subsequent
as “Materials”) concerning your relationship with Merrill, including but not joint accounts opened with Merrill by the same owners shall be held by such
limited to products, services, transactions, and other account details, will owners with the same ownership designation. All joint accounts are subject to
typically be provided to you in English; and (iii) on occasion we may provide the specific provisions pertaining to joint accounts contained in the applicable
certain Materials to you in Chinese, Spanish, or Portuguese, as applicable. account agreements. Joint ownership of property is an important element
of estate planning and entails important legal and tax consequences. Joint
關注客戶 ownership laws vary from state to state. You are responsible for verifying that
the joint registration that you select for your account(s) is valid in your state.
變化的通知在其自己的與MLPF &S的關係 In addition, state laws regarding community property vary. Please consult your
attorney if you have any questions regarding the joint ownership or community
您承认(i),你可以阅读并完全理解英语; (ii)有关与美林(Merrill Lynch)
property laws that may be applicable to your account(s).
的关系的书面文件,协议,以及信息(统称为“材料”),包括但不限于产
品,服务,交易,和其他帐户细节,通常会以英语向您提供,(iii)有时出 c) Additional signatures
于尊重,我们可能会向您提供某些非英文的翻译材料。 You may need to sign more than one Merrill Edge Self-Directed CRA. This will
be required if you want to open an account in a capacity other than as an
Atención a Nuestros Clientes:
“individual,” including as a:
Notificación de cambios en la relación de su cuenta con MLPF&S
• Trustee of a trust;
Ud. reconoce que (i) puede leer y entender el idioma inglés a cabalidad;
(ii) que, en general, todos los documentos escritos, contratos y demás • Personal representative or executor of an estate; or
información (denominada, en conjunto, como “Materiales”), que tengan que
• Guardian.
ver con la relación que sostiene con Merrill, incluyendo pero sin limitarse a
los productos, servicios, transacciones y demás detalles relacionados con su We may also require you to sign additional agreements or other documents
cuenta le serán entregados en el idioma inglés; y (iii) en ocasiones, podremos for certain services or instructions, including:
entregarle traducciones de ciertos materiales a otros idiomas distintos al • Selecting beneficiaries for an individual retirement account;
inglés, como un gesto de cortesía hacia Ud.
• Selecting the ownership of a joint account;
Atenção, todos os clientes: Notificação das mudanças realizadas nos
contratos de suas contas com MLPF&S: • Selecting beneficiaries of an account with the transfer on death service;
Você declara que (i) pode ler e compreender o idioma inglês perfeitamente; • Options trading;
(ii) que aceita que, em geral, todos os documentos escritos, os contratos e as • Financial planning;
outras informações (juntamente designados “Materiais”), que tenham a ver
com a relação que você mantém com a Merrill, inclusive, mas sem se limitar • Managed money services; and
a, os produtos, serviços, transações e outros detalhes relacionados a sua • Services involving the transfers of money or securities.
conta sejam entregues em idioma inglês; e que (iii), em ocasiões, poderemos
entregar traduções de alguns materiais em outros idiomas diferentes do d) Retirement account beneficiaries
inglês, como gesto de cortesia para você. Your signature is required to designate or change beneficiaries to receive the
b) New accounts and services balance of your account upon your death. If you do not do so, your account
balance will be paid to your spouse, if he or she survives or, if not, to your estate.
When you open a new account or enroll in a service, or convert all or part of
an existing Merrill account to MESD, we will provide you with the agreement e) Amendments
and any disclosures for that account or service and confirm your enrollment You agree that Merrill has the right to amend this Merrill Edge Self-Directed
in that account or service in writing. Those agreements and disclosures CRA at any time by providing notice of the amendment to you. The amendment
are incorporated by reference. This means that your initial signature acts will be effective on the date contained in the notice.
as your agreement to the terms of the new account or service. As a result,
in many cases, you will not need to sign an additional account agreement
or other form. 5. Customer information and due diligence
Merrill, like all U.S. financial institutions, is required to follow federal regulations
to assist the government in its efforts to fight money laundering and other

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financial crimes, and to counter terrorist financing efforts in the U.S. and or (ii) any other transaction you enter into with Merrill or its affiliates. You
globally. Merrill obtains specific personal information from you in order to further agree and acknowledge that you and any beneficial owner(s) if acting
verify your identity; and you may be required to present documentary evidence in a representative capacity are responsible for timely paying any taxes owed
of your identity in the form of government-issued identification. Merrill also to any tax authority, and for timely filing all relevant tax returns in relation to
uses third-party vendors to verify customer information. Foreign nationals assets held in any securities account held at Merrill now or in the future, or any
who are permanent legal residents of the U.S. may be required to present a other transaction you enter into with Merrill or its affiliates.
Permanent Resident Card (i.e., “green card”) and a Social Security number to
open an account in a U.S.-based Merrill office. Non-individuals (e.g., a business, 10. Special Provisions for FDIC Deposit Insurance Coverage
trust or estate) must submit sufficient evidence of legal status.
If you have opened a Merrill account that holds bank deposits on your behalf
In addition to verifying the identity of our customers, Merrill captures personal or on behalf of the beneficial owners of the assets in the account, you, as
information on all customers and related authorized parties who have the the account holder or representative, must be able to provide information, in
ability to transact, control, influence or manage an account, whether directly the event of adverse circumstances, about your ownership of the deposits or
or indirectly. Merrill, at its discretion, may elect not to accept an account, information regarding the interests of the beneficial owner(s) or beneficiaries
or to terminate the account agreement and the account agreements of any to Merrill in accordance with the FDIC’s requirements.
related parties.
In the event of adverse circumstances, you agree to:
• Cooperate fully with us and the FDIC in connection with determining the
6. Margin lending
insured status of funds in such accounts at any time;
If any account is established with the Margin Lending Program, you understand
and agree that: • Provide promptly the necessary data in the required format.
• You may borrow money from Merrill secured by a pledge of your eligible In the event of bank failure, the FDIC would be appointed as receiver and a hold
securities and other property in your account; would be placed on your account so that the FDIC can conduct the deposit
insurance determination; that hold will not be released until the FDIC obtains
• You will be charged interest on debit balances at a rate permitted by the laws
the necessary data to enable the FDIC to calculate the deposit insurance. You
of the state of New York;
understand and agree if you do not provide the necessary data to Merrill in
• Certain of your securities may be loaned to Merrill or loaned out to others; a timely manner, it may result in a delay in receipt of insured funds and your
and ability to transact with these funds.
• You are bound by the terms of the agreement for the Margin Lending service.
11. Fees
Further, in return for extending credit to you under the Margin Lending
Program, you acknowledge and agree that we may lend, either to Merrill You agree to pay your account fees, service fees, processing and other fees for
or to others, the securities in your account (along with all attendant rights the transactions and other services you receive from Merrill. You understand
of ownership), to the extent not prohibited by applicable laws, rules and that these fees will be charged to your accounts. Current information about
regulations. Please refer to the terms for the Margin Lending Program in the the fees that apply to your account is available under the “Online investing
Merrill Edge Self-Directed Cash Management Account Disclosures and Account and trading” tab at: www.merrilledge.com/pricing. You agree that Merrill
Agreement for more detail. may satisfy any amounts you owe to Merrill from available free credit
balances and assets in your account. If necessary, Merrill is permitted to sell
7. Liens assets in your accounts to pay those amounts due. You agree that you have
reviewed the schedule of fees applicable to your MESD Account, including
All of your securities and other property in any account — margin or cash — account fees, service fees, processing and other fees for the transactions
in which you have an interest, or which at any time are in your possession and services applicable to your account, and believe them, in addition to any
or under your control other than retirement accounts, such as IRAs, shall be third-party compensation that we may receive with respect to your account
subject to a lien for the discharge of any and all indebtedness or any other or transactions engaged in by your account discussed more fully below, to
obligations you may have to Merrill. Securities and other property held in be reasonable compensation to us in light of the totality of services we may
retirement accounts, such as IRAs, are not subject to this lien, and are not used provide with respect to the account.
as security for the payment of your obligations or indebtedness for other
non-retirement accounts — cash or margin — you maintain with Merrill. You a) Securities transactions
agree that Merrill holds all of your securities and other property in margin or When you purchase or sell securities, you may pay for each securities transaction
cash accounts, other than retirement accounts, as security for the payment on a per trade basis. This is called transaction-based pricing. Under this type
of any such obligations or indebtedness to Merrill in any account in which of pricing, you are charged a commission or other compensation for each
you have an interest. Merrill, subject to applicable laws, may at any time transaction. This compensation varies based on a number of factors, such as
and without giving you prior notice, use and/or transfer any or all securities your relationship with Merrill and Bank of America, the type of security and
and other property in any account in which you have an interest other than how often you trade. Commission rates are subject to change. Our current
retirement accounts, without regard to Merrill having made any advances in standard commission schedule is available under the “Online investing and
connection with such securities and other property and without regard to the trading” tab at: www.merrilledge.com/pricing.
number of accounts you may have with Merrill. In enforcing the lien, Merrill, at
The amount of commissions you may pay varies from product to product.
its sole discretion, may determine which securities and other property are to be
Where commissions apply, the more transactions you enter into, the more
sold or which contracts are to be closed.
compensation we receive. When you pay commissions with respect to
particular investments, we benefit from you buying and selling more frequently,
8. Governing law rather than holding investments, and from you purchasing investments that
Unless otherwise specified, your agreements and transactions with Merrill will result in higher commissions and compensation to us and our affiliates.
be governed by and interpreted under the laws of the State of New York. Merrill and its affiliates also receive compensation from third parties (including
You may not use your account or relationship to the firm to process transactions from the investment products in which you invest, and their manufacturers,
that are prohibited by law, including, but not limited to, restricted transactions distributors, managers, and their respective affiliates) in connection with
prohibited by the Unlawful Internet Gambling Enforcement Act of 2006. your investment transactions. The amount of this third-party compensation
generally varies from product to product. Merrill has an incentive for you to
engage in investment transactions that result in more compensation from third
9. Compliance with applicable laws
parties to Merrill and its affiliates. The costs of this third-party compensation
You represent that you and any beneficial owner(s), if acting in a representative generally represent an expense embedded in the investment that is ultimately
capacity, have complied, and you agree that you and any such beneficial borne by investors such as you. The specific types of third-party compensation
owner(s) will comply for so long as your account(s) remain(s) open, with all we may receive with respect to a particular investment are typically disclosed
applicable laws (including obligations related to tax payments and reporting in the relevant investment product prospectus or other offering document.
and to currency exchange controls) related to (i) the assets deposited, acquired Examples of the types of third-party compensation we can receive are listed
or otherwise held in any securities account held at Merrill now or in the future,

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hereafter, but note that not all types of compensation apply to all investments, a waiver of any rights under this Agreement except to the extent
and we may receive other compensation that is not listed here. The examples stated herein.
of third-party compensation include: Rule 12b-1 and other distribution and
servicing fees; revenue sharing payments; exchange-traded fund index 13. Important disclosures
licensing fees; event payments; gifts, gratuities, and other non-monetary
compensation; payment for order flow; securities lending fees; valuation fees; Merrill is a registered broker-dealer and a wholly owned subsidiary of
redemption fees; and underwriting fees. Bank of America Corporation. Unless otherwise disclosed, investments through
Merrill are not FDIC Insured, and are not Bank guaranteed, and may lose value.
b) Visa® cards issued by Bank of America, N.A. Investing in securities involves the risk of loss, and you should be prepared to
There is no annual fee for the Merrill CMA Access® Visa® card. However, bear this risk.
transaction charges apply with respect to particular transactions as disclosed Merrill offers its products, accounts and services through different service
in the Merrill CMA Access Visa card terms and conditions. models (e.g., self-directed, full-service). Based on the service model, the
This information is subject to change. You may call Merrill Edge Self-Directed same or similar products, accounts and services may vary in their price or fee
at 877.653.4732 to verify current fees. charged to a client.
You authorize Merrill to issue the Visa card that you have requested for use A Merrill financial advisor, Merrill Financial Solutions Advisor or other Merrill
with eligible accounts, and you understand that Merrill or an affiliate may employee (collectively referred to herein as an “Associate”) is eligible to
obtain a credit report in connection with your request. receive compensation if the Associate informs you about MESD and you
thereafter open an MESD account and/or add more assets to your existing
MESD account. The details of the compensation will depend on the Associate’s
12. Agreement to arbitrate controversies employment agreements and arrangements with Merrill, and the types of
This Agreement contains a predispute arbitration clause. By signing compensation for which the Associate is eligible. In general, the compensation
an arbitration agreement the parties agree as follows: the Associate receives will vary based on the amount of assets you invest in an
• All parties to this Agreement are giving up the right to sue each other MESD account at a specific time or over a specific period (e.g., upon account
in court, including the right to a trial by jury, except as provided by opening or during a given quarter). The Associate’s activity with respect to
the rules of the arbitration forum in which a claim is filed. other Merrill clients and the amount of assets other clients invest in MESD
accounts or other accounts with Merrill or its affiliates will also affect the
• Arbitration awards are generally final and binding; a party’s ability to
compensation for which the Associate may be eligible. Merrill’s compensation
have a court reverse or modify an arbitration award is very limited.
arrangements with Associates generally include thresholds regarding the
• The ability of the parties to obtain documents, witness statements amount of compensation to be paid to Associates. Associate compensation
and other discovery is generally more limited in arbitration than in varies and is based on, among other things, the amount clients invest in
court proceedings. accounts, the number of accounts clients open and/or close, and qualitative
factors such as client satisfaction. A Merrill financial advisor is eligible to
• The arbitrators do not have to explain the reason(s) for their award
receive ongoing compensation for a limited period of time if the total amount
unless, in an eligible case, a joint request for an explained decision
invested in an MESD account exceeds a certain threshold.
has been submitted by all parties to the panel at least 20 days prior
to the first scheduled hearing date. You can research Merrill and our representatives using FINRA’s BrokerCheck
database.
• The panel of arbitrators may include a minority of arbitrators who
were or are affiliated with the securities industry. Vesting age for UTMA (Uniform Transfer to Minor account) and UGMA
accounts (Uniform Gift to Minor account) defaults to the minimum age
• The rules of some arbitration forums may impose time limits for defined by individual state laws.
bringing a claim in arbitration. In some cases, a claim that is ineligible
for arbitration may be brought in court.
14. Sweep Program
• The rules of the arbitration forum in which the claim is filed, and any The deposit of checks, the sale of securities, and other activity will
amendments thereto, shall be incorporated into this Agreement. periodically generate cash in your account. You have the option to have cash
You agree that all controversies that may arise between us shall be balances in your account automatically deposited into Bank of America, N.A.
determined by arbitration. Such controversies include, but are not (BANA”) and/or Bank of America California, N.A. (“BA-CA”) under the Merrill
limited to, those involving any transaction in any of your accounts with Lynch Direct Deposit Program (“MLDD Program”). Alternatively, you may
Merrill, or the construction, performance or breach of any agreement elect that cash balances do not sweep. If you choose to not sweep your
between us, whether entered into or occurring prior, on or subsequent cash balances, they will not earn interest. These balances will be covered by
to the date hereof. the Securities Investor Protection Corporation (“SIPC”) up to $250,000 per
customer and by our excess-SIPC coverage, as described in your account
Any arbitration pursuant to this provision shall be conducted only
agreement, but they are not insured by the FDIC. For IRA Accounts, cash
before the Financial Industry Regulatory Authority Inc. (“FINRA”) or an
balances will be automatically deposited into Bank of America, N.A. (“BANA”)
arbitration facility provided by any other exchange of which Merrill is a
and/or Bank of America California, N.A. (“BA-CA”) under the Retirement Asset
member, and in accordance with the respective arbitration rules then in
Savings Program (the “RASP Program”). The MLDD and RASP Programs
effect at FINRA or such other exchange.
are collectively referred to as the “Sweep Program.” For details contact
You may elect in the first instance whether arbitration shall be Merrill Edge Self-Directed Investing at 877.653.4732, or view your account
conducted before FINRA or another exchange of which Merrill is a agreement. Please note that if your account is enrolled in a Merrill investment
member, but if you fail to make such election by registered letter advisory program, such as Merrill Guided Investing, and you choose to not
addressed to Merrill at the office where you maintain your account sweep your cash balances, you should understand that Merrill may charge an
before the expiration of five (5) days after receipt of a written request asset-based advisory fee on the cash in the account even though you are not
from Merrill to make such election, then Merrill may make such election. earning any interest or dividends on that cash.
Judgment upon the award of the arbitrators may be entered in any
Conflicts of interest Bank deposit programs
court, state or federal, having jurisdiction.
There are conflicts of interest relating to the Sweep Program. Deposits held
No person shall bring a putative or certified class action to arbitration, at BANA and/or BA-CA (collectively, the “Merrill Lynch Affiliated Banks”) are
nor seek to enforce any pre-dispute arbitration agreement against financially beneficial to Merrill and its affiliates. If you hold cash balances
any person who has initiated in court a putative class action or who in your account, both the Merrill Lynch Affiliated Banks and Merrill benefit
is a member of a putative class who has not opted out of the class financially when your cash is “swept” to and held in deposit with them under
with respect to any claims encompassed by the putative class action our sweep programs. The Merrill Lynch Affiliated Banks benefit from their use
until: (i) the class certification is denied; or (ii) the class is decertified; of the deposits, and Merrill receives compensation from the Merrill Lynch Bank
or (iii) the customer is excluded from the class by the court. Such Affiliates for its services relating to the cash sweep program.
forbearance to enforce an agreement to arbitrate shall not constitute
The participating Merrill Lynch Affiliated Banks use bank deposits to fund
current and new lending, investment and other business activities. This is a

Page 5 | Merrill Edge Self-Directed Investing Client Relationship Agreement Code 422000PM-1123
conflict of interest because, like other depository institutions, their profitability may establish multiple additional money accounts and make deposits at any
is determined in large part by the difference between the interest paid and time by speaking to your financial advisor. If you have established money
other costs incurred by them on bank deposits and the interest or other accounts in addition to your primary money account, and you do not have
income earned on their loans, investments and other assets, which may be sufficient balances in your primary money account, your additional money
funded in part by bank deposits. The deposits provide a stable source of account balances will be withdrawn to satisfy securities and cash management
funding, and borrowing costs incurred to fund their business activities have transactions, including check writing and Visa® Card activity, in or through your
been reduced by the use of deposits from Merrill clients. account. Ask for the applicable deposit account program disclosures for details
In addition, the Merrill Lynch Affiliated Banks determine the interest rate paid on deposits.
to depositors in the cash sweep program. Various deposit accounts are available as additional money accounts based
The deposits will bear a rate of interest that has been established for, and in on account type. Please contact Merrill Edge Self-Directed Investing at
light of the features of, the cash sweep program. Generally, this rate will likely 877.653.4732 to determine if a particular option is available to you to
be lower than (1) the interest rates available on non-sweep deposit accounts determine applicable rules and minimums (if any).
with Merrill Lynch Affiliated Banks and other banking institutions and (2) yields
Confirmations and statements
on cash alternatives, such as money market funds. The features of these non-
sweep deposit accounts and cash alternatives are different from bank deposit In general, when we execute a transaction, we will send you a confirmation
accounts affiliated with the cash sweep program. summarizing the details. We will not send you a confirmation for certain
pre-authorized transactions in securities, including mutual funds, Sweep
Merrill receives: Program transactions (whether for your primary money market account or any
• Up to $100 per year from BANA and BA-CA for each account that sweeps additional money accounts) and any transaction in a money market mutual
to the Merrill Lynch Bank Deposit Program, Merrill Lynch Business Deposit fund (“Exempt Transactions”). We will send you an account statement (monthly
Program and Merrill Lynch Direct Deposit Program or quarterly, based in part on account type and/or activity) as a record of the
• Up to $85 per year for each account that sweeps to the Retirement Asset securities, cash and other assets held by us and the activity in your account
Savings Program for the time period covered by the statement. Your statement will serve as a
confirmation of any Exempt Transactions. The statement will also give you
• A fee of up to 2% per annum of the average daily balances from the ISA year-to-date information on dividends and interest received, as well as market
banks prices of the securities in your account, if available.
This compensation is subject to change from time to time, and Merrill may
Automatic Liquidation of Additional Money accounts
waive all or part of it.
If you have a retirement account and the funds within your primary money
The greater the amount of the cash balance maintained in your Account that account are depleted, we will automatically liquidate your Additional Money
is swept into a cash sweep program bank deposit account and the lower the accounts in the following order to satisfy obligations to your account(s):
interest rate paid on the deposit, the more our bank affiliates benefit. Retirement Reserves I, Retirement Reserves II, Ready Asset Trust.
Interest rates paid on deposits are determined at the discretion of the Merrill If you have a CMA Account and the funds within your primary money account
Affiliated Bank based on economic and business conditions. Rates may change are depleted, you may select the order in which your Additional Money accounts
daily. The current yield on any deposits held under the MLDD Program or the are automatically liquidated to satisfy obligations to your account(s) by speaking
RASP Program will be included on your account statement. Note: The MLDD with Merrill Edge Self-Directed Investing at 877.653.4732, or view your
Program is the Sweep Program available to MESD Cash Management Accounts account agreement.
(CMAs), and the RASP Program is the Sweep Program available to Traditional
IRAs, Roth IRAs, Rollover IRAs, BASIC, SEP and SIMPLE accounts. You can also
access current yield information on our website (see the “Deposit Account &
15. Representations as to account ownership and capacity
Money Fund Rates” link at the bottom of each page of merrilledge.com), or by to enter into agreement
contacting Merrill Edge Self-Directed Investing at 877.653.4732. The interest You represent that no one except the person(s) signing this Agreement, or the
paid on retirement account assets will be at no less than a reasonable rate. beneficial owner(s) if signed in a representative capacity, has an interest in this
Your cash in the MLDD Program and the RASP Program is insured by the account or any additional accounts opened in the future for you or for such
Federal Deposit Insurance Corporation (“FDIC”) up to a total of the Standard beneficial owner(s). If this account is beneficially owned by any person who is
Maximum Deposit Insurance Amount (“SMDIA”) per depositor at the Merrill U.S. Securities and Exchange Act Section 16 reporting person of a U.S. public
Affiliated Bank. The SMDIA is $250,000 per depositor, per ownership category. company, you represent that no funds or assets belonging to such U.S. public
Each individual depositor receives up to the SMDIA of FDIC insurance and company, or any entity affiliate of such U.S. public company, will be invested
each joint account with two depositors up to two times the SMDIA of FDIC through this account. If this is an individual account, you represent that you are
insurance. It is your responsibility to monitor the total amount of your deposits of legal age to contract in your jurisdiction of residence and that you are not
with the Merrill Affiliated Bank to determine the extent of insurance coverage employed by a broker-dealer or other employer whose consent is required to
available on your deposits. It is important to note that uninvested cash held open and maintain this account by regulation or otherwise, unless such consent
in more than one Merrill account (such as a CMA) may be deposited to the has been provided to you. If any of the foregoing representations is inaccurate
same Merrill Affiliated Bank. Also, amounts in excess of the applicable FDIC or becomes inaccurate, you will promptly so advise.
insurance limit may be deposited to the Merrill Affiliated Bank from the same You acknowledge that you fully understand English and that written
Merrill account. Any certificates of deposit that you own issued by a Merrill documents, agreements and information concerning your relationship with
Affiliated Bank will also count towards the FDIC insurance limits. Merrill, including but not limited to products, services, transactions and your
The Securities Investor Protection Corporation (“SIPC”) does not cover cash on accounts will be provided to you in English.
deposit at the Merrill Affiliated Bank. You may obtain further information about
SIPC, including the SIPC Brochure, via SIPC’s website at www.sipc.org or by 16. Electronic fund transfers
calling SIPC at 202.371.8300. If you maintain more than one account with Merrill with the same ownership
Merrill reserves the right to offer different Sweep Programs for different type, you may transfer funds to and from each account through Merrill’s
accounts or clients. Merrill, may, with 30 days prior written notice, (i) make electronic funds transfer services.
changes to the terms and conditions of our Sweep Program; (ii) make changes You authorize Merrill to accept your telephonic or electronic instructions for
to the terms and conditions of any money account; (iii) change, add or remove those transfers.
the money account available as sweep product; (iv) transfer your money If you open any account as the trustee for a grantor revocable living trust,
account from one sweep product to another. Available cash balances are you represent and warrant to Merrill that:
automatically swept into the primary money account. You affirmatively consent
to having your available cash balances sweep to MLDDP and/or RASP. • The trust permits the funds transfers you are authorizing; or

Additional Money accounts • If applicable, such funds transfers represent valid partial or total revocations
by you and Merrill may conclusively rely on this representation.
Under the Sweep Program, you may only establish one primary money account
for the automatic deposit of cash balances in your account. However, you

Page 6 | Merrill Edge Self-Directed Investing Client Relationship Agreement Code 422000PM-1123
17. Third-party research email address is no longer valid, Merrill will mail via U.S. Postal Service a
Merrill may offer you access to third-party research on certain U.S. and notice to the primary mailing address on your account asking that you update
non-U.S. equity and fixed income securities. You agree that neither Merrill nor your email address. If your mailing address is invalid and the mailed notice is
any of its affiliates bears any responsibility or liability for third-party research returned by the post office, your account may be considered abandoned. Also,
or its content that may be made available to you. your account may be considered abandoned if there has not been any client-
initiated activity for a period of three to five years. Client-initiated activity
You assume full responsibility for any trading decision you make based includes, but is not limited to, reviewing account activity online, calling a Merrill
on third-party research. Access to third-party research is provided for call center, transacting in your account, or voting proxies.
informational purposes only and does not constitute investment advice. Merrill
does not endorse or otherwise adopt third-party research reports or ratings. Merrill is required by the unclaimed property laws to turn over accounts
considered abandoned to the applicable state. Before Merrill turns over an
18. Custody of securities abandoned account, the Firm may send a notice to the primary mailing address
on the account. Merrill may also utilize a third-party search vendor to locate a
Merrill will hold all securities for the Securities account in a control location better address to notify you of your abandoned account prior to turning your
acceptable to the Securities and Exchange Commission, which may include, account over to the state of last known address. After Merrill turns the funds
but is not limited to: (i) a securities depository, such as the federally regulated over to the state, Merrill has no further liability to you for the funds and/or
Depository Trust Company for U.S. issuers and Euroclear for European issuers, securities. You must apply to the appropriate state agency to claim your funds.
(ii) a Federal Reserve member bank, or (iii) a mutual fund’s Transfer Agent. The state may liquidate any securities once your shares are remitted to them.
Securities are commingled in a Merrill book-entry account, generally held in
nominee name at the control location, along with securities belonging to other If Merrill considers your account abandoned, then (unless prohibited by federal
Merrill customers. Your securities will at all times be separately identified or state law) we may:
on the books and records of Merrill as belonging to you, and Merrill will • Stop sending correspondence.
provide you with account statements that reflect your holdings. This method
• Refuse to pay items drawn on or payable out of the account.
of custody, which has significantly increased efficiencies and reduced the
risks associated with holding customer securities, is used by all major banks, • Charge regular account fees according to the type of account you maintain
trust companies and brokerage firms and has been recognized as providing with us.
unsurpassed safety for holders of securities. With regard to the custody of your
If you re-establish contact with Merrill, we do not have to reimburse you
securities, Merrill acts as your agent and transmits your instructions through
for these fees.
the appropriate control location.
Where securities are not held in nominee name, the issuer or control location, 22. Account owners with Texas mailing address
as appropriate, recognizes Merrill as your agent and honors instructions Clients with a mailing address in the state of Texas may appoint a designee
provided by Merrill on your behalf. who can respond to abandoned property notifications on the client’s behalf
and prevent an account from being classified as abandoned and turned over
19. Referral Policy to the state of Texas. Please contact Merrill Edge Self-Directed Investing at
Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S”) is an 877.653.4732 or the Abandoned Property Department at 800.581.5858 for
affiliate of Bank of America, N.A. and other subsidiaries of Bank of America additional information.
Corporation (collectively, “Merrill”). Merrill is one of the world’s largest
financial institutions, serving individual consumers, small- and middle-market 23. Rejection of Payment Orders
businesses, institutional investors, large corporations and governments with a Merrill and/or Bank of America may reject payment orders (e.g., wire transfers,
full range of banking, investing, asset management and other financial and risk checks, etc.). We will notify you of any rejection orally, electronically or in
management products and services. In the event Merrill refers your business writing. If we send written notices by mail, we will do so by the end of the next
among its affiliates to provide you with certain products or services, Merrill business day. We are not liable to you for the rejection or obligated to pay you
(or its employees or representatives) may receive financial or other benefits interest for the period before you receive timely notice of rejection.
for such referrals.
24. Revised Uniform Fiduciary Access to Digital Assets Act
20. Freezing Accounts
In connection with the Revised Uniform Fiduciary Access to Digital Assets
If at any time Merrill believes that your account may be subject to irregular, Act (“RUFADAA”) and applicable state enabling statutes, Merrill will provide
unauthorized, fraudulent or illegal activity, we may, in our discretion, freeze an authorized fiduciary for a Merrill client, as determined by Merrill, with
the assets in the account and in other accounts you maintain with us until “read-only” online access to such client’s account(s) provided that the
such time as we are able to complete our investigation of the account and client’s fiduciary creates his/her own user name and password, complies
transactions. If we do freeze your account assets, we will provide notice to with the terms and conditions set forth in the Brokerage Website Terms and
you as soon as reasonably possible. Notice may be made by mail or verbally Conditions, as appropriate and provides Merrill with any additional requested
or provided by other means such as via www.merrilledge.com, where documentation. Online access is at all times subject to the terms, conditions
applicable. We may not provide this notice to you prior to freezing the account and requirement applicable to websites and/or mobile applications, including
if we believe that such notice could result in a security risk to us or to the any requirements for access. If Merrill determines that online access cannot
owner of the funds in the account. be reasonably granted to such authorized fiduciary, hard copies of the
information/documents requested by the authorized fiduciary may be provided.
21. Unclaimed property — accounts presumed abandoned
State and federal law and Merrill policy govern when accounts are considered
abandoned. The applicable state law is generally the state listed as the primary
mailing address for your account. Your account could be considered abandoned
after one piece of mail is returned to us by the U.S. Postal Service. For
accounts with electronic statement delivery preferences, if the Firm attempts
to deliver your correspondence electronically and we receive notice that your

Merrill, its affiliates and financial advisors do not provide legal, tax or accounting advice. You should consult your legal and/or tax advisors before making any financial decisions.
Unless otherwise noted, all registered trademarks and trademarks are the property of Bank of America Corporation.
Visa is a registered trademark of Visa International Service Association and is used by the issuer pursuant to license from Visa U.S.A. Inc.
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Page 7 | Merrill Edge Self-Directed Investing Client Relationship Agreement Code 422000PM-1123
M209468PML
Disclosure and Custodial Agreement

Traditional IRA Disclosure Statement


1. INTRODUCTION — PAGE 2 Deductible and nondeductible
Purpose of this Disclosure Statement — page 2 contributions — page 14
Who can open an IRA — page 2 Penalty for contributions over the
annual limit — page 14
Revoking your IRA — page 2
Tax-free distributions for nondeductible
2. THE ROLE OF MERRILL LYNCH — PAGE 2
contributions — page 15
3. ABOUT YOUR IRA AND SERVICES Taxes on distributions — page 15
WE PROVIDE — PAGE 2 Substantially Equal Periodic Payments to
Services for your IRA — page 2 avoid penalty — page 15
4. DESIGNATING BENEFICIARIES — PAGE 3 Penalty for failure to take minimum
distribution — page 16
Types of beneficiaries — page 3
10. WORKSHEETS TO HELP YOU WITH
Designating beneficiaries as primary
CALCULATIONS — PAGE 16
or contingent — page 4
Changes in family status affecting Calculating tax-free distributions — page 16
designations — page 4 Active participants: Calculating your
Tax implications of making a designation — page 4 tax deduction — page 16
5. CONTRIBUTING TO YOUR IRA — PAGE 4 11. GLOSSARY — PAGE 17
Transfers and rollovers from another IRA — page 5 12. IRS APPROVAL — PAGE 20
Annual contributions limits — page 7
6. ADDITIONAL INFORMATION ABOUT
CUSTODIAL AGREEMENT — PAGE 21
YOUR ACCOUNT — PAGE 8
Investing your IRA assets — page 8 RETIREMENT ASSET SAVINGS PROGRAM — PAGE 35
Prohibited investments and transactions — page 9 MERRILL LYNCH STATEMENT LINK SERVICE — PAGE 43
Insurance and SIPC protection — page 9
Losing your IRA’s tax-deferred status — page 9
Sweep arrangements for cash in your IRA — page 9
Tax communications we’ll send — page 10 The following pages contain the agreement and
7. DISTRIBUTIONS FROM YOUR IRA — PAGE 10 disclosures governing your traditional IRA including
disclosures required by federal law.
Required minimum distributions — page 10
Calculating your minimum distributions — page 10 This Disclosure Statement and Custodial Agreement
Taking your minimum distributions — page 11 has not yet been updated for tax law changes
Distributions after your death — page 11 included in the Setting Every Community Up for
Calculating distributions to beneficiaries — page 11 Retirement Enhancement (SECURE) and SECURE 2.0
8. FEES AND EXPENSES — PAGE 12 Acts which became law in 2020 and 2023,
respectively. The SECURE Acts change the rules
Custodial fees — page 12
governing IRA contributions and the age at which
Account close-out fee — page 13 you are required to start your Required Minimum
Other fees and expenses — page 13 Distributions (RMDs). SECURE and SECURE 2.0
9. TAXES AND PENALTIES — PAGE 13 Acts changes to the law are not reflected in this
Your responsibility to file tax returns document. You should check with your tax advisor
and other reports — page 13 regarding your specific situation before making any
decisions concerning your IRA.

