As an officer, director, or employee of TCF Financial Corporation or its subsidiaries you are required to maintain high ethical standards.

The banking business is based on trust.

Our customers and stockholders entrust us with their money and confidential information because of our reputation for honesty, integrity and high ethical standards.

In this Code, "TCF" includes TCF Financial Corporation, TCF National Bank and any TCF-affiliated company. In this Code, the "Board" or "Board of Directors" is the Board of Directors of TCF Financial Corporation. "Executive Officer" is an executive of TCF Financial who is required to file stock ownership forms with the Securities and Exchange Commission.

The following is an outline of what we consider to be the basic standards of ethical behavior. Failure to abide by these standards can be grounds for disciplinary action up to and including termination.

Appearances can be as important as reality in the appropriate standard of ethical conduct. Since no list can take into account every situation, TCF's Code of Ethics is based on the exercise of conservative good judgment. It is the obligation of all officers, directors, and employees to know and understand the Code of Ethics and TCF's other policies and procedures and to consult with the Vice Chairman/General Counsel regarding any questions.

If you discover any officer, director, or employee engaging in an illegal or unethical act (other than accounting, accounting controls or auditing matters - see next paragraph), it is your responsibility to promptly notify TCF's General Counsel, (952) 475-7910; TCF Financial Corporation, 200 Lake Street East, MC EXO-03-F, Wayzata, MN 55391-1693.

You should promptly follow up your notification with a written report. Your report can be submitted anonymously or on a confidential basis. If you submit your report on a confidential basis, your name will not be disclosed in TCF's investigation, but TCF may be required to disclose your name to government entities. There will be no retaliation against a person making good faith reports or complaints.

If you have a complaint or a concern about any accounting, accounting control, or auditing matters at TCF (for example, if you believe an accounting or auditing practice is questionable or incorrect), you must submit your complaint or concern 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 General Auditor will assist as requested. If you prefer, your complaint or concern can be submitted anonymously or on a confidential basis. If you submit your report on a confidential basis, your name will not be disclosed in TCF's investigation, but TCF may be required to disclose your name to government entities. There will be no retaliation against any person making good faith reports or complaints.

A TCF officer, director, or employee shall not steal or convert to their own use, either TCF's or anyone else's property. You should protect TCF assets and use them only for legitimate TCF business purposes. This includes such things as software, office supplies, office equipment, and other company assets.

A TCF officer, director, or employee shall not solicit or accept a bribe. Good judgment shall be used as to what constitutes a bribe. When a customer buys you lunch, that is not a bribe. When a customer pays you a fee to make a loan, you are being bribed. A discount from a local department store, available to everyone, is not a bribe. A free car from a customer is a bribe. TCF has a separate Bank Bribery Policy.

A TCF officer, director, or employee may not pay a bribe. Good judgment shall be used as to what constitutes a bribe. A political contribution within the law, is not a bribe. An under-the-table fee paid to a government officer is a bribe. A loan made to a public official under normal terms and conditions and with proper approvals, is not a bribe. A no-interest loan to a government official is a bribe. Strict laws and regulations apply to favors granted to public officials and you must consult with TCF's Vice Chairman/General Counsel about any questionable situation.

TCF officers, directors and employees must keep TCF's information, and our customers' information, confidential (except where disclosure is legally mandated, such as in a court proceeding).Your legal obligation to maintain the confidentiality of such information will continue even upon the termination of your employment from TCF.

In the event of termination of employment with TCF, employees may not remove any documents, customer lists, customer information or other TCF proprietary materials from TCF premises, computers or otherwise without specific permission and are required to promptly return any and all TCF-related documents or other TCF proprietary materials in their possession.

"Confidential" information includes all non-public information that might be of use to competitors or harmful to the company or its customers, if disclosed. We cannot trade TCF stock or the stock of customers or others based on inside information. We cannot profit from confidential information received from our customers. We cannot assist others in insider trading and will not disclose information in a manner that results in violation of applicable insider trading restrictions. Our customers' financial information may and must be used in accordance with TCF's Privacy Policy.

TCF officers, directors and employees must comply with all applicable laws, rules and regulations in conducting the company's business. This includes (but is not limited to) antitrust laws, insider trading laws, and employment laws. TCF has separate policies on harassment, equal employment opportunity and other matters relating to treatment of employees. It is impermissible to secretly record other employees without their consent (except for legitimate business reasons such as the wire room).

