SAFEGUARDING CUSTOMER INFORMATION

The Directors, management and staff of Nevada Bank & Trust are concerned about and respect the privacy of our customer’s personal financial information.  We understand that our customers furnish sensitive information to us in the course of our daily business and we are committed to treating such information responsibly.  We know that our customers expect privacy and security for their personal and financial affairs.

The bank will take all the necessary steps to safeguard sensitive information that has been entrusted to us by our customers.  The following privacy policy outlines our bank’s practice regarding personally identifiable financial information for consumers and customers.

At Nevada Bank & Trust we protect consumer privacy by ensuring that only employees who have a business reason for knowing information have access to it.  We have appointed a Financial Privacy Coordinator who is responsible for maintaining internal procedures to ensure information in loan files can only be accessed by employees who work in our loan origination or loan operations departments.

All of our employees have a copy of this policy and are trained at least annually regarding the importance of safeguarding customer information.  The Financial Privacy Coordinator, the Human Resource Director and the appropriate department manager will take disciplinary action against any employee who violates our privacy policy and procedures.

We maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard nonpublic personal information.

If we change our policy or practice by, for example, adding a category of information we will disclose to a third party, we will notify existing customers and give them an appropriate time period to opt-out of the disclosure.

TYPES OF INFORMATION WE COLLECT

At Nevada Bank & Trust we collect nonpublic personal information from many sources.  Nonpublic personal information does not include that which is available from government records, widely distributed media, or government-mandated disclosures.

We collect nonpublic information about you from the following sources:

• Information we receive from you on applications or other forms;
• Information about your transactions with us, our affiliates, or others; and
• Information we receive from a consumer reporting agency.

TYPES OF INFORMATION WE DISCLOSE

We may disclose the following types of information about our customers or former customers to our family of affiliated businesses:

• Identification information such as your name, address and telephone number
• Transactional information
• Deposit or loan account experience

SERVICE PROVIDERS

We may disclose the following information to companies that perform services on our behalf:

1. Information we receive from you on applications or other forms, such as name, address, social security number, assets, liabilities and income
2. Information about your transactions with us, our affiliates or others such as account balances, payment history, credit card usage, and parties to the transaction
3. Information we receive from a consumer reporting agency, such as your creditworthiness and credit history.

We will not provide your personal information to non-bank companies for the purpose of their independent telemarketing or direct mail marketing of any non-financial products or services by those companies.

EXCEPTIONS TO YOUR OPT-OUT RIGHTS

We may share your personal information without allowing you the opportunity to opt-out, to the extent permissible under the Right to Financial Privacy Act, in the following circumstances:

1. With companies who perform transaction processing services for our bank in the following circumstances:  Federal Reserve Bank or selected correspondent banks who collect checks deposited by our customers, and Core Data who does the accounting for our debit card program.
2. If the transaction, service, or product is requested or authorized by you:
   1. To maintain or service your account as part of a private label credit card, other loan extension program, or Internet Banking.
   2. In connection with a securitization, secondary market sale, (including servicing rights), or similar transaction related to a customer.
3. For disclosures that are necessary to enforce our bank’s legal or contractual rights or any other person’s rights who is engaged in the financial transaction
   1. For disclosures required in the ordinary course of banking business, such as settlement of claims or benefits, providing confirmation of information to the consumer or his agent, and to bill, process or clear items in the normal course of business.
   2. To provide information to insurance rate advisory organizations, guaranty funds, or agencies that are rating the bank, persons that are assessing the bank’s compliance with industry standards, and the bank’s attorney’s, accountants and auditors.
   3. To a consumer reporting agency under the Fair Credit Reporting Act.
   4. To comply with Federal, State or local laws, rules and other applicable legal requirements.