Traditional Individual Retirement Account | 1


Section 1: Introduction Section 2: The role of
Merrill Lynch
PURPOSE OF THIS DISCLOSURE STATEMENT
[1] This Disclosure Statement describes the rules [7] We’ll follow your instructions for all purchases,
and benefits of your Traditional Individual sales, transfers, exchanges and other disposition
Retirement Account (IRA) as well as legal and of assets. If we don’t receive instructions from
federal tax information you should know about you, we’ll hold assets uninvested and contact
it. In case there is a discrepancy between you in writing at your last known address. If we
this Disclosure Statement and your Custodial can’t locate you within two months, we may
Agreement, the Custodial Agreement is the invest the cash proceeds in a money market fund
primary document governing your IRA other or interest-bearing account, if you don’t have a
than as provided in the second paragraph under sweep arrangement for cash in your IRA.
Section 2: The role of Merrill Lynch in this
Disclosure Statement, which shall govern with [8] Notwithstanding anything to the contrary in
respect to our role as fiduciary. the Custodial Agreement, we acknowledge
that, effective February 1, 2022, Merrill Lynch is
WHO CAN OPEN AN IRA acting as a fiduciary under Title I of ERISA and
[2] You can only open an IRA in an individual Section 4975 of the Tax Code in its capacity as
capacity. It cannot be opened under joint a broker-dealer when it provides investment
ownership or by non-individual entities. advice and makes recommendations to you
[3] To make annual contributions to your IRA, you regarding securities or investment strategies
must be under age 70½ at the end of the Tax in your IRA. The Merrill Best Interest Disclosure
Year and receive taxable compensation. But Statement provides a description of services
there are no age or compensation restrictions and information relating to our costs and fees,
to make contributions by rollover or direct compensation earned and material conflicts of
transfer. See Section 5 for more information. interest as required under these rules. At no
time will we act as your tax or legal advisor.
REVOKING YOUR IRA
[4] You can revoke your IRA and receive a complete
refund of any contributions you’ve made to Section 3: About your IRA and
us by notifying us in writing within 14 days services we provide
from the date this Disclosure Statement
was mailed to you. If your revocation is
postmarked, certified or registered within SERVICES FOR YOUR IRA
this period, we’ll return your contributions [9] Your IRA is being established for the sole
without any deduction for sales commissions, purpose of providing you and your beneficiaries
administrative expenses, other fees or with retirement benefits. An IRA provides
fluctuations in market value. you with a way to save for retirement
without paying taxes until you begin taking
[5] To revoke your IRA, send your written
distributions (or withdrawals). Your right to the
revocation to:
balance of your IRA, cannot be forfeited at any
Manager, Retirement Plan New Accounts time. As a non-bank custodian, we have been
Merrill Lynch, Pierce, Fenner & Smith Incorporated approved by the Internal Revenue Service (IRS)
1400 American Blvd. to administer your IRA, consistent with Section
NJ2-140-01-03 408(a) of the Tax Code.
Pennington, NJ 08534-4128
[10] IRS Publications 590-A and 590-B (or
[6] Contact your advisor or Service Associate or
replacement publications) contains helpful
call 1.800.MERRILL (637.7455), if you have any
information about your IRA and related tax
questions about revoking your IRA.

2 | Traditional Individual Retirement Account


topics. Visit irs.gov online or contact any IRS you, and we do not include any of your personal
Office to request a copy. or account information in the email alerts.
[11] Your advisor or Service Associate can offer you [17] Providing access to these documents
access to certain brokerage services and/or a electronically on MyMerrill.com will constitute
Merrill Lynch investment advisory program. good and effective delivery, regardless of
whether you actually access and review the
Statement Linking information. We will deliver all communications
[12] You can link multiple Merrill Lynch accounts, to you electronically. Certain cases may require
including those with different primary account us to send you paper copies as well. You may
holders, and appoint one of those account revoke your consent to Online Delivery and
holders to receive a single monthly statement receive paper copies of these documents at
and a summary of account information for all any time, by contacting your advisor or Service
linked accounts. Individual account holders Associate, or making your selection online.
remain responsible for checking individual
statements, reading notices and directing Merrill Lynch investment advisory program
account activity. The assets of linked accounts [18] You may enroll in a Merrill Lynch investment
are not commingled with other property, advisory program and authorize a financial
except as permitted by law in a common trust professional to make investment decisions and
fund or a common investment fund. manage your portfolio, based on criteria you
determine. You will need to sign an additional
[13] Linking some accounts may help you avoid
agreement to enroll. Fees for accounts enrolled
certain fees and deliver higher interest rates in
in a Merrill Lynch investment advisory program
the Retirement Asset Savings Program. See the
are based on assets under management.
Statement Linking Service fact sheet for more
Contact your advisor or Service Associate, if you
information in the Custodial Agreement.
have any questions about fees.
MyMerrill.com
[14] The online service, MyMerrill.com, allows you
to view your IRA balance, monitor transactions, Section 4: Designating
transfer funds and set up alerts. MyMerrill.com beneficiaries
also provides industry-leading research by
Bank of America Merrill Lynch Global Research
[19] You can designate in writing a beneficiary
to help inform your financial decisions. We can
to receive the balance of your IRA upon your
delete or modify any Merrill Lynch website and
death. If you make no designation, the balance
have the right to terminate your enrollment in
will be distributed to your surviving spouse,
the service at any time. Visit www.mymerrill.com
if you are married. If you do not have a surviving
or call (800) MERRILL to enroll.
spouse, the balance will be distributed to
Online Linking your estate.
[15] If you enroll multiple accounts in MyMerrill.com, [20] You can change your designation at any time
you can link them into a single MyMerrill.com by notifying us in writing. The change will not
account for a consolidated view and convenient become effective, until we receive notice and
online access to all of your account information. accept the change in beneficiary.
Online Delivery of communications [21] All beneficiary designations must be
[16] When you enroll in Online Delivery, you will compatible with our administrative and
receive an email alert when your statements operational requirements, which may change at
or documents are available for viewing online. any time.
Your records can be accessed online, where
they are protected by your password. We will TYPES OF BENEFICIARIES
never email your statements or documents to [22] A beneficiary can be an individual (e.g., a
natural person with a birth date), estate,

Traditional Individual Retirement Account | 3


charity or trust. You can designate multiple direct distributions. Consult your tax advisor,
beneficiaries for your IRA. However, special to better understand the tax implications of
rules apply for Required Minimum Distribution beneficiary designations.
(RMD) purposes following your death. For
example, if you want to extend payments
beyond five years after your death, each of Section 5: Contributing to
your designated beneficiaries should be a your IRA
natural person or a “look through” trust. Also,
if all your beneficiaries are natural persons, the
[27] You can make contributions to your IRA in-cash
oldest will be considered to be your designated
or in-kind (for rollover contributions or transfers
beneficiary for RMD purposes (see Distributions
from another IRA or qualified retirement plan).
after your death in Section 7) (US Treasury
Regulation 1.401(a)(9)-4). [28] In-cash contributions are those made by
check, money order or electronic funds transfer.
DESIGNATING BENEFICIARIES AS PRIMARY You can mail checks or money orders to:
OR CONTINGENT Merrill Lynch
[23] You can designate beneficiaries as primary or P.O. Box 16001
contingent: Newark, NJ 07199
• Primary beneficiaries will be the first to
[29] In-kind contributions are non-cash assets
receive the balance of your IRA.
like mutual funds and securities currently held
• Contingent beneficiaries will receive the at another financial institution that transfer
balance of your IRA, only if no primary into your IRA without being liquidated. In-kind
beneficiary survives you. contributions must be compatible with our
administrative and operational requirements.
CHANGES IN FAMILY STATUS AFFECTING
Certain in-kind contributions (e.g., limited
DESIGNATIONS
partnership interests) can typically only transfer
[24] Review your beneficiary designation periodically
into your IRA at specific intervals, such as
to make sure it reflects your intentions,
annually or semi-annually.
especially when your family status changes
(e.g., marriage, divorce, births, adoptions, death [30] You’re responsible for determining the
of a beneficiary), or during the establishment of eligibility of your contributions. We won’t
estate-planning trusts. knowingly accept contributions made by you
or for you that exceed annual limits for any Tax
[25] If you are married and designate your spouse
Year. We’ll return excess contributions to you, if
as beneficiary but later divorce or annul your
you ask us to do so in writing. (See Penalty for
marriage, your designation will be void, unless:
contributions over the annual limit in Section 9
• The decree of divorce or annulment for more information.)
designates your spouse as beneficiary,
[31] Assets in your IRA won’t be commingled
• You re-designate your spouse as beneficiary,
with other property for any reason, except as
or
permitted by law in a common trust fund or a
• Such spouse is re-designated to receive common investment fund.
proceeds or benefits in trust for, on behalf of,
or for the benefit of your child or dependent. [32] If this is an Inherited IRA, you can’t make any
contributions, and the early withdrawal penalty
TAX IMPLICATIONS OF MAKING A and minimum distribution rules during your
DESIGNATION lifetime don’t apply. See Distributions after your
[26] Designating a beneficiary is not generally death, in Section 7 which applies.
considered to be a gift subject to federal gift
tax, even if the designation is irrevocable, since
the account owner typically retains the right to

4 | Traditional Individual Retirement Account


TRANSFERS AND ROLLOVERS FROM deferred compensation plan
ANOTHER IRA • 403(b) annuity plan
[33] If you already have another IRA or individual
• Your deceased spouse’s IRA
retirement annuity at Merrill Lynch or another
financial institution, you can contribute assets • Your SRA, if you’ve participated for at least
from those funds to your IRA in two ways— two years
direct transfer or rollover. Tax implications differ • Your deceased spouse’s qualified retirement
between methods, so discuss your options plan (If you’re a nonspouse beneficiary, you
with your tax advisor. The rules explained in can only roll over these distributions into an
this Disclosure Statement for rollovers and Inherited IRA you control.)
transfers into your IRA generally apply to assets
transferred out of your IRA to another IRA as Rollovers from another IRA
well. [39] You can make only one tax-free rollover of
all or part of a distribution to or from your
[34] If you want to contribute assets from a SIMPLE Traditional IRA in a one-year period. The one-
Retirement Account (SRA) and keep the year period begins on the date you receive the
tax-deferred status of those assets, you must IRA distribution, not the date you roll it over.
have held your SRA for at least two years, or be You can make only one rollover from an IRA
exempt from the 25% penalty on premature to another (or the same) IRA in any 12-month
SRA distributions. period, regardless of the number of IRAs you
[35] A direct transfer moves assets from another own. You can, however, continue to make as
IRA into your Merrill Lynch IRA without many trustee-to-trustee transfers between
incurring taxes or penalties. To keep your IRAs as you want.
tax-deferred status, assets must be transferred
Rollovers from a qualified retirement plan
directly between IRA custodians or trustees
[40] You can roll over assets from a qualified
you cannot receive assets in your name.
retirement plan.
Transfers from Roth IRAs won’t be permitted,
unless you recharacterize those assets. [41] If you’re the non-spouse beneficiary of a
qualified retirement plan participant, you can
[36] A rollover moves assets from another
roll over such distributions to an Inherited IRA
retirement account to your IRA with us. You
in the decedent’s name that you control.
can roll over any kind of distribution—cash,
securities or other property, as long as it’s [42] If you don’t directly roll over eligible rollover
compatible with our systems. You can also distributions from a qualified retirement plan
sell non-cash distributions and roll over the to an IRA or another qualified retirement plan,
proceeds without paying capital gains tax. the amount will be subject to a mandatory
20% federal income tax withholding, plus any
[37] Assets must be rolled over into your IRA within
applicable state or local withholding. To avoid
60 days of the date you initially withdrew them
this withholding, you may want to directly roll
from the transfer IRA or Employer Retirement
over such distributions to your IRA. Ask your
Plan (ERP). Any portion of assets withdrawn
advisor or Service Associate for the information
but not rolled over (including tax withholding)
you need to provide to your plan administrator.
will be subject to tax. The IRS may waive the
60-day requirement, if you demonstrate how Ineligible rollovers from Employer
the delay in rolling over assets was beyond your Retirement Plans
ability to control (e.g., casualty or disaster). [43] We won’t accept certain distributions from
[38] You can roll over distributions from: your ERP as rollover contributions to your IRA:
• A Traditional IRA • Substantially equal periodic payments over a
period of 10 years or longer or measured by
• Your employer’s qualified retirement plan
your life or life expectancy
• A section 457(b) eligible governmental
• Required minimum distributions
Traditional Individual Retirement Account | 5
• Distributions from a designated Roth IRA conversion was withheld for taxes.
account • The one-year waiting period for rollovers
• Hardship distributions doesn’t apply to conversions.
• Certain corrective distributions • If your IRA assets were previously
• Employee Stock Ownership Plan (ESOP) recharacterized from a Roth IRA, you must
dividends wait 30 days before reconverting them, and
you may not make two such conversions of
• Loans treated as deemed distributions
the same assets in one year.
• Payments of certain automatic enrollment
contributions requested to be withdrawn [49] Once converted, your assets will be subject to
within 90 days of first contributions rules governing Roth IRAs. For tax purposes, the
applicable amount distributed from your IRA
• Cost of life insurance paid by the plan
in the conversion will be included in your gross
Rollovers from a defined benefit income for the year the conversion took place.
pension plan (See the Calculating tax-free distributions
[44] You can roll over a “restricted distribution” from worksheet in Section 10 for more information.)
a defined benefit pension plan. Your lump-sum [50] Certain IRA distributions can’t be converted to
distribution may be considered restricted if the Roth IRA:
plan does not have assets exceeding 110% of • Required Minimum Distributions
its accrued benefits and you’re one of its 25
• Distributions from an Inherited IRA, unless:
most highly paid participants.
— You’re the sole, spousal beneficiary, treating
[45] If you roll over a restricted distribution, you
the IRA as your own, or
may be required to:
— You’re a non-spouse beneficiary directly
• Repay a portion if the plan terminates
rolling over assets from a qualified
without sufficient assets
retirement plan
• Provide security for a possible repayment,
including pledging and assigning your IRA. Recharacterize Roth IRA conversions as
[46] We’ve designed your IRA to facilitate such IRA contributions
pledges and assignments in this limited [51] You can direct us or any custodian to
circumstance. Your advisor or Service Associate recharacterize a Roth IRA conversion as long as
can provide your attorney with the information you do so before the tax-filing deadline for the
necessary to do so. year you originally made the IRA contributions.
When you request a recharacterization,
Convert IRA contributions to Roth IRA your custodian will transfer your Roth IRA
contributions contributions (plus earnings) to an IRA.
[47] You can move assets from an IRA to a Roth IRA
[52] The IRS may grant an extension for
by either direct transfer or rollover, and this is
recharacterizing invalid conversions if
called a conversion. Conversions will generally
you provide sufficient evidence you acted
be treated as rollovers for tax purposes
reasonably and in good faith.
(except that the conversion is taxable). You’re
responsible for determining the eligibility of [53] You can recharacterize:
your conversion. • Annual IRA and Roth IRA contributions
[48] Most rules for rollovers also apply to • Roth IRA conversions from IRAs and certain
conversions, but there are a few exceptions, employer retirement plans
including: [54] You cannot recharacterize:
• The conversion amount won’t be subject • Tax-free transfers or rollovers:
to the 10% penalty for early withdrawals—
except to the extent that any portion of the — Between IRAs

6 | Traditional Individual Retirement Account


— Between Roth IRAs [60] If your annual compensation is less than these
— From an ERP to an IRA limits, you can’t contribute more than 100%
of your compensation. If your compensation,
• Employer contributions to Simplified however, is less than your spouse’s and you file
Employee Pension (SEP) IRAs and SRAs a joint tax return, you may add your spouse’s
• Contributions for which you’ve taken a tax compensation in excess of contributions he or
deduction she made to another IRA or Roth IRA to your
[55] A tax-free transfer or rollover between IRAs compensation.
or Roth IRAs will not disqualify you from [61] The IRS will sometimes adjust the annual dollar
recharacterizing an annual or conversion limit for cost-of-living increases (Tax Code
contributions. 219(b)(5)(D)). Any adjustment will be rounded
[56] To request a recharacterization, provide down to the next lower multiple of $500. This
complete and timely instructions to custodians will not apply to the $1,000 portion of the
on each end of the recharacterization. You then annual contributions limit for individuals age
must report the recharacterization on your 50 and over. The 2018 limits are reflected in
federal tax return as contributions made to the the above chart. See IRS Publication 590-A for
transferee (or recipient) IRA or Roth IRA for the the current year limits.
year you made the original contributions. Contributions over the annual limit
ANNUAL CONTRIBUTIONS LIMITS [62] You can make certain contributions over
[57] The contributions limits described in this the annual limit without penalty, including
Disclosure Statement apply to all your IRAs. repayments of:
For example, if you own two IRAs, your • Qualified Reservist Distributions
contributions limit doesn’t double. Your total • Plan distributions related to a federally
must also include contributions made by your declared disaster
employer on your behalf (except under SEP and • Plan distributions related to the Exxon Valdez
SIMPLE plans). litigation
[58] Until age 70½, you can contribute to your [63] Voluntary nondeductible contributions,
IRA at any time during the Tax Year, and up “elective” contributions and salary deferrals
until the tax-filing deadline (generally April made under your employer’s retirement plan
15), not including extensions. Contributions do not reduce the amount you can contribute,
will be reported in the calendar year they are but they may affect your tax deduction (see
made, unless you make contributions between Section 9) for IRA contributions.
January 1 and the tax-filing deadline and
designate in writing that it’s for the prior Tax How IRA contributions affect Roth IRA
Year. We’ll then report it to the IRS as such. contributions
After reaching the year you turn age 70½, you [64] Your IRA contributions for a year will reduce
can no longer contribute to your IRA. the amount you can contribute to a Roth IRA in
[59] There is a limit to the amount you can the same year. However, your IRA contributions
contribute each year that won’t be subject won’t affect designated Roth IRA contributions
to tax or penalty in the year contributed. The you can make to your employer’s retirement
amount varies based on your age: plan, 403(b) annuity program or government
457(b) plan.

AGE ANNUAL CONTRIBUTIONS LIMIT


Under 50 $5,500
50 to 70½ $6,500

Traditional Individual Retirement Account | 7


Computing your annual contributions limit Section 6: Additional
[65] When computing your annual contributions
limit, your (and your spouse’s, if married) information about your
compensation includes taxable amounts you
receive, such as: account
• Wages or salary
• Tips INVESTING YOUR IRA ASSETS
• Professional fees [68] Your IRA can invest in a range of investment
products made available by us or our Affiliates,
• Bonuses including:
• Commissions • Merrill Lynch money market funds
• Taxable alimony or separate maintenance • Securities traded on recognized exchanges or
payments (if divorced) “over the counter”
• Net income from a self-employment • Mutual funds
business, after deductions, for retirement
plan contributions, and one-half of the self- • Government securities, such as treasury bills
employment tax • Annuity contracts
• Non-taxable U.S. military service combat pay • 1-oz. Gold or Silver Eagle coins from
and differential wage payments (Tax Code the U.S. Mint
Section 3401(h)(2)) • Option strategies
[66] Your compensation cannot include amounts [69] All investments must be compatible with our
not included in your gross income, such as: administrative and operational requirements
• Deferred compensation and procedures which may change from
• Disability payments time to time. Ask your advisor or Service
Associate for more information about these
• Social Security benefits requirements.
• Pensions
[70] The investments you purchase for your IRA
• Earnings and profits from investments or may fluctuate in value and have varying rates of
property (such as interest, rents or dividends) return, so the future value of your IRA cannot
• Foreign-earned income and housing be guaranteed or projected.
allowances
[71] Careful consideration should be given to tax
[67] You can find your taxable compensation on advantaged investments held in your IRA:
your Form W-2 or 1099. For Form W-2, deduct • Tax exempt investments, such as
any “non-qualified plans” distributions reported municipal bonds, would become taxable
in box 11 that were also included in box 1. as a distribution upon withdrawal from a
If you were employed by the U.S. military, add traditional IRA, because IRA distributions are
in the non-taxable combat pay reported taxable regardless of the tax-exempt status of
on your Form W-2. investments held in your account.
• Dividends and earnings on investments in
foreign securities and foreign mutual funds
may be subject to foreign tax withholding.
The withholdings are often ineligible for
the U.S. foreign tax credit, if the underlying
securities are held in tax-exempt accounts,
including IRAs. As a result, the effective yield
on foreign securities and foreign mutual
funds held in your IRA may be lower than the

8 | Traditional Individual Retirement Account


effective yield of identical investments held in INSURANCE AND SIPC PROTECTION
a nonretirement account. [75] The securities and cash we hold in your
• You may find it preferable to hold tax- traditional IRA(s) are protected by the
exempt or foreign investments in a taxable Securities Investor Protection Corporation
investment portfolio, if you have one, instead (SIPC) for up to $500,000 per customer (as
of your IRA. Please consult your tax advisor if defined by SIPC rules), including $250,000 in
you have questions regarding tax advantaged cash. You may obtain further information about
investments and your specific tax situation. SIPC, including the SIPC brochure, via SIPC’s
website at http://www.sipc.org.
PROHIBITED INVESTMENTS AND [76] In addition, Merrill Lynch has obtained
TRANSACTIONS “excess SIPC” coverage from a Lloyd’s of
[72] You’re prohibited from making certain London syndicate. This policy provides further
investments, including: protection for each customer (including up to
• New issue offerings of equity and preferred $1.9 million for cash), subject to an aggregate
securities where Merrill Lynch or an affiliate loss limit of $1 billion for all customer claims.
acts as the underwriter of the securities Neither SIPC protection nor the additional
• Investments bought on margin “excess SIPC” coverage applies to deposits
• Commodities transactions (e.g., futures made through a bank deposit program
contracts) (including deposits established through the
Retirement Assets Savings Program (RASP)
• Series E and EE U.S. Savings Bonds
or to the other assets that are not securities.
• Investments in non-U.S. dollar-denominated Each account held by a separate customer (as
debt securities defined by applicable law) is treated separately
• Foreign currency for purposes of the above protection.
• Shares of “restricted” stock and stock in most [77] SIPC and excess SIPC coverage does not protect
S corporations against market losses, nor does it apply to
• Real estate deposits established through the Retirement
• Investments in life insurance contracts Asset savings program (RASP). See the
• Other investments that we designate from attached RASP Fact Sheet.
time to time. LOSING YOUR IRA’S TAX-DEFERRED STATUS
[78] If your IRA loses its tax-deferred status,
Certain prohibited investments and
your entire IRA balance (less nondeductible
transactions result in certain tax
contributions) would be included in your
consequences and penalties
taxable gross income for that year and subject
[73] Prohibited transactions and investments
to a 10% penalty tax for early withdrawal
treated as taxable distributions:
(unless you’re exempt). Refer to the Taxes on
• Pledging your IRA as security for a loan distributions section in Section 9 for more
• Collectibles, including works of art, rugs, information.
antiques, certain metals, gems, stamps, coins
(other than those listed above), alcoholic SWEEP ARRANGEMENTS FOR CASH IN
beverages and certain other tangible property YOUR IRA
[79] Each business day, available cash balances of
[74] Prohibited transactions and investments that $1 or more (in whole dollar amounts only) will
cause your IRA to lose tax-deferred status: be automatically deposited (or “swept”) into
• Pledging your IRA as security for a loan your primary sweep account in the Retirement
• Borrowing from your IRA Asset Savings Program (RASP). See the
• Buying property from your IRA attached RASP Fact Sheet. Cash balances swept
may include interest income, contributions
• Investing in life insurance contracts received or dividends from mutual funds.
Traditional Individual Retirement Account | 9
TAX COMMUNICATIONS WE’LL SEND • You have until April 1 of the year after the year
[80] For each Tax Year you make contributions, we’ll you turn age 70½ to take your first RMD.
send a Form 5498 to you (and your beneficiary • Even if you take your first RMD in the year
following your death) and the IRS that reports after you turn 70½, you’re still required to
your IRA valuation as of December 31 and IRA take your second RMD before December 31
contributions designated for that Tax Year. If that same year.
you don’t make any contributions, we won’t
• You must take your RMD in each following
send it.
year by December 31.
[81] We’ll include your IRA valuation in the year-end
[87] While taking your RMD, you may still withdraw
statement we send you.
any additional amounts you desire from
[82] After your death, we’ll provide a Form 5498 your IRA.
for the year of your death to your executor,
[88] No RMD was required for 2009.
upon request. Since any amount reported
on a beneficiary’s Form 5498 would not be CALCULATING YOUR MINIMUM
reported on the estate’s Form 5498, the value DISTRIBUTIONS
on the estate form will most likely be zero. Your [89] We will typically calculate your minimum
executor can submit a written request for a distribution for you, but not for your
date-of-death valuation, which we’ll generally beneficiaries after your death. We’ll need
provide within 90 days of receiving the request. your correct age and fair market value of your
[83] After your death, the total value of your IRA IRA. We’ll use the Uniform Lifetime Table to
assets will generally be included in your gross determine your distribution period, unless
estate for tax purposes. However, if your our records show that you qualify for the Joint
beneficiary is either your spouse or a charity, and Last Survivor Table. Our calculation won’t
deductions may be allowed. adjust the value of your IRA for outstanding
rollovers, transfers or recharacterizations. See
IRS Publication 590-B to reference the Uniform
Section 7: Distributions from Lifetime Table and Joint and Last Survivor Table.

your IRA [90] Even though we typically provide a calculation,


you’re ultimately responsible for determining
your RMD and verifying its accuracy. To
[84] Any amount you receive from your IRA is called
calculate it yourself, you’ll need the following
a distribution. You can request a distribution of
information:
all or part of the assets in your IRA at any time
by completing a form. Distributions can be • Your current age
made in the form of a single sum, installments, • The current age of your primary beneficiary
or an annuity. If you’re requesting a cash • Fair market value of your IRA (including
distribution, you must tell us which assets outstanding rollovers, transfers and
should be sold to generate sufficient cash. recharacterization transfers) as of December
Contact your advisor or Service Associate if you 31 of the preceding year from your year-end
have any questions about completing a form. statement or IRS Form 5498
[85] All distributions from your IRA will be subject • Distribution period
to rules of the Tax Code and the terms of the [91] To find the distribution period, you can use
Custodial Agreement. either:
REQUIRED MINIMUM DISTRIBUTIONS • Uniform Life time Table (If you’re unmarried,
[86] When you reach age 70½—your required you must use this table.)
beginning date (RBD)—you must begin to • Joint and Last Survivor Table, if you meet one
withdraw an annual amount from your IRA of two requirements:
called a required minimum distribution (RMD).

10 | Traditional Individual Retirement Account


— Your spouse must, generally, be your sole [98] For the purposes of calculating the RMD for
designated beneficiary for the entire year, or beneficiaries, your designated beneficiary will
— Your spouse is your sole designated be the designated beneficiary that survives you
beneficiary on January 1 of the year and as of September 30 of the year following your
your designated beneficiary changes in death.
that year because you or your spouse dies [99] RMD after your death, except for the five-
or you divorce. year rule (see Calculating distributions to
[92] To learn more about RMD calculations, beneficiaries below), must be calculated and
request a copy of the Guide to Calculating satisfied according to the Single Life Table. Your
Minimum Distributions from a Traditional IRA beneficiary’s RMD must be no less than the
from your advisor or Service Associate amount determined by dividing the value of
or call 800.MERRILL (637.7455). your IRA as of December 31 of the preceding
year by life expectancy. (See Calculating
TAKING YOUR MINIMUM DISTRIBUTIONS distributions to beneficiaries below for more
[93] You must notify us when you want to receive about determining life expectancy.) The value
your RMD. If you have multiple IRAs, you must of your IRA includes the value of outstanding
make separate calculations for each IRA, but rollovers, transfers and recharacterizations to
you can satisfy your RMD by taking a larger your IRA from other plans or accounts (Treasury
distribution from any IRA you own. Regulation Section 1.401(a) (9)-9, Q&A-1).
[94] You can set up a periodic payment plan CALCULATING DISTRIBUTIONS TO
that conveniently spreads the distributions BENEFICIARIES
throughout the year. [100] Beneficiaries will calculate their RMD based on
[95] As an alternative, you can use the entire the birth date of your designated beneficiary
balance of your IRA to purchase an annuity that and whether you die before or after your RBD.
makes payments at least equal to your required The Single Life Table (See IRS Publication
minimum distributions. 590-B) will be used to calculate your remaining
life expectancy and that of your designated
[96] Following your death, your beneficiary is
beneficiary, if applicable.
subject to similar regulations and rights
governing your IRA, including: [101] If you die after age 70½, your IRA balance

• Calculating the RMD for each IRA must be distributed over the period calculated
using your life expectancy or your designated
• Satisfying the RMD from one or multiple IRAs
beneficiary’s life expectancy, whichever
of which they’re the beneficiary of the same
is longer.
IRA owner
• If you do not have a designated beneficiary,
• Withdrawing any amount from your IRA in
distributions will be calculated based on your
a single sum, installments or in the form
remaining life expectancy using the Term
of an annuity, unless you specifically state
Certain Method.
otherwise
• If your designated beneficiary is not your spouse,
DISTRIBUTIONS AFTER YOUR DEATH the Term Certain Method will be used to
[97] After your death, we make distributions to determine your designated beneficiary’s life
beneficiaries you’ve designated, regardless of expectancy or your remaining life expectancy.
state community property law. If you live in a • If your spouse is your sole beneficiary, your
state with community property law, both your spouse can roll over the balance of your IRA
spouse and designated beneficiary must sign into his or her own IRA, or treat your IRA as
and submit a written statement authorizing us his or her own. Your spouse’s life expectancy
to make distributions to the spouse instead of will be determined using your spouse’s age
the designated beneficiary. each year until death.

