First Suburban National Bank

The directors, management and staff of First Suburban National Bank (“FSNB”) are concerned about and respect the privacy of customers’/consumers’ personal financial information. We understand that our customers furnish sensitive information to FSNB in the course of daily business, and FSNB is committed to treating such information responsibly. We know that our customers expect privacy and security for their personal and financial affairs.

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

Types of Information FSNB Collects

At FSNB we collect nonpublic, personal information about you from many sources, including the following:

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.

Nonpublic, personal information does not include that which is available from government records, widely distributed media or government-mandated disclosures.

Types of Information FSNB Discloses

FSNB does not disclose any personal financial information to any nonaffiliated or affiliated third party, except as permitted by law. By law FSNB may disclose certain personally identifiable information without allowing consumers the right to opt out of FSNB’s sharing agreements in the following circumstances:

To companies who perform transaction processing for FSNB in the following circumstances:
if the transaction, service or product is requested or authorized by the consumer;
to maintain or service a consumer’s account as part of a private label credit card or other loan extension program; and
in connection with a securitization, secondary market sale (including servicing rights) or similar transaction related to consumer.
To disclose information necessary to enforce FSNB’s legal or contractual rights or the rights of any other person who is engaged in the financial transaction
To disclose information required in the ordinary course of banking business, such as the settlement of claims or benefits, the confirmation of information to the consumer or the consumer’s agent, and the billing, processing or clearing of items in the normal course of business
To provide information rate advisory organizations, guaranty funds or agencies, agencies that are rating FSNB, persons who are assessing FSNB’s compliance with industry or government standards and FSNB’s attorneys, accountants and auditors
To the extent permissible under the Right to Financial Privacy Act
To a consumer reporting agency under the Fair Credit Reporting Act
To comply with federal, state or local laws, rules and other applicable legal requirements

Information Security

At FSNB we protect consumer privacy by ensuring that only employees who have a business reason for knowing information have access to it. We maintain internal procedures to ensure that our customers’ information is protected. For example, information in loan files may only be accessed by employees who work in the loan origination or loan operations department.

FSNB will maintain appropriate controls designed to ensure that consumer information is disposed of properly.

All employees have a copy of this policy and are trained at least annually regarding the importance of safeguarding customer information. The appropriate department manager will take disciplinary action against any employee who violates FSNB’s privacy policy and procedures.

If we change our policy or practice by, for example, adding a category of information that 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.

Approved by Board of Directors
March 21, 2005

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