First Federal Savings Bank

I. Background

With the convergence of banking, insurance, securities and other financial service firms, the need for good information is paramount to provide current and future financial products. Such information is important to help consumers meet their personal financial goals by providing the right products and services at the right time. In order to help us anticipate our customer's financial goals and needs we will collect information and, unless instructed otherwise by our customer, we may share some of this information on a confidential basis with our affiliates and third party marketing service providers so that we can better understand and serve our customers' financial needs.

While consumer concerns about privacy are not uniform, the vast majority of consumers want the ability to control their personal information and to feel comfortable with how it is used. Consumers have expressed three primary concerns about the privacy of personal information:

How personal information is being collected

How the information is used by the entity collecting the information, and

Whether personal information is transferred to third parties and how they will use it.

II. Mission Statement

First Federal Savings Bank recognizes that consumers have become increasingly concerned about the privacy of their personal information. We consider privacy of consumers' personal information an important element of public trust and confidence in our bank. We have consistently demonstrated our ability to protect such sensitive information that consumers have given in confidence. However, new privacy concerns are emerging due to changes in the financial industry, technology, and regulations.

First Federal Savings Bank will take all reasonable steps consistent with state and federal laws, regulations and normal business practices protecting consumer privacy by keeping confidential information shared with us.

Information about consumers is collected, used and retained only where it is reasonably necessary or useful in administering our business and in providing financial products and services to our customers. First Federal Savings Bank has procedures intended to assure that our customers' information is accurate, current and complete in accordance with commercial standards, applicable laws and regulations. Security procedures and policies limit employee access to personally indentifiable information to those with a business reason to know such information. In addition, employees are informed of and trained in their responsibility to protect confidential customer information.

To the extent permitted by this policy and applicable laws and regulations, First Federal may provide or disclose specific information.

First Federal Savings Bank may provide or disclose specific information about consumers' accounts or other business relationships with us when:

Developing financial products and services

Providing advisory assistance

Requested or expressly authorized by a customer

Necessary to properly execute a transaction initiated by a consumer,

Required to assert a legal claim, and

Lawfully permitted or required

Information that First Federal Savings Bank has about its customer is available to our employees and agents on a need to know basis so they can do their jobs. We prohibit our employees and agents from giving information about customers to anyone in a manner that would violate any applicable law or our privacy policy.

As part of our employee training, we caution our employees about disclosing customer information in response to pretext telephone calls. Our employees are trained to not provide customer information to third parties without first establishing the identity of the person requesting the information and determining whether that person is legally permitted to have access to the information being requested.

We value our banking relationship with our customers. At First Federal Savings Bank, our goal is to serve our customers as effectively and conveniently as possible, and to make sure they feel confident that information about their banking relationship with us is treated with the reasonable care.

III. Definitions

Some of the terms used in this policy are defined in the applicable federal Regulation. To facilitate reading and understanding this policy, some of the Regulation's definitions are repeated below:

Affiliate means any company that controls, is controlled by, or is under common control with First Federal Savings Bank, such as our subsidiary First Fed Insurance Agency, Inc.
Collect means to obtain any information which we organize or can retrieve by the name of an individual or by identifying number, symbol, or other identifying particular assigned to the individual, irrespective of the source of the underlying information.

Consumer means an individual who obtains a financial product or service from us that is to be used primarily for personal, family, or household purposes, or that individual's legal representative such as:

		An individual who applies to us for credit for personal, family, or household purposes is a consumer of a financial service, regardless of whether the credit is extended.
		An individual who provides nonpublic personal information to us in connection with obtaining or seeking to obtain financial, investment, or economic advisory services is a consumer regardless of whether we establish an ongoing advisory relationship.

Customer means a consumer that has a customer relationship with us.