Traditional Individual Retirement Account | 11


[102] If you die before age 70½, your IRA balance
Section 8: Fees and expenses
will be distributed in one of the following ways:
• If you don’t have a designated beneficiary, the [105] We will waive your IRA Custodial fees for
entire balance of your IRA must be distributed the time that your IRA is enrolled in a Merrill
by December 31 of the year that contains the Lynch investment advisory program. We may
fifth anniversary of your death (five-year rule). also waive fees at any time. If a fee is due,
• If your designated beneficiary is not your and there is insufficient cash in your account,
spouse, your beneficiary must begin taking then assets will be liquidated to collect fees
distributions no later than December 31 due. We reserve the right to liquidate assets
following the first anniversary of your death in the IRA to cover fees, purchases and
based on your beneficiary’s life expectancy other administrative expenses if there are
using the Term Certain Method; otherwise, insufficient cash/money market funds available
the entire balance of your IRA must be to cover those amounts.
distributed by December 31 of the year that
contains the fifth anniversary of your death.
Custodial fee Up to 0.25% of net assets
• If your spouse is your sole beneficiary, your (At least $50 per year,
spouse can choose to either: but not more than
$100 per year)
— Postpone distributions until the date you
* No custodial fees will be charged for Merrill Edge
would have reached age 70½*, or Self Directed (MESD) or Merrill Guided Investing
(MGI) IRAs.
— Roll over your IRA balance into his or her
own IRA or elect to treat your IRA as his Account close-out fee Up to $95
or her own IRA and make the minimum
withdrawals that apply to that IRA.
CUSTODIAL FEES
[103]* Note: If your spouse dies before the date you [106] In the first year after opening your IRA, you’ll
would have reached age 70½, distributions of the pay the custodial fee in the quarter following
remaining balance of your IRA will be made to your account opening. After that, you’ll pay
your spouse’s designated beneficiary, beginning custodial fees annually in your “anniversary
by the end of the year following the year of quarter” (or the calendar quarter containing
your spouse’s death. Distributions will be made your account-opening anniversary date). If
over the designated beneficiary’s remaining life your IRA has not been funded in the quarter
expectancy using the Term Certain Method based following your account opening, we’ll value
on the beneficiary’s age as of their birthday in the your account as of the last day of the quarter
year following your spouse’s death (or, if elected in which your IRA is funded to determine your
by the fifth anniversary of the spouse’s death). first year annual custodial fee.
If your spouse dies after distributions begin, the
[107] Your annual custodial fee will be 0.25% of the
remaining balance of your IRA will be distributed
asset value of your IRA. You’ll pay at least $50
over your spouse’s remaining life expectancy
per year, but not more than $100. We’ll value
based on your spouse’s age as of their birthday in
your IRA at the end of the quarter preceding
the year of your spouse’s death.
your anniversary quarter to determine your
[104] We’ll assume your spousal beneficiary elected fee. For example, if your account opening
to treat your IRA as their own if they make any anniversary date is February 10, we use the
contributions, rollovers or transfers to your asset value of your IRA on the last business
IRA or do not take minimum distributions that day of December.
would be required from your IRA.
[108] You can tell your advisor or Service Associate
how you wish to pay the custodial fee or
Merrill Lynch investment advisory program fee,
as applicable:

12 | Traditional Individual Retirement Account


• Direct debit from your IRA (if permitted advisor or legal representative about how your
by law) IRA investments, contributions, distributions
• Transfer from another Merrill Lynch account and beneficiary designations affect your tax
filing and estate planning. You can also refer
• Personal check
to IRS Publications 590-A and 590-B (or any
[109] If you pay the fee before it’s charged to replacement publication).
your IRA, the amount may be tax deductible.
[117] Specifically, you should consult your tax advisor
However, once the fee is debited directly from
about various tax implications, including:
your IRA, you can’t reimburse your IRA for
the fee. • Timing of distributions to meet your
financial needs
[110] We can change the available payment methods
• Calculating tax-free distributions
and timing of custodial fees at any time.
• Contributing to a Roth IRA instead of a
ACCOUNT CLOSE-OUT FEE Traditional IRA
[111] For accounts with balances of $1 or less, a fee
• Calculating substantially equal periodic
equal to the account balance may be assessed payments to avoid early withdrawal penalty
to such account resulting in the subsequent
account closure, regardless of your household’s • Changing the method you use for calculating
aggregate account balance. Substantially Equal Periodic Payments
[118] This Disclosure Statement only describes
[112] If you close or transfer your IRA, you’ll pay a
one-time fee of up to $95. This fee will be U.S. federal taxes, so you should consult your
charged to your IRA in addition to any pending tax advisor about your place of residence (e.g.,
custodial fees you owe. state, locality or foreign country). For example,
the Tax Code may permit certain federal tax
OTHER FEES AND EXPENSES deductions for higher contributions and
[113] Your IRA may be charged other routine fees income exclusions for certain rollovers, while
and expenses, including but not limited to: certain states prohibit such deductions and
• Asset-based fees exclusions on your state income tax return.
• Brokerage commissions YOUR RESPONSIBILITY TO FILE TAX
• Sales charges RETURNS AND OTHER REPORTS
• Federal funds wire transfer fees [119] You’re responsible for filing your tax return
and any other reports required by federal law
including reporting taxable distributions and
Section 9: Taxes and penalties rollovers in the year they were completed.
[120] You must file IRS Form 5329 with your federal
[114] Your IRA gives you the ability to take advantage income tax return if you owe:
of certain federal income tax deductions for • 6% penalty for excess contributions
contributions you make toward retirement
• 10% penalty for an early withdrawal, but
savings.
distribution code 1 is not shown in box 7 of
[115] Additionally, any gains and income on assets your Form 1099-R
in your IRA will not be subject to income tax • 50% penalty for failing to take your RMD
until distributed to you. However, certain
investments (e.g., limited partnerships) may [121] You also must file IRS Form 5329 if you don’t

generate unrelated business income that may owe the 10% penalty tax, but distribution
be taxable in the year earned regardless of codes 2, 3 or 4 do not appear in box 7 of
whether you made withdrawals from your IRA. your Form 1099-R, or the Tax code shown
is incorrect.
[116] The tax implications of your IRA can be very
complex, so you should consult your tax

Traditional Individual Retirement Account | 13


DEDUCTIBLE AND NONDEDUCTIBLE PENALTY FOR CONTRIBUTIONS OVER THE
CONTRIBUTIONS ANNUAL LIMIT
[122] You can take a full tax deduction on your [128] Excess contributions are subject to a 6%
federal income tax returns for your IRA annual penalty, which will be charged every year the
contributions (but not Roth IRA contributions) excess remains in your IRA. For example: If you
as long as neither you nor your spouse is an contribute $1,500 to your IRA when you’re
active participant in an ERP. single and your compensation is only $1,400,
your excess contributions is $100. The IRS
[123] Generally, you’ll be considered an active
would charge you $6 (or 6% of $100) for each
participant in an ERP if:
year that excess remains in your account.
• The “Pension Plan” box is checked on your (or Another example: If you also roll over $50,000
your spouse’s) W-2 form, from an employer-sponsored retirement plan
• You participated in a defined benefit plan, that turns out not to be a qualified plan, the
even if you accrued no benefits (unless no entire $50,000 is excess contributions. The IRS
participants received benefits and the plan would charge you $3,000 (or 6% of $50,000)
was terminated or frozen), or for each year such excess remains in your IRA.
• You participated in a defined contributions [129] You can avoid the 6% penalty by:
plan (e.g., SEP, profit sharing, 401(k),
• Withdrawing the excess and any related
money purchase or stock bonus) and any
earnings prior to your tax filing deadline
contributions or forfeitures were allocated to
(including extensions) for the Tax Year in
your account.
which the contributions was made, then
[124] If your employer made discretionary
• Including earnings on excess contributions
contributions to a defined contributions plan in your gross income for the year the
on your behalf, you’ll be considered an active contributions was made and not deducting
participant for the year contributions were any portion of the excess contributions from
made to the plan, not the year for which they your gross income.
were allocated to your account. If you have
questions, ask your employer about your status [130] If you don’t correct the excess contributions by

as an active participant. your tax-filing deadline, you can avoid paying


the penalty in subsequent years by either:
[125] If you or your spouse is an active participant
• Removing the excess contributions from your
in an ERP, you can still make nondeductible
IRA, or
IRA contributions, but your ability to claim
a deduction on your federal tax return may • Adjusting your contributions for the following
be limited. A nondeductible contributions year(s) to allow for the excess contributions.
is the difference between your maximum [131] If you’ve already taken a deduction for the excess
annual contributions limit and the deductible contributions, you may need to file an amended
portion of your contributions. (See Annual tax return to reduce or eliminate the deduction.
contributions limits in Section 5 for more If you’re under age 59½, excess contributions
information.) and related earnings you withdraw will be
[126] Use the Active Participants: Calculating Your subject to the 10% penalty for early withdrawal.
Tax Deduction worksheet in Section 10 to You’re responsible for computing the earnings
determine your tax deduction. on excess contributions and indicating the
amount on a distribution form we provide.
[127] Use IRS Form 8606 to report nondeductible
contributions on your federal income [132] If your total contributions did not exceed the

tax return. Overstating the amount of annual contributions dollar limit (see Section 5),
nondeductible contributions may incur a then the excess you withdraw is not included
penalty of $100, unless due to reasonable in your gross income for the Tax Year for which
cause. the withdrawal is made, unless you deducted
the contributions in the year it was made.
14 | Traditional Individual Retirement Account
[133] The same methods will apply to rollover insurance (see Health Insurance Premiums in
contributions above your contributions limit, if Section 11).
you reasonably relied on erroneous information • The distributions don’t exceed your
provided by your plan administrator to deductible medical expenses.
determine the permitted rollover contributions.
• The distributions don’t exceed your Qualified
TAX-FREE DISTRIBUTIONS FOR Higher Education Expenses for yourself or
NONDEDUCTIBLE CONTRIBUTIONS your spouse, children or grandchildren (see
[134] If you ever make nondeductible contributions Section 11).
(or roll over a nondeductible employee • You’re a Qualified First-Time Homebuyer (see
contributions) to any IRA, a portion of the Section 11).
distribution you take will be tax-free. You’ll • You take distributions in Substantially Equal
only be taxed on a prorated portion of the Periodic Payments.
distribution. If you’ve not reached age 59½, the
• The distribution is a Qualified Reservist
taxable portion of your distribution will still be
Distribution (see Section 11).
subject to the 10% early withdrawal penalty.
Use the Calculating Tax-Free Distributions • The distribution is made by your beneficiary
Worksheet in Section 10 to determine the tax- or estate after your death.
free portion of your distribution. • The distribution is a timely removal of excess
contributions.
TAXES ON DISTRIBUTIONS
• The distribution is caused by an IRS tax levy.
[135] IRA distributions (whether attributable to
contributions or earnings) will be taxed as [139] We report all distributions for the Tax Year
ordinary income, in most cases. on IRS Form 1099-R that we’ll send to you.
You’re responsible for presenting the IRS with
[136] Unless you indicate otherwise on the
documentation supporting the reasons for
distribution request form you complete, we’ll
an early distribution that’s exempt from the
deduct federal (and possibly state) income
penalty tax. Each of the exceptions described
taxes before paying you.
above can be complex. You should consult your
[137] Some distributions (subject to specific IRS tax advisor before requesting such distributions.
requirements) you request won’t be subject to
income tax, including: SUBSTANTIALLY EQUAL PERIODIC
PAYMENTS TO AVOID PENALTY
• Withdrawals of nondeductible contributions
[140] You can avoid the 10% penalty for early
• Tax-free transfers and rollovers to IRAs and withdrawals by taking Substantially Equal
certain employer retirement plans Periodic Payments (SEPP):
• Withdrawals to correct excess contributions • Required Minimum Distribution Method
• One-time, tax-free, direct transfers to health • Fixed Amortization Method
savings accounts
• Fixed Annuitization Method
• Certain transfers to spouses’ IRAs as part of
[141] See Section 11 for more information about
divorce proceedings
these methods.
[138] Any distributions made before you reach age
[142] You must continue taking SEPP under your
59½ attributable to earnings or deductible
contributions will be subject to ordinary chosen method for at least five years or until
income taxes plus a 10% penalty tax, unless age 59½, whichever is a longer period of time,
you qualify for one of the following exceptions: to avoid being assessed the 10% penalty (and
interest). In that time period, you can make
• You’re totally and permanently disabled.
a one-time change to the Required Minimum
• You’re unemployed and the distributions Distribution Method from either of the
don’t exceed amounts paid for health Fixed Methods.

Traditional Individual Retirement Account | 15


[143] You can discontinue SEPP without penalty Additional instructions:
if you become disabled. Your beneficiary can [147] In the first line, include all nondeductible IRA
discontinue SEPP without penalty after your and employee contributions through the end
death. of the applicable calendar year, but subtract
any distributions that were excluded from
PENALTY FOR FAILURE TO TAKE MINIMUM your taxable income in prior years. See IRS
DISTRIBUTION Form 1040 and Form 8606 for more detailed
[144] After age 59½ you can take distributions
information.
without penalty, but you’re not required to take
required minimum distributions until age 70½. [148] If you have not reached age 59½, you may

If you fail to take your RMD, you may be subject also be assessed a 10% penalty on the taxable
to a penalty tax of 50% on the difference portion of your distribution (see Taxes on
between your required distribution amount distributions in Section 9).
and your actual distribution amount. [149] If your Tax Year is not the calendar year, consult

[145] For example: If your RMD is $10,000 and you your tax advisor on how to calculate your tax-
only withdraw $9,000, the penalty is $500: free distribution.
($10,000—$9,000) x 0.50. [150] IRA distributions are not eligible for either the
capital gains treatment or the special forward
averaging computation that is available for
Section 10: Worksheets to certain lump-sum distributions from employer-
help you with calculations sponsored qualified retirement plans.
ACTIVE PARTICIPANTS: CALCULATING YOUR
CALCULATING TAX-FREE DISTRIBUTIONS TAX DEDUCTION
[146] If you make nondeductible contributions [151] If you or your spouse is an active participant
(or roll over nondeductible employee in an ERP, follow these steps to calculate how
contributions) to any of your IRAs, you much you may deduct:
would be only taxed on a prorated portion of
Step 1
your distribution. To calculate your tax-free
[152] Calculate your modified AGI by locating the
distribution, use this worksheet:
“adjusted gross income” line on your IRS Form
1040 and subtracting:
EXAMPLE WORKSHEET
• IRA deductions
Total $3,000 • Foreign earned income exclusions
nondeductible
contributions in • Foreign housing exclusions or deductions
all your IRAs
• Interest exclusions on U.S. savings bonds
Divide by total ÷ $15,000 used to pay higher education expenses
value of all
your IRAs (at • Adoption assistance program exclusions
year end plus • Deductions for qualified education loan
distributions
during the year) interest
Subtotal = 0.2000 • Deductions for qualified tuition and related
expenses
Multiply by x $2,000
distributions
(this year) Step 2
Match your modified AGI, filing status, plan
Total tax-free = $400
distribution status, and Tax Year against the following
(this year) table. If your modified AGI does not exceed
the amount in column (A), you may claim a full
deduction. If your modified AGI exceeds the

16 | Traditional Individual Retirement Account


amount in column (B), you may not claim any EXAMPLE WORKSHEET
deduction. If your modified AGI is described in
Subtotal = 0.7000
column (C), go to Step 3. If you receive Social
Security benefits, use the worksheets in IRS Multiply by x $5,000
contributions
Publication 590-A to calculate your modified (this year)
AGI and IRA deduction.
Total tax = $3,500
FILING A. FULL B. NO C. PHASEOUT deduction
STATUS DEDUCTION DEDUCTION DEDUCTION
UP TO: AT AND BETWEEN:
OVER:
Additional instructions:
Single/ head of $59,000 $69,000 $59,000 – [155] You may round up to the nearest $10. For
household $69,000
example, if you determined your deduction is
Married – $95,000 $115,000 $95,000 – $972, you may deduct $980.
joint return/ $115,000
qualifying [156] You may claim a $200 minimum deduction,
widow(er) as long as your calculated deduction is more
(IRA of active
participant)
than $0. For example, if you determined your
deduction is $120, you may still deduct $200.
Married – Not allowed $10,000 $0 –
separate return $10,000 [157] If you are married and file a joint tax return, you
Married – joint $178,000 $188,000 $178,000 – and your spouse must calculate your respective
return (IRA of $188,000 maximum tax deductions separately. Add the
nonparticipant)
two results to determine your joint deduction.
[158] If you are married and file separate returns, you
[153] The modified AGI amounts up to which full
must have a modified AGI of less than $10,000
deductions are permitted will be adjusted by to claim a partial deduction. However, if you
the IRS for cost of living changes, rounded to did not live together during the year and your
the nearest multiples of $1,000. The 2013 spouse (but not you) is an active participant
modified AGI limits are reflected above. See IRS in a retirement plan, you may claim a full
Publication 590-A (the “What’s New” section) deduction regardless of your modified AGI.
for the current year limits. (See IRS Publication 590-A).
Step 3
[154] If your modified AGI falls in column (C) (the
“phaseout” range), complete the following
Section 11: Glossary
worksheet:
Affiliate
EXAMPLE WORKSHEET A company controlled by, in control of, or
under common control with, Merrill Lynch or
Applicable dollar $69,000
amount from Bank of America.
column (B)
Agreement or Custodial Agreement
Subtract your – $62,000 The IRA Custodial Agreement between you and
modified AGI
(combined, if Merrill Lynch as it may be amended periodically.
married and
filing jointly) Client Relationship Agreement
Subtotal = $7,000 The signatory account-opening agreement
between you and Merrill Lynch as it may be
Divide by ÷ $10,000 amended periodically.
applicable dollar
spread in column
(C) Disclosure Statement
The document that describes your IRA

Traditional Individual Retirement Account | 17


Custodial Agreement as it may be amended federal mid-term rate during either of the two
periodically. months preceding the first payment.
Employer Retirement Plan (ERP) Health Insurance Premiums
An employer-sponsored plan to help you set You can take distributions without penalty to
aside money for your retirement — including pay for health insurance premiums, if you have:
a defined benefit plan (which promises a • Received federal or state unemployment
specified monthly benefit at retirement) and compensation for 12 consecutive weeks
a defined contributions plan (which promises (even if you received it because you were
no specified monthly benefit at retirement, self-employed),
but instead contributes to the employee’s
• Received the distributions during either
individual account, sometimes at a set rate, on
the same Tax Year in which you received
the employee’s behalf).
the unemployment compensation, or the
Eligible Educational Institution following year, and
Post-secondary educational institutions offering • Been re-employed for fewer than 60 days.
credit toward a bachelor’s, associate’s, graduate
or professional degree or another post-secondary Inherited IRA
credential. Certain proprietary schools and post- An IRA maintained for the benefit of a
secondary vocational institutions are also eligible designated beneficiary of a deceased individual
to participate in U.S. Department of Education (Tax Code Section 408(d)(3)(C)).
student aid programs.
Investment Advisers Act of 1940
Financial Advisor The federal law enforced and interpreted by
Reference to your advisor at Merrill Lynch is the Securities and Exchange Commission
used interchangeably with a Financial Solutions (SEC) that governs investment advisers, which
Advisor and a Merrill Financial Solutions is defined as any person or group that makes
Advisor. investment recommendations or conducts
securities analysis in return for a fee, whether
Fixed Amortization Method through direct management of client assets or
A method by which you calculate your via written publications.
Substantially Equal Periodic Payment (SEPP)
once, in the first year, and do not recalculate it Merrill Lynch
in subsequent years (i.e., “fixed”). You amortize Merrill Lynch, “us,” “we” or “our” means Merrill
your beginning account balance using an Lynch, Pierce, Fenner & Smith Incorporated,
interest rate not exceeding 120% of the federal a registered broker-dealer and wholly owned
mid-term rate during either of the two months subsidiary of Bank of America Corporation.
preceding the first payment and the current
Qualified First-Time Homebuyers
year’s life expectancy factor applicable to you
A Qualified First-Time Homebuyer Distribution
from one of the Life Expectancy Tables.
is one used to pay the costs of acquiring,
Fixed Annuitization Method constructing or reconstructing a principal
A method by which you calculate your residence for you, your spouse, a child, grandchild
Substantially Equal Periodic Payment (SEPP) or ancestor of you or your spouse. You can use
once, in the first year, and do not recalculate it in the distribution to cover eligible expenses,
subsequent years (i.e., “fixed”). You divide your including usual or reasonable settlement,
beginning account balance by an annuity factor financing or other closing costs. The total
derived from an IRS mortality table (based on lifetime amount that can qualify as a first-time
your life expectancy or the joint and last survivor homebuyer distribution from all IRAs and Roth
life expectancy of you and your beneficiary) IRAs is $10,000. To qualify for this exception:
and an interest rate not exceeding 120% of the

18 | Traditional Individual Retirement Account


• You or your spouse can’t have had ownership Recharacterize or Recharacterization
interest in a principal residence in the two An election to treat contributions made to
years prior to the purchase of the new one type of IRA as if it had been made to a
primary residence. different type of IRA for a taxable year. This
• The distribution must be used to pay eligible must be completed before the tax-filing
expenses or rolled over into your IRA within deadline (including extensions) for the year you
120 days (in which case you’re not limited to originally made the IRA contributions.
one rollover per year). Required Beginning Date (RBD)
The first day of April following the calendar year
Qualified Higher Education Expenses
in which you attain age 70½.
You can use distributions to pay for Qualified
Higher Education Expenses for a student Required Minimum Distribution (RMD)
attending classes at an Eligible Educational Method A method by which you recalculate
Institution including: your Substantially Equal Periodic Payment
• Tuition, fees, books, supplies and equipment each year. This is done by dividing the account
required for undergraduate or graduate balance as of the end of the preceding
enrollment or attendance year by the current year’s life expectancy
• Room and board expenses (up to the factor applicable to you (or to you and your
minimum allowed in calculations for federal beneficiary) from one of the Life Expectancy
aid programs) or the actual cost of student Tables. You must use the same table each year
housing owned or operated by the Eligible for your calculation.
Educational Institution, if higher Service Providers
The amount of your distribution cannot be Persons or entities that Merrill Lynch may
greater than the balance of your Qualified retain to provide services to your Account
Higher Education Expenses after you subtract under this Agreement and as described in the
all qualified scholarships, certain educational Disclosure Statement.
assistance provided to military veterans and
reservists, and other payments for educational SIMPLE Retirement Account (SRA)
expenses excluded from the student’s gross A type of tax-deferred employer-provided
income under federal laws. retirement plan that allows employees to set
aside money and invest it to grow for later use.
Qualified Reservist Distribution SIMPLE stands for Savings Incentive Match
A Qualified Reservist Distribution is one made Plan for Employees.
to a member of a U.S. military National Guard
or Reserve or the Reserve Corps of the Simplified Employee Pension (SEP)
U.S. Public Health Service who is called to A retirement plan that an employer or
active duty. self-employed individuals can establish.
The employer is allowed a tax deduction for
To qualify for this exception: contributions made to the SEP plan and makes
• The call-to-active-duty must have occurred contributions to each eligible employee’s SEP
after September 11, 2001 and lasted at least IRA on a discretionary basis.
179 days (or an indefinite period).
Tax Code
• The distribution must be after the call-to- The Internal Revenue Code of 1986 and the
active-duty, but before that active duty ends. regulations adopted under it, both as amended.
You can re-contribute these distributions
within two years of the end of the active Tax Year
duty, in which you took the distribution. Such The period for which you must report income
contributions are not subject to the usual on your federal income tax return. For most
limitations on annual contributions and are people, the Tax Year is the calendar year.
not tax-deductible.
Traditional Individual Retirement Account | 19
Term Certain Method
A method to calculate life expectancy for RMD
purposes, which calculates the life expectancy
once, then subtracts one year each subsequent
year until death.
Traditional Individual Retirement Account
(IRA)
A retirement account, held at either Merrill
Lynch or another financial institution, including
one under a qualified employer plan. An IRA is
not a Roth IRA, SIMPLE Retirement Account
(“SRA”) or Coverdell Education Savings Account
(Tax Code Section 408(a)).
Treasury Regulations
The U.S. Department of Treasury’s official
interpretation of the Internal Revenue Code
(also known as “Federal tax regulations”). You can
access Treasury Regulations from the Federal
Register online at www.federalregister.gov.

Section 12: IRS approval


[159] The Merrill Lynch IRA Custodial Agreement
has been approved by the Internal Revenue
Service as to form (subject to subsequent
amendments). Approval by the IRS is a
determination as to the form, not the merits,
of this IRA.
L-01-23

20 | Traditional Individual Retirement Account


Disclosure and Custodial Agreement

Traditional IRA Custodial Agreement


1. INTRODUCTION PAGE 21 11. HOW MERRILL LYNCH
Purpose of this Agreement page 21 HANDLES DISPUTES PAGE 30
Changes to this Agreement page 22 Disputes between you and Merrill Lynch page 30
Who can enter into this Agreement page 22 Other matters involving your IRA page 31
What you can do under this Agreement page 22

2. THE ROLE OF MERRILL LYNCH PAGE 22


Resigning as custodian page 22 Section 1: Introduction
3. ABOUT YOUR IRA PAGE 23
4. INFORMATION YOU PROVIDE PAGE 23 PURPOSE OF THIS AGREEMENT
Designating beneficiaries page 24 [1] This Custodial Agreement (“Agreement”)
Types of beneficiaries page 24 governs the Individual Retirement Account
Designating beneficiaries as primary you opened under the Client Relationship
or contingent page 24 Agreement and describes the custodial
Spousal beneficiaries after divorce responsibilities of Merrill Lynch, Pierce,
or annulment page 24 Fenner & Smith Incorporated, a registered
Rights of beneficiaries page 24
broker-dealer and wholly owned subsidiary of
5. CONTRIBUTING TO YOUR IRA PAGE 25 Bank of America Corporation.
Annual contributions limits page 25
Definitions
Contributions over the annual limit page 25
[2] IRA refers to a traditional individual retirement
6. OPERATIONS OF YOUR ACCOUNT PAGE 26 account, held at either Merrill Lynch or another
Investing your IRA assets page 26 financial institution, including one under a
Prohibited investments and transactions page 26 qualified employer plan. An IRA is not a Roth
Losing your IRA’s tax-deferred status page 26 IRA, SIMPLE Retirement Account (“SRA”) or
Communications we’ll send page 26 Coverdell Education Savings Account (Tax Code
Section 408(a)).
7. TAKING DISTRIBUTIONS FROM
YOUR IRA PAGE 27 [3] Typically, “you” and “your” refer to the person
Distributions during your lifetime page 27 for whom your IRA has been established. But
Calculating your minimum distributions page 27 other situations may occur when “you” and
Taking your minimum distributions page 27 “your” refer to someone else:
Purchase an annuity to take
• After your death, “you” and “your” refer to
minimum distributions page 28
Distributions after your death page 28
your beneficiaries.
Calculating distributions to beneficiaries page 28 • If this IRA is an Inherited IRA, “you” and “your”
refer to the deceased individual, not the
8. FEES AND EXPENSES PAGE 29
designated beneficiary of the deceased.
9. LIMITATION OF OUR LIABILITY PAGE 29 • If you appoint a third party to direct your
10. ABOUT THIS AGREEMENT PAGE 30 investments, “you” and “your” also refer to
Non-assignability page 30 that third party with respect to investment
Inurement to beneficiaries decisions, but not account ownership or
and successors page 30 contributions.
Governing law page 30
[4] “Merrill Lynch,” “we,” “our” and “us” refer
to Merrill Lynch, Pierce, Fenner & Smith

Traditional Individual Retirement Account | 21


Incorporated, a registered broker-dealer and • We find the agreement with the third party
wholly owned subsidiary of Bank of America acceptable; and
Corporation. • We do not object to acting on the third party’s
Note: Terms with initial caps (e.g., Tax Code) used direction, which we may do at any time for
in this Agreement are defined in the glossary any reason.
at the end of the Disclosure Statement. Headings
and subheadings contained in this Agreement are
for reference purposes only and will not in any Section 2: The role of
way affect the meaning or interpretation of this Merrill Lynch
Agreement.
CHANGES TO THIS AGREEMENT [10] Under this Agreement, we will, among other
[5] We may change this Agreement at any time. If things:
we do, we’ll notify you of the changes and their • Hold your IRA assets, including an annuity, in
effective dates. our custody
WHO CAN ENTER INTO THIS AGREEMENT • Follow your instructions for all purchases,
[6] You can only open an IRA in an individual sales, transfers, exchanges and other
capacity. It cannot be opened under joint disposition of assets
ownership or by non-individual entities. • Enter into relationships on your behalf
with Service Providers to carry out your
[7] To make annual contributions to your IRA, you
instructions
must be under age 70½ at the end of the Tax
Year and receive taxable compensation. But • Open subaccounts for permitted investment
there is no age or compensation restrictions purposes
to make contributions by rollover or direct • Follow your written instructions for voting
transfer. See Section 5 for more information. proxies and exercising other rights of
ownership
WHAT YOU CAN DO UNDER THIS
• Automatically deduct any IRA fees or
AGREEMENT
expenses you owe us from your IRA, unless
[8] Unless stated otherwise in this Agreement,
paid by you directly
you can instruct us to take certain actions,
including: • Keep accurate records of all your IRA
transactions
• Add, change or remove services described in
Section 3 of the Disclosure Statement [11] Keep in mind that you have discretion over
• Purchase, sell, exchange, transfer or otherwise the assets in your account. Without specific
dispose of assets instructions from you, we will not invest your
IRA assets or exercise certain rights. We won’t
• Reinvest proceeds from your investments
be responsible for any investment losses or
• Place your assets in any investment consequences resulting from our failure to act.
alternatives we offer
RESIGNING AS CUSTODIAN
[9] You are responsible at all times for directing the
[12] If we ever resign as custodian, we will
investment of assets in your IRA. You can appoint
notify you in writing at your last known
a third-party investment adviser or other person
address at least thirty (30) days in advance
to act as your representative with authority to
of our resignation. You acknowledge and
direct investments in your IRA. We will follow the
agree that, upon your receipt of notice of
direction of the appointed third party if:
our resignation as your custodian: (i) you
• You submit a signed copy of the agreement will have the right to select your successor
between you and the third party that custodian, provided that you have given
specifies the third party’s ability to act on your us written instruction to transfer your
behalf and direct your investments;
22 | Traditional Individual Retirement Account
IRA assets to another IRA custodian or Section 3: About your IRA
trustee in advance of the effective date
of our resignation; (ii) if you have not
[14] An IRA provides you with a way to save for
provided us with instructions regarding
retirement without paying taxes until you
your preferred successor custodian, we
need the funds you’ve saved. Your IRA balance
may, in our sole discretion and without
cannot be forfeited at any time. Contributions
further notice to you, designate a successor
you make to your IRA may be fully or partially
custodian (including one affiliated with
deductible, depending on your circumstances.
us) on your behalf; and (iii) in the event
no successor custodian is designated by [15] Your IRA will be established when we accept
you (including in particular if we appoint your first deposit. If your IRA isn’t established in
a successor custodian on your behalf), we accordance with our administrative procedures,
may liquidate without further notice to we have the right to reject your IRA.
you all of the assets in your account, and [16] Your IRA is being established for the exclusive
all proceeds from such liquidation will benefit of providing you and your beneficiaries
be either (a) transferred to the successor with retirement benefits. Your IRA will be
custodian or (b) sent to your last known funded by annual regular contributions,
address in the form of a check. Please note qualifying rollover contributions from another
that in the event we liquidate any of your IRA or qualified employer plan, certain rollovers
assets, any outstanding obligations and/or or transfers from an SRA, or benefits under
debit balance(s) you may owe in your IRA your employer’s Simplified Employee Pension
Account(s), including any annual and closing (SEP) plan (Tax Code Sections 408(a) and
fees, will be deducted by Merrill Lynch prior 408(k)).
to any checks being issued. Additionally,
the liquidation of any security may incur [17] You may choose to link accounts to consolidate
fees, including mutual fund contingent account statements or for any other purpose.
deferred sales charges, or other applicable (See Section 3 of the Disclosure Statement for
liquidation fees, which also will be paid with more information about our Statement Linking
the proceeds of your liquidated assets. Service.) However, the assets of your IRA will
not be commingled with other property, except
[13] In the unlikely event the IRS disqualifies us as permitted by law in a common trust fund or
from acting as custodian, you must appoint a a common investment fund.
successor custodian. If you don’t, we’ll appoint
one for you. We’ll transfer your IRA balance
after we receive the successor custodian’s Section 4: Information you
written acceptance of appointment.
provide
[18] We use the information you provide to
establish your IRA. Accurate information
helps us to best serve your brokerage needs
and meet our legal reporting requirements.
Please notify us promptly if there’s a change
in your information. You have 60 days after
we send you a notice verifying the change to
correct any errors. We’re not responsible for
any consequences resulting from inaccurate
information, if you fail to report it. We may
share information obtained about you with
our Bank of America affiliated companies

Traditional Individual Retirement Account | 23


for reasonable business purposes. (See the DESIGNATING BENEFICIARIES AS PRIMARY
Consumer Privacy notice for more information OR CONTINGENT
about how we share your information). [23] You can designate beneficiaries as primary or
contingent:
DESIGNATING BENEFICIARIES
• Primary beneficiaries will be the first to
[19] Before your death, you must designate in
receive the balance of your IRA.
writing at least one primary beneficiary to
receive the balance of your IRA after your • Contingent beneficiaries will only receive the
death. If you make no designation, the balance balance of your IRA if no primary beneficiary
will be distributed to your surviving spouse or survives you.
your estate, if no spouse survives you. If you
designate a trust or your estate as beneficiary, SPOUSAL BENEFICIARIES AFTER DIVORCE
we will make distributions to the trustee or OR ANNULMENT
executor. However, the trustee or executor can [24] If you designate your spouse as beneficiary
direct us in writing to make distributions to and you divorce or annul your marriage, your
beneficiaries of the trust or estate. designation will be void unless:
• The decree of divorce or annulment
[20] Once we accept your designation, it will govern
designates your spouse as beneficiary;
distributions from your IRA after your death.
You can limit the distributions taken by your • You redesignate your spouse as beneficiary; or
beneficiaries, but the amounts you specify • Such spouse is redesignated to receive
must at least equal minimum distributions proceeds or benefits in trust for, on behalf of,
described in Section 7 of this Agreement. or for the benefit of your child or dependent.
[21] All beneficiary designations must be RIGHTS OF BENEFICIARIES
compatible with our administrative and [25] After your death, unless you specify otherwise,
operational requirements, which may change your beneficiaries will have the same rights and
at any time. You can change your designation at responsibilities regarding your IRA as you do,
any time by notifying us in writing. The change including:
will not become effective until we receive
• Designating successor beneficiaries, who
notice and accept the change.
will take precedence over any successor
TYPES OF BENEFICIARIES beneficiaries you designated
[22] A beneficiary can be an individual (e.g., a • Withdrawing any amount from your IRA in
natural person with a birth date), estate, a single sum, installments or in the form
charity or trust. You can designate multiple of an annuity, unless you specifically state
beneficiaries for your IRA. However, special otherwise
rules apply for Required Minimum Distribution • Calculating minimum distributions for
(RMD) purposes following your death. For each IRA
example, if you want to extend payments
• Satisfying the minimum distributions from
beyond five years after your death, your
one or multiple IRAs of which they’re the
designated beneficiaries should be a natural
beneficiary of the same owner (Treasury
person or a “look-thru” trust. Also, if all your
Regulation Section 1.408-8, Q&A-9)
beneficiaries are natural persons, the oldest
will be considered your designated beneficiary
for RMD purposes (see Distributions after your
death in Section 7) (US Treasury Regulation
1.401(a)(9)-4).

