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 in regards to non public 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, the Bankers’ Bank of the West recognizes its 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 uses any information about our customers and their customers solely to legitimately conduct our business.

Bankers’ Bank of the West is precluded from conducting business with the general public. Normally, personal and confidential information is not collected in the course of cash letter or other deposit processing. We do not 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 is allowed to conduct business on a limited basis with officers, directors and principal shareholders of financial institutions and holding companies. In the course of that business, we may make personal loans to such individuals or transact electronic funds transfers.

With respect to any agreements that BBW may enter into with respondent bank customers and to the extent BBW receives from its respondent bank customers, non public 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), BBW shall not disclose or use any such non public personal information other than to carry out the purpose for which such information was disclosed by the respondent bank customers to BBW or as otherwise required by law. BBW shall restrict access to such non public 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. BBW shall maintain physical, electronic and procedural safeguards that comply with federal regulations to guard such non public 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 shall treat all non public 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 as a result of this notice, but you do have certain rights as described in GLBA.

Bankers’ Bank of the West

GLBA Notice of Disclosure

Collection of non public Personal information

Title V of the Gramm-Leach-Bliley Act (GLBA) generally prohibits any financial institution, directly or through it affiliates, from sharing non public 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. [Paragraph]Why we collect information

We may collect non public personal information about customers or potential customers that is necessary for BBW 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 a number of sources, including but not limited to the following:

• Information on applications and other forms via paper or electronic means [Paragraph+bullet}Information from consumer credit reporting agencies
• Information from other sources, such as government agencies

How we disclose information

Non public 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 BBW, its management and staff. Non public, 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. BBW shall maintain physical, electronic and procedural safeguards for storage, retention and destruction of non public personal information that comply with federal regulation for such requirements. Our privacy policy continues to apply even if the relationship with BBW has terminated.
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