Customer Relationship means a continuing relationship between a customer and First Federal under which we provide one or more financial products or services to the consumer that is to be used primarily for personal, family, or household purposes. Examples:

		Has a deposit, or investment account with us
		Obtains a loan from us
		Has a loan for which we own the servicing rights
		Purchases an insurance product from us
		Holds an investment product through us, such as when we act as a custodian for assets held in an Individual Retirement Arrangement.

A consumer does not, however, have a continuing relationship with First Federal if the consumer only obtains a financial product or service in an isolated transaction, such as withdrawing cash from our ATM or purchasing a cashier's or traveler's check.

Nonaffiliated third party means any person or company that is not the bank's affiliate.
Nonpublic personal information means personally identifiable financial information and any list, description, or other grouping of consumers (and publicly available information pertaining to them) that is derived using any personally identifiable financial information that is not publicly available
1. Nonpublic personal information includes:
  1. Any list of individuals' names and street addresses that is derived in whole or in part using personally identifiable financial information that is not publicly available, such as account numbers.
2. Nonpublic personal information does not include:
  1. Any list of individuals' names and addresses that contains only publicly available information, is not derived in whole or in part using personally identifiable financial information that is not publicly available, and is not disclosed in a manner that indicates that any of the individuals on the list is a consumer of a financial institution.
Personally identifiable financial information means any information a consumer provides to First Federal to obtain a financial product or service from us.
Publicly available information means any information that we have a reasonable basis to believe is lawfully made available to the general public:
1. From federal, state, or local government records (includes information contained in government real estate records and security interest filings).
2. That is required to be disclosed to the general public by federal, state, or local law
3. From widely distributed media (includes information from a telephone book, a television or radio program, a newspaper, or an Internet site that is available to the general public without requiring a password, special fee, or similar restriction).

IV. Informational Risk

Accumulation of information pertaining to customers and consumers increases the diligence necessary to ensure that risks are recognized and properly managed. First Federal Savings Bank will strive to establish and maintain adequate controls to manage and monitor these risks.

V. Safeguards

First Federal Savings Bank is dedicated to the confidentiality and security protection of customer information. We have implemented administrative technical and physical safeguards to;

Protect the security and confidentiality of customer information,
Protect against anticipated threats or hazards to the security or integrity of such information; and,
Protect against unauthorized access to or use of such records or information which could result in substantial harm or inconvenience to any of our valued customers.

The board will oversee the Bank's privacy program, and its efforts to develop, implement and maintain an effective information security program. The board will be presented with reports periodically describing the status of the information security program.

VI. Fair Information Practice Principles

First Federal Savings Bank understands the new evolving marketplace and its information practices' impact on consumers and we have addressed these issues by identifying the core principles of privacy protection. We recognize the growing importance of confidentiality and privacy of consumer information and our privacy policy covers the following items:

Notifying consumers about our institution's information practices
When appropriate, providing consumers a choice about the disposition of personal information
Ensuring the accuracy of personal information maintained by the bank
Maintaining security measures to protect consumers' personal information; and,
Providing a mechanism to handle consumer questions or complaints about the handling of personal information.

The fundamental components of First Federal's privacy policy are; (i) strict compliance with all applicable laws and regulations; and (ii) a recognition of the importance of the following elements.