24 | Traditional Individual Retirement Account


Section 5: Contributing to Exxon Valdez litigation
We cannot accept contributions (including
your IRA [30]
income deferrals) made on your behalf under
an employer’s SIMPLE plan (Tax Code Section
[26] You can make contributions to your IRA 408(p)).
in-cash or in-kind (for rollover contributions
or transfers from another IRA or qualified [31] If your IRA is an Inherited IRA, you can’t make
retirement plan). any contributions, and the early withdrawal
penalty and minimum distribution rules during
[27] In-cash contributions are those made by your lifetime don’t apply. See Distributions
check, money order or electronic funds transfer. after your death in Section 7 of this Agreement
[28] In-kind contributions are non-cash assets for rules applying to your Inherited IRA (Tax
like mutual funds and securities currently held Code Section 408(d)(3)(C)).
at another financial institution that transfer
ANNUAL CONTRIBUTIONS LIMITS
into your IRA without being liquidated. Certain
[32] Until age 70½, you can contribute to your IRA at
in-kind contributions (e.g., limited partnership
any time during the Tax Year, and up until the tax-
interests) can typically only transfer into your
filing deadline (generally April 15), not including
IRA at specific intervals, such as annually or
extensions. Contributions will be reported in
semi-annually. In-kind contributions must
the calendar year they are made, unless you
be compatible with our administrative and
make contributions between January 1 and the
operational requirements.
tax-filing deadline and designate in writing that
[29] We’ll accept the following types of it’s for the prior Tax Year.
contributions:
[33] There is a limit to the amount you can
• Annual contributions made in-cash by you or contribute each year that won’t be subject
on your behalf to tax or penalty in the year contributed. The
• Rollovers or transfers of assets (cash, amount varies based on your age (Tax Code
securities or other property) from another IRA Section 219(b)(1)(A)):
• Rollovers or transfers from certain other
retirement plans (Tax Code Sections 402(c), AGE ANNUAL CONTRIBUTIONS LIMIT
402(e)(6), 403(a)(4), 403(b)(8), 403(b)(10), Under 50 $5,500
408(d) (3) and 457(e)(16))
50 to 70½ $6,500
• Rollovers or transfers from an SRA only after
you have participated in your employer’s
Savings Incentive Match Plan for Employees [34] These dollar limits do not apply to rollover and
(SIMPLE) plan for at least two years (Tax Code SEP contributions. The IRS will sometimes
Sections 408(d)(3), 408(p)) adjust the annual dollar limit for cost-of-
living increases (Tax Code 219(b)(5)(D)). Any
• Recharacterizations from a Roth IRA (Tax Code
adjustment will be rounded down to the next
Section 408A(d)(6))
lower multiple of $500. This will not apply to
• SEP contributions (including income the $1,000 portion of the annual contributions
deferrals) made by your employer—we’re not limit for individuals age 50 and over. The 2018
responsible for determining whether the plan limits are reflected in the above chart. See IRS
or the amount of the contributions meets Tax Publication 590-A for the current year limits.
Code requirements (Tax Code Section 408(k))
• Other contributions specifically authorized CONTRIBUTIONS OVER THE ANNUAL LIMIT
by the Tax Code, including repayments of [35] We will not knowingly accept contributions
certain plan distributions made on account (including recharacterization contributions)
of a federally declared disaster, and certain made by you or for you that exceed annual
amounts received in connection with the limits for any Tax Year (Tax Code Sections

Traditional Individual Retirement Account | 25


219(b)(1)(A)). We’ll return excess contributions Certain prohibited investments and
to you, if you ask us to do so in writing. See transactions result in certain tax
Section 9 in the Disclosure Statement for more consequences and penalties
information about the 6% penalty for excess [40] Prohibited transactions and investments
contributions. treated as taxable distributions:
[36] You can make certain contributions over the • Pledging your IRA as security for a loan
annual limit without penalty as permitted by • Collectibles, including works of art, rugs,
the Tax Code, including repayments of: antiques, certain metals, gems, stamps, coins
• Qualified Reservist Distributions (Tax Code (other than those listed above), alcoholic
Section 72(t)(2)(G)(ii)) beverages and certain other tangible property
• Plan distributions related to a federally [41] Prohibited transactions and investments that
declared disaster cause your IRA to lose tax-deferred status:
• Plan distributions related to the Exxon Valdez • Pledging your IRA as security for a loan
litigation • Borrowing from your IRA
• Buying property from your IRA
Section 6: Operations of your • Investing in life insurance contracts

account LOSING YOUR IRA’S TAX-DEFERRED STATUS


[42] If your IRA loses its tax-deferred status,
your entire IRA balance (less nondeductible
INVESTING YOUR IRA ASSETS contributions) would be included in your taxable
[37] Your IRA can invest in a range of investment gross income for that year and may be subject
products offered by us or our Affiliates. to a 10% penalty tax for early withdrawal. Refer
[38] All investments must be compatible with to Section 9 of the Disclosure Statement for
Merrill Lynch’s administrative and operational more information.
requirements and procedures of the account
COMMUNICATIONS WE’LL SEND
system through which your IRA is administered
[43] As custodian of your IRA, we’ll send you various
which may change from time to time. See
communications, including:
Section 6 of the Disclosure Statement for more
information about investing your IRA assets. • Notices about your account
• Proxies and proxy solicitations
PROHIBITED INVESTMENTS AND
• Monthly statements
TRANSACTIONS
[39] You’re prohibited from making certain • Year-end statements that include your
investments in your IRA, including but not IRA valuation
limited to: [44] We’ll also send reports to you and the IRS as
• Investments bought on margin required:
• Commodities transactions (e.g., futures • Annual calendar-year and other reports,
contracts) which include information about required
• Series E and EE U.S. Savings Bonds minimum distributions (as prescribed by the
Commissioner of the IRS)
• Foreign currency
• Form1099-R, which includes all distributions
• Shares of “restricted” stock and stock in most
from your IRA (including those resulting from
S corporations
account revocations)
• Real estate
[45] If you find an error in any report we send to
• Investment in life insurance contracts
you, you must report it to us within 60 days
of the date we sent it to you. Otherwise,
we’ll consider it approved, and we won’t be
26 | Traditional Individual Retirement Account
responsible for its accuracy. EXAMPLE
If you turn 70½ in: 2014
Section 7: Taking distributions
from your IRA Ten your required April 1, 2015
beginning date is
April 1 of the
[46] Any amount you receive from your IRA is called following year:
a distribution. You can request a distribution You can take your first On or before
of all or part of the assets in your IRA at any RMD: April 1, 2015
time by completing our distribution request Or, if you don’t take In 2015 (the first by
form. Distributions can be made in the form your first RMD in the April 1, and the second
of a single sum, installment or an annuity. If year you turn 70½, by December 31)
you must take two of
you’re requesting a cash distribution, you must your RMDs:
tell us which assets should be sold to satisfy
your request. Distributions before age 59½ are
subject to a 10% early-withdrawal penalty. See CALCULATING YOUR MINIMUM
Section 9 of the Disclosure Statement for more DISTRIBUTIONS
information about this penalty. [52] Your RMD will be based on Tax Code Section
408(a)(6) and the U.S. Treasury Regulations, the
[47] We can distribute assets to you directly or to provisions of which are incorporated in your
your other non-retirement accounts with us, IRA by reference.
according to our policies and procedures.
[53] Your RMD must be no less than the amount
[48] Keep in mind that certain assets (e.g., stocks, determined by dividing the value of your IRA as
bonds and other noncash investments) of December 31 of the preceding year by your
may only be transferred at specific times or life expectancy. The value of your IRA includes
take longer to process, so you should allow the value of outstanding rollovers, transfers
extra time for processing such distributions, and recharacterizations to your IRA from other
particularly when planning minimum plans or accounts.
distributions.
DISTRIBUTIONS DURING YOUR LIFETIME Example:
[49] When you reach age 70½, your Required Your RMD Value of your Your life
Beginning Date (RBD), you must begin to in 2015 = IRA as of ÷ expectancy
withdraw an annual amount from your IRA December 31,
2014
called a Required Minimum Distribution (RMD).
[50] You have until April 1 of the year after the year
[54] To find your life expectancy, you can use either:
you turn age 70½ to take your first RMD. If you
don’t take your first RMD in the year you turn • Uniform Lifetime Table, or
70½, you’re still required to take your second • Joint and Last Survivor Table (if your spouse
RMD before December 31 of the next year. is your sole beneficiary and is more than
10 years younger than you).
[51] You must take your RMD in each following year
by December 31. [55] Both tables can be found in IRS Publication
590-B. You can get a copy online (irs.gov) or by
contacting any IRS office.
TAKING YOUR MINIMUM DISTRIBUTIONS
[56] If you have multiple IRA accounts, you must
make separate calculations for each IRA, but
you can meet your RMD by taking a larger

Traditional Individual Retirement Account | 27


distribution from any IRA you own. For further according to the Single Life Table. Your
information on how RMDs are calculated, beneficiary’s RMD must be no less than the
see Section 7 of the Disclosure Statement amount determined by dividing the value of
(Treasury Regulation Section 1.408-8, Q&A-9). your IRA as of December 31 of the preceding
year by life expectancy. (See “Calculating
[57] You can set up a periodic payment plan
distributions to beneficiaries” below for more
that conveniently spreads the distributions
about determining life expectancy.) The value
throughout the year. To learn more about RMD
of your IRA includes the value of outstanding
calculations, request a copy of the Guide to
rollovers, transfers and recharacterizations to
Calculating Minimum Distributions from a
your IRA from other plans or accounts (Treasury
Traditional IRA from your advisor or Service
Regulation Section 1.401(a) (9)-9, Q&A-1).
Associate or call 800.MERRILL (637.7455).
CALCULATING DISTRIBUTIONS TO
PURCHASE AN ANNUITY TO TAKE MINIMUM
BENEFICIARIES
DISTRIBUTIONS
[63] Beneficiaries will calculate their RMD based on
[58] As an alternative, you can use the entire
the birth date of your designated beneficiary
balance of your IRA to purchase an annuity that
and whether you die before or after your RBD.
makes payments to satisfy your RMD. Merrill
Lynch will act as the custodian for annuities [64] If you die after age 70½, your IRA balance
purchased with your IRA funds, and any death must be distributed over the period calculated
benefit under the annuity must be payable using your life expectancy or your designated
to your IRA for distribution to any beneficiary beneficiary’s life expectancy, whichever is
designated under your IRA (Treasury Regulation longer.
Section 1.401(a)(9)-6). • If you do not have a designated beneficiary,
[59] If you use an annuity to take minimum distributions will be calculated based on your
distributions, your premiums will be paid with remaining life expectancy using the Term
cash balances in your IRA. If cash balances in Certain Method.
your IRA don’t cover the premium due, we’ll • If your designated beneficiary is not your spouse,
ask if you want us to sell any assets in the IRA the Term Certain Method will be used to
to pay the premium. If we’re unable to pay the determine your designated beneficiary’s life
premium when due, the annuity will either be expectancy or your remaining life expectancy.
placed on a paid-up basis or the annuity benefit • If your spouse is your sole beneficiary, your
will be reduced. spouse can roll over the balance of your IRA
DISTRIBUTIONS AFTER YOUR DEATH into his or her own IRA, or treat your IRA as
[60] After your death, we make distributions to his or her own. Your spouse’s life expectancy
beneficiaries you’ve designated, regardless of will be determined using your spouse’s age
state community property law. If you live in a each year until death.
state with community property law, both your [65] If you die before age 70½, your IRA balance
spouse and designated beneficiary must sign will be distributed in one of the following ways:
and submit a written statement authorizing us • If you don’t have a designated beneficiary, the
to make distributions to the spouse instead of entire balance of your IRA must be distributed
the designated beneficiary. by December 31 of the year that contains the
[61] For the purposes of calculating the RMD for fifth anniversary of your death (five-year rule).
beneficiaries, your designated beneficiary will • If your designated beneficiary is not your
be the designated beneficiary that survives you spouse, your beneficiary must begin taking
as of September 30 of the year following your distributions no later than December 31
death. following the first anniversary of your death
[62] RMD after your death, except for the five- based on your beneficiary’s life expectancy
year rule, must be calculated and satisfied using the Term Certain Method; otherwise,

28 | Traditional Individual Retirement Account


the entire balance of your IRA must be [69] See Section 8 of the Disclosure Statement for
distributed by December 31 of the year that more information about fees and expenses.
contains the fifth anniversary of your death.
• If your spouse is your sole beneficiary, your
spouse can choose to either:
Section 9: Limitation of our
— Postpone distributions until the date you
liability
would have reached age 70½*, or
— Roll over your IRA balance into his or her
[70] We’re not responsible for performing any
own IRA or elect to treat your IRA as his duties other than those described in this
or her own IRA and make the minimum Agreement. Unless you’re enrolled in a Merrill
withdrawals that apply to that IRA. Lynch investment advisory program, we are
also not responsible for reviewing the assets
[66] * Note: If your spouse dies before the date you in your IRA or making recommendations on
would have reached age 70½, distributions of the buying, selling or transferring any assets. In
remaining balance of your IRA will be made to addition, we’re not liable for failing to act if
your spouse’s designated beneficiary, beginning you don’t give us directions. No Merrill Lynch
by the end of the year following the year of Research opinion, Independent Research
your spouse’s death. Distributions will be made opinion, the inclusion of a security on any list,
over the designated beneficiary’s remaining life or any information provided to you either on
expectancy using the Term Certain Method based the Merrill Edge website or by mail or any other
on the beneficiary’s age as of their birthday in the means constitutes a recommendation to you
year following your spouse’s death (or, if elected to purchase, hold or sell any investment nor
by the fifth anniversary of the spouse’s death). should you view Merrill Lynch as providing
If your spouse dies after distributions begin, the impartial investment advice to you by reason
remaining balance of your IRA will be distributed of making such research, opinions, lists or
over your spouse’s remaining life expectancy information available to you.
based on your spouse’s age as of their birthday
in the year of your spouse’s death. [71] We provide no advice on the investment
consequences involving your IRA, unless
[67] We’ll assume your spousal beneficiary elected provided under a separate agreement. Except
to treat your IRA as their own if they make any as provided under such separate agreement,
contributions, rollovers or transfers to your we will not have discretionary authority or
IRA or do not take minimum distributions that control with respect to the investment of your
would be required from your IRA. IRA assets and will not render advice that is
individualized for your IRA under any mutual
Section 8: Fees and expenses agreement, arrangement or understanding
that the advice will serve as a primary basis for
your IRA investment decisions. We’re not liable
[68] You’ll pay all applicable fees and costs, for any taxes or other consequences of your
including: investment decisions or directions. In addition,
• Custodial fee and expenses we provide no advice on the tax or other
• Legal expenses we incur from matters consequences involving your IRA and we are
involving your IRA not liable for any taxes or other consequences
• All taxes related to your IRA of your decisions or directions.
• Annuity premiums and taxes, if applicable [72] We’re not responsible for the validity of any
• Merrill Lynch investment advisory program annuity held in your IRA or the failure of any
fees, if enrolled insurance company to make annuity payments.
Additionally, we’re not liable if we fail to
• Costs for calculating and reporting unrelated
purchase an annuity or pay a premium when
business income to the IRS for you, if applicable

Traditional Individual Retirement Account | 29


due, unless caused by gross negligence or • Arbitration awards are generally final and
willful misconduct on our part. binding; a party’s ability to have a court
reverse or modify an arbitration award is
very limited.
Section 10: About this • The ability of the parties to obtain
Agreement documents, witness statements and other
discovery is generally more limited in
arbitration than in court proceedings.
NON-ASSIGNABILITY
• The arbitrators do not have to explain
[73] You can’t sell or assign any interest in your IRA.
the reason(s) for their award unless, in
However, you may be able to transfer your IRA
an eligible case, a joint request for an
to a former spouse under a divorce decree or
explained decision has been submitted
written agreement related to your divorce.
by all parties to the panel at least 20 days
INUREMENT TO BENEFICIARIES AND prior to the first scheduled hearing date.
SUCCESSORS • The panel of arbitrators may include a
[74] This Agreement will be binding and will remain minority of arbitrators who were or are
in effect for the benefit of beneficiaries, heirs, affiliated with the securities industry.
successors and personal representatives of • The rules of some arbitration forums may
yours and Merrill Lynch. impose time limits for bringing a claim in
GOVERNING LAW arbitration. In some cases, a claim that is
[75] This Agreement will be governed and ineligible for arbitration may be brought
interpreted by the laws of the State of New in court.
York and applicable federal law, without • The rules of the arbitration forum in which
regard to community property laws of any the claim is filed, and any amendments
state. However, determining the interests of thereto, shall be incorporated into this
beneficiaries will be governed by the laws of Agreement.
the state of your residence at the time of [77] You agree that all controversies that may
your death. arise between us shall be determined by
arbitration. Such controversies include,
Section 11: How Merrill Lynch but are not limited to, those involving
any transaction in any of your accounts
handles disputes with Merrill Lynch, or the construction,
performance or breach of any agreement
between us, whether entered into or
DISPUTES BETWEEN YOU AND occurring prior, on or subsequent to the
MERRILL LYNCH date hereof.
[76] This Agreement contains a predispute
arbitration clause. By signing an arbitration [78] Any arbitration pursuant to this provision
agreement the parties agree as follows: shall be conducted only before the Financial
Industry Regulatory Authority, Inc. (FINRA)
• All parties to this Agreement are giving
or an arbitration facility provided by any
up the right to sue each other in court,
other exchange of which Merrill Lynch
including the right to a trial by jury, except
is a member, and in accordance with the
as provided by the rules of the arbitration
respective arbitration rules then in effect in
forum in which a claim is filed.
FINRA or such other exchange.

30 | Traditional Individual Retirement Account


[79] You may elect in the first instance whether OTHER MATTERS INVOLVING YOUR IRA
arbitration shall be conducted before [84] Disputes between us will be resolved in
FINRA or another exchange of which arbitration, as described above. For all other
Merrill Lynch is a member, but if you fail matters involving your IRA, we can apply to a
to make such election by registered letter court at any time for judicial settlement. If we
addressed to Merrill Lynch at the office do so, we must give you the opportunity to
where you maintain your Account before participate in the court proceeding, but we can
the expiration of five days after receipt of a also involve other persons.
written request from Merrill Lynch to make
L-07-20
such election, then Merrill Lynch may make
such election.
[80] Judgment upon the award of the arbitrators
may be entered in any court, state or
federal, having jurisdiction.
[81] No person shall bring a putative or
certified class action to arbitration, nor
seek to enforce any predispute arbitration
agreement against any person who has
initiated in court a putative class action or
who is a member of a putative class who
has not opted out of the class with respect
to any claims encompassed by the putative
class action until: (i) the class certification
is denied; (ii) the class is decertified; or (iii)
the customer is excluded from the class by
the court. Such forbearance to enforce an
agreement to arbitrate shall not constitute
a waiver of any rights under this Agreement
except to the extent stated herein.
[82] This Agreement does not prohibit or restrict
you from requesting arbitration of a dispute
in the FINRA arbitration forum as specified
by FINRA rules.
[83] Notwithstanding the foregoing, any
agreement or award made as a result of
an arbitration proceeding shall not be in
violation of Section 408 of the Tax Code and
related regulations.

Traditional Individual Retirement Account | 31


32 | Traditional Individual Retirement Account
Traditional Individual Retirement Account | 33
34 | Traditional Individual Retirement Account
Merrill Lynch Retirement not backed or guaranteed by any bank nor are
they insured by the FDIC.
Asset Savings Program [6] Deposits at each depository institution in
Fact Sheet which your funds are deposited through RASP
are insured by the FDIC to a maximum amount
of $250,000 (including principal and accrued
[1] This Fact Sheet describes the Retirement Asset
interest) for all qualifying retirement account
Savings Program offered to certain sponsors
deposits held in the same legal capacity, except
and beneficiaries of retirement plan accounts
for Coverdell Education Savings Accounts which
at Merrill Lynch, Pierce, Fenner & Smith
are FDIC insured in the Trust Account category
Incorporated (“Merrill Lynch”).
(Trust Account). Trust deposits are insured in
ABOUT THE RETIREMENT ASSET an amount up to $250,000 multiplied by the
SAVINGS PROGRAM total number of eligible beneficiaries identified
[2] The Retirement Asset Savings Program (“RASP”) by each grantor, up to a maximum of five
is a feature of retirement plan accounts for beneficiaries per grantor. The Trust Account
which Merrill Lynch is custodian (each a category provides for a maximum amount of
“Retirement Plan Account”). These include deposit insurance coverage of $1,250,000 per
Individual Retirement Accounts, Roth Individual grantor, per insured depository institution for
Retirement Accounts, Individual Retirement trust deposits. Your federal deposit insurance
Rollover Accounts, Simplified Employee protection takes effect as soon as a depository
Pension, SIMPLE IRA, Coverdell Education institution receives your deposit. Any deposits,
Savings Accounts and BASIC™ Plan accounts. including certificates of deposit (“CDs”), that
you maintain in the same legal capacity as
[3] The RASP feature makes available to you a
your Retirement Plan Account directly with a
money market deposit account (“Deposit
particular depository institution, through other
Account”), for each Retirement Plan Account
Merrill Lynch accounts or through another
which is opened on your behalf at one or
intermediary would be aggregated with the
more participating depository institutions, the
deposits maintained in the Deposit Accounts
deposits of which are insured by the Federal
at that institution for purposes of the FDIC
Deposit Insurance Corporation (“FDIC”), an
insurance limit. Since there may be more than
independent agency of the U.S. Government.
one depository institution at which you may
[4] A minimum deposit of $1 is required to open establish a Deposit Account, you may have
an account through RASP. However, no deposit more than the Standard Maximum Deposit
relationship shall be deemed to exist prior to Insurance Amount in federal deposit insurance
the receipt and acceptance of your funds by a protection for funds deposited through RASP.
participating depository institution.
[7] You are responsible for monitoring the total
[5] Each deposit into a Deposit Account is a amount of deposits that you hold with one
direct obligation of the depository institution depository institution, in a single legal capacity,
at which the Deposit Account is established including deposits maintained through RASP,
and is not directly or indirectly an obligation deposits (including CDs) held through other
of Merrill Lynch. Merrill Lynch does not Merrill Lynch accounts and deposits held
guarantee in any way the financial condition directly with the depository institution.
of any institution at which you may establish
accounts through RASP. Upon request, you How the RASP feature works
will be provided with the publicly available [8] Your money is remitted initially for deposit
summary financial information relating to by Merrill Lynch, acting as your agent, into a
participating institutions. Merrill Lynch is not a Deposit Account at the primary depository
bank and securities offered by Merrill Lynch are institution. The primary depository institution

Traditional Individual Retirement Account | 35


is Bank of America, N.A. (BANA). The secondary [11] It is important for you to monitor the
depository institution is Bank of America amounts of your total deposits with each
California, N.A.(BA-CA) (and together with participating depository institution, so that
BANA, are the “Merrill Lynch Affiliated Banks,” you will know the extent of federal deposit
which will accept deposits once you exceed insurance available to you for such deposits
$246,000 in the Deposit Account at the (see the following section Additional
primary institution as described below). Information on Federal Deposit Insurance).
[9] From time to time, one or more of the [12] Generally, funds will be transferred to the next
participating depository institutions may be priority depository institution tuition, if any,
replaced with a new institution, including one in the priority sequence established. However,
that may not have been previously included. there may be exceptions if a depository
Also, new depository institutions may be added institution is closed for the day, or if it reaches
and the depository sequence changed. You the aggregate deposit limit it will accept from
will receive notification in advance of such Merrill Lynch clients. If a depository institution
movement, inclusion or change before any in which you have a Deposit Account chooses
funds you have in a Deposit Account are moved to no longer make its accounts available
to another institution. Notification may be by through RASP, funds in your Deposit Account
means of a letter, an entry on your Retirement at that institution will be transferred, after
Plan Account statement, or the delivery to notification to you, to another participating
you of a new listing of available depository depository institution.
institutions.
[13] Available free credit balances of $1 or more
[10] For each Retirement Plan Account, the will be automatically deposited in your Deposit
following rules apply: Funds up to $246,000 are Account on a daily basis, except for Saturdays,
remitted to the Deposit Account established Sundays and legal holidays.
for you at the primary depository institution,
BANA. If the balance in your Deposit Account at Transfers and withdrawals
BANA reaches $246,000, then your funds are [14] Merrill Lynch, as your agent, will make
remitted for deposit in the same manner to a withdrawals from your Deposit Accounts
Deposit Account established for you at BA-CA, as necessary to satisfy any debits in the
until the balance in your Deposit Account at Retirement Plan Account. However, as required
BA-CA reaches $246,000. If the balance in your by federal regulations, each depository
Deposit Accounts at BA-CA reaches $246,000, institution at which Deposit Accounts may
subsequent funds are deposited in your be established reserves the right to require
Deposit Account at BANA, even if the amounts seven days prior notice before permitting a
then deposited in your Deposit Account at withdrawal out of an individual account.
BANA exceed $246,000. This may cause the [15] If you have funds on deposit at both BANA and
amount deposited in BANA through RASP BA-CA, withdrawals will be made from your
to exceed the Standard Maximum Deposit Deposit Accounts in the reverse of the order
Insurance Amount. All deposits at an institution in which deposits are made to the Deposit
held in the same legal capacity are protected Accounts.
by federal insurance up to a maximum of the
[16] Payment out of your account may be delayed
Standard Maximum Deposit Insurance Amount.
when funds placed in an account on your
Amounts on deposit at BANA or BA-CA held
behalf had as their original source a check, draft
in the same legal capacity, including deposits
or similar instrument given to Merrill Lynch.
maintained through RASP, in excess of the
Merrill Lynch may delay the deposit of funds
Standard Maximum Deposit Insurance Amount,
into a Deposit Account until funds submitted
will not be covered by federal deposit insurance.
to your Retirement Plan Account have cleared.

