BANKERS’ BANK OF THE WEST

PRIVACY DISCLOSURE

The Financial Services Modernization Act, also known as the Gramm‐Leach‐Bliley Act (GLBA),was enacted into law in November 1999. The Act has caused many modifications and disclosure restrictions to the way that financial service providers conduct business regarding nonpublic confidential information of their customers and their customers' customers.

PRIVACY POLICY

As a provider of correspondent bank technologies, products, and services that serve financial institutions, Bankers' Bank of the West and its affiliates recognize their responsibility for:

  • Maintaining the integrity of information entrusted to us, and

  • Safeguarding the privacy of our customers and our customers' customers whose information we may collect.

Bankers' Bank of the West and its affiliates use any information about our customers and their customers solely to legitimately conduct our business. Bankers' Bank of the West and its affiliates are precluded from conducting business with the general public. Normally, personal and confidential information is not collected during cash letter or other deposit processing. We do not directly transact, nor do we solicit or maintain deposit accounts, with any individuals, partnerships, or corporations (other than bank holding companies or other financial institutions).

Bankers' Bank of the West and its affiliates can conduct business on a limited basis with officers, directors and principal shareholders of financial institutions and holding companies. During that business, we may make personal loans to such individuals or transact electronic funds transfers.

With respect to any agreements that Bankers’ Bank of the West and/or its affiliates may enter with respondent financial institution customers and to the extent Bankers’ Bank of the West and its affiliates receive from its respondent financial institution customers, nonpublic personal information (as such term is defined under Title V of the Gramm‐Leach‐Bliley Act, 15 U.S.C. s. 6801 et. seq. and the applicable regulations), Bankers’ Bank of the West and its affiliates shall not disclose or use any such nonpublic personal information other than to carry out the purpose for which such information was disclosed by the respondent financial institution customers to Bankers’ Bank of the West and/or its affiliates or as otherwise required by law. Bankers’ Bank of the West and its affiliates shall restrict access to such nonpublic personal information to those persons who need to know that information to provide services pursuant to those agreements and who are bound by obligations of confidentiality at least as strict as those set forth herein. Bankers’ Bank of the West and its affiliates shall maintain physical, electronic, and procedural safeguards that comply with federal regulations to guard such nonpublic personal information.

We also require other companies and independent contractors who provide services on our behalf or with whom we have entered into a joint marketing agreement, to enter into agreements that protect the confidentiality of any customer information we provide and to restrict the use of such information to those purposes.

Bankers' Bank of the West and its affiliates shall treat all nonpublic and confidential information with the same degree of care it accords to such information supplied by our customers as required by the provisions of GLBA.

You do not need to take any action because of this notice, but you do have certain rights as described in GLBA.

Bankers’ Bank of the West

G L B A Notice of Disclosure

Collection of Nonpublic Personal Information

Title V of the Gramm‐Leach‐Bliley Act (GLBA) generally prohibits any financial institution, directly or through its affiliates, from sharing nonpublic personal information about customers or potential customers with a non‐affiliated party unless the institution provides the customer with a notice of its privacy policies and practices, such as the type of information that it collects about them and the categories of persons or entities to whom it may be disclosed. In compliance with GLBA, we are providing this document, which notifies our customers or potential customers of the privacy policies and practices of Bankers' Bank of the West.

Why we collect information

We may collect nonpublic personal information about customers or potential customers that is necessary for Bankers’ Bank of the West and/or its affiliates to review pertinent financial information that enables the bank to render a financial decision to approve or decline requests for credit. We gather this information from several sources, including but not limited to, the following:

  • Information on applications and other forms via paper or electronic means

  • Information from consumer credit reporting agencies

  • Information from other sources, such as government agencies

How we disclose information

Nonpublic personal information we collect is to be used to make credit decisions. This information is not shared except with consumer credit reporting agencies.

Information Security Practices

Safeguarding customer privacy and the physical security of information are taken seriously by Bankers’ Bank of the West, its affiliates, management, and staff. Nonpublic, personal information is restricted to those persons who need to know that information to provide services pursuant to agreements and who are bound by obligations of confidentiality. Bankers’ Bank of the West and its affiliates shall maintain physical, electronic, and procedural safeguards for storage, retention and destruction of nonpublic personal information that comply with federal regulation for such requirements. Our privacy policy continues to apply even if the relationship with Bankers’ Bank of the West and/or its affiliates has terminated.

Safeguarding Customer Information Policy approved 12/15/2023 8