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Introduction
Be it resolved, the Board of Directors of FIRST NATIONAL BANK OF MUHLENBERG COUNTY, acknowledges the legal restrictions on the disclosure of nonpublic personal information on its customers who establish relationships for personal, family and household use. It is the Bank's policy not to disclose customer information unless disclosure is:
- required by law,
- specifically permitted by law,
- requested by the customer, direct or indirectly, or
- properly disclosed to the customer and the customer has not elected against it within 30 days from the disclosure date.
The Board
authorizes limited voluntary disclosures of nonpublic personal
information to nonaffiliates when management believes those
disclosures are in the customer's financial interest. In
general, FNB may give specific information to be described in
written procedures about our current customers to vendors who offer
financial products or services that we feel may be of interest or
are particularly appropriate based on what we know about the
customer. Acceptable vendors include life insurance companies
and brokerage firms whose products or services are felt to be better
than those generally available to the public.
Customers are to receive an initial written disclosure describing
this policy prior to establishing a customer relationship and
annually thereafter. The time frame for annual distribution
of disclosures shall be May beginning the year of 2002.
Officers
Responsible for Compliance
The VP/Compliance Officer is responsible for assuring that
appropriate written procedures and internal controls are adopted
within each operating area of the bank to assure customer financial
privacy. Senior Management is responsible for developing,
implementing and complying with these procedures, in addition to
information security.
Internal Controls
FNB's
Information Security Program identifies internal controls for
administrative, technical and physical safeguards to assure that
customer information is disclosed only as permitted by law and as
stated above by each department.
The internal controls on all disclosures are to first assure that disclosures are limited to the information required and are delivered in a timely fashion. In addition, internal controls on disclosures are to assure that the facts being distributed are accurate. Whenever a customer indicates information distributed on him/her is inaccurate, the matter is to be investigated and resolved promptly.
As suggested by FNB's primary federal regulatory agency (Office of the Comptroller of the Currency), appropriate "know your customer" procedures are maintained in the areas of account documentation and the monitoring of customer activity. The information gained there is used only to protect the bank from fraud and to prevent its use by others in illegal activities.
Independent Testing
The Internal Auditor must include in FNB's audit program an initial (thereafter, annually) review of privacy related issues in each department. These results will be reported to the Audit/Compliance Committee of the Board.
Training
All employees will be trained on or before the Financial Privacy Disclosure is mailed initially and annually thereafter. Each employee will be given a copy of this policy, in addition to procedures for handling customer information. Breaches of confidentiality are addressed in the employee handbook and can serve as the basis for dismissal.
First National Bank will never request confidential information through e-mail. Please report any such request to the Bank immediately.
It is FIRST NATIONAL BANK'S commitment to keep customer non-public personal information accurate, current, and secure. If any information is found to be incorrect, notification must be made as soon as possible to FIRST NATIONAL BANK, P. O. BOX 389, CENTRAL CITY, KY 42330, BY PHONE AT 270/754-3300, OR E-MAIL to dgray@fnbmc.net or bdrenan@fnbmc.net.
Privacy Policy