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Regulation R Disclosure

Employees of Zions Bancorporation, N.A. participate in an incentive compensation program under which the employee may receive a fee of more than a nominal amount for referring a customer to Zions Direct, Inc. and payment of this fee may be contingent on whether the referral results in a transaction with Zions Direct, Inc.

Zions Direct Business Continuity Plan

Zions Direct has developed a Business Continuity Plan to help the firm operate in response to an emergency or significant business disruption.