36 | Traditional Individual Retirement Account


[17] The Deposit Accounts established at the Merrill “IA Program” means any of the following
Lynch Affiliated Banks are not transferable. investment advisory programs offering
fiduciary advice and guidance and other
Interest investment advisory services made available
[18] The rate paid for RASP will be established by or through Merrill Lynch and/or Merrill
periodically as determined by the Merrill Account Advisors, its affiliate, registered with
Lynch Affiliated Banks, and other participating the Securities Exchange Commission: (1) the
depositories. For accounts established through Merrill Lynch Investment Advisory Program;
RASP, the Merrill Lynch Affiliated Banks, and (2) the Merrill Lynch Strategic Portfolio Advisor
any other participating depositories, will set Service; (3) the Merrill Lynch Managed Account
interest rates based on economic and business Service; (4) the BlackRock Private Investors
conditions. For RASP, interest rates will be Service; (5) the Merrill Guided Investing
tiered based upon your relationship with Merrill Program (6) the Merrill Guided Investing with
Lynch as determined by the value of assets Advisor Program; and (7) the Merrill Edge
in your eligible Retirement Plan Account(s), Advisory Account program.
Deposit Account(s) and eligible accounts linked
through the Merrill Lynch Statement Link [20] In general, Merrill Lynch will determine your
service. For these tiered Deposit Accounts, Tier toward the end of each month (the
deposits of clients in higher Tiers (as defined “Valuation Date”) for application the next
below) generally will receive higher interest statement month. The valuation procedure
rates than deposits of clients in lower Tiers. generally will work like this:
A Retirement Plan Account assigned to Tier 5 • Your Tier(s) will be based on Merrill Lynch’s
may receive a higher yield on bank deposits determination of the long market value of
than a Retirement Plan Account with a lower assets and Deposit Account balances in your
tier assignment. eligible Retirement Plan, including other
eligible accounts linked through the Merrill
[19] Your interest rate generally will correspond
Lynch Statement Link service. Retirement
with your Tier as determined by the value
Plan Accounts enrolled in IA Programs will
of assets in your eligible Retirement Plan
be assigned Tier 5 regardless of the value of
Account(s), Deposit Account(s) and accounts
assets and Deposit Account balances.
linked through the Merrill Lynch Statement
Link service. For regulatory or other reasons, • Your Tier(s) will not change until the next
certain types of accounts that can be linked Valuation Date even if you open new accounts
for statement delivery purposes cannot be or link accounts.
counted for the purpose of determining your • If you have accounts enrolled in the Merrill
total eligible client assets for tier assignment. Lynch Statement Link service on the Valuation
For more information on the Merrill Lynch Date, then the valuation will reflect the dollar
Statement Link service, please refer to the value of assets in those linked accounts
description in this booklet. Certain Retirement (except excluded accounts) to determine
Plan Accounts will be assigned a tier regardless your Tier. Assets of eligible Retirement Plan
of the value of assets. Retirement Plan accounts enrolled in IA Programs will be
Accounts enrolled in “IA Programs” as defined included in the valuation.
below will be assigned Tier 5. • If your accounts are not linked on the
Retirement Plan Accounts Valuation Date, then the assets in each
Tier 1 – Less than $250,000 Retirement Plan Account will be valued
Tier 2 – $250,000 to $999,999 individually to determine your Tier for that
account.
Tier 3 – $1,000,000 to $9,999,999
• New Retirement Plan Accounts are not
Tier 4 – $10,000,000 or more valued until the next applicable Valuation
Tier 5 – IA Programs Date. In the first month, deposit balances

Traditional Individual Retirement Account | 37


in all new accounts will receive the interest its records on behalf of its Retirement Plan
rate that corresponds to the Tier that ranges Account clients will be evidenced by a book
from $250,000 to $999,999. This Tier may entry on the account record of the participating
be adjusted, as appropriate, on the next depository institution. No evidence of
Valuation Date. ownership, such as a passbook or certificate,
will be issued to the Retirement Plan Account
[21] Without notice, interest rates may change daily,
clients who establish accounts through RASP,
the interest rate differential between Tiers may
nor will any depository institution be given
change, and Tiers may also change. To learn the
the names of Retirement Plan Account clients.
annual percentage yield, call your Merrill Lynch
In addition, all transactions are effected
advisor or the Merrill Advisory Center. You
through Merrill Lynch, as agent, and not
may also visit MyMerrill.com (see the “Deposit
directly between a client and the participating
Account & Money Fund Rates” link at the
depository institution.
bottom of the page).
[26] You may obtain information about your
[22] The rates of return paid with respect to the
Deposit Accounts, including the names of each
Deposit Accounts may be higher or lower than
depository institution in which your funds are
the rates of return available to other depositors
currently being deposited, balances, the current
of the participating depository institution for
interest rate and the names and priority of the
comparable accounts. Of course, you should
other institutions at which Deposit Accounts
compare the terms, rates of return, required
are currently available, by calling your Merrill
account minimums, charges and other features
Lynch advisor.
of a Deposit Account with other accounts and
alternative investments before deciding to [27] Each participating depository institution, in
maintain a Deposit Account. its sole discretion and without notice, may
change the conditions of or terminate a client’s
[23] Interest will accrue on the balances in a Deposit
Deposit Account. If Merrill Lynch does not wish
Account from the day funds are deposited with
to continue to act as your agent or custodian
a participating depository institution to (but
with respect to your Deposit Account(s),
not including) the date of withdrawal, and will
you may deal directly with each depository
be compounded daily and credited monthly.
institution (subject to its rules in effect at that
Client statements time) with respect to maintaining such an
[24] All of your transactions will be confirmed account.
and will appear in chronological sequence on [28] Similarly, if you decide that you no longer
your Merrill Lynch Retirement Plan Account wish to have Merrill Lynch act as your agent
statement. The statement will show the total and messenger with respect to the Deposit
of your opening and closing Deposit Account Account established for you at a depository
balances, along with a breakdown of your institution, you may establish a direct
Deposit Account balance at each individual depository relationship with the depository
depository institution (if more than one institution (subject to its rules in effect at that
depository institution is participating in the time) with respect to maintaining such an
RASP feature and your funds are deposited account.
in more than one depository institution). The
statement will also show interest earned for [29] This may result in the severing of your Deposit
the statement period. Account at that depository institution account
from the Retirement Plan Account service.
Your relationship with Merrill Lynch
[25] Merrill Lynch is acting as agent and messenger Conflicts of interest
for its Retirement Plan Account clients who [30] There are conflicts of interest relating to the
establish accounts through RASP. The separate Sweep Program (including RASP). If you hold
accounts established by Merrill Lynch on cash balances in your account, both Merrill

38 | Traditional Individual Retirement Account


Lynch and the Merrill Lynch Affiliated Banks them on bank deposits (including payments
benefit financially when your cash is “swept” to Merrill Lynch), on the one hand, and the
to and held in deposit with them under interest or other income earned on their loans,
the Sweep Program. Merrill Lynch receives investments and other assets, which may be
compensation from the Merrill Lynch Affiliated funded in part by bank deposits, on the other
Banks for its services relating to the Sweep hand. The greater the amount of cash balances
Program. maintained in deposit accounts with the Merrill
Lynch Affiliated Banks (which could be as a
[31] Merrill Lynch receives:
result of a recommendation from your financial
• Up to $100 per year from BANA and/or BA-CA advisor) and the lower the interest rate paid on
for each account that sweeps to the Merrill the related bank deposit, the more the Merrill
Lynch Bank Deposit Program and the Merrill Lynch Affiliated Banks benefit.
Lynch Direct Deposit Program
The deposits will bear a rate of interest that has
• Up to $85 per year for each account that
been established for, and in light of the features
sweeps to the Retirement Asset Savings
of, the Sweep Program. The rate of interest
Program
for such deposit accounts is periodically set
• Up to $100 per year from MLBTC for each and reset by the Merrill Lynch Affiliated Banks
account that sweeps to the International Bank in their discretion. Accounts that enroll in IA
Variable Rate Deposit Facility Programs (as defined in section 19) receive the
• A fee of up to 2% per annum of the daily highest tier rate available under RASP.
balances from the participating banks in the
The interest rate you earn in a bank deposit
ISA Program
account affiliated with the Sweep Program will
This compensation is subject to change from likely be lower than yields on certain money
time to time, and Merrill Lynch may waive all or market funds and other cash alternatives.
part of it. Financial advisors are compensated
based on their clients’ total deposits held in Additional information
Merrill Lynch Affiliated Banks (excludes RASP), [32] You will always know where your money
in participating banks in the ISA Program and is by referring to the information in the
in sweep money market funds. In addition, section titled Your relationship with Merrill
they can receive a compensation award based Lynch, previous page, in conjunction with
on achieving a number of strategic objectives, your Retirement Plan Account statement.
including, among other activities, the growth Additionally, by calling your Merrill Lynch
in their clients’ balances in bank sweep deposit advisor or Merrill Edge representative, you can
accounts and sweep money market funds. confirm the name of the depository institution
Together, these compensation incentives that has accepted your most recent deposit.
create a conflict of interest. Upon request, you will be provided with the
publicly available information that Merrill Lynch
The Merrill Lynch Affiliated Banks benefit has relating to the participating depository
financially from their use of the deposits. institutions.
Through the Sweep Program, they receive
a stable, cost-effective source of funding. ADDITIONAL INFORMATION ON FEDERAL
They use bank deposits to fund current and DEPOSIT INSURANCE
new lending, investment and other business [33] In the event that federal deposit insurance
activities. Their participation in the Sweep payments become necessary, the FDIC is
Program increases their respective deposits required to pay principal plus unpaid and
and overall profits. Bank profitability is accrued interest to the date of the closing
determined in large part by the “spread” they of the relevant depository institution, as
earn on the deposits — the difference between prescribed by law and applicable regulations.
the interest paid and other costs incurred by Since there is no specific time period during

Traditional Individual Retirement Account | 39


which the FDIC must make available such [36] On February 8, 2006, the President of the
insurance payments, you should be prepared United States signed the Deficit Reduction Act
for the possibility of an indeterminate delay of 2005 (the “Act”), which contains provisions
in obtaining insurance payments. In addition, affecting federal deposit insurance coverage.
you may be required to provide certain The principal amount of your deposits held
documentation to the FDIC and to Merrill Lynch in Qualified Retirement Accounts (as defined
before any insurance payouts are released below), plus accrued interest, together with any
to you. For example, you may be required to other deposits held at the issuing depository
furnish affidavits and indemnities regarding institution through such Qualified Retirement
the payout. Merrill Lynch will not be obligated Accounts, are protected by federal deposit
to you for amounts not covered by deposit insurance and backed by the U.S. government
insurance and will not be obligated to you in to a maximum amount of $250,000 for the
advance of payment from the FDIC. total amount of all such deposits held by you in
the same ownership capacity at the depository
[34] Since deposit insurance coverage is based
institution. Retirement accounts that qualify
on a customer’s funds on deposit in any one
for this increased coverage are: (i) any individual
depository institution, coverage can change
retirement accounts (“IRAs”) described in
if two or more institutions where you have
section 408(a) of the Internal Revenue Code
funds on deposit merge. In this case, deposits
of 1986, as amended (“Code”); (ii) any eligible
maintained through RASP continue to be
deferred compensation plan described in
separately insured for six months from the
section 457 of the Code; (iii) any individual
date that the merger takes effect. Thereafter,
account plan described in section 3(34) of the
any assumed deposits will be aggregated
Employee Retirement Income Security Act
with your existing deposits with the acquirer
of 1974, as amended (“ERISA”), to the extent
held in the same legal ownership category for
the participants and beneficiaries under such
purposes of federal deposit insurance. Any
plans have the right to direct the investment
deposit opened at the acquired institution
assets held in the accounts; and (iv) any plan
after the acquisition will be aggregated with
described in section 401(d) of the Code, to
deposits established with the acquirer for
the extent the participants and beneficiaries
purposes of federal deposit insurance.
under such plans have the right to direct the
Special rules for Retirement Plan Accounts investment assets held in the accounts (each, a
[35] You may have interests in various retirement “Qualified Retirement Account”).
and employee benefit plans and accounts
Pass-through deposit insurance for
that have deposits in a depository institution.
retirement and employee benefit plan
The amount of deposit insurance you will be
deposits
entitled to will vary depending on the type
of plan or account and on whether deposits [37] Subject to the limitations discussed below,
held by the plan or account will be treated under FDIC regulations, an individual’s non-
separately or aggregated with deposits in the contingent interest in the deposits of one
same depository institution held by other depository institution held by certain types
plans or accounts. It is therefore important of employee benefit plans are eligible for
to understand the type of plan or account insurance on a “pass-through” basis up to the
holding the deposit. The following sections Standard Maximum Deposit Insurance Amount
entitled Pass-through deposit insurance for for that type of plan. This means that, instead
retirement and employee benefit plan deposits of an employee benefit plan’s deposits at one
and Aggregation of Retirement and Employee depository institution being entitled to only
Benefit Plans and Accounts generally discuss the applicable Standard Maximum Deposit
the rules that apply to deposits of retirement Insurance Amount in total per depository
and employee benefits plans and accounts. institution, each participant in the employee
benefit plan is entitled to insurance of his or

40 | Traditional Individual Retirement Account


her interest in the employee benefit plan’s the insurance provided for any other funds
deposits of up to the applicable Standard owned by or attributable to the employer or an
Maximum Deposit Insurance Amount per employee benefit plan participant.
institution (subject to the aggregation of the
participant’s interests in different plans, as AGGREGATION OF RETIREMENT AND
discussed below). The pass-through insurance EMPLOYEE BENEFIT PLANS AND ACCOUNTS
provided to an individual as an employee Self-directed retirement accounts
benefit plan participant is in addition to the [40] The principal amount of deposits held in
deposit insurance allowed on other deposits Qualified Retirement Accounts described
held by the individual at the issuing institution. above, plus accrued but unpaid interest, if
However, pass-through insurance is aggregated any, are protected by FDIC insurance up to a
across certain types of accounts (see the maximum of $250,000 for all such deposits
following section, Aggregation of Retirement held by you at the issuing depository
and Employee Benefit Plans and Accounts). institution together with other accounts held
[38] A deposit held by an employee benefit plan in the same capacity. The FDIC sometimes
that is eligible for pass-through insurance is generically refers to Qualified Retirement
not insured for an amount equal to the number Accounts as “self-directed retirement
of plan participants multiplied by the applicable accounts.” Supplementary FDIC materials
Standard Maximum Deposit Insurance Amount. indicate that Roth IRAs, self-directed Keogh
For example, assume an employee benefit Accounts, Simplified Employee Pension plans,
plan that is a Qualified Retirement Account and self-directed defined contribution plans
(i.e., a plan that is eligible for deposit insurance are intended to be included within this group
coverage up to $250,000 per qualified of Qualified Retirement Accounts. Accordingly,
beneficiary) owns $500,000 in deposits at one all accounts that participate in RASP, other than
institution and the plan has two participants, Coverdell Education Savings Accounts, should
one with a vested non-contingent interest qualify for $250,000 of FDIC insurance in the
of $350,000 and one with a vested non- aggregate.
contingent interest of $150,000. In this case, Other employee benefit plans
the individual with the $350,000 interest would [41] Any employee benefit plan, as defined in
be insured up to the $250,000 limit, and the Section 3(3) of ERISA, described in Section
individual with the $150,000 interest would be 401(d) of the Code, or eligible deferred
insured up to the full value of such interest. compensation plan under section 457 of the
[39] Moreover, the contingent interests of Code, that does not constitute a Qualified
employees in an employee benefit plan Retirement Account—for example, certain
and overfunded amounts attributed to employer-sponsored profit sharing plans—can
any employee defined benefit plan are still satisfy the requirements for pass-through
not insured on a pass-through basis. Any insurance with respect to non-contingent
interests of an employee in an employee interest of individual plan participants, provided
benefit plan deposit which are not capable that FDIC requirements for recordkeeping
of evaluation in accordance with FDIC rules and account titling are met (“Non-Qualifying
(i.e., contingent interests) will be aggregated Benefit Plans”). For Non-Qualifying Benefit
with the contingent interest of other Plans, the Standard Maximum Deposit
participants and insured up to the applicable Insurance Amount (“SMDIA”) applies. Under
Standard Maximum Deposit Insurance FDIC regulations, an individual’s interests in
Amount. Similarly, overfunded amounts are Non-Qualifying Benefit Plans maintained by
insured, in the aggregate for all participants, the same employer or employee organization
up to the applicable Standard Maximum (e.g., a union) which are holding deposits at
Deposit Insurance Amount separately from the same institution will be insured up to

Traditional Individual Retirement Account | 41


the SMDIA in the aggregate, separate from
other accounts held at the same depository
institution in other ownership capacities.
[42] If you have questions about the FDIC insurance
coverage of your account, please contact your
Merrill Lynch advisor or visit the FDIC website
at fdic.gov for more information.
[43] FDIC regulations and interpretations governing
the availability of federal deposit insurance are
subject to change from time to time. Neither
BANA nor BA-CA or any other depository
institution participating in RASP assumes
any responsibility with respect to any such
changes.

L-SHEET-01-16-8284 | 04-2024

42 | Traditional Individual Retirement Account


Merrill Lynch Statement [4] You also may link your IRA with IRAs (or other
accounts) of immediate family members
Link Service and their spouses to achieve a higher Tier. If
you want to link IRAs with accounts of other
[1] You may elect to enroll in the Merrill Lynch persons to achieve a higher Tier, you should
Statement Link service (“Statement Link consult your legal or tax advisor. For more
service”). This service allows certain types of information on enrolling in this service, please
accounts to be “linked” for various purposes, call your financial advisor or 1.800.MERRILL.
including (1) to receive statements for all L-04-24
linked accounts in a single package and (2) to
establish your Tier (defined on the previous
pages) for the Retirement Asset Savings
Program (“RASP”).
Linking accounts for statement delivery
purposes
[2] The Statement Link service allows a
Retirement Plan Account client (the “Primary
Account client”) to link other Merrill Lynch
accounts, usually in the same household
or related to a single business, so that the
monthly statements for the linked accounts
are packaged together and mailed by us
to the Primary Account client’s address,
together with a summary page that combines
account information from all linked accounts.
Statements will continue to be sent to clients
of the linked accounts as required. The assets
of the linked accounts are not commingled
and all of the clients retain control over their
individual accounts. The individual clients also
remain responsible for verifying the accuracy
of their individual statements, for reading
any notices that are mailed with the linked
statements and for directing the activity in
their individual accounts.
Important considerations for individual
retirement accounts
[3] You generally may link your Individual
Retirement Account (IRA), Individual
Retirement Rollover Account (IRRA), Roth
Individual Retirement Account (Roth IRA),
Simplified Employee Pension (SEP), SIMPLE
Retirement Account (SRA), and Coverdell
Education Savings Account (ESA) with your
other accounts to achieve a higher Tier. Except
for a SEP/IRA or a SRA/IRA, you cannot link an
IRA which accepts employer contributions.

Traditional Individual Retirement Account | 43


Merrill Lynch, Pierce, Fenner & Smith Incorporated (also referred to as “MLPF&S” or “Merrill”) makes available certain
investment products sponsored, managed, distributed or provided by companies that are affiliates of Bank of America
Corporation (“BofA Corp.”). MLPF&S is a registered broker-dealer, registered investment adviser, Member SIPC and a
wholly owned subsidiary of BofA Corp.
Investment products:

Are Not FDIC Insured Are Not Bank Guaranteed May Lose Value
Unless otherwise noted, all trademarks are the property of Bank of America Corporation.
© 2024 Bank of America Corporation. All rights reserved. | BRO-02-24-0201 | 209468PM-0424 | 04/2024

44 | Traditional Individual Retirement Account


Merrill Edge® Self-Directed Investing
Terms of Service
These Merrill Edge® Self-Directed Investing Terms of Service (the “Terms of 1. Nature of the Merrill Edge Self-Directed Investing Service
Service”) are made between Merrill Lynch, Pierce, Fenner & Smith Incorporated
Merrill Edge Self-Directed Investing is designed for U.S.-based investors who
(“Merrill”) and you and govern your Merrill Edge Self-Directed Investing Account
wish to make their own investment choices in a Merrill Lynch, Pierce, Fenner &
Relationship. “You” and “your” refers to each Merrill Edge Self-Directed
Smith Incorporated brokerage account.
Investing Account owner.
Neither Merrill, nor MESD, nor any Merrill or MESD representative will provide
In the case of an entity, “you” and “your” refers to the entity, and by enrolling,
you with investment advice, including any recommendations, or offer any
the entity agrees that access to Merrill Edge Self-Directed Investing shall be
opinion regarding the suitability of any security, order, transaction, or strategy
restricted to Authorized Representatives (as defined in the Account Agreement)
in a Merrill Edge Self-Directed Investing Account, or monitor your investment
for such entity and that the entity will be liable for all acts or omissions of such
or the appropriateness of your account or service level, or alert you to any
Authorized Representatives in violation of these Terms of Service.
recommended change to your investments, investment accounts, or services.
Merrill Edge Self-Directed Investing (also referred to herein as “MESD”) is Neither Merrill nor MESD, nor any Merrill or MESD representative, will provide
the marketing name for certain brokerage services offered to clients on a any tax or legal advice.
self-directed basis through Merrill Lynch, Pierce, Fenner & Smith Incorporated
No Merrill Research opinion, Independent Research opinion, the inclusion of
(“Merrill”). For the purpose of the Merrill Edge Self-Directed Terms of Service,
a security on any list, or any information provided to you either on the Merrill
Merrill and MESD, which are made available through Merrill Lynch, Pierce,
website or by mail or any other means constitutes a recommendation to you
Fenner & Smith Incorporated (“MLPF&S”), refer to certain brokerage services
to purchase, hold or sell any investment. By entering into this Agreement, you
offered to clients on a self-directed basis through Merrill Lynch, Pierce, Fenner
agree that any transactions executed through your Merrill Edge Self-Directed
& Smith Incorporated (“Merrill”) and which are the subject of these Terms.
Investing Account, whether based on information obtained from Merrill or
When you agree to these Terms of Service, you are agreeing that such terms elsewhere, will be solely your own decision and based on your own evaluation
will apply to all of your MESD Accounts, transactions and services. of your personal financial situation, needs, and investment objective(s).

These Terms of Service incorporate all disclosures displayed on the In addition to retaining the sole responsibility for investment decisions, you
Merrill Edge Self-Directed Investing website from time to time, including our understand and agree that you are responsible for knowing the rights and
fees and commissions, and they supplement the Merrill Edge Self-Directed terms of all securities in your account, specifically including valuable rights
Client Relationship Agreement which you are required to sign as well as your that expire unless the holder takes action. This includes, but is not limited to,
Merrill Edge Self-Directed Investing Cash Management Account Agreement warrants, stock rights, convertible securities, bonds, and securities subject to
and/or your Merrill traditional IRA or IRA Rollover Custodial Agreement or a tender or exchange offer. You understand and agree that Merrill accepts no
Roth Individual Retirement Account Agreement and/or your Merrill Edge obligation to notify you of any upcoming expiration or redemption dates, or,
Self-Directed Investing Business Investor Account Financial Service Account except as required by applicable law or regulation, to take any action on your
Agreement and/or your Merrill Retirement Cash Management Financial behalf without specific instructions from you. You also agree that all dividends
Service Account Agreement and/or your Merrill Simple Retirement Account and interest payments credited to your account shall accumulate rather than
Custodial Agreement and/or your Merrill Simplified Employee Pension Program be paid to you upon receipt, but shall be subject to your withdrawal from time
Agreements, as applicable, which otherwise remain in full force (and all such to time upon request for a check or other funds transfer.
account types, and any account types that may be introduced by MESD from
Notwithstanding the foregoing, in its capacity as an investment adviser
time to time, will herein be referred to as “Account”). By using Merrill Edge
Merrill may provide investment advice or recommend securities transactions
Self-Directed Investing, you are representing to Merrill and its licensors and
or investment strategies to you within certain investment advisory programs.
Information Providers that you are at least eighteen years old (or the minimum
To enroll in such an investment advisory program, such as the Merrill
legal age in your jurisdiction).
Guided Investing Program, you may be required to establish and maintain a
Merrill reserves the right to add, delete or modify MESD functionality and Merrill Edge Self-Directed Investing Account. Merrill acts as an investment
trading rules and to amend or supplement these Terms of Service or any other adviser and not a broker-dealer for the investment advisory services provided
agreement among or between the parties upon notice, such notice delivered within these investment advisory programs. To the extent that Merrill provides
by regular mail, by email, by an on-screen alert or via the Merrill websites. In investment advice or recommends any securities transactions or investment
particular, Merrill reserves the right upon notice to change its fees, to add fees strategies to you within any such investment advisory program, you understand
for items for which it does not currently charge and to institute an inactivity and agree that Merrill does so in its capacity as an investment adviser and not
fee for periods in which there is no fee-generating activity in your Account. as a broker-dealer. You will be required to enter into a separate agreement with
Merrill also reserves the right to terminate your enrollment in Merrill Edge Self- Merrill and its affiliates to participate in an investment advisory program. The
Directed Investing at any time for any reason without notice. terms governing any such investment advisory program will control if there are
any inconsistencies with the terms of these Terms of Service. If your account
Merrill Lynch, Pierce, Fenner & Smith Incorporated offers its products, serves as the securities account for a Merrill investment advisory program,
accounts and services through different service models (e.g., self-directed, certain features of Merrill Edge Self-Directed Investing, such as the Margin
full-service). Based on the service model, the same or similar products, Lending Program, check writing, and Visa cards, may not be available to you. If
accounts and services may vary in their price or fee charged to a client. your account serves as the securities account for a Merrill investment advisory
program and if, for any reason, you terminate from the investment advisory

Page 1 | Merrill Edge Self-Directed Investing Terms of Service Code 422001PM-0321


program without transferring the securities and assets out of your account, If you complete the Account application process via a hardcopy paper
your account will be a Merrill Edge Self-Directed Investing Account without application or via the iPad or other device that is provided by Bank of America
any investment advisory relationship. As such, and as explained more fully in and/or Merrill in a Bank of America, N.A. Financial Center, you agree to receive
the preceding paragraphs, neither Merrill, nor any Merrill representative, will all notices, statements, disclosures and other information regarding your
provide any investment advice or give any advice or offer any opinion regarding Account in paper form, delivered to your last-designated postal mailing address
the suitability of any security, order or transaction in a Merrill Edge Self- unless and until you elect to change the method of delivery for documents
Directed Investing Account. and other written communications to electronic delivery. In order to make that
change, you will be required to (1) enroll in www.merrilledge.com, which is an
internet-based service that provides 24-hour access to Account information,
2. Account Data Access; User ID and Password; Merrill research and investment information, market data, and news; (2)
Safeguarding Credentials demonstrate access to the information available via www.merrilledge.com;
Merrill Edge Self-Directed Investing is intended to be delivered to you via the and (3) affirmatively consent to the eCommunications Disclosure.
Internet using commercially available third-party web browsers. Merrill Edge
Note regarding Small Business 401(k) accounts: You must complete the
Self-Directed Investing permits you to view account data for your primary Merrill
application process via the internet, but you will not be required to consent
Account and any other accounts that are linked to such primary Account from
to the eCommunications Disclosure as you do not have the option to
time to time. By using Merrill Edge Self-Directed Investing, you represent
exclusively receive communications related to this Account electronically.
on a continuing basis that you are authorized to have viewing access to any
Some communications, such as Account statements, may be retrieved via
Account for which you and other linked account parties have requested linking
the internet, but all communications will be delivered in paper.
of Accounts. Merrill allows each account holder to create a separate User ID
and Password for each Merrill Edge Self-Directed Investing Account. You agree
that each account holder shall be responsible at all times for maintaining the
confidentiality of their personal information and their User ID and Password 4. Corporate Actions
and will not make them available to other account holders or any third parties. If It is important to understand corporate actions (such as stock splits, tender
you do allow other account holders or third parties to access Merrill Edge Self- offers, rights issues, etc.) and how they can affect your investments. In certain
Directed Investing (including your accounts) using your personal information instances outside of our control, issuers may provide late notice on voluntary
or your User ID and Password, you agree to hold Merrill, its directors, officers, corporate action events which, in turn, delays notices from being delivered to
employees, agents and affiliates (collectively, “Other Persons”) harmless and to you. Merrill will make best efforts to notify you as soon as practically possible
indemnify Merrill and all Other Persons against any liability, costs or damages of a corporate action, but due to printing and mailing timelines, some notices
arising out of claims or suits by any account holder, including yourself, or such third may be delivered late, even past the deadline. Enrolling in Online Delivery of
parties based upon or relating to such access. If you believe that someone has Service Notices will help ensure the timeliest delivery possible of corporate
used your credentials, such as your User ID and Password, to access Merrill Edge action notices and also give enhanced flexibility, convenience, and visibility
Self-Directed Investing without your authorization, you agree to contact our on your accounts. Merrill may also provide corporate action notices to you
Merrill Edge Self-Directed Investment Center immediately at 877.653.4732. on voluntary events where eligibility restrictions apply. We will ensure that
all shareholders are notified of these type of events, although it is your
All daily Account data is provided as a convenience and for your information, responsibility to determine whether you are eligible to participate in an event
but it is not the official record of your Account activity with Merrill; your Merrill based on the terms of the notification.
Account statement provided to you online each month (or by mail quarterly
or monthly as required) is such official record. Account data provided through
Merrill Edge Self-Directed Investing is generally updated as of the prior 5. Hyperlinks
business day’s close of business, but is subject to adjustment and correction.
Merrill may make available links from its websites to other third-party websites
Merrill may also collect and/or use certain information from or through your or electronic services providers that are not affiliated with Merrill. Merrill does
browser or device. Most browsers and/or devices (including your computer, tablet not control these other websites or services, and Merrill has not adopted and
and mobile phone) collect certain information, including but not limited to your makes no representations or endorsements whatsoever concerning those
Media Access Control (MAC) address, device type, screen resolution, operating websites or services. The fact that Merrill has provided a link to a website is not
system version, internet browser type and version, local date and time, and the an endorsement, authorization, sponsorship, or affiliation with respect to such
prior web page visited leading you to our websites. Merrill uses this information website, its owners, or its providers. There are risks in using any information,
to ensure our websites function properly, for fraud detection and prevention, and software, service or product found on the Internet and Merrill cautions you
security purposes. For more information about our privacy and security practices to make sure you understand these risks before retrieving, using, or relying
and a link to our Privacy Notice for U.S. Consumer Customers and U.S. Online upon anything via the Internet. You agree that under no circumstances will you
Privacy Notice, go to our website at www.ml.com/privacy. hold Merrill liable for any loss or damage caused by use of or reliance on any
content, goods or services available on such other websites.

3. Account Application Process and Delivery of Communications


6. Quotes, News and Research; Use of Data and Information
You may be able to apply for an Account by completing the Account application
process (1) via the internet; (2) via a hardcopy paper application; or (3) via an Quotes, news, research, ratings and other information provided through
iPad or other device that is owned and provided by Bank of America and/or Merrill Edge Self-Directed Investing are obtained from sources we believe to be
Merrill in a Bank of America, N.A. Financial Center. You must have a valid email reliable, but we cannot guarantee the accuracy, timeliness or completeness of
address to open any Merrill Edge Self-Directed Investing Account. You agree such information for any particular purpose. Such data and information and any
that you will provide us with a valid email and postal mailing address, and that Merrill Research or independent research opinions provided do not constitute
you will immediately notify us of any changes to your email or mailing addresses. investment advice, or a solicitation by Merrill for the purchase or sale of any
securities, or a representation that any securities are suitable for you.
With the exception of Small Business 401(k) accounts (which are discussed in more
detail below), if you complete the Account application process via the internet, you All such data and information is protected by copyright and other intellectual
must consent to the Electronic Communications Disclosure (“eCommunications property laws and may only be used for personal and non-commercial use, and not
Disclosure”). Your consent to the eCommunications Disclosure allows us to for providing professional investment advice or for providing securities processing
provide communications to you electronically. The eCommunications Disclosure services or other similar back office functions. If you download any information
also provides important information about paperless delivery, such as, among from Merrill Edge Self-Directed Investing for your personal reference, you agree
other things, the types of communications you can receive electronically and the that you will not remove or obscure any copyright or other notices contained
hardware and software required to receive communications electronically. As in any such information. Except as provided in the preceding sentence, you
discussed in Section 4 of the eCommunications Disclosure, we may, at times and agree not to copy, reproduce, modify, sell, distribute, transmit, display, perform,
in our sole discretion, mail you a paper copy of certain communications even if you circulate, transfer, broadcast, create derivative works from, publish, or use for any
agree to electronic delivery by consenting to the eCommunications Disclosure. commercial or unlawful purpose any quotes, news, research, text images, audio,
video or other information you receive through Merrill Edge Self-Directed Investing.

Page 2 | Merrill Edge Self-Directed Investing Terms of Service Code 422001PM-0321


Merrill and its licensors and Information Providers (as defined in Section 14 below) Unsecured Email
may change or discontinue any quotes news, research or other information at any Unsecured email is available via the Help & Support link prior to client login.
time provided within Merrill Edge Self-Directed Investing at any time. Unsecured email provides individuals with the opportunity to send messages
concerning Merrill procedures and general Merrill questions. No Account-
Merrill offers you access to Independent Research on all domestic and specific information will be provided in response to a message received via
selected international stocks covered by Merrill Research under the terms of unsecured email. Additionally, Merrill will not open any documents or files that
an agreement with regulators. The providers of this independent Research are attached to or submitted via unsecured email.
are chosen by an Independent Consultant, not by Merrill. You agree that
Merrill will not be responsible or liable for (i) the procurement decisions of the Secure Message Center
Independent Consultant with respect to the Independent Research, (ii) the The Secure Message Center is available to you after logging in to
Independent Research or its content (iii) customer transactions, to the extent www.merrilledge.com as a secure email tool to contact Merrill representatives.
based on the Independent Research, or (iv) claims arising from or in connection Through the Secure Message Center, you can submit Account-specific inquiries
with the inclusion of Independent Research ratings in confirmations and to Merrill. You can also submit documents to Merrill via the Secure Message
Account statements, to the extent such claims are based on those ratings. You Center and perform or request certain administrative functions. You understand
also agree that Merrill will not be required to supervise the production of the and agree that Merrill may change the functionality of the Secure Message
Independent Research procured by the Independent Consultant and will have Center from time to time.
no responsibility to comment on the content of the Independent Research.