Notice/Awareness
The most fundamental principle is notice. The Bank's consumers and customers will be given notice of our practices in a clear and conspicuous manner. First Federal Savings Bank believes some or all of the following are essential to ensuring that consumers are fully informed when divulging personal information.
1. Identification of the categories of information that we collect.
2. Identification of the categories of Nonpublic Personal Information which the bank discloses about consumers.
3. Identification of the category of affiliates with whom we may disclose Nonpublic Personal Information.
4. Explanation of the bank's disclosure practices regarding Nonpublic Personal Information and nonaffiliated third parties.
5. Any disclosure the bank makes under the Fair Credit Reporting Act regarding the consumer's ability to opt-out of sharing between affiliates.
6. Explanation of the bank's policies and practices with respect to protecting the confidentiality and security of nonpublic personal information.
Choice/Consent
A widely accepted core principle of fair information practice is consumer choice or consent. Choice means giving consumers' options as to how any personal information collected from them may be used. To the extent permitted by applicable laws and regulations, First Federal Savings Bank will disclose certain information to its insurance brokerage affiliate, First Fed Insurance Agency, Inc., including: name, address, account balances and types of accounts. In its notice to consumers and customers, First Federal Savings Bank will provide the opportunity to opt out of disclosures of nonpublic personal information, other than nonpublic personal information relating to the customer's transactions and experiences with First Federal, with First Federal's affiliates.
Access/Participation
First Federal Savings Bank believes that individuals should be able to access the data about themselves and to be informed of personal data in our files and to contest the accuracy or completeness of any such data. Our practice provides customers with the ability to ensure that confidential data is accurate and complete.
First Federal Savings Bank wants its customers to have the ability to contest inaccurate and incomplete data by making arrangements with bank officers to verify the information that has been collected. We also will allow customers to correct or allow customers to add comments to their data files pertaining to information that we use that affects past or future activities to make credit decisions and also pertaining to the confidentiality of such information.
Integrity/Security
Ensuring data integrity is a high priority, and First Federal Savings Bank takes reasonable steps to assure the accuracy of the information and the safeguarding of such confidential data.
Security involves both the managerial and technical measures to protect against loss and the unauthorized access, destruction, use or disclosure of data. First Federal Savings Bank will guard against threats and misuse of data when physically feasible or possible.
Oversight/Redress
First Federal Savings Bank believes that privacy protection can only be effective if there is a mechanism in place to ensure that the regulatory mandates are being met. We are committed to complying with all state and federal regulatory laws and good business practices ensuring the confidentiality of nonpublic information. We will work effectively with our supervisory agencies to ensure that we comply with all appropriate rules and we'll provide customers the opportunity to view and to correct their data if it is incomplete or inaccurate or to add statements to the information to provide clarifications, if necessary.

VII. Internet

First Federal Savings Bank does not collect personal identifying information about those who are merely visiting our web site. Standard software is used to collect and store the following non-identifying information about the visitors:

		The name of the domain from which they access the site
		The date and time the site was accessed
		The internet address of the web site from which they linked to our site.

Customers may communicate with First Federal Savings Bank by use of e-mail.

Information submitted to us by e-mail is treated as confidential and used only where appropriate for business purposes. To make our web site as efficient as possible to our online visitors and customers, we use cookies as part of our interaction with browsers. A cookie is a small text file placed on the visitor's hard drive by our web site server. Cookies are used to determine if visitors have previously visited our web site and for administrative purposes. They are not used to collect personally identifiable information or to determine e-mail addresses. Cookies will be treated as personally identifiable information and protected in accordance with the privacy regulations.

VIII. Disclosure Notifications

While each fair information practice principle plays an important role in protecting consumer privacy, a notice to consumers outlining First Federal Savings Bank's privacy practice may be the most important action taken by our financial institution. This notice will benefit customers by permitting them to make more informed choices about the level of protection they want before divulging personal informational. A copy of First Federal Savings Bank's privacy notice is attached to and incorporated into this policy. First Federal's privacy notice will be provided to consumers and to customers as required by, and in a manner consistent with, the applicable Regulation and to the extent that anything contained in this Policy is inconsistent with the applicable Regulation, the provisions of the Regulation will govern and control.

Initial disclosure
First Federal Savings Bank will provide a clear and conspicuous notice that accurately reflects our privacy policy and practices to -

		Our customers, prior to the time that they establish a customer relationship
		Consumers, at the time of, or prior to, providing a financial product or service to the consumer.

