Our goal is to help clients achieve peace of mind.
A copy of this letter was sent to Chevy Chase Trust clients on December 19,
2008:
Dear Client,
In light of headline
news about certain financial firms, we want to assure you that confidence
in Chevy Chase Trust continues to be well placed. Attached is a description of
the oversight, controls, and separation of duties that Chevy Chase Trust
maintains
to protect the integrity of the accounts entrusted to us.
Three additional points are important to note: 1) Chevy Chase Trust has never invested in hedge funds of any kind; 2) Chevy Chase Trust is not a broker/dealer and, therefore, does not self-clear any client securities transactions; and 3) Chevy Chase Trust does not self-generate client statements.
Finally, Chevy Chase Bank continues to be a well capitalized bank. The decision to sell the Bank was completely voluntary, as was the decision to maintain Chevy Chase Trust as a private independent trust company.
Chevy Chase Trust has a team of more than 50 professionals who average 19 years of industry experience. We are always available for you. Please do not hesitate to call if you have any issues or concerns that you would like to discuss.
Sincerely,
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Chevy Chase Trust Company Oversight and Controls |
| Fiduciary Asset Protection |
A number of protections assure the safety of assets managed by Chevy Chase Trust. Chevy Chase Trust is required under federal law to segregate all assets held in any fiduciary capacity from Chevy Chase Trust’s general assets. All client assets at Chevy Chase Trust are kept on a separate set of books and records showing in proper detail all transactions engaged. Thus, fiduciary assets would not be subject to any claims of general creditors of Chevy Chase Trust.
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| Regulatory Oversight |
Chevy Chase Trust is continually monitored to ensure the safety of client assets. On an annual basis, Chevy Chase Trust files a statement of its financial condition with, and for review by, the Office of Thrift Supervision. Additionally, Chevy Chase Trust is subject to annual internal audits of its operations and administration, as well as regular examinations by the Office of Thrift Supervision and the Securities and Exchange Commission.
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| Fiduciary Standards and the Avoidance of Conflicts of Interest |
Chevy Chase Trust is held to a strict fiduciary standard by the Office of Thrift Supervision. Chevy Chase Trust must act in the best interest of its clients at all times. As such, Chevy Chase Trust maintains a Code of Ethics as well as Policies and Procedures regarding the avoidance of conflicts of interests. These policies include topics such as brokerage placement practices, the investment of fiduciary funds, disclosure of material events, and the monitoring of employee personal securities transactions. Compliance with all of these policies is audited annually by Chevy Chase Trust’s internal audit staff, as well as all applicable regulatory agencies.
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| Fiduciary Account Reviews |
All managed accounts undergo rigorous reviews. Managed accounts are individually reviewed prior to their acceptance to ensure that Chevy Chase Trust can properly administer the account. Once accepted, the assets held in respective accounts are promptly evaluated. In addition to frequent reviews by the investment manager throughout the year, a formal review of the account is conducted on an annual basis. Internal auditors and federal regulatory examiners annually review this process to ensure compliance with federal regulations.
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| Compliance |
Chevy Chase Trust has a Chief Compliance Officer who is responsible for designing and implementing policies and procedures to prevent and detect securities fraud. The Chief Compliance Officer has extensive experience in banking and investments, and has an independent reporting structure that alleviates any potential conflicts of interest.
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| Audit |
An internal audit is conducted annually by persons independent of Chevy Chase Trust. The internal auditors communicate directly to Chevy Chase Trust’s Board of Directors. In addition, Chevy Chase Trust employs Ernst & Young LLP as its external CPA firm to conduct an annual financial statement audit. Ernst & Young is a national firm with the depth and experience necessary to conduct an independent audit in accordance with the best practices of the accounting industry.
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| SEI Private Trust (sub-custodian) |
SEI Private Trust Company (“SPTC”) serves as Chevy Chase Trust’s sub-custodian. All fiduciary assets are held in a custody account in SPTC’s name, for the benefit of Chevy Chase Trust and further credit to individual clients.
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| Operations Controls |
Chevy Chase Trust Company ensures the safety of client assets by segregating
the investment and cash functions. Portfolio managers are not able to
move cash for any client accounts, nor are they permitted to process
any transactions to client accounts other than securities trades.
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| Board of Directors / Management Committee |
Chevy Chase Trust has a Management Committee that consists of the senior managers of the Company. The Committee meets monthly to review and approve the activities of the prior month – new and closed accounts, discretionary account distributions, account reviews, investment performance, investment policy changes, financial results, compliance activities, audit reports and regulatory issues. The Management Committee is chartered by, and reports directly to, Chevy Chase Trust’s Board of Directors, which meets to review and ratify the activities of the Management Committee.
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| Insurance Coverage |
Chevy Chase Trust maintains both Professional (Errors & Omissions) and Directors and Officers Liability insurance. Each policy has total coverage of $25,000,000. Chevy Chase Trust has never had to make a claim under either policy. Chevy Chase Trust also carries excess liability insurance policies in the amount of $65,000,000. In addition, Chevy Chase Trust’ sub-custodian, SEI Private Trust, carries Errors & Omissions Insurance coverage of $50,000,000. |