As an officer, director, or employee of TCF, your first duty of loyalty is to TCF. Both the appearance and the reality of conflicts of interest are to be avoided. A "conflict of interest" occurs when an individual or private interest in any way conflicts with the interest of TCF as a whole. These rules apply to the individual and members of his or her family*. A conflict can arise when you take any action or have interests that may make it difficult to perform your job at TCF objectively and effectively. Buying supplies from a company you have an interest in is a conflict of interest. Borrowing money from a customer is a conflict of interest. Taking employment from a customer is a conflict of interest. Buying a product on normal terms and conditions from a customer is not a conflict of interest. If a question arises, get a written interpretation from TCF's General Counsel. Any actual or potential conflicts of interest must be disclosed to the Board of Directors.

TCF employees' duty of loyalty to the company includes a duty to not compete against TCF while employed by TCF.

Receiving improper personal benefits from TCF, either for yourself or for your family*, is a conflict of interest. You may not: (a) take for yourself any business opportunities discovered through the use of TCF property, information, or position; (b) use TCF property, information, or position for personal gain (outside of your job remuneration), or (c) while you are employed by TCF, compete with TCF. You shall not accept any personal gain from TCF subsidiaries or affiliates (other than your employer) without full disclosure and written approval from TCF's General Counsel, or the Board of Directors. You owe a duty to TCF to advance its legitimate interest when the opportunity arises to do so.

Transactions with TCF and its officers, directors, and employees are subject to special rules and regulations. Transactions involving an officer, director, or employee's purchase or other receipt of property from TCF, or sales of property by Officers, Directors, or employees to TCF, are discouraged and are subject to supervisory approval and approval of TCF's General Counsel. Loans or guarantees from TCF Financial Corporation to employees (including Executive Officers) or Directors are absolutely prohibited. Loans from TCF Bank to you, your family or your close friends must be made on arm's length terms, and must be referred to others for approval. Loans from TCF Bank to Executive Officers, Directors and their related interests are acceptable only if they are in compliance with Regulation O (as applicable). Likewise, leases from Winthrop Resources or TCF Equipment Finance to Executive Officers, Directors and their related interests are acceptable only if they are in compliance with Regulation O (as applicable). Questions as to the proper procedures may be directed to TCF's General Counsel.

You should deal fairly with our customers, suppliers, competitors, and employees in your relations with them on behalf of TCF. You should not take unfair advantage of them through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair dealing or practice.

Community involvement, including political involvement, by TCF's Officers, Directors, and employees is encouraged, but not required. (All laws must be obeyed). TCF's Officers and employees must obtain approval from your bank president, TCF's General Counsel, or (for Executive Officers) TCF's Chief Executive Officer, before accepting a position as Officer for Director in any entity (this does not apply to outside Directors).Conflicts of interest must be avoided and approval of such appointments should consider the potential for conflicts and other appropriate considerations, such as the risk of liability to TCF.

It is not TCF's intention to pry into our employee's personal lives, but TCF's Officers, Directors, and employees must conduct their personal affairs in a manner appropriate for a representative of a bank.

Compliance Standards and Procedures - TCF's General Counsel will promptly investigate all reports of violations of this code. Any TCF supervisor or Executive Officer who receives such a report must promptly forward it to the General Counsel. Reports will be investigated as confidentially as possible. Any report made in good faith shall not result in retaliation against the employee making the report. The General Counsel shall provide a written report of conclusions from any investigation to the Audit Committee of the Board. Management shall have authority to direct any discipline deemed appropriate, up to and including dismissal of any TCF employee found to have engaged in wrongdoing. The Audit Committee will promptly investigate any reports it receives of concerns or complaints about accounting, accounting controls, or auditing matters. The Audit Committee will review the outcome of any such investigations and record the results in the minutes of its meetings. The Audit Committee shall have authority to direct any discipline it deems appropriate, up to and including dismissal of TCF employees found to have engaged in wrongdoing.

If an individual commits fraud or theft against TCF, he or she is subject to disciplinary action up to and including dismissal.

The requirements of this Code may not be waived for Directors or Executive Officers except by the Board of Directors of TCF followed promptly by disclosure of the waiver to TCF shareholders.

Always act in a manner that is consistent with the highest ethical standards!

*For the purpose of this policy, the term "family" includes spouses, parents, children, siblings, mothers and fathers-in-law, sons and daughters-in-law, brothers and sisters-in-law, or anyone who shares your home address other than domestic employees.