ELIZABETHTON FEDERAL SAVINGS BANK

Privacy Policy and Disclosure

INTRODUCTION

The directors, management, and staff of Elizabethton Federal Savings Bank 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 Elizabethton Federal Savings Bank 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
• 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 Elizabethton Federal Savings Bank we protect consumer privacy by ensuring that only employees who have a business reason for knowing information have access to it. The bank has appointed a financial privacy coordinator, Joseph W. Howard, who is responsible for maintaining internal procedures to ensure that our customers’ information is protected. For example, information in loan files can only be accessed by employees who work in the loan origination or loan operations departments.

All employees have a copy of this policy and are trained at least annually regarding the importance of safeguarding customer information. The Chief Executive Officer will take disciplinary action against any employee who violates the bank’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.