Privacy Policy and Disclosure - No Opt-Out Form

[Marquis Bank does not disclose information (including marketing information) to affiliates or nonaffiliated third parties]

The directors, management, and staff of Marquis Bank are concerned about and respect the privacy of our customers’ 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 Marquis Bank we collect nonpublic personal information from many sources. The Bank collects nonpublic personal information directly from consumers on various applications and forms, for example, loan applications, deposit account applications, and requests for information about accounts or products and services.

The Bank also collects information as a result of transactions between the Bank and our customers and as a result of providing a product or service to our customers. This includes transaction information from checks, debit cards, automated teller machine (ATM) cards, and electronic transfers (e.g., home Banking or automated clearinghouse (ACH) transactions).

Nonpublic personal information does not include that which the Bank obtains 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 in 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 that 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 Marquis Bank we protect consumer privacy by ensuring that only employees who have a business reason for knowing information have access to it. The Bank’s Compliance Officer 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 and/or other authorized individuals. These are other minimum guidelines that are presently in place and every employee should follow.

• Verifying customers’ identity. Customers who call in to speak with any of our employees about their accounts must be able to identify themselves as authorized users of an account. For example, if someone calls for his or her account balance, you should require some personal information such as the date and amount of last deposit and the address (if domestic, a tax identification number will be useful as well) before you release information over the phone.

• PINs. Customers who access their accounts by automated teller machine (ATM), debit cards, home banking, Internet delivery channels, or automated telephone banking services should have PINs (generally chosen by the customer except for ATM which is sent by Harland EFT) before they can access account information. The Bank has implemented ways for the customer to get the PIN and make changes without a Bank employee having access to this information (refer to other system operation procedures for further details).

Note: The regulation states that the Bank is not responsible for unauthorized access to an account if the customer gives a PIN or other identifying information to a third party.

• Authorization to give information to third parties. Every deposit or loan references to third parties will require the customer’s written authorization. The Bank will verify the customer’s signature on the authorization.

• Check approval. The Bank’s policy is not to respond to a request from a third party about whether a check presented for payment will be paid (the Bank will not give a check approval on the phone). Once a check number is given by the third party to determine the sequence, the Bank will only indicate whether the check is good or not at present. In this way, we can ensure that the number falls within the current sequence being used by the customer. While this is not foolproof, it can discourage people using pretext calling to determine if the customer has an account at our Bank. Remember that the fact that a customer has an account at our Bank is considered nonpublic personally identifiable information under the privacy rules.

• Restricted employee access to information. The Security area, together with Operations, performs an evaluation of employee access to restrict access to certain customer information to particular employees. If a customer at a teller window asks a question about his or her consumer loan they may be referred to a Personal Banker or Loan Department employee for further assistance.

• Service providers. Our Bank has taken steps to ensure that all third-party providers safeguard our customer’s information. We review all existing contracts and submit addendums for those contracts that do not have any confidentiality clause. All new third-party arrangements will be required to contain provisions for safeguarding customer information.

Note: Agreements will also be sent to Bank’s lawyers, accountants, and consultants.

All employees have a copy of this policy and are trained at least annually regarding the importance of safeguarding customer information. The Compliance Officer, the Human Resources area, and the appropriate department manager 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 will be disclosed to a third party, the Bank will notify existing customers and give them an appropriate time period to opt out of the disclosure.

Marquis Bank will provide notice annually as long as you maintain an ongoing relationship with us. This policy may change from time to time but we will inform you of any changes in a timely manner. Additionally, you may obtain our privacy disclosure at your local branch and on our website at www.marquisbank.com.