Vanguard's Online Fraud Policy

Our commitment regarding online security is simple. If assets are taken from your account in an unauthorized online transaction on Vanguard.com®—and you've followed the steps described in the Your responsibilities section below—we will reimburse the assets taken from your account in the unauthorized transaction.

By working together, we can help maximize the safety of your accounts and your personal information.

Your responsibilities:

At a minimum, in order for this protection to apply, you must take the following steps:

Review your accounts regularly.

Check your account frequently. Promptly and completely review all information we send you. Report any errors or discrepancies in your account and any suspected unauthorized transactions or account changes to Vanguard immediately.

Protect your Vanguard.com user name, password, and other account-related information.

Make sure your user name, password, and answers to your security questions are unique and strong. Never share your user name, password, or other account-related information with anyone. Never store your user name, password, or answers to security questions in your browser. Clear any temporarily stored copies of online information by closing your browser after signing off. Do not leave your computer unattended while logged on to Vanguard.com.

Protect your computer.

Make certain that any computer you use to access Vanguard.com has up-to-date security and anti-spyware, antivirus, and firewall software.

Do not reply to e-mail requests for personal or financial information.

Do not respond to, open an attachment in, or click on a link within an e-mail if you suspect the message is fraudulent. Vanguard will not ask for personal information such as your Social Security number, account numbers, or passwords in an e-mail.

Cooperate with us and stay informed.

Cooperate fully with Vanguard in investigating and prosecuting any unauthorized activity in your account, and follow our recommendations about how to protect your account. We may require you to file a police report, complete a notarized affidavit, or permit access to your computer.

Details regarding this protection:

This protection applies only to the following types of Vanguard® accounts: Vanguard nonretirement mutual fund accounts; Vanguard individual retirement accounts (IRAs); accounts maintained with Vanguard Brokerage Services®, a division of Vanguard Marketing Corporation; participant accounts in retirement plans for which Vanguard provides recordkeeping and administrative services; and accounts held by plan sponsors, financial advisors, broker-dealers, or other intermediaries. Accordingly, this protection does not apply to annuities or to 529 college savings plan accounts. This protection does not apply to unauthorized activity caused in whole or in part by your fraudulent, intentional, or negligent acts or omissions, including activity by a person whom you have intentionally or negligently permitted to transact in your account, or to whom you have intentionally or negligently given access to security information relating to your account. This protection does not apply to unauthorized account activity or account access by an employer, plan sponsor representative, or employee or representative of a financial advisor, broker-dealer, or other intermediary who is authorized to access your account but is acting outside the scope of his or her authority. Vanguard will determine the type and amount of reimbursement—including whether to restore to your account cash and/or shares of securities equal to the amount of cash and/or shares of securities in your account at the time of any unauthorized activity—and whether to reverse unauthorized trades and reinstate positions as held at the time of any unauthorized activity. This protection does not cover any tax consequences; legal fees or expenses; other professional fees or expenses; or any special, indirect, incidental, consequential, punitive, exemplary, lost opportunity, or non-monetary damages. Vanguard reserves the right to offset any amount it would otherwise pay to you pursuant to this policy by compensation you have received from other sources for the same loss. Vanguard may seek restitution for reimbursements made to you from the person(s) or entity that committed the unauthorized activity. Vanguard may, at its discretion and as a condition of this protection, require that you assign to Vanguard certain rights you may have regarding your loss and/or sign a release form. You may not assign any rights to this protection from Vanguard to any other individual or entity.