10. Order Entry Security


7. Financial Tools, Education and Calculators Merrill allows each Account holder to create a separate User ID and Password
Merrill Edge Self-Directed Investing may also provide you with financial tools for each Merrill Edge Self-Directed Investing Account. You agree that each
and education, including calculators. The tools and calculators may allow you Account holder shall be responsible for all orders entered through Merrill Edge
to model “what-if” scenarios for various financial goals, the results of which are Self-Directed Investing using the User ID and Password initially created or
illustrative and are based on the information and assumptions identified. There changed by the Account holder regardless of who enters such orders. You
is no guarantee that the results shown will be achieved, and changes in tax laws, agree that each account holder shall be responsible at all times for maintaining
financial markets or your financial situation may cause actual results to deviate the confidentiality of their personal information and their User ID and
substantially from those reflected in these tools. In addition, these tools and Password and will not make them available to other account holders or any
calculators are not part of any financial report for which you may have paid a fee, third parties. If you do allow other account holders or third parties to access
even if the tools and calculators include information derived from or contained in Merrill Edge Self-Directed Investing (including your accounts) using your
the financial report. In addition, no tools, education or calculators are intended to personal information or your User ID and Password, you agree to hold Merrill,
provide individual product recommendations or investment strategies. its directors, officers, employees, agents and affiliates (collectively, “Other
Persons”) harmless and to indemnify Merrill and all Other Persons against any
liability, costs or damages arising out of claims or suits by any account holder,
8. Phone Service including yourself, or such third parties based upon or relating to such access.
Merrill Edge Self-Directed Investing phone-based representatives are available
24 hours per day, 7 days per week. These representatives are available to assist
you with various administrative functions related to applying for and opening 11. Order Entry Trading Rules
Accounts and providing you with access to www.merrilledge.com. They can also Merrill Edge Self-Directed Investing allows you to enter orders to buy and sell
assist with various requests related to your Account, such as address changes, U.S. market traded equities, including exchange-listed and widely-held over­
name changes, changes to the beneficiaries designated on your Account (if the-counter stocks, a wide selection of mutual funds, and certain bonds and
applicable), and money movement requests, among other things. certificates of deposit. Merrill Edge Self-Directed Investing is not designed
to be a brokerage service for investors who trade in low-priced securities or
Merrill Edge Self-Directed Investing phone-based representatives are also foreign securities. Merrill intends to maintain an order entry policy for low-
available to you for technical support between the hours of 7:30 a.m. and priced stocks and other trading rules, which will be subject to change from
6:00 p.m. Eastern, Monday through Friday. You understand and agree that time to time upon posting on the Merrill Edge Self-Directed Investing site
the services described above are only examples of the types of services that or the optional Merrill Mobile Brokerage service. Merrill Edge Self-Directed
the phone-based representatives may be able to perform, and that Merrill Investing is intended to be available for order entry seven (7) days a week,
reserves the right to change the services and functions that the phone-based twenty four (24) hours a day, except for brief maintenance periods; however,
representatives may perform from time to time. Merrill does not warrant that the service will be uninterrupted. Orders sent
outside of regular U.S. Market hours will be held and entered on the primary
Merrill Edge Self-Directed Investing phone-based representatives will not
market during market hours on the next trading day. Certain orders may be
provide investment advice or investment recommendations or offer any
blocked or subject to pre-review by Merrill, which may take up to several
opinion regarding the suitability of any security, order, transaction or strategy
minutes to process. Merrill reserves the right to place restrictions on your
in a Merrill Edge Self-Directed Investing Account. Merrill Edge Self-Directed
Account in its sole discretion, and to cancel any order that we believe would
Investing phone-based representatives will not provide any tax or legal advice.
violate federal credit regulations or other regulatory limitations; however,
Merrill Edge Self-Directed also provides an automated phone service referred to as Merrill will have no responsibility or liability for failing to cancel any order.
the MESD IVR. Through the MESD IVR, you are able to request security quotes and
review account information, such as balances, account holdings, and recent activity.
12. Your Responsibilities Regarding Order Entry
All orders entered through Merrill Edge Self-Directed Investing shall be subject
9. Email to the applicable rules, customs and usages of the exchange or market, and
Two email or electronic mail options are available via www.merrilledge.com, its clearinghouse, on which such orders are transacted by Merrill, including our
unsecured email and electronic mail via the Secure Message Center. You agree that affiliates, including cancellation of orders in certain circumstances. Whether or not
neither unsecured email nor the Secure Message Center is to be used to request, funds are available in your Account on trade date, you agree to pay by settlement
authorize or effect the purchase or sale of any securities or other investments, to date for any trade for which you place an order through Merrill Edge Self-Directed
send funds transfer instructions, or for any other financial transactions that require Investing. You agree that you will immediately notify Merrill by telephone and
real-time communication or more formal written authorization in accordance with confirm the same in writing if you become aware of any discrepancy in your
applicable law or Merrill policies. Any such requests, orders, or instructions that you Account balance or security positions or if you have reason to believe that a third
send via email in contravention of the foregoing agreement will not be accepted party is using your User ID and Password without your authority. If you fail to
and will not be processed by Merrill. Merrill will not be responsible for any loss or notify Merrill when any of the above conditions occur, neither Merrill nor any Other
damage that could result from your supplying us with personal information via Persons shall have any responsibility or liability to any account holder or any other
email or your requests, orders or instructions not being accepted or processed in person claiming through any account holder for any claims with respect to the
accordance with the preceding sentence. handling, mishandling or loss of any order. You agree to accept full responsibility for
the monitoring of your Account with respect to all transactions entered.

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13. Limitation on Merrill’s Responsibilities and Liability 15. Order Execution and Routing Disclosures
You agree that Merrill will not be responsible for the accuracy, completeness Exchange-listed securities — When you buy or sell round lots (usually 100
or use of any market data news or research information provided through shares) of listed stocks, or when you buy or sell listed options, we generally
Merrill Edge Self-Directed and Merrill does not make any warranty concerning route your order through a routing system to what are expected to be the
such information. You further agree that all orders placed through Merrill Edge best execution venues for the order. We handle your order so as to obtain
Self-Directed Investing are at your sole risk and responsibility based on your a competitive execution price in line with our regulatory obligations. Our
own evaluation of your financial circumstances and investment objectives. electronic order-processing system automatically channels your order to an
Merrill Edge Self-Directed Investing may display on the order entry screen appropriate market center given the characteristics of the order, market data
Merrill Research’s quality rating and investment opinion on companies, if and trading statistics. Our trading desks, or the trading desks of one or more
available, as well as Independent Research opinions; however, such information of our affiliates, may be one of these market centers or venues where the
and opinions by themselves do not constitute investment advice, or a solicitation execution may occur. If that is the case, your confirmation will indicate that
or recommendation by us for the purchase or sale of any securities, or a we acted as principal in connection with the purchase or sale transaction.
representation that any securities are suitable for you. We have in place effective internal controls, including information barriers,
You understand and agree that Merrill Edge Self-Directed Investing utilizes to prevent the inappropriate sharing of order information among our equity
the Internet to transport data and communications. Merrill will take reasonable trading desks. In this regard, each of our equity trading desks independently
security precautions to safeguard data and communications; however, conducts its trading activities. To the extent permitted by rule or law, when a
Merrill disclaims any liability for interception and/or use of any such data or Merrill equity trading desk or unit (including a market-making desk or unit that
communications. You agree that neither Merrill nor any third party working engages in block positioning and provides firm bid/offer quotes) handles your
with Merrill to provide services hereunder shall be responsible for any damages equity orders, other equity trading desks or units of Merrill or its affiliates may
caused by communications line failure, systems failure, and other occurrences separately transact — without knowledge of your orders — for their principal
beyond their control, or from any unauthorized trading or theft by any third accounts at prices that would satisfy your orders. Conversely, if your orders
party who gains access to your Account by use of your User ID and Password are handled by an equity trading desk or unit of Merrill or its affiliates, and no
as a result of your intentional or unintentional conduct, including negligence by attempt is made to obtain liquidity for your orders from our market-making
you. Merrill will not be responsible for any access costs you incur to connect to desk or the market-making desk of one of our affiliates, you should understand
Merrill Edge Self-Directed Investing. that the market-making desk may separately transact — without knowledge of
your orders — for its principal at prices that would satisfy your orders. In either
Neither Merrill nor any third party makes any representations or warranties case, the execution prices of any trading desk or unit that did not handle your
expressed or implied with respect to Merrill Edge Self-Directed Investing, order, transacting for its principal accounts, could be better, the same, or worse
including without limitation, any implied warranties of merchantability than the prices you receive for the same security.
or fitness for a particular purpose. To the extent permitted by law, under
no circumstances, including negligence, will Merrill or any of its affiliates, Over-the-counter markets — Securities that are not listed on an exchange
directors, officers or employees, or any third party vendor be liable or have any may be traded in the over-the-counter markets. Merrill and its affiliates may be
responsibility of any kind for any loss or damage that you incur in the event of participants in an over-the-counter market and execute your orders as principal.
any failure or interruption of Merrill Edge Self-Directed Investing, or resulting Merrill fully complies with SEC and FINRA order handling requirements. We
from the act or omission of any other party involved in making Merrill Edge handle your order so as to obtain a competitive execution price. We regularly
Self-Directed Investing available to you, or from any other cause relating monitor the quality of our executions. This includes reviewing the order
to your access to or use of Merrill Edge Self-Directed Investing, whether or flow sent to Merrill affiliates who may support or provide order routing and/
not the circumstances giving rise to such cause may have been within the or execution services on our behalf, as well as to certain third-party broker-
control of Merrill or of any vendor providing software or services support for dealers or counterparties who we authorize as our liquidity providers. We
Merrill Edge Self-Directed Investing. In no event will Merrill or any such parties take into account many factors in determining the quality of executions and
be liable to you for any special, indirect, consequential or incidental damages to inform our routing decisions for retail-sized held orders. This includes, for
even if Merrill or any other party have been advised of the possibility thereof. National Market System equity securities, certain industry metrics, including
Any liability arising out of any action or omission by Merrill or any such parties but not limited to execution prices in relation to the publicly quoted spread
shall be limited to an amount equal to the benefit which the transaction at the time (referred to as “effective over quoted” or E/Q), to the extent such
would have resulted in during the period between the date of a trade and reference data is available.
the applicable time for settlement of such trade.
Under FINRA rules, we are required to disclose to you descriptions of stop
quote and stop quote limit orders. Depending on your Merrill service channel,
14. Executing Your Order you may have the option to place one or both of these order types. Merrill may
We do business with our clients in two ways: as an agent or as a principal. execute any of these orders itself or through one or more of its affiliates.

As an agent — We act as an agent in many listed and unlisted securities, A stop quote order is a market order to buy or sell when the bid quote or
obtaining a buyer or seller for you. Depending on your service model and offer quote, as applicable, reaches a specified price.
account type, we may add a commission to the execution price.
Equity sell stop quote orders are placed at a stop price below the current
As a principal — We or our affiliates act as a principal in many listed and market price and will trigger if the national best bid quote is at or lower than
unlisted securities, buying from sellers and selling to buyers. There may appear the specified stop price.
on your confirmations from time to time the words, “We or our affiliate may
act as principal.” This means that Merrill or its affiliates are buying or selling Equity buy stop quote orders are placed at a stop price above the current
that particular security, acting as a dealer, and maintaining their own inventory market price and will trigger if the national best offer quote is at or higher than
for that purpose. To the execution price (with the exception of underwriting the specified stop price.
transactions), we add a charge on the buy side called a “markup” and we
Option sell stop orders are placed at a stop price below the current market
subtract a “markdown” on the sell side.
price and will trigger if the national best offer is at or lower than the specified
Our role as agent or principal, and the marketplace in which your transaction stop price.
was effected, is disclosed on your confirmation. In either role, our objective is
to find a competitive execution price for you.

Page 4 | Merrill Edge Self-Directed Investing Terms of Service Code 422001PM-0321


Option buy stop orders are placed at a stop price above the current market of SEC Regulation NMS” section. Merrill affiliates may maintain trading desks
price and will trigger if the option trades or has a prevailing bid quote at or higher engaged in market making or other trading functions to which your orders may be
than the specified stop price on the exchange to which the order is routed. Once routed for execution or from whom an execution price for the transaction may be
triggered, a stop quote order becomes a market order (buy or sell, as applicable), and obtained. The execution disclosures of BofA Securities, Inc., a Merrill affiliate and
execution prices can deviate significantly from the specific stop price. For equities, market center, are available for public review by visiting https://www.bofaml.com/
a stop quote order is not guaranteed to execute as the order will not be triggered en-us/content/best_execution.html.
unless the stop price is reached. For listed options, a stop order is not guaranteed to
execute as the order will not be triggered unless the stop price is reached and, even Note: Under SEC rules, we are required to inform you that Merrill does not receive
if triggered, your order may not be executed if there is no prevailing bid quote (in the payment for order flow from liquidity providers to which Merrill routes its customer
case of a sell stop order) or a prevailing offer quote (in the case of a buy stop order) orders in equity securities. Merrill may receive rebates from and pays fees to
available on the exchange to which your order is routed. certain registered securities exchanges for providing or taking liquidity on those
exchanges, according to those exchanges’ published fee schedules approved by
A stop quote limit order combines the features of a stop quote order and a the SEC. In some cases, the rebates received by Merrill from an exchange may,
limit order. over a period of time, exceed the fees paid to the exchange. Merrill may also
participate in the options order flow programs sponsored by the NYSE American
Equity sell stop quote limit orders are placed at a stop price below the current Options, the NYSE Arca Options, the Cboe options exchanges, and the Nasdaq
market price and will trigger if the national best bid quote is at or lower than the options exchanges. These exchange sponsored programs offer payments for listed
specified stop price. option orders that are directed to such options markets. In addition, in some cases
involving large equity securities trades where you direct that a Merrill affiliate
Equity buy stop quote limit orders are placed at a stop price above the current
execute your order as principal, Merrill may share in the compensation paid to its
market price and will trigger if the national best offer quote is at or higher than the
affiliate for the affiliate’s services.
specified stop price above the current market price and will trigger if the option
trades or has a prevailing bid quote at or higher than the specified stop price on
the exchange to which the order is routed. Once triggered, a stop quote limit order 16. Agreement With Information Providers Regarding Market Data
becomes a limit order (buy or sell, as applicable) at a specified limit price, and
execution may not occur as the market price can move away from the specified The securities prices, quotations, research, ratings, news and other information
limit price. For equities, a stop quote limit order is not guaranteed to execute as the provided on Merrill Edge Self-Directed Investing are provided by various third
order will not be triggered unless the stop price is reached and, even if triggered, party sources that include, but are not limited to, the New York Stock Exchange,
your order may not be executed as the market price can move away from the Inc., American Stock Exchange Inc., NASDAQ Stock Market, Inc., The Options
specified limit price. For listed options, a stop limit order is not guaranteed to Price Reporting Authority, and its participant exchanges, Dow Jones & Company,
execute as the order will not be triggered unless the stop price is reached and, even Inc., Standard & Poor’s Financial Services, LLC, Moody’s Investor Services, Inc.,
if triggered, your order may not be executed if there is no prevailing bid quote (in Morningstar Inc., and their respective affiliates, agents and others, including persons
the case of a sell stop limit order) or a prevailing offer quote (in the case of a buy or entities that act as data processors on behalf of the foregoing (collectively,
stop limit order) available on the exchange to which your order is routed or if the “Information Providers”). By using the Merrill Edge Self-Directed Investing website,
market price moves away from the specified limit price. you acknowledge and agree that: (1) securities prices, quotations research, ratings,
news and other information received from Information Providers (“Market Data”)
Option sell stop limit orders are placed at a stop price below the current market are solely for your individual use and you will not retransmit or furnish Market
price and will trigger if the option trades or has a prevailing offer quote at or lower Data to any other person or entity, except to other officers, partners or employees
than the specified stop price on the exchange to which the order is routed. if you are an entity; (2) the Market Data is and shall remain the property of the
respective Information Providers or of the market on which a reported transaction
Option buy stop limit orders are placed at a stop price above the current market took place or a reported quotation was entered; (3) at any time, Information
price and will trigger if the option trades or has a prevailing bid quote at or higher Providers may discontinue disseminating any category of Market Data, may change
than the specified stop price on the exchange to which the order is routed. Once or eliminate any transmission method and may change transmission speeds or
triggered, a stop quote limit order becomes a limit order (buy or sell, as applicable) signal characteristics, and you shall not hold the Information Providers liable for
at a specified limit price, and execution may not occur as the market price can any resulting liability, loss or damages that may arise there from; and (4) your
move away from the specified limit price. For equities, a stop quote limit order is agreements set forth herein and the disclaimers of warrant, and disclaimers of
not guaranteed to execute as the order will not be triggered unless the stop price is liability set forth below are for the express benefit of the Information Providers as
reached and, even if triggered, your order may not be executed as the market price third party beneficiaries and they may enforce these provisions against you.
can move away from the specified limit price. For listed options, a stop limit order
is not guaranteed to execute as the order will not be triggered unless the stop price Notwithstanding any provisions to the contrary contained herein, with respect to
is reached and, even if triggered, your order may not be executed if there is no Dow Jones & Company, Inc. only: (1) you may, on an occasional and irregular basis,
prevailing bid quote (in the case of a sell stop limit order) or a prevailing offer quote reproduce, distribute, display or transmit an insubstantial portion of the Market
(in the case of a buy stop limit order) available on the exchange to which your order Data provided by Dow Jones & Company, Inc. (the “Dow Jones information”), for a
is routed or if the market price moves away from the specified limit price. non-commercial purpose and without charge, to a limited number of individuals,
provided you include all copyright and other proprietary rights notices with such
Often for those securities in which Merrill or one of its affiliates makes a market, portion of the Dow Jones Information in the same form in which the notices appear
we will use best efforts to execute larger-sized client orders by testing whether, on the Dow Jones Information, the original source attribution, and the phrase
and how much, stock can be bought at currently displayed quotes, in addition “Used with permission from Dow Jones & Company”; (2) if you are an entity, you
to what is reflected in the quote of Merrill or its affiliate. We may then manually may only retransmit or furnish the Dow Jones information to officers, partners or
execute client orders based on the liquidity we are able to access, which may employees in accordance with the foregoing sentence.
involve the simultaneous execution of one or more client orders received over a
period of time. Those orders may receive executions at prices that approximate Notwithstanding any provisions to the contrary contained herein, the following
the volume-weighted average price during that period. Merrill Lynch routes orders additional provisions apply to Market Data provided by Moody’s Investor
in securities in which we do not make a market to other market makers, which can Services, Inc. (“Moody’s”): The credit ratings if any, constituting part of the
include one or more of its affiliates or other unaffiliated third-party market makers. Market Data are, and must be construed solely as, statements of opinion and
not statements of fact or recommendations to purchase, sell or hold securities.
The Securities and Exchange Commission (“SEC”) adopted a rule requiring market Each rating or other opinion must be weighted solely as one factor in any
centers to publicly disclose, on a monthly basis, uniform statistical measures of investment decision made by or on behalf of any user of the Market Data, and
order execution quality. These measures include, but are not limited to, how market each user must make its own study and evaluation of each security and of
orders of various sizes are executed relative to the public quotes and information each issuer and guarantor of, or of each provider of credit support for, each
about the spreads paid by investors. The SEC has also adopted a rule requiring all security that it may consider purchasing, holding, or selling. Moody’s hereby
brokerage firms to make publicly available quarterly reports on their order routing discloses that most issuers of debt securities and rated by Moody’s have, prior
practices. In accordance with these rules, Merrill’s order routing statistics are to assignment of any rating, agreed to pay Moody’s for the appraisal and rating
available for public review by visiting https://www.ml.com/legal.html and clicking services rendered by its fees ranging from $1,500 to $1,500,000.
through the link provided in the “Routing Disclosures Made Pursuant to Rule 606

Page 5 | Merrill Edge Self-Directed Investing Terms of Service Code 422001PM-0321


These Terms of Service shall remain in effect as to the Information Providers Note: The Funds Transfer Service and Bill Payment Services are governed
for so long as you have the ability to receive Market Data through the by separate enrollment terms and conditions, which are available in the
Merrill Edge Self-Directed Investing website as contemplated hereby. In Documents & Forms Library, and are not governed by the above Merrill Edge
addition, either you or Merrill may terminate your access to Market Data at Self-Directed Investing Terms of Service.
any time. You understand that Merrill is obligated to terminate access to
this site as to the provision of any or all of the Market Data pursuant to this
paragraph upon notice to that effect from any of the Information Providers. 17. Callable Securities/ Procedures for a partial redemption
The foregoing provisions regarding the proprietary nature of Market Data, third If you hold securities with us that may be redeemed or called prior to maturity
party beneficiary enforcement by the Information Providers, and the disclaimer and a partial call occurs, a fair and impartial approach will be used among
of liability and disclaimer of warranty by the information Providers survive impacted clients to allocate the securities selected to be called.
termination of your access to Market Data. These Terms of Service supersede
each previous agreement between you and the Information Providers insofar For Merrill’s allocation procedures, please go to the following link or you may
as the superseded agreement pertains to Market Data provided to you through request a hard copy by contacting the Investment Center at 1.877.653.4732.
the Merrill Edge Self-Directed Investing website.
https://olui2.fs.ml.com/Publish/Content/application/pdf/GWMOL/
Disclaimer of Warranties and Liability Regarding Information Providers PartialCallProcessNotice.pdf
and Market Data
THE MARKET DATA ACCESSIBLE THROUGH the Merrill Edge Self-Directed 18. Extended Hours Trading Agreement
Investing website IS PROVIDED “AS IS” AND THERE MAY BE DELAYS,
OMISSIONS OR INACCURACIES IN SUCH DATA. MERRILL, THE INFORMATION IMPORTANT INFORMATION ABOUT EXTENDED HOURS TRADING
PROVIDERS, AND THEIR RESPECTIVE DIRECTORS, OFFICERS, EMPLOYEES, THROUGH ELECTRONIC COMMUNICATION NETWORKS.
AFFILIATES AND AGENTS CANNOT AND DO NOT GUARANTEE THE Due to the nature of the extended hours trading market, trading in the
ACCURACY, SEQUENCE, COMPLETENESS, CURRENTNESS, TIMELINESS, pre-market and after hours through an ECN may pose certain risks which
MERCHANT-ABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE OR are greater than those present during normal market hours.
NONINFRINGEMENT Of THE MARKET DATA MADE AVAILABLE THROUGH
the Merrill Edge Self-Directed Investing website AND HEREBY DISCLAIM Risk of Lower Liquidity
ANY SUCH EXPRESS OR IMPLIED WARRANTIES. NEITHER MERRILL, Liquidity refers to the ability of market participants to buy and sell securities.
THE INFORMATION PROVIDERS, NOR THEIR RESPECTIVE DIRECTORS, Generally, the more orders that are available in a market, the greater the
OFFICERS, EMPLOYEES, AFFILIATES AND AGENTS SHALL BE LIABLE TO liquidity. Liquidity is important because with greater liquidity it is easier for
YOU OR TO ANYONE ELSE FOR ANY LOSS OR INJURY WHETHER OR NOT investors to buy or sell securities, and as a result, investors are more likely to
CAUSED IN WHOLE OR IN PART BY THEIR NEGLIGENCE OR OMISSION IN pay or receive a competitive price for securities purchased or sold. There may
PROCURING, COMPILING, INTERPRETING, EDITING, WRITING, REPORTING, be lower liquidity in extended hours trading as compared to regular trading
OR DELIVERING ANY MARKET DATA THROUGH the Merrill Edge Self- hours. As a result, your order may only be partially executed, or not at all.
Directed Investing website OR BY ANY FORCE MAJEURE OR ANY CAUSE
BEYOND THEIR REASONABLE CONTROL. IN NO EVENT WILL MERRILL, THE Risk of Higher Volatility
INFORMATION PROVIDERS, OR THEIR RESPECTIVE DIRECTORS, OFFICERS, Volatility refers to the changes in price that securities undergo when trading.
EMPLOYEES, AFFILIATES OR AGENTS BE LIABLE TO YOU OR ANYONE ELSE Generally, the higher the volatility of a security, the greater its price swings.
FOR ANY DECISION MADE OR ACTION TAKEN BY YOU IN RELIANCE UPON There may be greater volatility in extended hours trading than in regular
SUCH MARKET DATA OR FOR ANY CONSEQUENTIAL, INDIRECT, SPECIAL trading hours. As a result, your order may only be partially executed, or not
OR SIMILAR DAMAGES, INCLUDING BUT NOT LIMITED TO LOST PROFITS, at all, or you may receive an inferior price when engaging in extended hours
TRADING LOSSES, DAMAGES RESULTING FROM INCONVENIENCE, OR LOSS trading than you would during regular trading hours.
OF USE OF the Merrill Edge Self-Directed Investing website, EVEN If ADVISED
OF THE POSSIBILITY Of SUCH DAMAGES. Risk of Changing Prices
The prices of securities traded in extended hours trading may not reflect the
Incorporation of Market Data Agreements With Exchanges prices either at the end of regular trading hours, or upon the opening the next
BY ACKNOWLEDGING THESE TERMS OF SERVICE, YOU AGREE (A) THAT morning. As a result, you may receive an inferior price when engaging in
YOU UNDERSTAND, AND AGREE TO BE BOUND BY, THE AGREEMENT FOR extended hours trading than you would during regular trading hours.
MARKET DATA DISPLAY SERVICES (THE “EXCHANGE AGREEMENT”), THE
MATERIAL TERMS AND CONDITIONS OF WHICH ARE INCORPORATED Risk of Unlinked Markets
HEREIN; (B) THAT MERRILL IS NOT AN AGENT OF ANY OF THE EXCHANGES Depending on the extended hours trading system or the time of day, the prices
OR OF NASDAQ AND IS NOT AUTHORIZED TO DEPART FROM THE displayed on a particular extended hours trading system may not reflect the
EXCHANGE AGREEMENT; AND (C) THAT NO PROVISION MAY BE ADDED prices in other concurrently operating extended hours trading systems dealing
TO OR DELETED FROM THE EXCHANGE AGREEMENT AND THAT NO in the same securities. Accordingly, you may receive an inferior price in one
MODIFICATIONS HAVE BEEN MADE TO IT ON YOUR BEHALF. YOU WARRANT extended hours trading system than you would in another extended hours
THAT YOU ARE LEGALLY ABLE TO UNDERTAKE THE OBLIGATIONS SET trading system.
FORTH IN, AND THE SIGNATORY IS DULY AUTHORIZED TO BIND YOU TO,
THE EXCHANGE AGREEMENT. Risk of News Announcements
THE NASDAQ STOCK MARKET, INC. IS A THIRD PARTY BENEFICIARY TO THE Normally, issuers make news announcements that may affect the price of their
TERMS AND CONDITIONS OF THIS AGREEMENT. TO THE EXTENT THAT YOU securities after regular trading hours. Similarly, important financial information
HAVE ANY CLAIMS AGAINST NASDAQ ARISING OUT OF THIS AGREEMENT is frequently announced outside of regular trading hours. In extended hours
OR THE NASDAQ SUBSCRIBER AGREEMENT, THOSE CLAIMS SHALL BE trading, these announcements may occur during trading, and if combined
GOVERNED BY AND CONSTRUED AND ENFORCED IN ACCORDANCE WITH with lower liquidity and higher volatility, may cause an exaggerated and
THE STATE OF MARYLAND WITHOUT REFERENCE TO PRINCIPLES Of unsustainable effect on the price of a security.
CONFLICTS OF LAW, AND YOU CONSENT TO SUBMIT TO THE JURISDICTION
Of THE COURTS OF OR FOR THE STATE Of MARYLAND IN CONNECTION Risk of Wider Spreads
WITH ANY SUCH CLAIM. The spread refers to the difference in price between what you can buy a
security for and what you can sell it for. Lower liquidity and higher volatility in
BY ACKNOWLEDGING THESE TERMS OF SERVICE, YOU CERTIFY TO THE extended hours trading may result in wider than normal spreads for a particular
INFORMATION PROVIDERS, AND TO MERRILL, THAT YOU HAVE READ, security.
UNDERSTAND AND INTEND TO BE BOUND BY THESE TERMS OF SERVICE.

Page 6 | Merrill Edge Self-Directed Investing Terms of Service Code 422001PM-0321


Time and Price Priority of Orders ECN pre-market orders can be placed from 7:00 to 9:30 a.m. Eastern. Pre-market
Orders entered into the extended hours session are generally handled in Orders we receive will be sent to the ECN for execution in the order in which they
the order in which they were received at each price level. Therefore, orders are received. We will continue to send ECN pre-market orders as they are received
transmitted to the ECN by other investors before your order may match an until 9:30 a.m. Eastern unless trading is halted prior to 9:30 a.m. Eastern.
existing order that you were attempting to match, thereby removing that order
ECN after-hours orders can be placed from 4:01 to 8:00 p.m. Eastern (After
from the ECN order book. Similarly, your order may not be first in line to be
Hours Orders). After Hours Orders we receive will be sent to the ECN for
executed if a matching order comes into the ECN. This may prevent your order
execution in the order in which they are received. We will continue to send
from being executed, in whole or in part, or from receiving as favorable a price
After Hours Orders to the ECN until 8:00 p.m. Eastern unless trading is halted
as you might receive during normal market hours.
prior to 8:00 p.m. Eastern.
Communication Delays If ECN pre-market trading is available, orders not filled during the ECN pre­
Delays or failure in communications due to a high volume of orders or market session are automatically canceled if they are not filled by the end of
communications, or other computer system problems, may cause delays the session (i.e., 9:30 a.m. Eastern) during which they were placed. You must
in, or prevent execution of your order. re-enter these orders during normal market hours if you still wish to have the
trades executed.
Terms and Conditions
Orders not filled during the ECN after hours session are automatically canceled
Trading through ECN Extended Hours session on the ECN is subject to the
if they are not filled by the end of the session (i.e., 8:00 p.m. Eastern) during
terms and conditions (“Terms”) and policies set forth by Merrill and subject to
which they were placed. You must re-enter these orders during normal market
change without notice. Trading in the pre-market session may not be available
hours if you still wish to have the trades executed.
to all users. Users of the extended hours trading session should contact an
investment specialist to determine the availability of pre-market trading. Merrill is not liable for delays in the transmission of orders due to a breakdown
By using the ECN Extended Hours trading facility, you acknowledge your or failure of transmission, communication or data processing facilities, or for
understanding of the risks set forth above and your agreement to the Terms any other cause beyond our reasonable control.
set forth below.
Transactions are subject to the applicable rules and regulations of the self-
We reserve the right not to accept an order for the ECN Extended Hours session regulatory organizations and governmental authorities.
at their discretion and will attempt to notify you if your order is not accepted.
Transactions are subject to all other agreements applicable to your account(s).
We will only accept limit orders for ECN Extended Hours trading. You must
indicate a specific price at which you are willing to buy or sell the security you
are interested in. You may not trade against an order entered by you. In other
words, you may not buy securities you offered for sale in the ECN, and vice versa.

The maximum order size is 100,000 shares.

Prices must be entered in decimals.

Only certain securities will be eligible for trading through the ECN Extended
Hours session, so all orders must be for securities traded on the ECN. If a stock
normally traded on the ECN closes on a trading halt in its primary market, or
trading is later halted by its primary exchange or a regulatory authority, trading
of that stock will be suspended on the ECN.

Merrill Lynch, Pierce, Fenner & Smith Incorporated (also referred to as “MLPF&S” or “Merrill”) makes available certain investment products sponsored, managed, distributed or
provided by companies that are affiliates of Bank of America Corporation (BofA Corp.). MLPF&S is a registered broker-dealer, registered investment adviser, Member SIPC and a
wholly owned subsidiary of BofA Corp.
Merrill Edge® Self-Directed is available through MLPF&S.
Banking products are provided by Bank of America, N.A., and affiliated banks, Members FDIC and wholly owned subsidiaries of BofA Corp.
Investment products:
Are Not FDIC Insured Are Not Bank Guaranteed May Lose Value
© 2021 Bank of America Corporation. All rights reserved. | BRO-03-21-0179 | 03/2021

To learn about Bank of America’s environmental goals and initiatives, go to bankofamerica.com/environment. Leaf icon is a registered trademark of Bank of America Corporation.

