AMERICAN NATIONAL BANK FINANCIAL
PRIVACY POLICY AND PROCEDURES

POLICY

It is the policy of American National Bank to have an affirmative and continuing obligation to respect the privacy of its customers and to protect the security and confidentiality of those customers’ nonpublic personal information. It is ANB’s policy not to disclose such information unless disclosure is:

• Required by law
• Specifically allowed by law or
• Requested by the customer, directly or indirectly

INITITAL DISCLOSURE

ANB is required by law to mail an initial privacy disclosure notice to all existing customers as of a specific date prior to July 1, 2001. The majority of the privacy notices will be sent out in customer’s DDA and Savings statements. Customers with Safe Deposit Boxes, Certificate of Deposits, and Loan’s that do not have a DDA & Savings account will be mailed separately. Initial Disclosure will be mailed to customers’ last known address. Returned mail will be evaluated and retained as undeliverable.

It is not mandatory to send notices to customers having accounts:

• Classified as dormant
• With “do not mail” instructions
• Closed within the year

ANNUAL DISCLOSURE

During the continuation of the customer relationship, we must provide an annual privacy notice to the customer at least once in any 12 consecutive-month period during which the customer relationship exists. The 12-consecutive-month period may be defined as a calendar year and the annual privacy notice to the customer should be provided once in each calendar year following the calendar year in which we provided the initial notice.

The time frame for distributing annual disclosures shall be the calendar year beginning in 2002.

WHEN THE REGULATIONS APPLY

The privacy provisions apply only to nonpublic personal information about individuals who obtain financial products or services primarily for personal, family, or household purposes. The privacy provisions do not apply to information about companies or about individuals who obtain financial products or services for business, commercial, or agricultural purposes.

Note: The best practical policy is to treat all information about a person as nonpublic personal information and subject to the regulation.

HOW THIS INFORMATION ENTERS OR LEAVES OUR BANK

American National Bank distributes information by a variety of methods, some intentional, some not. Listed below are some of the passages that information travels:

Note: Sharing information among co-workers (especially when they are in different departments) or among affiliated businesses can be as much an issue as giving the information to a third party.

All printed confidential information will be shredded before discarding.

PROTECTION OF INFORMATION VIA ESTABLISHED SECURITY PROCEDURES

American National Bank maintains security levels for each employee regarding unauthorized access to customer information. We restrict access to nonpublic information about customers to those employees who need to know the information to provide products or services to the customer. ANB maintains physical, electronic, and procedural safeguards that comply with Federal regulations to guard customer’s nonpublic personal information.

RESTRICTIONS ON THE DISCLOSURE OF ACCOUNT INFORMATION

Employees should not reveal specific information about customer accounts or other personally identifiable data to unaffiliated third parties, unless

1. The information is provided to help complete a customer initiated transaction

2. The customer request’s it

3. The disclosure is required/allowed by law (i.e. investigation of fraudulent activity).

An employee is to never disclose a customer’s account number or access code to an account for any purpose, other than is required for credit bureau reporting. All employees are required to obtain positive identification from customers calling for information on their account by requesting the amount and date of their last deposit or some other specific identifying data.

MAINTAINING CUSTOMER PRIVACY IN BUSINESS RELATIONSHIPS

When personally identifiable customer information is provided to a third party to perform services for ANB or functions on ANB’s behalf, ANB will require the third party to adhere to similar privacy principles that provide for keeping such information confidential. ANB will obtain a contractual agreement with the third party that prohibits the third party from disclosing or using the information other than to carry out the purposes for which we disclosed the information.

NEW CUSTOMER INITIAL PRIVACY NOTICE

ANB will disclose a privacy notice to all new customers no later than when we establish a customer relationship. A customer relationship is established when ANB and the consumer enter into a continuing relationship.

ANB establishes a customer relationship when the customer:

1. Executes the contract to open a deposit account

2. Rent a safe deposit box

3. Make a loan, & etc.

The notice should be provided with the agreement and signature card.

JOINT RELATIONSHIPS

If two or more consumers jointly obtain a financial product or service, we may satisfy the initial notice requirements by providing one initial notice to those consumers jointly.

MERGERS

In the event of a merger or an acquisition of another financial institution, new initial notices are required if the policies and practices of the other financial institution differ from those previously disclosed.

TRAINING

Employees will be alerted to the level of confidentiality required in banking relationships during new employee orientation and must acknowledge receipt of a copy of policy and procedures.

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San Marcos, Texas  78666
2202 Hunter Road
 
Phone (512)392-5588
Fax (512) 392-7177