Transfer Agent Online Privacy and Security

In Global Fund Services’ capacity as transfer agent and a covered institution under Regulation S-P (Reg S-P), we developed and implemented a written Reg S-P Program (Program) to meet the requirements of Reg S-P. In Global Fund Services capacity as a service provider, we are mindful of our clients’ privacy obligations to their investors under Reg S-P. Accordingly, pursuant to its transfer agency or investor recordkeeping agreements with its clients, Global Fund Services keeps all records and other information relative to investors confidential and will not use this information other than for purposes of fulfilling its transfer agent or investor recordkeeping duties, except when requested to divulge such information by duly constituted authorities or court process, or when requested by an investor or an investor’s agent.

We will collect the following Nonpublic Personal Information from current and prospective customers/investors on behalf of its clients:

  • Information concerning identity such as name, address, date of birth and social security number;
  • Information about current and historical financial transactions;
  • Information on applications including beneficiary and bank information;
  • Information received on other documents, through data transmissions, email, facsimile or by telephonic device which may include all the above Nonpublic Personal Information.

This information is collected by employees in their normal course of employment with U.S. Bank. All services agent employees may have some type of access to Nonpublic Personal Information. 

We have controls to ensure compliance with Reg S-P and to prevent any unauthorized access, use or dissemination of Nonpublic Personal Information. These controls include, but are not limited to:

  • All employees must be fingerprinted.
  • All employees complete online Information Security Awareness training, which requires a passing grade on the course assessment, and receive ongoing training to reinforce the importance of data privacy.
  • Duties are segregated among personnel, including any quality control checks completed on a sample basis of incoming and outgoing non-public personal information and customer information entered into customer information systems.
  • Verify the authenticity of customers by requiring customers to provide certain pieces of non-public personal information to prevent unauthorized access.
  • Require unique logon IDs and passwords. All computers, mobile devices and storage media must be password protected, employees are not to share passwords with anyone, and employees are to make passwords difficult to guess or predict. User access to each application is controlled and monitored by standardized procedures, including:
    • Terminated or transferred employees have access to applicable applications removed in a timely manner
    • Users are assigned unique preferred IDs
    • Passwords follow appropriate standards.
  • On a quarterly basis, audits are conducted to determine whether changes to user access were made in accordance with procedures.
  • When sending confidential or personal information, employees are to know who they are sending information to and to make sure that the receiver is authorized to receive the information. All electronic data transmissions containing non-public personal information are encrypted.
  • Employees are not to leave confidential or personal information on desks unattended. Mobile devices (laptops, tablets, mini portable desktops, etc.) containing confidential or personal information must be secured when unattended. Computers are password-protected when an employee leaves their desk.
  • Mobile devices must be encrypted, must have a password-protected feature enabled. Employees are discouraged from placing any confidential or personal information on a personally owned device; devices owned by the company must be configured according to bank standards. Employees connecting to bank systems using a wireless connection must do so through an authorized USB VPN Portal. Any lost or stolen device must be reported to the USB Privacy Office immediately.


For privacy related information, please visit usbank.com/privacy. For California related privacy requests, please visit the U.S. Bank California Privacy Center or call our toll-free phone number 1-800-872-2657.

General Data Protection Regulation (GDPR) notices

Depositary Services GDPR Privacy Notice Fund Services Ireland GDPR Privacy Notice Depositary Services Luxembourg GDPR Privacy Notice Fund Services Luxembourg GDPR Privacy Notice
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Disclosures

Investment and insurance products and services including annuities are:
Not a deposit • Not FDIC insured • May lose value • Not bank guaranteed • Not insured by any federal government agency.

U.S. Bank does not guarantee products, services or performance of its affiliates and third-party providers.

U.S. Bank Global Fund Services is not a chartered bank, trust company or depository institution and is not authorized to accept deposits or trust accounts. All U.S. Bank Global Fund Services entities are wholly-owned subsidiaries of U.S. Bank, N. A. Custody, lending, treasury and banking services are offered by U.S. Bank, N.A.

U.S. Bank’s Securities Lending Program is administered by U.S. Bancorp Asset Management, Inc. U.S. Bancorp Asset Management, Inc. is a registered investment adviser and subsidiary of U.S. Bank National Association. U.S. Bank National Association is a separate entity and wholly owned subsidiary of U.S. Bancorp and does not guarantee the products, services or performance of U.S. Bancorp Asset Management, Inc.

U.S. Bank Global Fund Services (Ireland) Limited is registered in Ireland, Company Number 413707. Registered Office at 24 - 26 City Quay, Dublin 2, Ireland. Directors: Eimear Cowhey, Ken Somerville, Hosni Shadid (USA), Barry O'Connor, Maureen Stanley. U.S. Bank Global Fund Services (Ireland) Limited is regulated by the Central Bank of Ireland.

U.S. Bank Global Fund Services (Guernsey) Limited is licensed under the Protection of Investors (Bailiwick of Guernsey) Law, 2020, as amended, by the Guernsey Financial Services Commission to conduct controlled investment business in the Bailiwick of Guernsey.

U.S. Bank Global Fund Services (Luxembourg) S.a.r.l. is registered in Luxembourg with RCS number B238278 and Registered Office: Floor 3, K2 Ballade, 4, rue Albert Borschette, L-1246 Luxembourg. U.S. Bank Global Fund Services (Luxembourg) S.a.r.l. is authorised and regulated by the Commission de Surveillance du Secteur Financier.

U.S. Bank Europe DAC Luxembourg Branch (trading as U.S. Bank Depositary Services Luxembourg) is registered in Luxembourg with RCS number B244276 and Registered Office: Floor 3, K2 Ballade, 4, rue Albert Borschette, L-1246 Luxembourg, regulated and authorised by the Central Bank of Ireland (CBI) as well as by the Commission de Surveillance du Secteur Financier (CSSF). Details about the extent of our authorisation and regulation by the CBI and the CSSF are available from us on request.

U.S. Bank Europe DAC, trading as U.S. Bank Depositary Services, is regulated by the Central Bank of Ireland and is registered in Ireland with the Companies Registration Office Reg. No. 418442. The registered office is Block F1, Cherrywood Business Park, Loughlinstown, Dublin 18, Ireland D18 W2X7.