Page 7 | Merrill Edge Self-Directed Investing Terms of Service Code 422001PM-0321


Merrill Personal Advisor Progra
Client Agreement

Mutual Fund Investing at Merrill


A Client Disclosure Pamphlet
April 2024

Merrill Lynch, Pierce, Fenner & Smith Incorporated

One Bryant Park


New York, N.Y. 10036
1.800.MERRILL

1 Code 311619PM-0210
Mutual Fund Investing at Merrill
Table of Contents

Introduction 2-3

U.S. Registered Mutual Fund Share Classes 3-7

Merrill Sales Load Waiver and Discounts 7-8

Asset-Based Fee Programs 8-9

Retirement & Benefit Plan Services Programs 9-10

Merrill Edge® Self-Directed Investing 10

Compensation of Merrill, Merrill Financial Advisors and Their Managers 10-11

Compensation of Merrill Financial Solutions Advisors 11

Fund Families’ Cost Sharing for Training Events and Other Meetings & Gifts, Meals and
Entertainment 11-12

Additional Merrill Services and Compensation 12-14

Money Market Mutual Funds 14-16

Purchases, Sales and Transfers 16

Provision of Diversified Financial Services by Merrill and its Affiliates 16

Mutual funds are not FDIC insured; are not deposits or obligations of, or guaranteed by, any financial institution; and are subject to
investment risks, including possible loss of the principal amount invested. Investment return and principal value will fluctuate so that an
investor’s shares, when redeemed, may be worth more or less than their original cost.

Prospectuses for mutual funds can be obtained through the investor’s sign-in area of merrilledge.com. Clients of Merrill Advisory Center
can also call 1.888.654.6837. If you’re not currently a Merrill Edge client, please call 1.888.637.3343.

Merrill Lynch, Pierce, Fenner & Smith Incorporated (also referred to as “MLPF&S” or “Merrill”) makes available certain investment
products sponsored, managed, distributed or provided by companies that are affiliates of Bank of America Corporation (“BofA Corp”).
MLPF&S is a registered broker-dealer, registered investment adviser, Member SIPC and a wholly owned subsidiary of BofA Corp.

Investment products:
Are Not FDIC Insured Are Not Bank Guaranteed May Lose Value

Merrill is providing third-party website only as a convenience and the inclusion of the website does not imply any endorsement,
approval, investigation, verification or monitoring by Merrill or any of its affiliates of any content or information contained within or
accessible from the website. Merrill and its affiliates do not control the accuracy, completeness, timeliness or appropriateness of
the content or information on the website. If you choose to visit the website you will be subject to its terms of use and privacy
policies, over which Merrill and its affiliates have no control. In no event will Merrill or any of its affiliates be responsible for any
information or content within the website or your use of the website.

The Chief Investment Office (“CIO”) provides thought leadership on wealth management, investment strategy and global markets;
portfolio management solutions; due diligence; and solutions oversight and data analytics. CIO viewpoints are developed for Bank
of America Private Bank, a division of Bank of America, N.A., (“Bank of America”) and Merrill Lynch, Pierce, Fenner & Smith
Incorporated (“MLPF&S” or “Merrill”), a registered broker-dealer, registered investment adviser and a wholly owned subsidiary of
BofA Corp. This information should not be construed as investment advice and is subject to change. It is provided for informational
purposes only and is not intended to be either a specific offer by Bank of America, Merrill or any affiliate to sell or provide, or a
specific invitation for a consumer to apply for, any particular retail financial product or service that may be available.

© 2024 Bank of America Corporation. All rights reserved.

©
2016 Bank of America Corporation. All rights reserved. 1 ARXXXXXX 351205PM-0417
Mutual Fund Investing at Merrill
Disclosure Statement (Continued)

Introduction through our call center or at certain


When selecting a mutual fund (also referred to bank branches and the services you
herein as a “fund”) that fits your needs, there are receive are limited by our internal
several key factors to consider: policies.

• The fund’s investment strategy • Self-directed- Clients who execute


transactions on a self-directed basis
• The fund’s risk profile
without a relationship with a financial
• The fund’s investment performance
advisor.
• The fund’s relationship to your overall
asset allocation strategy, investment time
horizon and liquidity needs Based on the service model, the same or
similar products, accounts and services may
• The fund’s manager
vary in their price or fees charged to a client.
• The fund’s fees and expenses, which will
reduce investment returns In addition, you may be able to purchase mutual
fund shares, including different share classes,
This pamphlet offers information about fees and directly from the mutual fund family, its distributor,
expenses for the U.S. registered open-end mutual or other financial intermediaries, without paying a
fund share classes available through Merrill, as fee or sales charge to Merrill or for lower fees and
well as the compensation that Merrill and its expenses. Further, some mutual funds have
financial advisors earn with respect to mutual investment strategies that can be substantially
funds. similar to the strategies of other investment
products, such as exchange traded funds and
Merrill, a wholly owned subsidiary of BofA Corp, separately managed accounts. These other
offers a wide range of investment products and investment products can have lower costs and
services, including many different open-end expenses but have different features, eligibility,
mutual funds. Mutual funds available through
and risks than those offered by mutual funds (e.g.,
Merrill include (i) funds that are registered in the
exchangeability, certain discounts and waivers, or
United States and typically only offered for sale to
daily net asset value). You should be aware that a
“U.S. persons” (“domestic” mutual funds) and (ii)
funds that are domiciled outside of the United Merrill financial advisor’s compensation varies
States and typically only available to people or based on the type of investment product;
entities that are not “U.S. persons” under therefore a Merrill financial advisor can receive
Regulation S of the Securities Act of 1933 more or less compensation if you invest in a
(“offshore” mutual funds). This pamphlet only mutual fund over another investment product.
refers to domestic mutual funds. For information
about offshore mutual funds at Merrill, refer to the You should consider and compare any eligible
Offshore Mutual Fund Disclosure at reasonably available alternatives to mutual funds
www.ml.com/funds. in light of your particular investment profile. This
comparison should take into account the potential
Merrill offers its products, accounts and services costs and expenses of the product and any
through different service models, for example: relevant alternatives as well as any tax
considerations. For information, refer to the Guide
• Full-service- Clients who work with a to Pooled Investment Vehicles at Merrill at
financial advisor or financial solutions www.ml.com/funds.
advisor (collectively, “financial advisor”) in
some capacity: A review by, or under the supervision of personnel
of, CIO, referred to as the “CIO Review Process,”
- Merrill Financial Advisor: You work is conducted on each mutual fund that Merrill
with a dedicated financial advisor makes available to its clients. The CIO Review
(“Merrill financial advisor”) and have Process consists of (1) proprietary evaluation
access to a wide range of securities processes conducted by the CIO, and (2)
and other investment products. processes and reviews provided by third parties
that Merrill has engaged for this purpose. The
- Merrill Financial Solutions third-party reviewers apply evaluation processes
Advisor: You decide to work with a that are generally consistent with, but not identical
Merrill financial solutions advisor to, the multi-factor processes that the CIO applies.
©
2016 Bank of America Corporation. All rights reserved. 2 ARXXXXXX 351205PM-0417
Mutual Fund Investing at Merrill
Disclosure Statement (Continued)

Merrill, through the CIO, reviews such third-party 1 fees), as described in their respective
reviewers’ evaluation processes on an ongoing sections below. However, these share classes
basis and believes that such processes are generally are not available to clients purchasing
reasonable and appropriate. Please note that mutual funds in a full-service brokerage
Merrill and the third-party reviewers can differ with account. For information about a particular mutual
respect to their approach to analyzing and rating fund’s share classes, you should review the
particular funds or share classes of funds. fund’s prospectus, including the fee table.
Accordingly, in certain instances, Merrill may
continue to make available to clients funds or It is your responsibility to notify your financial
share classes that have been assigned a negative advisor of any eligible holdings of a specific fund
rating by such third-party reviewers; this is family held by your related accounts, whether at
particularly likely to occur where a third-party Merrill, with the fund family, or another
reviewer’s negative rating is driven solely by intermediary to ensure that the most
reference to the internal expenses associated with advantageous share class is made available to
a particular share class, and not the total cost of you.
ownership of such share class to the client. The
CIO Review Process may not apply to all The Financial Industry Regulatory Authority
investment choices in a Merrill Edge self-directed (“FINRA”) maintains a Mutual Fund Expense
investing account. Analyzer tool on its website at
www.finra.org/fundanalyzer that may help you
For more information on any mutual fund, please
in making a decision about which share class
request a summary prospectus and/or a full is best for you.
prospectus from your financial advisor or Merrill
Edge self-directed investing Investment Center Class A Shares. Class A shares typically impose a
representative and read it carefully. Before front-end sales charge, also known as a “load”,
investing, carefully consider the investment which you pay at the time of purchase. However,
objectives, risks, sales charges and expenses of these funds typically have lower annual operating
the fund. This and other information can be found expenses than Class C shares, so they can be
in the fund’s prospectus. more economical for investors who have an
intermediate to longer-term investment time
U.S. Registered Mutual Fund Share Classes horizon.

In order to accommodate different investing How it works: In general, when buying Class A
shares, a front-end sales charge ranging from
needs, many mutual funds offer more than one
0.00% to 5.75% is deducted from your initial
“class” of shares – generally front-end load
investment at the time of purchase. When you
(typically known as and referred to herein as
purchase Class A shares through a Merrill
“Class A shares”), level-load (typically known
financial advisor, Merrill generally only permits
and referred to herein as “Class C shares”), and
purchases of an amount of Class A shares where
no-load or load-waived shares. Each share class
the sales charge is 3.5% or lower. The amount of
represents an interest in the same mutual fund’s
the sales charge you pay varies based upon
investment portfolio, but with different fees and
factors such as the fund’s particular sales charge
expenses. An investor who holds a more
schedule, whether you are eligible for any
expensive share class of a mutual fund will pay
discounts or waivers and/or the asset class of the
higher fees over time—and earn lower
fund. Based on your investment needs, if you are
investment returns—than an investor who holds
unable to complete the purchase of Class A
a less expensive share class of the same fund.
shares due to the maximum 3.5% sales charge,
At Merrill, certain share classes offered by a
you can choose to invest the same dollar amount
mutual fund are limited to specific service
in Class C shares or purchase an amount of Class
models, or certain types of investors, accounts or
A shares that would bring the sales charge to
programs. For example, certain no-load mutual
3.5% or lower. Most of this front-end sales charge
fund share classes are available only through
is paid to Merrill as a “dealer concession” or “dealer
certain Merrill asset-based fee programs (e.g.,
commission” and a portion of that amount is paid to
institutional or “advisory” shares with no 12b-1
your Merrill financial advisor (see discussion
fees) and Merrill Edge self-directed investing
below). A fund may offer discounts on, or waivers
accounts (e.g., load waived or no-load with 12b-
©
2016 Bank of America Corporation. All rights reserved. 3 ARXXXXXX 351205PM-0417
Mutual Fund Investing at Merrill
Disclosure Statement (Continued)

of, a front-end sales charge depending on the $249,999, and further reduce or eliminate the
terms set forth in the fund’s prospectus and/or front-end sales charge for even larger investments.
statement of additional information, such as rights Mutual fund investors are typically permitted to
of reinstatement, breakpoint discounts and rights aggregate holdings in related accounts (such as
of accumulation, and letters of intent, as described your own or those of certain family members) to
in more detail below. calculate the appropriate breakpoint (called “rights
of accumulation”). Your financial advisor can help
If you purchase shares through certain Merrill you determine whether you are eligible for any
platforms or accounts you may be eligible for breakpoint discounts.
other front-end sale charge waivers as described
in the “Merrill Sales Load Waiver and Discounts” Please refer to the “Merrill Sales Load Waiver and
section below and in the Merrill-specific disclosure Discounts” section below or the Merrill-specific
in the funds’ prospectuses. sales load waiver section of a fund’s prospectus to
obtain fund-specific information on breakpoint
Reinstatement of Class A Shares: Reinstatement discounts. It is your responsibility to notify your
privileges allow investors who have recently sold financial advisor of any eligible holdings of a
shares to purchase new shares of the same share specific fund family held by your related accounts,
class, within the same fund family, generally up to whether at Merrill, with the fund family or another
the dollar amount of the sale proceeds with no intermediary to ensure that the most advantageous
sales charge. At Merrill, shares will be reinstated breakpoint is made available to you.
provided (1) the repurchase is in a mutual fund
within the same fund family; (2) the repurchase Letter of Intent: A Letter of Intent (“LOI”) is a
occurs within 90 calendar days from the written statement that you sign to express your
redemption settlement date, and (3) the intent to invest a specific dollar amount of shares
redemption and purchase occur in the same within a fund family within a specified time period
account. Automated transactions (i.e. systematic (usually 13 months) that if bought all at once,
purchases and withdrawals) and purchases made would entitle you to an applicable breakpoint
after shares are automatically sold to pay Merrill’s discount. Keep in mind that if you do not purchase
account maintenance fees are not eligible for the amount committed to within the specified time
reinstatement. period, a sufficient amount of your fund shares
can be sold to collect the difference between the
Because Class A shares with no sales charge full sales charge stated in the fund’s prospectus
have lower annual 12b-1 and/or service fees than applicable to your actual purchase amount and
Class C shares, if you qualify for reinstatement the reduced sales charge that was originally
privileges for Class A shares, you will not be able charged to you. Merrill only offers an LOI feature
to purchase Class C shares of the same fund with participating fund families that allow LOIs;
family until you use the full reinstatement see “Merrill Sales Load Waiver and Discounts”
privileges for Class A shares to which you are below or the Merrill-specific disclosure in the
entitled. participating fund’s prospectus. A list of
participating fund families can be found at
Merrill's reinstatement privileges apply to shares www.ml.com/funds under “Merrill SLWD
held in Merrill accounts, which can differ from the Supplement”. Contact your financial advisor to
reinstatement privileges available for shares held obtain more information on the Merrill LOI or to
outside of Merrill with the fund family, its request a copy of the Merrill LOI form. Purchases
distributor, or other financial intermediaries made outside of Merrill do not count towards LOIs
established at Merrill.
Breakpoints and Rights of Accumulation: Mutual
funds issuing Class A shares generally offer Breakpoints, rights of accumulation, and LOIs can
discounts, called “breakpoints,” on the front-end help reduce sales charges for investments within
sales charge for larger investments or additional the same fund family. Investors can choose to
investments within the same fund family. For invest across multiple fund families for many
example, a mutual fund might impose a front-end reasons, including potential diversification, as well
sales charge of 3.00% for investments between as having the ability to invest in fund strategies
$50,000 and $99,999 but reduce the charge to that may not be available within the same fund
2.50% for investments between $100,000 and family. It is important to consider that investing
©
2016 Bank of America Corporation. All rights reserved. 4 ARXXXXXX 351205PM-0417
Mutual Fund Investing at Merrill
Disclosure Statement (Continued)

across multiple fund families reduces the typically impose a CDSC, which may be charged to
opportunity to qualify for breakpoint, rights of shareholders who redeem Class B shares within a
accumulation, and LOI discounts or benefits. certain number of years. This charge declines over
time and eventually is eliminated. For example, the
Net Asset Value (“NAV”) Purchases and CDSC typically starts at 5% for shares redeemed
Contingent Deferred Sales Charge (“CDSC”): Also during the first year and is reduced over time until it
keep in mind that mutual funds issuing Class A is eliminated, generally after six years.
shares with a breakpoint that eliminates the front-
end sales charge generally impose a CDSC, which Class B shares are not available for purchase at
is typically between 0.25% and 1.00% of the Merrill. Existing Class B shares may be redeemed or
redemption amount, on purchases meeting that exchanged to purchase shares of the same class of
breakpoint if you redeem (sell) the shares during the another fund within the same fund family. For
first year or longer, with no CDSC thereafter. A additional information about exchanges, refer to the
CDSC reduces the amount of proceeds you section below titled Mutual Fund Family Fund to
receive when you sell all or a portion of your Fund Exchange Privileges and the fund’s
investment. CDSCs are typically paid to the fund’s prospectus.
distributor or other service provider, not to Merrill
or your Merrill financial advisor. CDSCs are typically paid to the fund’s distributor
or other service provider, not to Merrill or your
Merrill financial advisor. Although Class B shares
While a front-end sales charge will not be usually do not impose a front-end sales charge,
imposed, Merrill will typically receive up-front they do include an annual 12b-1 and/or service fee
compensation of between 0.25% and 1.00% of the (typically paid to the fund’s distributor or other
invested amount, paid by the fund’s distributor or service provider) that is equal to a maximum of
other service provider at the time of sale, and a 1.00%, which is higher than the 12b-1 and/or
portion of this amount is paid to your Merrill service fee for the fund’s Class A shares. As with
financial advisor (see discussion below). Class A shares, Merrill is compensated by the
fund’s distributor or other service provider for
Class A shares’ annual operating expenses providing distribution and/or ongoing personal
typically include an annual 12b-1 and/or service shareholder services, typically at an annual rate of
fee that ranges from between 0.00% and 0.50% 0.25% of the net assets of the Class B shares, and
of the net assets of the Class A shares. The 12b- a portion of this amount is paid to your Merrill
1 and/or service fee for most funds offered at Merrill financial advisor (see discussion below). The
typically ranges between 0.20% and 0.30%. This remainder of the Class B 12b-1 and/or service fee
annual 12b-1 and/or service fee is used to (e.g., 0.75%) is typically retained by the fund’s
compensate the fund’s distributor and/or firms like distributor or other service provider. Class B shares
Merrill for distribution and/or ongoing personal often convert to Class A shares after a period of
shareholder services, maintenance of shareholder time (typically 8 to 10 years), which effectively
accounts, and/or related services, if applicable. A lowers the 12b-1 and/or service fee.
portion of this amount is paid to your Merrill
financial advisor. Reinstatement of Class B Shares: When you
redeem Class B shares at Merrill and reinvest the
The dollar amount at which you should consider proceeds of the redemption into a mutual fund in
purchasing Class A shares of a fund can be the same fund family in the same account within 90
evaluated using FINRA’s Mutual Fund Expense calendar days of the redemption settlement date,
Analyzer tool mentioned previously above. The you will be reinstated into Class A shares with no
tool will help analyze the fund’s one-time front-end sales charges, and the newly purchased shares will
sales charge and annual operating expenses not have a CDSC to the extent the redeemed
compared to the sales charges and the annual shares were no longer subject to a CDSC.
operating expenses of other share classes of the Automated transactions (i.e. systematic
same fund. purchases and withdrawals) and purchases made
after shares are automatically sold to pay Merrill’s
Class B Shares. Class B shares, often referred to as account maintenance fees are not eligible for
“back-end load” shares, typically do not impose a reinstatement at Merrill.
front-end sales charge. Class B shares do, however,
©
2016 Bank of America Corporation. All rights reserved. 5 ARXXXXXX 351205PM-0417
Mutual Fund Investing at Merrill
Disclosure Statement (Continued)

Class C Shares. Class C shares typically do not This annual 12b-1 and/or service fee is used to
assess a front-end sales charge when you buy compensate the fund’s distributor and/or firms like
shares. However, they often impose a CDSC and Merrill for distribution and/or ongoing personal
higher annual operating expenses. Class C shares shareholder services, maintenance of shareholder
become less economical compared to Class A accounts, and/or related services, if applicable. A
shares for investors who hold their investments portion of this amount is paid to your Merrill
over a longer term. In some instances, Class C financial advisor.
shares are more economical for investors who
have a short to intermediate investment horizon Mutual funds may offer CDSC waivers in certain
and are not investing a sufficient amount to qualify circumstances. Not all CDSC waivers included in
for a front end sales charge breakpoint. Class C
the fund’s prospectus or statement of additional
shares also may be more appealing to you if you
information are available through Merrill. See
prefer the flexibility to change your investments
“Merrill Sales Load Waiver and Discounts” below
among different fund families periodically, without
paying front-end sales charges or potential or the Merrill-specific disclosure in the
CDSCs, or if you prefer not to pay front-end sales participating fund families fund’s prospectus for a
charges on each transaction. At Merrill, purchases full list of CDSC waivers available through Merrill.
of Class C shares are not permitted if your
aggregate holdings of Class C shares in your The dollar amount at which you should consider
related accounts exceeds the lesser of (1) the purchasing Class C shares of a fund can be
purchase limit on aggregate Class C shares set evaluated using FINRA’s Mutual Fund Expense
forth in the fund’s prospectus or (2) the net asset Analyzer tool mentioned previously above.
value breakpoint for Class A shares (both of which
are typically $250,000, $500,000, or $1 million). For participating fund families, Merrill will
automatically exchange your Class C shares for
Class C shares generally impose the following sales Class A shares (or another eligible share class as
charges: disclosed in the fund’s prospectus) of the same
fund in the month following the 5-year anniversary
• Class C shares typically impose a CDSC of of the purchase date. If a fund family’s prospectus
1.00% of the redemption amount if you sell allows for automatic Class C share conversions
during the first year, with no CDSC (the fund’s terminology for an exchange) sooner
thereafter. CDSCs are typically paid to the than 5 years from the date of purchase, the earlier
fund’s distributor or other service provider, prospectus conversion requirements will apply.
not to Merrill or your Merrill financial Some funds do not have a Class C conversion
advisor. feature. In this case, your Class C shares held at
• Class C shares generally include an Merrill will not be exchanged for Class A shares;
annual 12b-1 and/or service fee that equal please see the specific fund’s prospectus for more
no more than 1.00% of the net assets of information. Some fund families do not participate
the Class C shares. This is higher than in certain discounts, waivers and/or share class
comparable charges or fees for the fund’s exchange rights available at Merrill (“non-
Class A shares. participating fund families”). If you hold shares of
funds from non-participating fund families in your
Merrill typically receives up-front compensation of Merrill account, you are eligible for the Class C
1.00% of the invested amount. This compensation share conversion rights set forth in the fund’s
is paid by the fund’s distributor or other service prospectus, if applicable.
provider at the time of sale, and a portion of this
amount is paid to your Merrill financial advisor (see Reinstatement of Class C Shares: When you
discussion below). The initial compensation paid to redeem Class C shares at Merrill, you can
Merrill in connection with your purchase of Class C reinvest into Class C shares of mutual funds in the
shares is generally lower than that paid on Class A same fund family up to the dollar amount of the
share transactions. However, Merrill typically redemption proceeds without a CDSC period if the
receives a higher annual 12b-1 and/or service fee purchase is (1) in the same account and (2) if the
in connection with your investment in Class C purchase is within 90 calendar days of the
shares, generally between 0.50% to 1.00% of the redemption settlement date. Automated
net assets of the Class C shares. transactions (i.e. systematic purchases and
withdrawals) and purchases made after shares
©
2016 Bank of America Corporation. All rights reserved. 6 ARXXXXXX 351205PM-0417
Mutual Fund Investing at Merrill
Disclosure Statement (Continued)

are automatically sold to pay Merrill’s account intermediaries to be eligible for waivers or
maintenance fees are not eligible for discounts not listed below.
reinstatement at Merrill.
It is the client’s responsibility to notify Merrill at the
Retirement, Institutional, No-Load, Load-Waived time of purchase or sale of any relationship or other
In addition to Class A and C shares, other share facts that qualify the transaction for a waiver or
classes that charge different fees may be discount. A Merrill representative may ask for
available through Merrill. In most instances, only reasonable documentation of such facts and Merrill
certain types of investors, accounts or programs may condition the granting of a waiver or discount
qualify for these other classes. For example, some on the timely receipt of such documentation.
fund companies offer “retirement” shares through
Additional information on waivers and discounts is
Merrill for certain types of retirement plans. These
available in the Merrill “Sales Load Waivers and
retirement shares do not charge an up-front sales
Discounts Supplement” (the “Merrill SLWD
charge or CDSC but may impose a 12b-1 and/or
Supplement") at www.ml.com/funds. Clients are
service fee and administration fees. Some fund
encouraged to review these documents and speak
families offer “institutional” or no-load shares,
with their financial advisor to determine whether a
which do not charge an up-front sales charge,
transaction is eligible for a waiver or discount.
CDSC, or 12b-1 and/or service fee, which typically
are only available in asset based fee programs.
Finally, for Merrill Edge self-directed accounts, If you hold shares of funds from non-participating
no-load or “load-waived” Class A shares do not fund families in your Merrill account, you are
charge an up-front sales charge or CDSC but can eligible for the CDSC waivers and Class C share
impose a 12b-1 and/or service fee or are assessed conversion rights set forth in the fund’s prospectus,
a transaction fee For additional details, see the if applicable. Consult the fund’s prospectus or
“Asset-Based Fee Programs”, Retirement & statement of additional information for information.
Benefit Plan Services Programs, and “Merrill Edge
Self-Directed Investing” sections below. For participating fund families, the following sales
load waivers and discounts will apply to
Mutual Fund Family Fund to Fund Exchange transactions in your Merrill brokerage account:
Privileges: Mutual funds may permit investors to
exchange their shares in one mutual fund into the Front-end Load Discounts
same share class of another fund within the same
fund family without a sales charge. Fund • Breakpoint discounts, as described in the
exchanges are subject to the exchange conditions Merrill SLWD Supplement, where the sales
set forth in the fund’s prospectus and fund and load is at or below the maximum sales load
share class availability at Merrill. Consult the that Merrill permits to be assessed to a
fund’s prospectus and statement of additional front-end load purchase
information to obtain fund-specific information on • Rights of Accumulation (ROA), as
exchange privileges. described in the Merrill SLWD Supplement,
which entitle clients to breakpoint
Merrill Sales Load Waivers and Discounts discounts based on the aggregated
holdings of mutual fund family assets held
Purchases or sales of Class A or Class C mutual
in accounts in their Merrill Household (as
fund shares through a Merrill platform or account
defined in the Merrill SLWD Supplement)1
will be eligible only for the following sales load
• LOIs, which allow for breakpoint discounts
waivers (front-end, contingent deferred, or back-
on eligible new purchases based on
end waivers) and discounts, which differ from those
anticipated future eligible purchases within
disclosed in a fund’s prospectus. Purchasers will
a fund family at Merrill, in accounts within
have to buy mutual fund shares directly from the
your Merrill Household (as defined in the
fund family, its distributor, or other financial
Merrill SLWD Supplement)

1 fee program account (e.g., front-end load, level load and advisory
On or around April 1, 2024, share classes eligible for ROA will
generally be limited to share classes available for purchase for a share classes).
respective fund family in a Merrill brokerage account or asset-based
©
2016 Bank of America Corporation. All rights reserved. 7 ARXXXXXX 351205PM-0417
Mutual Fund Investing at Merrill
Disclosure Statement (Continued)

Front-end Sales Load Waivers CDSC Waivers on Front-end, Back-end,


and Level Load Shares
• Shares of mutual funds available for
purchase by employer-sponsored • Shares sold due to the client’s death or
retirement, deferred compensation, and disability (as defined by Internal Revenue
employee benefit plans (including health Code Section 22E(3))
savings accounts) and trusts used to fund • Shares sold pursuant to a systematic
those plans provided the shares are not withdrawal program subject to Merrill’s
held in a commission-based brokerage maximum systematic withdrawal limits as
account and shares are held for the benefit described in the Merrill SLWD Supplement
of the plan. For purposes of this provision, • Shares sold due to return of excess
employer-sponsored retirement plans do contributions from an IRA account
not include SEP IRAs, Simple IRAs, SAR- • Shares sold as part of a required minimum
SEPs or Keogh plans distribution for IRA and retirement
• Shares purchased through the Merrill Edge accounts due to the investor reaching the
Self-Directed platform qualified age based on applicable IRS
• Shares purchased through the systematic regulation
reinvestment of capital gains distributions • Shares exchanged from back-end load (i.e.
and dividend reinvestment when Class B) shares to front-end load shares of
purchasing shares of the same mutual the same mutual fund
fund in the same account • Front-end or level-load shares held in
• Shares exchanged from level-load shares commission-based, non-taxable retirement
to front-end load shares of the same brokerage accounts (e.g. traditional, Roth,
mutual fund in accordance with the rollover, SEP IRAs, Simple IRAs, SAR-
description in the Merrill SLWD SEPs or Keogh plans) that are transferred
Supplement2 to fee-based accounts or platforms and
• Shares purchased by eligible employees of exchanged for a lower cost share class of
Merrill or its affiliates and their family the same mutual fund
members who purchase shares in
accounts within the employee’s Merrill Asset-Based Fee Programs
Household (as defined in the Merrill SLWD You can purchase mutual funds through various
Supplement) asset-based fee programs available at Merrill,
• Shares purchased by eligible persons including discretionary and non-discretionary
associated with the fund as defined in the programs. In these programs, you pay Merrill an
fund’s prospectus (e.g. the fund’s officers annual fee based on a percentage of the value of
or trustees) the assets held in your Merrill account associated
• Shares purchased from the proceeds of a with these programs.
mutual fund redemption in front-end load
shares provided (1) the repurchase is in a These asset-based fee programs allow you to
mutual fund within the same fund family; purchase institutional shares, “no-load” shares, or
(2) the repurchase occurs within 90 another share class without a front-end sales
calendar days from the redemption trade charge or CDSC (“Advisory Share Classes”) that
date, and (3) the redemption and purchase are not available for purchase in a Merrill
occur in the same account (known as brokerage account that offers mutual funds that
rights of reinstatement or reinstatement have sales charges or transaction fees. The total
privileges). Automated transactions (i.e. cost of purchasing and holding mutual fund
systematic purchases and withdrawals) shares through an asset-based fee program may
and purchases made after shares are be more or less than investing in mutual fund
automatically sold to pay Merrill’s account shares in a Merrill brokerage account that is
maintenance fees are not eligible for rights serviced by your financial advisor, or through a
of reinstatement Merrill Edge self-directed investing account,

2Level-load shares held in employer-sponsored retirement, deferred accounts) accounts will not be exchanged for front-end load shares.
compensation, and employee benefit plan (including health savings Contact your financial advisor to confirm your account’s eligibility.
©
2016 Bank of America Corporation. All rights reserved. 8 ARXXXXXX 351205PM-0417
Mutual Fund Investing at Merrill
Disclosure Statement (Continued)

depending on various factors including but not higher expenses over funds, including proprietary
limited to, the amount of the asset-based fee, the funds, with lower expenses and creates a conflict
amount and frequency of mutual fund purchases, of interest relating to the third-party manager’s
the amounts of assets within the same fund selection of funds. You should ask your Merrill
family, the anticipated holding period, and the financial advisor for more information about these
specific mutual fund shares in which you invest. cost differences and whether an asset-based fee
For example, purchasing and holding Class A program might be right for you.
shares of a mutual fund in a Merrill brokerage
account, with a front-end sales charge eliminated In the event your advisory agreement governing
due to breakpoints and rights of accumulation, will your asset-based fee program account is
have a lower total cost than purchasing and terminated and you transition your holdings to a
holding an Advisory Share Class in an asset- Merrill brokerage account, or you transfer
based fee program. Conversely, purchasing and Advisory Share Class holdings from an asset-
redeeming Class A shares, within a short based fee program account to a Merrill brokerage
timeframe, in a Merrill brokerage account with a account, Merrill will exchange the positions from
smaller investment amount and a maximum front- Advisory Share Classes to brokerage share
end sales charge will likely have a higher total classes after you transition to a brokerage
account, if available. Brokerage share classes
cost than purchasing and redeeming an Advisory
have different expenses than Advisory Share
Share Class, within the same timeframe, in an
Classes (including 12b-1 and/or service
asset-based fee program.
fees). While the exchange transaction will not be a
taxable event and will not be subject to sales
Advisory Share Classes are not available for loads, all future purchase transactions in the fund
purchase in a Merrill brokerage account. Fund
will be subject to sales loads and fees as detailed
share classes available for brokerage accounts
in the fund’s prospectus. Not all exchanged funds
generally have higher operating expenses than
will be available for subsequent purchases in a
Advisory Share Classes and will charge sales
brokerage account. Please note that this
loads and 12b-1 and/or service fees, which are exchange provision will not apply to Advisory
used to compensate Merrill and your Merrill Share Classes that are purchased in asset-based
financial advisor. This creates a conflict of interest
fee program retirement plan accounts or trust
because it provides an incentive for your Merrill
managed accounts that are transitioned to a
financial advisor to advise or recommend that you
Merrill brokerage account even if the asset-based
terminate your asset-based fee program account fee program account is terminated.
and open a brokerage account or move individual
positions to a brokerage account if the sales loads
Retirement & Benefit Plan Services Program
and 12b-1 and/or service fees are higher than the
program fee. Conversely, Merrill financial advisors You can purchase mutual funds through various
could have an incentive to recommend purchasing retirement or benefit plans and custodial accounts
mutual funds in an asset-based fee program for certain individually held retirement plans or
account because they earn ongoing arrangements available at Merrill. For these
compensation based on the program fee, which is programs, the share class availability may be
used to compensate Merrill and your Merrill determined by the plan sponsor, the size or
financial advisor and can be higher than the sales nature of the plan, or other factors. Terms and
load and 12b-1 and/or service fees that they are pricing (including discounts, waivers, exchanges
compensated on in a brokerage account. and conversions) for mutual funds offered
through retirement plans can differ from other
In addition, certain model portfolios, only available programs. In addition, the compensation paid to
in Merrill's asset-based fee program, invest your Merrill or to the Merrill financial advisor differs
assets in funds. Clients enrolled in these models from what is described in the sections below. For
indirectly incur the funds’ expenses. If the model more information, including information on fees
portfolio is managed by a third-party investment and compensation, please contact your Merrill
manager that invests in funds that are proprietary financial advisor or the retirement or benefit plan’s
to that manager, the manager receives a portion sponsor or refer to the fund’s prospectus and
of the proprietary funds’ expenses directly from statement of additional information. For purposes
the funds as compensation. This provides an of this section plans do not include SEP IRAs,
incentive for the third-party manager to select Simple IRAs, SAR-SEPs or Keogh plans.
proprietary funds for the model portfolio with
©
2016 Bank of America Corporation. All rights reserved. 9 ARXXXXXX 351205PM-0417
Mutual Fund Investing at Merrill
Disclosure Statement (Continued)

