The following policy has been developed and adopted by First Commercial Bank to instill trust in all customers. First Commercial Bank realizes its obligation to provide trust to all customers that disclose personal information to complete and perfect all business transactions within the bank. The elements of First Commercial’s privacy policy include the following: mission statement, the recognition of the customer’s expectation of privacy, collection, using, and retention of a current and/or non-customers’ information, maintenance of accurate information, limitations of employee access to information, protection of information via established security procedures, restrictions on the disclosure of account information, and providing privacy information to third parties, customers, and inquiries. All previously mentioned elements of this policy are based on the Joint Industry Privacy Principles adopted in 1997 by the American Bankers Association and other trade groups.

Mission Statement:

At First Commercial Bank, our mission is to meet the desires and needs of our customers. Our Customer Information Privacy Principles serve as standards for all First Commercial Bank employees for collection, use, retention, and security of individual customer information. As financial service professionals entrusted with sensitive financial information, we respect the privacy of our customers and are committed to treating customer information responsibly.

Recognizing the Customer’s Expectation of Privacy:

At First Commercial Bank, we recognize that one of our most important assets is our customers’ trust. First Commercial Bank believes the confidentiality and protection of customer information is one of our fundamental responsibilities and must be considered a priority for First Commercial Bank and all its employees.

Collection, Using, and Retention of a Current and/or Non-Customers’ Information:

We collect and retain information about you only for specific purposes within the bank and we will tell you why we are collecting and retaining it upon your request. First Commercial Bank will collect, retain, and use information about you to help administer our business and/or provide products, services, and other opportunities to you the customer. First Commercial Bank will only use your information to protect and administer your records, accounts, and funds; to comply with certain laws and regulations; to help us design or improve our products and services; and to understand your financial needs so that we can provide you with quality products and superior service. However, if the customer leaves First Commercial Bank and/or terminates the relationship with the bank, thus becoming a non-customer, First Commercial Bank will follow all record retention laws as described by the federal and state governing bodies. Also, after a reasonable period of time of non-activity between the customer and First Commercial Bank, it may be determined if the non-customer information is useful to the administration of First Commercial Bank; if not the information will not be retained.

Maintaining Accurate Information:

First Commercial Bank is continually striving to maintain complete and accurate information about you and your accounts. We will investigate your concerns and correct any inaccuracies should you ever believe that our records contain inaccurate or incomplete information. Please do not hesitate to contact us if for any reason you feel that an update or revision needs to be made to the information in your customer database.

Limitations on Employee Access to Information:

At First Commercial Bank, employee access to personally identifiable customer information is limited to those with a business reason to know such information. Employees are educated on the importance of maintaining the confidentiality of customer information on these Privacy Principles. Because of the importance of these issues, all First Commercial Bank employees are responsible for maintaining the confidentiality of customer information. Employees who violate these Privacy Principles will be subject to disciplinary measures.

Established Security Procedures Protecting Customer Information:

Customer information is protected by established security standards and procedures developed and maintained by First Commercial Bank in accordance with Federal and State Laws. All informational systems, operational and data, are well secured and unattainable by third parties. Employees are trained to understand and comply with these security standards and procedures. Disciplinary measures are enforced for those that breach the security environment of the bank by internal and/or external threats.

Restrictions on the Disclosure of Account Information:

It is First Commercial Bank’s policy not to reveal specific information about customer accounts or other personally identifiable data to unaffiliated third parties for their independent use. However, the following are exceptions of sharing customer information with unaffiliated third parties: 1) the information is provided to help complete a customer initiated transaction; 2) the customer requests or permits it; 3) the disclosure is required by or allowed by law (e.g., subpoena, investigation of fraudulent activity, request by regulator, etc.); or 4) the customer has been informed about the possibility of disclosure for marketing or similar purposes through a prior communication and given the opportunity to decline (i.e., “opt out”).

Maintaining Customer Privacy in Business Relationships With Third Parties:

When First Commercial Bank conducts business with third parties; it requires its outside consultants, counsels, auditors, vendors and suppliers to maintain similar standards of conduct regarding the privacy of personally identifiable customer inquiries. If personally identifiable customer information is provided to a third party, First Commercial Bank will insist that the third party adhere to similar privacy principles that provide for keeping such information confidential.

Providing Privacy Information to Customers and Responding to Inquires:

First Commercial Bank recognizes and respects the privacy expectations of our customers. We want our customers to understand our commitment to privacy in our use of customer information. As a result of our commitment, we have developed these Privacy Principles, which are made readily available to our customers. Employees are to instruct customers who have questions about these Privacy Principles or have a question about the privacy of their customer information to contact the CEO of the bank.