Table of Contents

1. Disclosure of Customer Information
2. Collection, Retention and Use of Information
3. Maintenance of Accurate Information
4. Employee Access to Information and Enforcement
5. Customer Notification
6. Internet Information

1. Disclosure of Customer Information

First Commercial Bank will not disclose any nonpublic personal information (hereafter referred to as customer* information) about our customers or former customers except as permitted by law.

Customer information will only be disclosed to authorized account holders, and only after identification of that account holder has been verified. Verifying information may include social security number, date of birth, amount and date of last deposit, mother’s maiden name, signature and/or other identifying information. If the information request is made over the telephone and we are uncertain about the identity of the person requesting the information, we will ask that the request be made in writing or in person.

First Commercial Bank employees will not share personal or financial customer information with nonaffiliated third parties except when legally required (in order to comply with federal or state laws/regulations and government or court orders) or when legally permitted to serve the customer’s interest (such as disclosure to credit reporting bureaus).

Examples are as follows:

• Where it is necessary to complete a transaction initiated by the customer.
• In order to report the existence and condition of an account to companies such as credit bureaus or merchants.
• In order to comply with government or court orders.
• If we have the written permission of the account holder.

First Commercial Bank will provide certain customer information to nonaffiliated third party companies that we hire to provide us operational support. These nonaffiliated third party companies provide services that allow us to complete transactions such as a real estate loan. Examples of these services include, but are not limited to, appraisals, title searches, flood certifications and credit reports.

First Commercial Bank will not knowingly do business with any nonaffiliated third party provider or company that sells this information for marketing purposes.

First Commercial Bank will share certain customer information with its affiliate banks as necessary to permit you to complete banking transactions with First Commercial Bank at affiliate bank locations, e.g. deposits to your First Commercial Bank account(s), check cashing against your First Commercial Bank account(s), loan payments, etc. Please see your Personal Banker/Teller for further details. First Commercial Bank may also share discretionary current and historical transactions and experiences about you with our affiliates in order to establish necessary credit worthiness and general good standing to further provide you with a variety of financial services offered by our affiliates.

2. Collection, Retention and Use of Information

First Commercial Bank collects nonpublic personal information about you
from the following sources:

• Information we receive from you on applications or other forms;
• Information about your transactions with us, our affiliates, or others; and
• Information we receive from a credit reporting agency.

We may disclose all of the information we collect as described above to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements.

First Commercial Bank will only collect information as we believe is reasonably useful in administering our business and to provide products, services and other opportunities to you, our customer. First Commercial Bank will never make unexpected telephone calls or e-mails to our customers asking for customer’s user ID access codes, personal identification numbers or other account information.

3. Maintenance of Accurate Information

First Commercial Bank will correct known inaccurate information in a timely
manner.

4. Employee Access to Information and Enforcement

All First Commercial Bank employees are educated on the importance of confidentiality and customer privacy. They are thoroughly trained to learn and follow the First Commercial Bank Privacy Policy. Employees with access to customer information are required to adhere to the Privacy Policy.

• Any employee that violates the Privacy Policy will be subject to disciplinary measures (warnings, reprimands, suspensions) and possible termination of employment.
• Employees of First Commercial Bank will only have access to customer information on a need-to-know basis. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

5. Customer Notification

In the event of a breach of the security of the bank’s system data, the bank shall notify you of the breach in the most expedient time possible and without unreasonable delay, consistent with any measures taken by the bank as necessary to determine the scope of the breach and to restore the reasonable integrity, security and confidentiality of the data system. This notice may be delayed if an appropriate law enforcement agency determines that the notice will interfere with a criminal investigation.

6. Internet Information

First Commercial Bank recognizes the trust you have placed in us and the related responsibility we have regarding your financial privacy. It is First Commercial Bank’s responsibility to keep your sensitive financial and personal information confidential. First Commercial Bank has always had formal procedures to help protect your privacy.

With the exponential growth in the use of the Internet, it has become even more crucial that steps be taken to insure that your private information remains private. First Commercial Bank Privacy Principles include: a) web site security, b) web site privacy and c) control over your personal information.

A. Web Site Security

First Commercial Bank has implemented technology to assure you that any sensitive personal information you provide us or any account information you receive on-line is managed in a safe and secure manner. Additionally, procedures have been implemented to assure you that only authorized

First Commercial Bank employees may view the information you share. This is accomplished by limiting access to that information (via access capability and password control) to only those employees having a legitimate business purpose for viewing your information and responding to your inquiries.

This is the same procedure that is followed for customers utilizing other banking
methods, such as telephone banking or branch banking.

B. Web Site Privacy

The First Commercial Bank site includes sections that are public (for example, www.thefirstcommercialbank.com/investments.htm - First Commercial Bank Investment Accounts) and areas that are password protected (for example, NetBanker - First Commercial Bank On-line Banking Service.)

When any person visits the public areas of the web site, certain basic information is collected, such as how many people visited the site and what pages were visited.

Unlike the personal information that you provide and view with respect to your personal banking relationship (which is subject to the security procedures described above), all of the information gathered in the public areas of the web site is general. This general information is used to determine which parts of the First Commercial Bank web site are most popular and how people access them. The information gathered will help improve the content in the web pages and assist First Commercial Bank in our continuing efforts to improve service to all customers.

Also included in the First Commercial Bank web site is the capability for you to correspond with customer service. This correspondence may be for the purpose of asking general questions, requesting literature or responding to bank promotions. E-mail addresses from those who correspond with First Commercial Bank are collected along with any other information you provide, for example site registration or survey information.

Whether or not you are a customer of First Commercial Bank, personal information will be collected from you if, and only if, you voluntarily provide that information. The First Commercial Bank Privacy Policy prohibits any sale or rental of customer information to any nonaffiliated third party for marketing purposes.

C. Control of Your Personal Information

First Commercial Bank will not share information with any third parties other than as required or permitted by law, regulation or contractual obligations. Consequently, you will not receive information from another company as a result of your relationship with First Commercial Bank. If you provide First Commercial Bank with your postal address, you may receive periodic mailings from First Commercial Bank with information on products, services or upcoming events. First Commercial Bank encourages you to request any marketing information that interests you from us, such as loan rate or deposit account promotions.

FURTHER INFORMATION REGARDING FIRST COMMERCIAL BANK PRIVACY POLICY

This statement addresses our policies on Internet information and internal customer information. Additional inquiries or comments should be addressed to:

First Commercial Bank
6945 North Clark Street
Chicago, IL 60626
773.761.4300
ATTN: Cashier

1. Customer is herein defined to mean any person or entity that obtains a financial product or service from the bank, for personal or business purposes, regardless whether the person establishes an ongoing relationship with the bank.