TCF FINANCIAL CORPORATION
Policy for Reporting Complaints or Concerns Regarding Accounting, Internal Accounting Controls or Auditing Matters to the Board of Directors Audit Committee

Employees or others who have a concern or complaint concerning TCF's accounting, internal accounting controls, or auditing matters must submit their concern or complaint to the Chief Audit Executive as the designee for the Audit Committee Chairman, via the Post Office box address, or via telephone through the Ethics and Compliance Hotline, independently administered by the Network.

Chief Audit Executive
Internal Audit Department
P.O. Box 776
Wayzata, MN 55391-9903
Phone: 1-800-620-8601

The Chief Audit Executive will forward the complaint to the Audit Committee Chairman. The Chairman will determine the appropriate method to investigate the complaint. The Chief Audit Executive will assist as requested.

An employee or other complainant may remain anonymous. If an employee or other complainant wishes their complaint to be kept confidential, any information they provide will be investigated on a confidential basis to the extent it is feasible to do so. There will be no retaliation against a person making good faith reports or complaints.

The results of all investigations will be reported to the Audit Committee.

All documentation will be maintained by Internal Audit indefinitely.