Exception
No initial notice to a consumer is provided if;

		We do not disclose any nonpublic personal information about the consumer to any nonaffiliated third party; and
		The consumer does not have a customer relationship with us. A customer relationship is established at the time the bank and the consumer enter into a continuing relationship. If we and the consumer orally agree to enter into a customer relationship, we will provide our privacy policies and practices within a reasonable period of time.

Delivery of notice
We shall provide the privacy notice required so that each customer or consumer can reasonably be expected to receive actual notice in writing.
Prohibited Distribution
We will not provide the regulatory privacy notice explaining our policies and practices orally, whether in person or over the telephone, or any other prohibited method of distribution.

Annual Notice to Customers
First Federal Savings Bank will provide a clear and conspicuous notice to our customers that accurately reflects our privacy policies and practices not less than annually during the continuation of the customer relationship. Annually means at least once in any period of twelve consecutive months during which that relationship exists.
1. We shall provide the annual notice to a customer using a means permitted for providing the initial notice to that customer.
2. We will not provide an annual notice to a customer with whom we no longer have a continuing relationship.
Limitation on disclosure of nonpublic personal information
1. Conditions for disclosure
  First Federal Savings Bank shall not directly or through any affiliate, disclose any nonpublic personal information about a consumer to a nonaffiliated third party unless:
  1. The consumer received an initial notice
  2. The consumer received an opt out notice
  3. The consumer had a reasonable opportunity to opt out of the disclosure
  4. The consumer does not opt out.
2. Opt out definition
  Opt out means a direction by the consumer that we do not disclose nonpublic personal information of that consumer to a nonaffiliated third party.
3. Reasonable opportunity to opt out
  The customer is provided a reasonable opportunity to opt out if the notice is hand-delivered, or mailed, and the customer is allowed a reasonable period of time, such as 30 days to opt out.
4. Notice of change in terms
  1. Before we disclose any nonpublic personal information about a consumer other than as described in the initial notice we shall provide to the consumer;
    1. A revised notice that accurately describes our policy and practices
    2. A new opt out notice
    3. A reasonable opportunity to opt out of the disclosure.
  2. We shall provide the revised notice of our policy and practices and opt out notice to a customer using the means permitted for providing the initial notice to that consumer.

IX. Fair Credit Reporting Act

First Federal Savings Bank may share on an unrestricted basis information other than our transaction and experience information with our affiliates if we clearly and conspicuously disclosed to the consumer that such other information may be shared and the consumer is given the opportunity to direct that such information not be shared. Consumers may opt-out of the sharing of nonpublic personal information, other than nonpublic personal information relating to a customer's transactions and experiences with First Federal, with First Federal's affiliates. This procedure would be performed in conjunction with the opt out rules in the federal privacy regulation.

X. State Laws

First Federal Savings Bank will comply with state confidentiality and privacy laws and regulations, if and to the extent required by law.

XI. Training

Privacy training shall be conducted for appropriate current bank personnel and new bank employees. Training for all applicable employees in those areas shall be conducted periodically. The purpose of the training shall be to explain the requirements of the privacy law and regulation, and the procedures and practices necessary to assure compliance.

XII. Control

The Compliance Officer shall periodically monitor adherence with the privacy rules and regulations. The Operations Officer will verify that the bank's privacy policy is given when opening consumer accounts and annually thereafter. The Operations Officer shall also conduct periodic reviews of customer service personnel to determine that appropriate information is given in response to consumer inquires.

First Federal Savings Bank shall review any consumer complaint alleging a violation of the privacy regulation and the appropriate officer will advise management and, where appropriate, the Board of Directors. If violations of privacy are noted, and they relate to deficiencies in forms or practices, they will corrected immediately.

The Compliance Officer will be responsible for monitoring changes in privacy rules and for making any necessary changes in the institution's polices, procedures, disclosures and compliance training.

To the extent required by applicable laws and regulations, First Federal Savings Bank will include in any agreement with unaffiliated third parties a confidentiality agreement that binds such parties to limit the use of confidential nonpublic information to those uses permitted by law.