Merrill Edge® Self-Directed Investing Compensation of Merrill, Merrill Financial


Advisors and Their Managers
Mutual funds are available through a Merrill
Edge self-directed investing account and are Merrill and Merrill financial advisors’
subject to service, transaction, short-term compensation varies depending on the fund
redemption, and other fees, which are sponsor, fund product or share class, and the
described on the Merrill Edge website at availability of discounts such as breakpoints. It
www.merrilledge.com/pricing. Merrill Edge self- also depends on whether mutual fund shares are
directed investing is designed for U.S. - based purchased through a Merrill brokerage
investors who wish to make their own investment account, an account enrolled in an asset-
choices in a Merrill Edge self-directed investing based fee program, or a self-directed investing
account. In addition to access to certain no-load or account. The fund share-class specific
load-waived Class A shares, you may be able to compensation and asset-based fee program
purchase a less expensive share class of a fund compensation (described above) are the basis
through a Merrill Edge self-directed investing upon which Merrill financial advisors are paid. For
account than through your financial advisor. brokerage accounts, the portion of Merrill’s
These share classes are not available to clients compensation that is paid to its Merrill financial
purchasing shares in a full-service brokerage advisors is calculated by the same formula
account. regardless of which funds are purchased.
However, some share classes of a fund carry
The funds and share classes available through a higher front-end sales charges, 12b-1 and/or
Merrill Edge self-directed investing account, and service fees than others (e.g., Class A shares
the related fees, may vary and may change from may have higher front-end sales charges and
time to time. You should consult the Merrill Edge therefore pay higher up-front compensation than
website to determine which specific funds and Class C shares). In addition, some funds may set
share classes are available at any given time. You higher front-end sales charges and/or 12b-1
may be able to purchase these funds or share and/or service fees than other funds.
classes directly from the fund family, its As a result of these differences, Merrill and/or a
distributor, or other financial intermediaries Merrill financial advisor may receive more or less
without paying a fee to Merrill, or for lower fees or compensation depending on the share class or
expenses than if you purchase through a Merrill fund you purchase. This creates a conflict of
Edge self-directed investing account. If you have interest because the different compensation
any questions, please contact an Investment provides Merrill and/or Merrill financial advisors
Center representative. with an incentive to recommend share classes or
funds that pay more compensation over those that
Generally, fund sponsors that make share classes pay less. In addition, the compensation Merrill
of their funds available through Merrill Edge self- and/or Merrill financial advisors receive when a
directed investing accounts on a no-load or load- client is eligible for a breakpoint discount is
waived basis pay a fee to Merrill of between typically lower than the compensation received for
0.10% and 0.40% annually of the value of shares a purchase that is not eligible for a breakpoint
held through Merrill Edge (some mutual funds pay discount. Further, breakpoint schedules vary from
Merrill both a “per account” fee and a percentage fund to fund. As a result, Merrill and/or Merrill
fee of less than 0.40%. The aggregate of these financial advisors have an incentive to
fees may exceed 0.40% in certain cases). This recommend the purchase of an amount of a
fee compensates Merrill for development, mutual fund that will not provide the client with the
operation and maintenance of the Merrill Edge benefit of a breakpoint.
service, the servicing of Merrill Edge self-directed
investing accounts that purchase shares of these To address the conflict of interest related to the
mutual funds, and the sub-accounting and related variable nature of how Merrill financial advisors
services described below. Investment Center are compensated for the sale of Class A shares,
representatives do not make recommendations Merrill has a policy that pays Merrill financial
or receive compensation on the sale of mutual advisors a standardized, level commission for
funds. the sale of Class A shares depending on the
fund’s asset class (e.g., equity, fixed income or
other asset class, such as an asset allocation
©
2016 Bank of America Corporation. All rights reserved. 10 ARXXXXXX 351205PM-0417
Mutual Fund Investing at Merrill
Disclosure Statement (Continued)

fund) and the amount of the Class A shares financial advisors and managers are
purchased. This eliminates the conflict of interest compensated in a variety of ways, including the
for Merrill financial advisors to choose a Class A disclosure of the conflicts in this pamphlet.
share of a fund in a particular asset class that Moreover, Merrill financial advisors are required
pays a higher commission than a Class A share to recommend or select mutual funds in
of another fund in that asset class. Under the accordance with the applicable standard of care.
policy, Merrill receives the sales charges
disclosed in the fund’s prospectus. Therefore, to In addition, Merrill has established a variety of
the extent the sales charges collected from the policies, procedures, restrictions and disclosures
sales of mutual fund Class A shares exceeds the designed to address and to monitor for these
commissions paid to Merrill financial advisors, potential conflicts of interest, both those arising
Merrill will retain the difference. between and among accounts as well as
between accounts and Merrill’s business.
Merrill also sets a limit as to the maximum Further, Merrill selects mutual funds that are
portion of front-end sales charge and 12b-1 available on the CIO Review Process.
and/or service fee included in the Merrill financial
advisors’ compensation formula based on the Additional information on compensation and
conflicts of interest is available in the Regulation
share class and size of investment. All mutual
Best Interest Disclosure Statement.
funds available at Merrill are subject to this policy.
When a fund has a front-end sales charge and
Compensation of Merrill Financial Solutions
12b-1 and/or service fee that exceeds the policy Advisors
limit, Merrill retains the difference, and it is not
paid as compensation to the Merrill financial Merrill compensates Merrill financial solutions
advisor. For brokerage accounts, Merrill only advisors differently than Merrill financial advisors.
offers and recommends mutual funds that pay Merrill Financial solutions advisors are not
12b-1 fees. As a result, Merrill has a conflict of compensated based on mutual fund purchases.
interest in selecting certain funds and share Instead, Merrill financial solutions advisors receive
classes for inclusion as part of its product offering a salary and incentive compensation based on the
available to you over others. Therefore, you assets included in an account and on assets that
should not assume that you will be invested in the are enrolled in accounts that are opened and
share class with the lowest possible fees and funded as a result of these advisors’ efforts.
expenses that the fund sponsor makes available Additional information on compensations and
to the investing public. conflicts of interest is available in the Regulation
Best Interest Disclosure Statement.
From time to time, Merrill may recognize certain
Merrill financial advisors through promotional Fund Families’ Cost Sharing for Training
programs that factor in, among other criteria, Events and Other Meetings & Gifts, Meals and
overall sales of mutual funds. These programs Entertainment
may reward Merrill financial advisors with
Fund family representatives periodically
compensation, including attendance at off-site
participate in Merrill-hosted internal training and
locations and/or various employee training
education conferences for invited Merrill financial
sessions that may be sponsored or co-sponsored
advisors and Merrill-hosted client and prospect
by fund companies whose funds Merrill makes events, like seminars, trade shows and booth
available. events and share in the costs of such events.
In addition, fund families periodically host
Merrill financial advisors’ managers are
educational meetings for Merrill financial advisors
compensated differently than the Merrill financial (Manager Meetings) where Merrill financial
advisors, reflecting their different responsibilities advisors are provided with information on
and accountabilities. However, the portion of total products and services and the opportunity to
compensation earned by Merrill with respect to interact with investment and sales personnel.
mutual fund sales that is paid to managers is Fund families are permitted to pay for eligible
calculated pursuant to the same formula for all costs associated with such meetings, including
funds. the financial advisors cost of travel and
accommodation and continuing education fees.
Merrill addresses conflicts related to how Merrill
©
2016 Bank of America Corporation. All rights reserved. 11 ARXXXXXX 351205PM-0417
Mutual Fund Investing at Merrill
Disclosure Statement (Continued)

Furthermore, fund family representatives are fees paid by the mutual fund or by its adviser,
permitted to provide gifts, meals and principal underwriter or another agent on its
entertainment subject to the limits established behalf. Merrill does not retain compensation for
under Merrill’s internal policies and also can annual 12b-1 and/or service fee or for sub-
provide monetary support directly to charities for accounting services for mutual funds held in
charitable events that our employees attend or retirement accounts in asset-based fee programs.
can contribute, from time to time, to charitable
events and causes that Merrill supports. Depending on the specific arrangements, as
The participation of, and payment of costs by, a compensation for these sub-accounting services,
fund family for conferences, client events, and Merrill receives from all the fund families with
Manager Meetings, and the provision of gifts, share classes that charge sales loads either
entertainment and charitable sponsorships or typically between $16 annually for each position
donations present conflicts of interest. They or 0.10% annually of the value of fund shares held
create incentives for Merrill financial advisors to in a client’s account at Merrill, depending on the
recommend products of participating third-party fund company’s election. In the case of the no-
firms. Additional information on these conflicts of load fund shares, the sub-accounting,
interest is available in the Regulation Best Interest administrative services, distribution and marketing
Disclosure Statement. services and support fees payable by no-load
fund companies are typically bundled into one
Additional Merrill Services and Compensation asset-based fee typically between 0.10% to
0.35% (which may include up to a 0.25% 12b-1
and/or service fee) annually of the value of shares
In addition to receiving dealer concessions and held in a client’s account at Merrill.
12b-1 and/or service fees in connection with
clients’ purchasing and holding mutual fund Sub-accounting service arrangements and the
shares, Merrill provides other services for which it amount of the compensation paid to Merrill varies
may receive additional compensation from funds by fund and by share class. Merrill receives the
or their affiliates. This compensation is often but agreed-upon sub-accounting fee for providing
not always disclosed in detail in a fund’s these sub-accounting services and this cost is
prospectus, summary prospectus, statement of either borne by the mutual fund (like other mutual
additional information or website. fund expenses) as part of its operating costs or by
its adviser, principal underwriter or other agent.
Merrill only makes available to its clients shares of
those mutual funds whose affiliates have entered Merrill only offers funds and fund share classes
into contractual arrangements with Merrill that that pay Merrill for sub-accounting related
generally include the payment of one or more of the services. A fund may offer a share class that does
fees described below. The following fees do not not include a fee for these services. Accordingly,
purchase placement on any preferred lists or any you should not assume that you will be invested in
special positioning or coverage of certain funds by the share class with the lowest possible fees and
Merrill. These fees are used to cover the types of expenses that the fund sponsor makes available
services outlined below and are not passed on to to the investing public. It is generally in your best
Merrill financial advisors or their managers as interest to purchase lower fee share classes
compensation. because your returns are not reduced in whole or
part by additional fees and expenses. In addition,
Sub-Accounting Related Services. Merrill provides funds that would otherwise meet Merrill’s criteria
various sub-accounting services (as defined for inclusion on its product platform but whose
below) and other related administrative services principal underwriters, agents or sponsors do not
with respect to each mutual fund position held in agree to pay such fees will not be available for
an account at Merrill. These services include, for purchase in your account at Merrill, thereby
example, aggregating and processing purchases, limiting the available universe of mutual funds and
redemptions, exchanges, dividend distribution and share classes available to you.
reinvestment, consolidated account statements,
tax reporting, and other recordkeeping and You should be aware that the amount of sub-
reporting services (“sub-accounting services”). For accounting fees paid by the different funds varies
these services, Merrill receives sub-accounting among funds and, in certain instances, between
©
2016 Bank of America Corporation. All rights reserved. 12 ARXXXXXX 351205PM-0417
Mutual Fund Investing at Merrill
Disclosure Statement (Continued)

share classes of individual funds. Therefore, In addition to the front-end and 12b-1 and/or service
Merrill receives more sub-accounting fees from fees discussed in the “U.S. Registered Mutual Fund
some funds than it receives from others. This Share Classes” section, Merrill receives
results in a conflict of interest because it creates compensation for purchases made through
an incentive for Merrill to recommend that you brokerage accounts from fund sponsors for its
invest in mutual funds and/or share classes that distribution, marketing services and support
pay higher fees. generally ranging from 0.035% to 0.25% on a
portion of mutual fund purchases and from 0.035%
Merrill addresses conflicts related to sub-accounting to 0.10% annually on a portion of mutual fund
fees for the services described in this section in a assets. Merrill typically receives 0.25% on a portion
variety of ways, including the disclosure of the of mutual fund purchases and 0.10% annually on a
conflicts in this pamphlet. In addition, Merrill selects portion of mutual fund assets from most fund
mutual funds that are available on its platforms sponsors. Unlike 12b-1 and/or service fees,
based on qualitative and quantitative evaluation of marketing services and support fees are not
such factors as performance, risk management generally paid from the fund’s assets and are
policies and procedures and on the consistency of typically paid from the profits of the fund’s
the execution of their strategy. Merrill also has investment advisor, distributor or other fund
adopted various policies and procedures affiliate. The amount of compensation Merrill
reasonably designed to prevent the receipt of sub- receives from funds for marketing services and
accounting fees from affecting the nature of the support can exceed the cost of the services provided
advice or recommendations provided to clients by in any given year. Merrill does not receive or retain
Merrill financial advisors, although such policies these marketing service and support fees with
and procedures do not eliminate such conflicts of respect to the underlying investment options that
interest. Merrill financial advisors do not have an serve as funding vehicles for variable insurance and
incentive to recommend or select certain funds or variable annuity products and for Merrill retirement
share classes that pay sub-accounting fees or benefit plan clients or for asset-based fee
because Merrill financial advisors do not receive programs but does receive fees from sub-
additional compensation as a result of these types accounting services (except as described below).
of payments.
In brokerage accounts, Merrill only offers funds
Marketing Services and Support. For certain from fund families that pay Merrill marketing
brokerage accounts, Merrill provides a variety of services and support fees. Further, mutual funds
distribution, marketing services and support to that would otherwise meet Merrill’s criteria for
sponsors of mutual funds that are available inclusion on its product platform but whose
through Merrill. These services include, but are principal underwriters, agents or sponsors do not
not limited to the provision of: a mutual fund agree to pay such marketing services and support
specialist support desk for financial advisors or fees will not be available for purchase in your
Investment Center representatives to answer brokerage account at Merrill, thereby limiting the
questions regarding their funds; work stations that available universe of mutual funds available to
you. You should be aware that the amount of
include information, announcements, data, and
marketing services and support fees paid by the
tools relating to their funds; ongoing review and
different mutual fund families varies, therefore
implementation of features and restrictions
Merrill receives more fees from some fund
imposed by their funds; strategic planning support families than it receives from others. This results
that is intended to assist fund sponsors with in a conflict of interest because it creates an
strategies that are aligned with Merrill’s incentive for Merrill to recommend that you invest
investment themes and goals; making Merrill in mutual funds from fund families that pay higher
financial advisors or other employees available for marketing services and support fees.
education regarding their funds; sales related
reports and other information; and branch office Merrill addresses conflicts related to marketing
support, including phones, computers, conference services and support fees for the services
rooms, as well as facilities and personnel support described in this section in a variety of ways,
for prospectuses, summary prospectuses, and including the disclosure of the conflicts in this
promotional and other materials relating to their pamphlet. In addition, Merrill selects mutual funds
funds. that are available on its brokerage platforms
based on qualitative and quantitative evaluation of
©
2016 Bank of America Corporation. All rights reserved. 13 ARXXXXXX 351205PM-0417
Mutual Fund Investing at Merrill
Disclosure Statement (Continued)

such factors as performance, risk management ability to exchange into a different fund family’s
policies and procedures and on the consistency of Exchange-Only Money Fund, you will need to
the execution of their strategy. Merrill has also open an account, outside of your relationship with
adopted various policies and procedures Merrill, directly with that fund family’s transfer
reasonably designed to prevent the receipt of agent or other service provider. For purposes of
marketing services and support fees from this pamphlet, Exchange-Only Money Funds are
affecting the nature of the advice or made available on the same terms as mutual
recommendations provided to clients by Merrill funds described in the preceding sections in
financial advisors, although such policies and respect to available share classes, fees and
procedures do not eliminate such conflicts of expenses, and compensation to Merrill.
interest. Merrill financial advisors do not have an
incentive to recommend certain funds or share
Similar to the information provided in the “U.S.
classes that pay marketing services and support
Registered Mutual Fund Share Classes” section
fees because Merrill financial advisors do not
receive additional compensation as a result of above, the Money Funds available at Merrill may
these types of payments. offer more than one “class” of shares. Each share
class represents an interest in the same investment
portfolio but may have or be subject to different
A list of mutual fund families that paid Merrill
$100,000 or more in marketing support payments fees and expenses. The availability and eligibility
and the range of marketing services and support requirements of share classes offered by a Money
payments received as of the prior calendar year is Fund are typically outlined in the prospectus and
available at www.ml.com/funds under “Marketing statement of additional information of the fund and
Support Disclosure”. may vary from class to class.

Certain Retirement/Benefit Program Administration For brokerage accounts, the Money Funds
Fees. Merrill receives fees from fund sponsors available at Merrill are not subject to front-end
whose funds are made available to Merrill sales charges, but they can include an annual 12b-
retirement or benefit plan clients. These fees 1 and/or service fee or administrative service fee
compensate Merrill for providing sub-accounting ranging from 0.00% to 0.50%. However, the Money
services and/or administrative services to the Funds available for purchase in your Merrill
retirement or benefit plan’s sponsor, in connection brokerage account typically do not include these
with these funds. For more information, including fees. Money Funds available to certain brokerage
information on fees and compensation, please and asset-based fee accounts as an automatic
contact the retirement or benefit plan’s sponsor or cash sweep option typically include a 0.40%
refer to the fund’s prospectus and statement of administrative service fee. Fund families may offer
additional information, which you may request from a share class of the Money Fund that does not
the fund. include these annual 12b-1 and/or service fee or
administrative service fees. In addition, you may
Money Market Mutual Funds be able to purchase other share classes that have
lower fees and expenses directly from the fund
Merrill makes available money market mutual company or its distributor, or through other
funds (“Money Funds”) for purchase in a Merrill financial intermediaries. It is generally in your best
account. The Money Funds available for purchase interest to purchase lower fee share classes
in a Merrill account typically require a client to because your returns are not reduced in whole or
place a purchase or redemption order in order to part by additional fees and expenses.
transact in the fund. A limited number of Money
Funds are made available to certain accounts as Assets held in the Money Funds are also
an automatic cash sweep option as described financially beneficial to Merrill. Merrill provides
within the specific account agreement. distribution and marketing services and support
(see Marketing Services and Support section
Merrill also makes available a limited number of above) with respect to the Money Funds. In
money market mutual funds to give clients the consideration of the provision of marketing
ability to exchange assets from mutual funds services and support, Merrill receives
within the same fund family (“Exchange-Only compensation between 0.045% and 0.10%
Money Funds,” and together with Money Funds, annually of the value of Money Fund shares held
“Money Market Funds”). If you would like the in Merrill accounts, but typically receives between
©
2016 Bank of America Corporation. All rights reserved. 14 ARXXXXXX 351205PM-0417
Mutual Fund Investing at Merrill
Disclosure Statement (Continued)

0.09% and 0.10% from fund sponsors. Merrill incentive to recommend or select certain funds or
does not receive these marketing services and share classes that pay these fees because Merrill
support fees in asset-based fee programs. financial advisors do not receive additional
compensation as a result of these types of
payments.
In addition, Merrill provides various sub-
accounting and other related administrative Certain Retirement/Benefit Program Administration
services with respect to each Money Fund Fees. Merrill receives fees from fund sponsors
position held in an account at Merrill (see Sub- whose Money Funds are made available to Merrill
Accounting Related Services section above). As retirement or benefit plan clients. These fees
compensation for these services, Merrill receives compensate Merrill for providing sub-accounting
up to 0.005% annually of the value of money fund services and/or administrative services to the
retirement or benefit plan’s sponsor, in connection
shares held in a client’s account at Merrill. Merrill
with these funds. For more information, including
does not retain compensation for annual 12b-1
information on fees and compensation, please
and/or service fee or administrative service fees
contact the retirement or benefit plan’s sponsor, or
or for sub-accounting services for Money Funds refer to the fund’s prospectus and statement of
held in retirement accounts in asset-based fee additional information, which you may request from
programs. the fund.

In brokerage accounts, Merrill only offers Money For brokerage accounts, Merrill financial advisors
Funds from fund families that pay marketing are compensated at a rate based on their clients’
services and support fees and, for all accounts, total assets invested in the Money Funds held in
sub-accounting fees. Therefore, Money Funds Merrill accounts. For asset-based fee accounts,
that would otherwise meet Merrill’s criteria for Merrill financial advisors receive an annual fee
inclusion on its product platform but whose based on a percentage of the value of the total
principal underwriters, agents or sponsors do not assets held in your account associated with these
agree to pay such fees will not be available for programs.
purchase in your brokerage and/or asset-based
account at Merrill, thereby limiting the available
universe of funds available to you. You should be Money Fund transactions receive the price next
calculated following receipt of the order by a fund.
aware that the amount of marketing services and
However, effective October 11, 2016, certain
support fees and sub-accounting fees paid by the
Money Funds transitioned from calculating their
different fund families varies, therefore Merrill
prices per share at the end of the day to pricing
receives more fees from some fund families than
their shares multiple times a day. Merrill submits
it receives from others. This results in a conflict of
orders to funds only once at the end of the day.
interest because it creates an incentive for Merrill
Therefore, Merrill customer transactions will
to recommend or select funds from fund families
continue to receive the end of the day price. If the
that pay higher fees.
value of a fund’s shares decreases over the
course of the day, you may receive a lower price
Merrill addresses conflicts related to marketing
per share if you place an order through your
services and support and sub-accounting fees in a
variety of ways, including the disclosure of the Merrill account than if you placed an order directly
conflicts in this pamphlet. In addition, Merrill selects with the fund. If you would like the flexibility of
funds that are available on its platforms based on multiple pricing times, you will have to transfer
qualitative and quantitative evaluation of such your position to the fund’s transfer agent. For
factors as performance, risk management policies more information, please speak with your financial
and procedures and on the consistency of the advisor or an Investment Center representative.
execution of their strategy. Merrill has also
adopted various policies and procedures You could lose money by investing in a Money
reasonably designed to prevent the receipt of Market Fund. There are different types of Money
marketing services and support and sub- Market Funds. For certain Money Market Funds,
accounting fees from affecting the nature of the the share price of the fund will fluctuate and,
advice or recommendations provided to clients by therefore, when you sell your shares of such a
Merrill financial advisors, although such policies fund, they may be worth more or less than what
and procedures do not eliminate such conflicts of you originally paid for them (fluctuating Money
interest. Merrill financial advisors do not have an
©
2016 Bank of America Corporation. All rights reserved. 15 ARXXXXXX 351205PM-0417
Mutual Fund Investing at Merrill
Disclosure Statement (Continued)

Market Funds). While other Money Market Funds reasons, including situations where the other
seek to preserve the value of your investment at financial intermediary does not have appropriate
$1.00 per share (stable value Money Market agreements with those funds. The same may be
Funds), they cannot guarantee that they will do so. true if you hold your mutual fund shares at another
Money Market Funds generally may impose a financial intermediary and attempt to transfer those
discretionary liquidity fee of up to 2% of the value of shares to your Merrill account. In these instances
the shares redeemed if the Money Market Fund you will need to determine what you would like to
board determines that such fee is in the best do with the fund shares: (i) liquidate them (which
interests of the fund. In addition, certain Money may result in redemption or other fees, sales
Market Funds are required to impose a mandatory charges or a taxable event), (ii) transfer them from
liquidity fee on redeeming shareholders when daily the financial intermediary to the fund (or its transfer
net redemptions exceed 5% of net assets, unless agent), (iii) request share certificates to be issued
liquidity costs are de minimis. A liquidity fee to you (typically not available for mutual fund
imposed by the Money Market Fund will reduce the shares), or (iv) retain them at the financial
amount you will receive upon the redemption of intermediary through which you currently hold
your shares and will decrease the amount of any them. Some funds may offer waivers of redemption
capital gain or increase the amount of any capital or other fees in certain circumstances. Please refer
loss you will recognize from such redemption. An to the applicable fund prospectus or contact your
investment in any Money Market Fund is not financial advisor or an Investment Center
insured or guaranteed by Bank of America, N.A., representative for further information. It is your
Merrill or any bank affiliate of Merrill, the Federal responsibility to notify your financial advisor or an
Deposit Insurance Corporation or any other Investment Center representative if any
government agency. A Money Market Funds’ redemption or other fee waivers are available to
sponsor has no legal obligation to provide financial you.
support to the Money Market Funds, and you
should not expect that the sponsor will provide
financial support to the Money Market Fund at any Provision of Diversified Financial Services by
time, including during periods of market stress. Merrill and its Affiliates

Purchases, Sales and Transfers BofA Corp. is a diversified financial services


company that generally provides, through Merrill and
Merrill maintains policies prohibiting late trading in, its affiliates, a wide range of services to retail and
and the excessive trading of, mutual fund shares. institutional clients for which it receives
Merrill’s excessive trading policies may not be compensation. As a result, Merrill, BofA Corp. and its
consistent with fund companies’ excessive trading affiliates can be expected to pursue additional
policies and is in addition to any monitoring for business opportunities with the entities whose
excessive trading conducted by the fund investments Merrill and its financial advisors
companies. Merrill personnel may not open recommend to you. More detailed information on
accounts or enter client transactions for the these services is available in the Regulation Best
purpose of late trading, excessive trading or market Interest Disclosure Statement.
timing, nor may they facilitate late trading,
excessive trading or market timing in accounts at
Information about a particular mutual fund’s policies
the funds’ transfer agents or assist clients in regarding selection of brokers may be found in the
making other arrangements to late trade, fund’s statement of additional information, which
excessively trade or market time mutual funds. The you may request from the fund. For additional
Merrill Edge self-directed investing account also information on mutual funds in general, you can
may not be used for any of the above-described visit educational websites of the Securities and
purposes. There is no guarantee that all instances Exchange Commission (www.sec.gov ), FINRA
of excessive trading will be prevented. (www.finra.org ), the Securities Industry and
Financial Markets Association (www.sifma.org),
In certain cases, the funds you hold through and the Investment Company Institute
Merrill may not be transferable to another financial (www.ici.org).
intermediary. This may occur for a number of

©
2016 Bank of America Corporation. All rights reserved. 16 ARXXXXXX 351205PM-0417
© 2024 Bank of America Corporation. All rights reserved.
The Merrill Edge Self­Directed Investing Client Relationship Agreement and Merrill Edge Self­Directed Investing Terms of Service are the general agreements
governing the Merrill Edge Self­Directed Investing services available to you. You are also subject to additional agreements and disclosures that cover other products,
services or account features for which you may be enrolled, including cash management, margin and retirement accounts and services like bill payment.

You will also be subject to additional agreements and disclosures we may send you from time to time. If a provision in any additional agreement conflicts or is
inconsistent with the Merrill Edge Self­Directed Investing Client Relationship Agreement and Merrill Edge Self­Directed Investing Terms of Service, the provisions of
the additional agreement will control for matters and services covered by that additional agreement.

The following contains: (A) your consent to 1) the Merrill Edge Self­Directed Investing Client Relationship Agreement; 2) the Merrill Edge Self­Directed Investing
Terms of Service; and 3) the agreement(s) applicable to the type of account(s) you are applying for, such as, by way of example, the CMA Financial Service Cash
Management Account Disclosures and Account Agreement or Traditional IRA Disclosure and Custodial Agreement; and (B) your acknowledgement that you have
received and reviewed the documents provided below in the section labeled, "Important Documents About Your Relationship with Merrill," such as the Bank of
America Privacy Policy for U.S. Consumers and the Affiliate Marketing Notice. Your consent to the Electronic Communications Disclosure allows us to provide you
with documents electronically. Please carefully review these documents. You can also request printed copies for your records or download and save the documents.

Your Agreements with Merrill

Merrill Edge Self Directed Investing Client Relationship Agreement (PDF)


Traditional IRA — Disclosure and Custodial Agreement (PDF)
Merrill Edge Self Directed Terms of Service (PDF)

Important Documents About Your Relationship with Merrill

US Consumer Privacy Notice (PDF)


Online Privacy Notice (PDF)
Affiliate Marketing Notice (PDF)
Business Continuity
Mutual Fund Disclosure Document (PDF)

By signing below, you represent, acknowledge, and/or agree to: (please scroll down to the end)

1. You agree to arbitrate all controversies that may arise between you and us in accordance with Section 12, page 5 of the Merrill Edge Self Directed Investing
Client Relationship Agreement provided above in the section labeled "Your Agreements with Merrill."
2. You are the person(s) named in the "Personal Information" section(s) of this application, you acknowledge that you are of legal age under the laws of your place
of residence, and have reviewed all information contained in this application whether prefilled systematically, by a representative, or entered by you and you
confirm that all the information is accurate;
3. You agree to receive electronic delivery of all documents related to your accounts (in accordance with Section 3 of the Merrill Edge Self­Directed Investing
Terms of Service);
4. You have received and reviewed the documents provided above in the section labeled, "Important Documents About Your Relationship with Merrill";
5. You have received, reviewed, and agreed to the terms of the agreements provided above in the section labeled, "Your Agreements with Merrill," and you intend
to be legally bound by them;
6. Any devices you are using for this application and will use to review subsequent electronic communications meet the Hardware and Software Requirements, as
described in the eCommunications Disclosure;
7. You authorize Merrill Lynch and its affiliates to request a consumer report or credit report about you from one or more consumer reporting agencies to verify the
information provided in this client relationship agreement and for any other legitimate business purposes;
8. Merrill Lynch has a lien on your accounts and assets in those accounts for any payment obligations you have to Merrill Lynch, in accordance with the Merrill
Lynch Agreements and Disclosures, including Section 7 of the Merrill Edge Self­Directed Investing Client Relationship Agreement;
9. New York law governs your agreements and transactions unless we indicate otherwise;
10. The Primary Account holder has completed the Taxpayer Certification;
11. Unless you have declined margin lending in the account features section above or your account is not eligible, margin loans may be extended to you from time to
time, and certain of your securities may be loaned to Merrill Lynch or loaned out to others, pursuant to Section 6 of the Merrill Edge Self­Directed Investing
Client Relationship Agreement and the applicable paragraph of the securities account agreement;
12. You acknowledge and understand that non­deposit investment products are provided by Merrill Lynch, Pierce, Fenner & Smith Incorporated ("MLPF&S"), a
registered broker­dealer and wholly owned subsidiary of Bank of America Corporation, and that investment products offered through MLPF&S and insurance
and annuity products offered through its subsidiary, Merrill Lynch Life Agency Inc. (i) are not insured by the FDIC or any federal government agency, (ii) are not
a deposit or other obligation of, or guaranteed by, issued or underwritten by Bank of America, N.A. or any of its bank affiliates, (iii) are subject to investment
risks, including possible loss of the principal amount invested, and (iv) are not a condition to any banking service or activity;
13. You affirmatively consent to having your available cash balances deposited or invested through the Sweep Program in accordance with Section 14 of the Merrill
Edge Self­Directed Investing Client Relationship Agreement;

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