The directors, management, and staff of The First National Bank of Livingston, and its subsidiaries, are concerned about and respect the privacy of customers/consumers personal financial information. We understand that our customers furnish sensitive information to the bank in the course of daily business, and the bank is 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 and disclosure outlines our bank's practice regarding personally identifiable financial information for consumers and those consumers who become our customers.

TYPES OF INFORMATION THE BANK COLLECTS

At The First National Bank of Livingston we collect nonpublic, personal information about consumers from many sources, including the following:

• Information we receive from them on applications or other forms
• Information about their transactions with us, our affiliates, or others
• 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 THE BANK DISCLOSES

The bank does not now, nor does it intend in the future, to disclose any personal financial information to any nonaffiliated or affiliated third party. By law the bank may disclose certain personally identifiable information without allowing consumers the right to opt out of the bank's sharing agreements in the following circumstances:

• To companies who perform transaction processing for the bank 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
  • In connection with a securitization, secondary market sale (including servicing rights), or similar transaction related to a consumer

   

• To disclose information necessary to enforce the bank'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 to insurance rate advisory organizations, guaranty funds or agencies, agencies that are rating the bank, persons who are assessing the bank's compliance with industry standards, and the bank'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

SAFEGUARDING CUSTOMER INFORMATION

At The First National Bank of Livingston we protect consumer privacy by ensuring that only employees who have a business reason for knowing information have access to it. The Compliance Officer is responsible for assuring that appropriate written procedures and internal controls are adopted within each operating area of the bank to assure customer financial privacy. Responsibility for developing, implementing and complying with those procedures rests with the respective department heads and facility managers; they are responsible for information security in their areas.

Each department and branch has internal controls to assure that customer information is dispensed only as allowed or required by law or regulation. (Administrative, technical and physical safeguards for customer information are addressed in the Bank's security procedures.)

Departmental compliance audits conducted by the Internal Auditor must include a review of privacy related issues in each appropriate subject area. This review shall incorporate compliance with the general philosophy of this policy as well as the specific requirements of law or regulation.

All employees are alerted to the level of confidentiality required in banking relationships during new employee orientation and must acknowledge receipt of a copy of this policy. Training incorporates privacy-related issues in each appropriate subject area. Maintenance of the confidentiality of customer information is a primary responsibility of all bank personnel. Breaches of confidentiality are addressed in the employee handbook and can serve as the basis for dismissal. All employees have a copy of this policy and are trained at least annually regarding the importance of safeguarding customer information.

The board of directors of The First National Bank of Livingston approved and adopted this policy on April 11 2001.

Privacy Policy

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